PTAB

IPR2017-00421

Sony Corp v. Broadcom Corp

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petition Intelligence

1. Case Identification

2. Patent Overview

  • Title: Visually associating a wireless game controller with a player in a wireless gaming system
  • Brief Description: The ’332 patent relates to multi-player video game systems using multiple wireless controllers. The invention aims to solve the technical problem of associating each controller with its corresponding virtual player on-screen by using matching colored indicator lights on both the controller and the host system.

3. Grounds for Unpatentability

Ground 1: Obviousness over Saiki and Gosior - Claims 1-3, 6, 8-9, 11-12, 14, and 16 are obvious over Saiki in view of Gosior.

  • Prior Art Relied Upon: Saiki (Japanese Patent Application No. H10-249064) and Gosior (Patent 6,684,062).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Saiki taught the core concept of the ’332 patent: a video game controller with multiple, different-colored light-emitting elements that "coincide with" the colors of on-screen characters to help users identify which character they control in a multi-player game. However, Saiki did not specify a wireless controller. Gosior remedied this deficiency by explicitly teaching a "Wireless Game Control System," including a controller with an integrated radio frequency (RF) transceiver that communicates wirelessly with a game console. Petitioner contended that combining Saiki's color-matching identification system with Gosior's wireless controller technology rendered the key limitations of the independent claims obvious.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine the teachings of Saiki and Gosior to gain the well-understood benefits of wireless technology. Gosior explicitly detailed the disadvantages of wired controllers (limited mobility, tangled wires) and taught wireless implementation as a known solution. A POSITA would have been motivated to apply Saiki's useful player-identification feature to a modern wireless controller to create an improved, commercially desirable product.
    • Expectation of Success: Petitioner asserted a high expectation of success, as Gosior established that no significant technical obstacles existed for replacing wired connections with wireless RF. The basic design and operation of the controllers in both references were similar, and Gosior’s disclosure of an LED on its wireless controller demonstrated the compatibility of lighting elements with wireless implementations, making the combination a predictable engineering task.

Ground 2: Obviousness over Saiki, Gosior, and Conway - Claims 7, 10, 13, and 15 are obvious over Saiki in view of Gosior and Conway.

  • Prior Art Relied Upon: Saiki, Gosior, and Conway (Patent 7,876,255).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Saiki and Gosior combination to address dependent claims reciting a single multi-colored LED rather than multiple separate colored lights. While Saiki taught using four distinct LEDs, Conway taught a wireless controlling device for game consoles and explicitly stated that "a single, multi-colored LED" and "multiple, different colored LEDs may be easily substituted" for one another. This, Petitioner argued, showed the interchangeability of the two approaches was well known.
    • Motivation to Combine: A POSITA implementing the system of Saiki and Gosior would have been motivated to incorporate Conway’s teaching as a simple design choice. Using a single multi-colored LED instead of multiple LEDs was a known alternative that could offer benefits such as reducing component count and saving physical space on the controller housing. Conway presented this as a routine substitution, not a novel invention.
    • Expectation of Success: Success would have been expected, as this modification involved substituting one known type of light indicator for another functionally equivalent and explicitly interchangeable type, representing a predictable design choice rather than a technical challenge.

Ground 3: Obviousness over Saiki, Gosior, and Nintendo Power - Claims 1-3, 6, 8-9, 11-12, 14, and 16 are obvious over Saiki in view of Gosior and Nintendo Power.

  • Prior Art Relied Upon: Saiki, Gosior, and Nintendo Power (Nintendo Power Vol. 58, March 1994).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1, specifically addressing the claim limitation of an "indicator light ... on the host computing system." Petitioner argued that if this limitation were interpreted to require a separate on-screen indicator (distinct from the color of the player character itself, as taught by Saiki), then Nintendo Power would render it obvious. Nintendo Power, in a review of the game NBA Jam, showed on-screen gameplay with distinct, colored markers or icons above the virtual players to indicate which player was which, providing a separate visual cue on the host display.
    • Motivation to Combine: A POSITA would combine the teachings of Nintendo Power with the Saiki/Gosior system to provide enhanced usability. Using dedicated on-screen color markers, as shown in NBA Jam, was a known method to clearly convey player identification. It would have been a logical and obvious step to make the colored lights on the controller correspond to these on-screen markers, rather than the player character's uniform, to provide a consistent and unambiguous visual link for the user.
    • Expectation of Success: The combination was a straightforward application of known user interface design principles. Matching an indicator light on a peripheral to a corresponding indicator on a display screen was a common and predictable technique for associating related elements.
  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) against claims 7, 10, 13, and 15 based on the combination of Saiki, Gosior, Conway, and Nintendo Power, which relied on merging the design modification theories from Grounds 2 and 3.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3 and 6-16 of the ’332 patent as unpatentable.