PTAB

IPR2016-00307

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 slot machines, that use video reels on a display. The invention centers on displaying "exhibitions," such as animations, over one or more reels upon a triggering event to inform a player of a game outcome, like entering a bonus round.

3. Grounds for Unpatentability

Ground I: Claims 18-19, 23, 26, 27, 30, and 32 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, a patent for a video slot machine, discloses all elements of the independent claims. Manship taught a display with a 3x3 array of video reels, a processor, game outcomes, and bonus spin outcomes. Petitioner asserted that Manship’s "Swinging Bells" bonus mode, triggered by a "crossed bells" symbol combination, meets the definition of the claimed "exhibition." This feature enhances display colors and enlarges the bell symbols on the reels, thereby informing the player of entry into the bonus mode. Petitioner further argued this exhibition appears on reels adjacent to other reels, satisfying the positional limitations of the claims.
    • Motivation to Combine (for §103 grounds): As a single-reference ground, formal motivation to combine was not required. However, for dependent claims, Petitioner argued it would be obvious to modify Manship in minor ways. For example, to meet claim 19, a POSITA would find it obvious to have all reels spin during the bonus mode, as this was a well-known and conventional feature of slot machines that players would expect.
    • Expectation of Success (for §103 grounds): Implementing conventional slot machine features into the Manship system would have been straightforward with a high expectation of success.

Ground II: Claims 24-25, 28, and 29 are obvious over Manship and 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 built upon the teachings of Manship by adding Barrie to address limitations in dependent claims 24, 25, 28, and 29, which require the bonus opportunity to be provided "through a data network" or "an internet." Petitioner argued that Barrie explicitly discloses a slot machine connected to a central computer over a network, including the Internet, for controlling game operations.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Manship's game features with Barrie's network technology to gain known advantages of networked gaming. Petitioner asserted that Barrie teaches such benefits, including centralized accounting, greater security, ease of software upgrades, and the ability to offer larger, more exciting linked progressive jackpots.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success in combining the systems, as it involved implementing known game features on a known network architecture to achieve predictable benefits.

Ground VI: Claims 18-19, 23, and 26 are obvious over Cannon and 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 presented this combination as an alternative to the Manship-based grounds. Cannon was argued to teach a video game device with a processor, display, and multiple side-by-side video reels. The feature in Cannon of highlighting winning symbols with brighter colors or fading non-winning symbols was asserted to be the claimed "exhibition." To meet the "plurality of bonus spin outcomes" limitation, Petitioner relied on Watts, which discloses awarding one to three bonus spins based on certain symbol combinations.
    • Motivation to Combine (for §103 grounds): A POSITA designing a game based on Cannon would have been motivated to incorporate a bonus spin feature to make the game more attractive to players, as this was a well-known feature in the industry. Watts provided an express teaching for implementing such a bonus feature. The winning combinations in Cannon that already trigger an exhibition would be a natural and logical trigger for the bonus spins taught by Watts.
    • Expectation of Success (for §103 grounds): Combining a known bonus feature from Watts with a known game display system from Cannon represented a straightforward application of existing technologies to enhance player appeal, with predictable results.
  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges. These included combinations of Manship with Thomas (adding shaking reels), Manship with Dickenson (adding reels spinning in opposite directions), and Walker alone (teaching an animated interlocking puzzle exhibition). Further grounds combined Cannon and Watts with other references like Bennett, Thomas, and Dickenson to add similar features.

4. Key Claim Construction Positions

  • Petitioner argued that the term "exhibition" should be construed according to the patentee's explicit definition provided in the ’675 patent specification.
  • The specification defines "exhibition" as "(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 various dynamic characteristics like changing colors, shapes, or patterns. Petitioner asserted this express definition is controlling and that the prior art disclosures meet this definition.

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.