PTAB

IPR2016-01907

Apple Inc v. Immersion Corp

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus For Providing Tactile Sensations
  • Brief Description: The ’488 patent discloses systems and methods for providing tactile feedback on electronic devices, such as smartphones. The technology involves an input device capable of sensing multiple levels of pressure and a processor that generates distinct haptic effects via an actuator based on whether the applied pressure crosses predefined thresholds.

3. Grounds for Unpatentability

Ground 1: Obviousness over JP725 - Claims 1-2, 9-10, and 17-18 are obvious over JP725.

  • Prior Art Relied Upon: JP725 (Japanese Published Application No. H11-212725).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that JP725, which describes a touch panel system for devices like ATMs, discloses all elements of the challenged claims. JP725 teaches a touch-sensitive display that provides haptic feedback (vibrations) to confirm user input. The system uses piezoelectric elements to detect the force of a user's touch and classifies the force into one of five ranges (F0-F4) based on four predefined force thresholds. Based on the detected force range and touch location, a control circuit selects a specific vibration mode (e.g., S11 for force F1 in region R1) from a matrix to drive the piezoelectric elements as actuators. This directly maps to the claimed method of receiving a sensor signal indicating pressure, determining an interaction based on that pressure, and generating an actuator signal to cause haptic effects corresponding to different pressure thresholds.

Ground 2: Obviousness over Komata and Niedzwiecki - Claim 29 is obvious over Komata in view of Niedzwiecki.

  • Prior Art Relied Upon: Komata (Application # 2001/0008849) and Niedzwiecki (Patent 5,896,125).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Komata discloses a pressure-sensitive video game controller with buttons that can be moved to different positions based on applied pressure, generating a corresponding digital signal (0-255). Komata’s controller also includes actuators (motors with eccentric weights) that provide vibration feedback based on signals from the game console. Niedzwiecki discloses an adapter for connecting various game controllers, including the Sony PlayStation controller taught by Komata, to a personal computer (PC). The combination results in an apparatus where Komata's controller is the "input device," Niedzwiecki's adapter and the PC's CPU constitute the "processor," and the controller's motors are the "actuators."
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the references to use an advanced, pressure-sensitive controller with vibration feedback (Komata) on the more powerful and versatile platform of a PC. Niedzwiecki explicitly states its purpose is to bring "the element of good player game control to the personal computer video game platform" and mentions its applicability to Sony PlayStation controllers, providing a clear motivation for the combination.
    • Expectation of Success: Petitioner argued success would be expected because Niedzwiecki teaches that its adapter's microcontroller can be "easily programmed" to emulate the communication protocol of any given controller, making the integration of Komata's controller straightforward.

Ground 3: Obviousness over Komata and Rosenberg - Claim 29 is obvious over Komata in view of Rosenberg.

  • Prior Art Relied Upon: Komata (Application # 2001/0008849) and Rosenberg (Patent 6,088,019).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground again relies on Komata's pressure-sensitive, vibrating controller, which is host-controlled. Rosenberg discloses force-feedback interface devices and teaches the inclusion of a local microprocessor within the device itself to manage low-level force control loops. This local processor handles reading sensor inputs and driving actuators independently of the host computer, receiving only high-level commands from the host.
    • Motivation to Combine: A POSITA would be motivated to add Rosenberg's local microprocessor architecture to Komata's controller to offload the processing burden from the host system (e.g., a game console or PC). Relieving the host from managing the real-time haptic feedback loop would free its processing power for more demanding tasks, such as running more sophisticated video games. Rosenberg explicitly mentions its applicability to Sony game systems, reinforcing the relevance of this modification to Komata's controller.
    • Expectation of Success: The integration was presented as predictable, involving placing Rosenberg's local processor between Komata's interface and its internal components (A/D converters, etc.) to manage the haptic feedback control loop as described in both references.

4. Key Claim Construction Positions

  • "pressure": Petitioner argued that the Patent Owner should be held to its proposed construction from a related ITC investigation: "application of force from a contact."
  • "cause a first haptic effect if the pressure is less than a first pressure threshold": Petitioner argued this phrase requires the haptic effect to be caused for at least one pressure value below the threshold, not for all possible pressures below it. This construction prevents improperly excluding a disclosed embodiment in the ’488 patent where no haptic effect occurs until a minimum pressure is applied, which is still below a subsequent threshold.
  • "input device" (claim 29): Petitioner proposed a broad construction that encompasses both an entire assembly (e.g., a mouse, keyboard, or controller) and its individual sub-components (e.g., a single button or switch). This position was based on the varied usage of the term in the ’488 patent specification and the Patent Owner's infringement contentions in co-pending litigation.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-2, 9-10, 17-18, and 29 of the ’488 patent as unpatentable.