Aristocrat Technologies Inc v. Igt

1. Case Identification

• Case #: To Be Assigned
• Patent #: 6,702,675
• Filed: December 9, 2015
• Petitioner(s): Aristocrat Technologies, Inc.
• Patent Owner(s): IGT
• Challenged Claims: 18-32 and 35-37

2. Patent Overview

• Title: Gaming Device with Multi-Purpose Reels
• Brief Description: The ’675 patent discloses a gaming machine, such as a video slot machine, that uses video reels on a display. The invention focuses on displaying "exhibitions," such as animations or graphical effects, on the video reels to inform a player of a specific game outcome, like triggering a bonus round.

3. Grounds for Unpatentability

Ground I: Obviousness of Claims 18-19, 23, 26-27, 30, and 32 over Manship

• Prior Art Relied Upon: Manship (Patent 5,697,843).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Manship, which discloses a video slot machine, taught all elements of the challenged claims. Manship’s device includes a display screen (a 3x3 array of cells), a processor, and a plurality of video reels, each displaying symbols. Manship discloses a "Swinging Bells" bonus mode triggered by a specific "crossed bells" symbol combination. Upon triggering, the bells are animated (enlarged, color-enhanced, and swinging), which constitutes an "exhibition" under the patent's definition. This exhibition replaces the static symbols on the reels and informs the player they have reached a bonus outcome, meeting the core limitations of independent claims 18, 23, 26, 30, and 32.
  • Motivation to Combine (for §103 grounds): As a single-reference ground, the motivation was to apply the known options and design choices disclosed within Manship itself. Petitioner argued that a person of ordinary skill in the art (POSA) would find it obvious to use the animated "swinging bells" feature not only for bonus payouts but also to announce the entry into the bonus mode itself, as this would increase player appeal and excitement—a stated goal in Manship.
  • Expectation of Success (for §103 grounds): A POSA would have a high expectation of success as it involves applying features disclosed within a single reference in a predictable manner to enhance a known game function.

Ground II: Obviousness of Claims 24-25 and 28-29 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 Ground I, addressing dependent claims that require the bonus opportunity to be provided "through a data network" or "an internet." While Manship discloses the core gaming device, Barrie teaches connecting slot machines to a central computer via a network, including the internet. Barrie explicitly discloses this for controlling game operations. Therefore, the combination of Manship's game features with Barrie's networked environment discloses the limitations of these claims.
  • Motivation to Combine (for §103 grounds): A POSA would combine Manship's gaming device with Barrie's networking technology to achieve predictable benefits known in the art. These benefits, taught by Barrie, include centralized accounting, enhanced security, ease of software updates, and the ability to offer larger, more exciting prizes through linked progressive jackpots.
  • Expectation of Success (for §103 grounds): There was a reasonable expectation of success in implementing Manship's game features over a network, as this was a known method for expanding the functionality and appeal of electronic gaming devices.

Ground VI: Obviousness of Claims 18-19, 23, and 26 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: Petitioner asserted this ground as an alternative to the Manship-based grounds. Cannon discloses a video slot machine with multiple reels that displays an "exhibition" by altering the appearance of symbols (e.g., highlighting winning symbols with brighter colors and fading non-winning ones). This meets the base limitations of claim 18. However, Cannon does not explicitly teach a bonus spin outcome. Watts remedies this by teaching a bonus spin feature for a slot machine, where certain symbol combinations trigger one to three free bonus spins. The combination of Cannon's exhibition with Watts' bonus spin functionality renders the claims obvious.
  • Motivation to Combine (for §103 grounds): A POSA would have been motivated to add the bonus spin feature from Watts to the gaming device of Cannon to make the game more attractive to players. Bonus spins were a well-known and highly desirable feature that increased player engagement and the potential prize size, a goal consistent with improving any gaming machine.
  • Expectation of Success (for §103 grounds): A POSA would have reasonably expected success in combining these references, as it involved incorporating a known bonus feature (bonus spins from Watts) into a standard video slot machine platform (Cannon) using established programming techniques.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Manship or Cannon with Thomas (Patent 5,449,173) to add shaking reels; with Dickenson (Patent 5,251,898) to add reels spinning in opposite directions; and with Bennett (WO 97/32285) to add animated wild card symbols. These grounds relied on similar motivations of combining known gaming features to increase player appeal.

4. Key Claim Construction Positions

• The petition argued that the term "exhibition" should be given the broad definition provided by the patentee in the ’675 patent specification. The patent states: "The term, exhibition as used in this specification means: (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, including video images, graphics, activities, animations, virtual representations, simulations or movement." This explicit definition was central to Petitioner's arguments, as it allowed features like the color-enhanced symbols in Cannon or the swinging bells in Manship to be construed as the claimed "exhibition."

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 18-32 and 35-37 of the ’675 patent as unpatentable under 35 U.S.C. §103.