PTAB

IPR2016-01372

Apple Inc v. Immersion Corp

Key Events

Petition

petition

Title: Interactivity Model for Shared Feedback on Mobile Devices
Brief Description: The ’571 patent discloses systems and methods for providing dynamic haptic effects on mobile devices. The technology aims to improve upon static haptic feedback by generating effects that evolve over time in response to multiple user gesture signals and/or device sensor signals.

Prior Art Relied Upon: Burrough (Application # 2010/0156818).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Burrough discloses a method for providing dynamic, multi-touch haptic feedback on a device with a touchscreen. Specifically, Burrough taught generating a haptic response that varies based on the distance between two fingers performing a gesture, such as a "zoom" gesture. Petitioner asserted this met the limitations of independent claim 1, which requires receiving a first and second gesture signal, generating a "dynamic interaction parameter" based on those signals (e.g., the distance between fingers), and applying a corresponding drive signal to a haptic output device. Petitioner contended that Burrough’s teaching of adjusting vibration intensity based on finger distance directly corresponds to the claimed method.
- Key Aspects: Petitioner argued that Burrough’s teachings rendered every challenged claim obvious. For dependent claims, Petitioner mapped limitations such as using a "physical model" (claim 5) to Burrough's disclosure of determining contact areas based on the geometric features of a finger, and using an "animation" (claim 6) to Burrough's disclosure of haptic effects mapped to zoom animations on the display.

Prior Art Relied Upon: Rosenberg ’373 (Patent 5,734,373).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Rosenberg ’373, an earlier patent from the same patent owner, taught a force-feedback system for user interface devices like joysticks. The system generated a "force value" (the claimed "dynamic interaction parameter") based on sensor data representing the position, velocity, or acceleration of the user object over time. Petitioner asserted that the continual receipt of sensor data as a user manipulates the joystick constituted receiving first and second "gesture signals." The calculated force value, which changes based on user input, was then used to generate haptic effects via actuators. This, Petitioner argued, disclosed the core method of claims 1, 12, and 23.
- Key Aspects: This ground asserted that the fundamental concept of generating dynamic haptic feedback based on a series of user inputs was well-established by Rosenberg ’373, albeit in the context of non-touchscreen devices like joysticks.

Prior Art Relied Upon: Rosenberg ’373 (Patent 5,734,373) and Rosenberg ’846 (Patent 6,429,846).
Core Argument for this Ground:
- Prior Art Mapping: This ground specifically addressed claims 3, 14, and 25, which require that the gesture signal comprise an "on-screen signal." While Rosenberg ’373 taught the core dynamic haptic feedback system, it focused on devices like joysticks. Petitioner introduced Rosenberg ’846, which explicitly discloses providing haptic feedback to planar touch-control devices, including touchscreens. Rosenberg ’846 taught generating haptic effects (vibrations) based on the location or velocity of a user’s finger on the touch surface.
- Motivation to Combine: Petitioner argued a POSITA would combine these references for several reasons. Both patents were assigned to the same entity (Immersion), shared the same lead inventor, and addressed the common problem of providing haptic feedback. A POSITA would have been motivated to apply the sophisticated, dynamic force-feedback algorithms of Rosenberg ’373 to the touchscreen interfaces described in Rosenberg ’846 to provide richer haptic experiences on modern devices.
- Expectation of Success: Success would be expected because both systems relied on processing user position/velocity data to generate haptic output, making the integration of the concepts straightforward.

"gesture signal": Petitioner argued this term should be broadly construed to encompass "a signal indicating user interaction with a user interface device," consistent with the specification's description of gestures from devices including mice, touchpads, and joysticks, not just touchscreens.
"dynamic interaction parameter": Petitioner submitted that this term should be construed, at a minimum, as broadly as the Patent Owner proposed in a related ITC investigation: "an interaction parameter that changes over time or reacts in real time." This construction was central to mapping the "force value" from Rosenberg '373 and the distance-based haptic function from Burrough to the claims.
"on screen signal": Based on Patent Owner's contentions in litigation, Petitioner argued this term should encompass a signal generated based on interactions with a touchscreen, such as a user touching the screen.

Petitioner requested institution of an inter partes review and cancellation of claims 1-7, 12-18, and 23-29 of the ’571 patent as unpatentable.