Apple Inc v. Immersion Corp

1. Case Identification

• Case #: IPR2016-01884
• Patent #: 7,336,260
• Filed: September 23, 2016
• Petitioner(s): Apple Inc.
• Patent Owner(s): Immersion Corporation
• Challenged Claims: 1-2

2. Patent Overview

• Title: Method and Apparatus For Providing Tactile Sensations
• Brief Description: The ’260 patent discloses a system for providing tactile feedback on electronic devices. The claimed invention involves a processor that detects multiple, successively greater levels of pressure on an input device and, in response, provides distinct tactile sensations corresponding to each detected pressure level.

3. Grounds for Unpatentability

Ground 1: Claims 1 and 2 are obvious over Komata.

• Prior Art Relied Upon: Komata (Application # 2001/0008849).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Komata, which discloses a pressure-sensitive controller for a Sony PlayStation video game system, rendered the challenged claims obvious. The Komata controller features buttons that detect a range of pressures, represented by digital values from 0-255. An associated game console receives these pressure values and uses a lookup table to select and generate a corresponding vibration in the controller via an integrated motor. Petitioner asserted this system inherently detects a first, second, and third pressure (e.g., digital values of 252, 253, and 254) and provides a corresponding first, second, and third tactile sensation (vibration), meeting all limitations of claim 1. The same logic was extended to the fourth pressure level required by claim 2.
  • Key Aspects: Petitioner highlighted that Immersion’s own provisional application, to which the ’260 patent claims priority, characterized the analog buttons on Sony PlayStation gamepads as examples of switches capable of detecting levels of pressure, which Petitioner framed as a binding admission that Komata’s disclosure met this limitation.

Ground 2: Claims 1 and 2 are obvious over Tang.

• Prior Art Relied Upon: Tang (“A Multi-Level Input System with Force-Sensitive Elements,” a 2001 journal article).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that Tang, which describes an experimental tactile input system, taught all elements of the challenged claims. Tang’s system used force-sensitive pads that convert finger pressure into a voltage signal. This signal was segmented into three distinct levels: "Low," "Medium," and "High." For each detected level, the system provided a unique tactile feedback to the user in the form of vibratory bursts at different frequencies (1.5 Hz for Low, 3 Hz for Medium, and 6 Hz for High). Petitioner argued this directly disclosed the limitations of claim 1: detecting a first pressure ("Low"), a greater second pressure ("Medium"), and a still greater third pressure ("High"), and providing a distinct tactile sensation for each. Petitioner argued it would have been obvious to a POSITA to extend this concept to a fourth pressure level and corresponding sensation, as required by claim 2, to increase the system's input capacity.

Ground 3: Claim 2 is obvious over Tang in view of Synaptics.

• Prior Art Relied Upon: Tang (a 2001 journal article) and Synaptics (“Synaptics TouchPad Interfacing Guide”).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground specifically addressed the fourth pressure level required by claim 2. Petitioner argued that while Tang explicitly taught a three-level pressure system, Synaptics provided the rationale for extending it to four levels. Synaptics describes a touchpad that measures finger pressure (a "Z" value) and provides examples of four distinct pressure classifications: "hovering," "very light," "normal," and "very heavy" contact.
  • Motivation to Combine: A POSITA would combine Tang and Synaptics to increase the number of unique inputs available in Tang’s system. Tang’s three-level, three-sensor system allowed for 27 unique "chords" or inputs (3x3x3), which is insufficient for a full alphabet plus numbers and special characters. To expand this input capability without adding costly hardware, a POSITA would look to increase the number of pressure levels. Synaptics' disclosure of a four-level pressure scheme provided an explicit and logical roadmap for modifying Tang’s system from three to four levels, thereby increasing the number of possible inputs to 64 (4x4x4).
  • Expectation of Success: Modifying Tang’s software to segment the existing voltage output into four thresholds instead of three was a simple, predictable design choice with a high expectation of success.

• Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 1 and 2 based on JP725, which disclosed a touch panel system that detected multiple force ranges and provided corresponding vibrations.

4. Key Claim Construction Positions

• "pressure": Petitioner argued that this term should be construed as “application of force from a contact,” consistent with Patent Owner’s own proposed construction in a related ITC investigation.
• "input device": Petitioner advocated for a broad construction encompassing not only individual buttons but also complex assemblies like a mouse or keyboard, as well as touchscreens that deflect microscopically upon pressure. This broad interpretation was argued to be consistent with the patent’s specification and the Patent Owner’s infringement contentions.
• "detect a ... pressure on a ... input device": Petitioner proposed this phrase be construed to mean “receive a signal indicating a pressure from an input device,” arguing the patent’s specification used the terms "detecting" a pressure and "receipt" of a signal interchangeably.
• "tactile sensation based at least in part on the ... pressure": Petitioner argued this required only that a specific tactile sensation be selected in response to a detected pressure level. The properties of the sensation itself (e.g., frequency, amplitude) would not need to be proportional to or otherwise mathematically dependent on the magnitude of the pressure.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1 and 2 of the ’260 patent as unpatentable.