PTAB

IPR2016-01603

Apple Inc v. Immersion Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Methods For Haptic Confirmation of Commands
  • Brief Description: The ’710 patent discloses systems for providing haptic feedback to confirm user commands in electronic devices. The technology is particularly aimed at providing non-visual and non-audible confirmation for inputs like voice commands or interactions in distracting environments where traditional feedback may be ineffective.

3. Grounds for Unpatentability

Ground 1: Obviousness over Martin - Claims 1, 7-10, and 12 are obvious over Martin.

  • Prior Art Relied Upon: Martin (Patent 7,336,260).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Martin, which is prior art owned by the Patent Owner, discloses every element of the challenged claims. Martin teaches an electronic device with input devices (sensors), a controller (processor), and an actuator to provide tactile feedback. Specifically, Martin describes using a lookup table (Fig. 9) that maps detected user inputs to specific device functions (commands) and corresponding haptic sensations. Petitioner asserted this teaches generating a first haptic effect when a command is recognized. Martin further discloses generating a distinct haptic effect for an "ambiguous input," which Petitioner argued meets the "otherwise" limitation of claim 1, where a second haptic effect is generated if a command is not determined.
    • Motivation to Combine (for §103 grounds): As this ground relies on a single reference, the motivation was inherent in Martin's own disclosure. Petitioner contended that a person of ordinary skill in the art (POSITA) would find it obvious to implement the controller as a processor and enclose the system components within a housing, as these are simple, predictable design choices disclosed in Martin’s alternative embodiments and well understood in the art.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success in making these minor, conventional modifications to Martin's disclosed system.

Ground 2: Obviousness over Martin and Nokia - Claims 1, 7, 9, 10, and 12 are obvious over Martin in view of Nokia.

  • Prior Art Relied Upon: Martin (Patent 7,336,260) and Nokia (Nokia 9110 Communicator User’s Manual).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground focused on an alternative embodiment in Martin: a Personal Digital Assistant (PDA) with a haptic-enabled touchpad displaying softkeys (Fig. 5). Martin teaches that its haptic feedback system would benefit devices like mobile phones. Nokia discloses a smartphone that can generate dual-tone multi-frequency (DTMF) tones from keyboard inputs during an active call. The combination of Martin’s haptic PDA and Nokia’s DTMF functionality was alleged to render the claims obvious.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the teachings because Martin expressly identifies mobile phones as a key application for its haptic technology. Nokia provided a well-known, necessary function for any device operating as a phone: the ability to generate DTMF tones to interact with automated systems (IVRs). Adding this standard functionality to Martin’s haptic-enabled phone was presented as a predictable and desirable improvement.
    • Expectation of Success (for §103 grounds): A POSITA would expect success in implementing the known DTMF functionality of Nokia into the haptic PDA design of Martin, as it involved combining known technologies for their intended purposes.

Ground 3: Obviousness over Martin, Nokia, and Rank - Claim 8 is obvious over Martin in view of Nokia and Rank.

  • Prior Art Relied Upon: Martin (Patent 7,336,260), Nokia (User's Manual), and Rank (Application # 2003/0067440).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically targeted the limitation in claim 8 requiring the "first haptic effect is configured to emulate the command." Building on Ground 2, where the command is established as generating a DTMF tone, Petitioner introduced Rank. Rank teaches generating haptic feedback with a frequency and magnitude proportional to an associated audio signal.
    • Motivation to Combine (for §103 grounds): After deciding to add DTMF functionality to Martin's device (motivated by Nokia), a POSITA would need to determine what type of haptic effect should accompany the command. Petitioner argued a POSITA would look to prior art like Rank, which teaches how to correlate haptic feedback with audio. The motivation was to create a more intuitive user experience by making the haptic sensation feel related to the audible DTMF tone being generated, thereby "emulating" the command.
    • Expectation of Success (for §103 grounds): A POSITA would have a reasonable expectation of success in applying Rank's audio-to-haptic conversion technique to the DTMF tones in the combined Martin/Nokia system, as it represented the application of a known method to a known type of audio signal.

4. Key Claim Construction Positions

  • "haptic effect configured to emulate the command" (claim 8): Petitioner argued this term should be construed broadly, consistent with Patent Owner's infringement contentions in a related International Trade Commission (ITC) proceeding. In that case, the Patent Owner asserted that a simple, short vibration "emulated" a command to display a menu. Petitioner contended that under this broad construction, a haptic "pop" sensation as described in Martin would be sufficient to emulate a command, supporting the obviousness argument in Ground 1. This construction was also central to the argument in Ground 3, where a haptic effect corresponding to an audible DTMF tone would constitute emulation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 7-10, and 12 of the ’710 patent as unpatentable.