PTAB

IPR2016-00655

Samsung Electronics Co Ltd v. Advanced Touchscreen Gesture Technologies LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Touch Screen Supporting Continuous Grammar Touch Gestures
  • Brief Description: The ’810 patent describes a touch screen system that recognizes complex gestures from sequential hand contact patterns, termed "postures." The technology aims to interpret the dynamic movements of different parts of a user's hand over time to generate control signals, including "continuous grammars" where gestures are performed without breaking contact with the touch surface.

3. Grounds for Unpatentability

Ground 1: Obviousness over Westerman and Bach - Claims 1, 3-5, and 10 are obvious over Westerman in view of Bach.

  • Prior Art Relied Upon: Westerman (Patent 6,323,846) and Bach (WO 90/14604).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Westerman taught the core functionality of the challenged claims, including a multi-touch surface apparatus capable of sensing and tracking multiple, distinct hand contacts simultaneously. Westerman disclosed recognizing gestures from sequences of motions, such as a "slide chord," where adding fingers to an existing sliding contact changes its function (e.g., from cursor control to window scrolling). This mapped directly to the ’810 patent’s concept of recognizing a gesture from sequential dynamics among different hand parts. Petitioner asserted that Bach supplied the final, obvious element: a transparent sensing screen placed over a visual display unit (VDU).
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Bach's transparent overlay with Westerman's multi-touch system to achieve well-known benefits of compactness, direct-manipulation user interfaces, and flexibility. Petitioner contended the motivation was particularly strong because Westerman itself suggested using a "reprogrammably displayed" keyboard, making the use of a transparent touch screen as taught by Bach an obvious implementation choice to realize that feature.
    • Expectation of Success: The combination was portrayed as a straightforward application of known technologies. A POSITA would have reasonably expected that implementing Westerman's capacitive sensor system with transparent materials taught by Bach would predictably result in a functional multi-touch screen with advanced gesture recognition.

Ground 2: Obviousness over Ure and Edwards - Claims 1, 3-5, and 10 are obvious over Ure in view of Edwards.

  • Prior Art Relied Upon: Ure (Patent 5,982,302) and Edwards (Patent 5,194,862).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Ure, which expressly incorporates the Edwards patent by reference, disclosed all limitations of the challenged claims. Ure taught a touch screen comprising a sensor array overlaid on a display. It described sensing contiguous regions of contact, such as from a thumb and fingers, and distinguishing between them. Critically, Ure taught a "drag" gesture recognized from a specific sequence of postures: first, "grounding" the thumb in a stationary position (a first posture from a first hand part), and second, moving one or more fingers across the screen (a second posture from a second hand part). This directly mapped to the key claim limitation that the examiner previously found patentable.
    • Motivation to Combine: The motivation was explicit, as Ure incorporates Edwards for its touch sensor array technology. Petitioner argued this was not a combination of disparate references but an application of technology expressly contemplated and integrated by the primary reference itself.
    • Expectation of Success: A POSITA would have had a 100% expectation of success, as Ure was specifically designed to operate with the sensor technology disclosed in Edwards. The combination was inherent to Ure's disclosure.

  • Additional Grounds: Petitioner asserted that claims 1, 3-5, and 10 are also obvious under 35 U.S.C. §103 over Westerman alone, arguing it taught all claim elements without requiring a secondary reference.

4. Key Claim Construction Positions

  • Petitioner argued that, for the purpose of the IPR, certain claim terms should be construed consistent with positions taken in related district court litigation.
  • "contiguous region": Petitioner proposed adopting the Patent Owner's proposed litigation construction of "connected region" under the Broadest Reasonable Interpretation (BRI) standard.
  • "gesture" / "posture" / "sequential dynamics": Petitioner noted that the parties in litigation had already agreed on constructions for these terms, defining a "gesture" as "dynamic variations among postures...combined in sequence" and a "posture" as "the two-dimensional shape of a contiguous region of contact." Petitioner submitted these constructions were appropriate for the IPR.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1, 3-5, and 10 of the ’810 patent as unpatentable.