PTAB

IPR2017-00897

Apple Inc v. Immersion Corp

Key Events

Petition

petition Intelligence

Title: Method and Apparatus for Providing Tactile Sensations
Brief Description: The ’356 patent is directed to providing tactile feedback, such as vibrations, to touch-sensitive input devices. The technology involves a system with a processor that receives a sensor signal from a user interaction and, based on "haptic effect data" stored in a "lookup table," generates and transmits a corresponding signal to an actuator to create a tactile sensation on the device's surface.

Prior Art Relied Upon: Fukumoto (WO 2002/12991 A1 and corresponding Application # 2002/0149561).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Fukumoto discloses all elements of the challenged claims. Fukumoto describes handheld devices like PDAs with a touchscreen, a processor (CPU), and an actuator to provide vibratory feedback. Critically, Fukumoto teaches using lookup tables that store waveform data corresponding to user inputs, such as the position of a touch and the pressure level applied. The CPU uses this data to select and generate the appropriate actuator signal. Petitioner contended this directly maps to the core limitations of the ’356 patent, including the "lookup table" limitation that was added during prosecution to establish patentability.
- Motivation to Combine (for §103 grounds): As a single-reference ground, this argument focused on Fukumoto's teachings rendering the claimed invention obvious. Petitioner asserted that Fukumoto's comprehensive disclosure of a system linking touch inputs to haptic outputs via lookup tables would have made the claimed system obvious to a person of ordinary skill in the art (POSITA).
- Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success in implementing the system described, as Fukumoto provides a detailed and functional blueprint for such a device.

Prior Art Relied Upon: Fukumoto and Roysden (Patent 5,575,576).
Core Argument for this Ground:
- Prior Art Mapping: This ground targets claims 8 and 18, which add the limitation that a displayed keypad comprises the key configuration of a "standard 101-key keyboard." Petitioner asserted that Fukumoto teaches implementing its haptic touchscreen system in "mobile computers" and "stationary computers." Roysden discloses the standard 101-key IBM keyboard layout.
- Motivation to Combine (for §103 grounds): A POSITA would combine Fukumoto's haptic system with the standard keyboard layout taught by Roysden to improve usability and meet user expectations. Roysden establishes that this specific keyboard layout was desirable and had become the standard for computers due to widespread user familiarity. Applying this known standard to a softkeyboard on Fukumoto's computer systems was presented as a simple and predictable design choice.
- Expectation of Success (for §103 grounds): Implementing a well-established keyboard layout on a soft-display was a routine task for a POSITA at the time, ensuring a high expectation of success.

Prior Art Relied Upon: Tsuji (Japanese Application Publication No. 11-212725).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner presented Tsuji as a strong alternative single-reference challenge. Tsuji discloses information display devices, such as ATMs, with touch panels that provide vibratory feedback via piezoelectric elements. The system in Tsuji uses a processor and a lookup table to associate user interactions—including both the position (which button) and the force of the contact—with specific haptic effect data. This data is then used to generate a corresponding actuator signal. Petitioner argued that this disclosure provides a complete mapping for the core limitations of the challenged claims, paralleling the teachings of Fukumoto.
- Motivation to Combine (for §103 grounds): This ground asserted that Tsuji's detailed disclosure of a complete haptic feedback system based on stored data associations renders the claimed invention obvious.
- Expectation of Success (for §103 grounds): Tsuji's teachings on associating various user inputs with specific haptic outputs using a lookup table demonstrated a functional system, providing a POSITA with a clear expectation of success.

"Lookup table": Petitioner argued this term should be construed as a "data structure in the form of a table containing associations between interactions and haptic effect data." This construction was central to all grounds, as it aligned directly with the data tables disclosed in Fukumoto and Tsuji that link user inputs to specific haptic waveform data.
"Standard 101-key keyboard": Petitioner contended this term should be construed to mean the standard 101-key IBM keyboard layout introduced in 1986. This construction was critical for Ground 2, as it provides the specific, conventional layout that Roysden allegedly motivates a POSITA to apply to Fukumoto's system.

Petitioner argued that discretionary denial under 35 U.S.C. §315(d) would be improper. This petition followed a prior challenge (IPR2016-01381) on the same patent. Petitioner asserted that this filing was necessary because it raised substantively different arguments based on different prior art (Fukumoto, Roysden, Tsuji) and challenged additional claims that were not at issue in the first IPR, which had been limited to claims asserted in a parallel ITC investigation.

Petitioner requests institution of an inter partes review and cancellation of claims 1-26 of Patent 8,773,356 as unpatentable.