PTAB

IPR2017-02069

Sensata Technologies Inc v. Danfoss Power Solutions Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Joystick Device
  • Brief Description: The ’828 patent discloses a joystick device for controlling heavy machinery. The system uses a "second" microprocessor in the grip assembly to aggregate button signals and an "interconnect device" to send the aggregated signals to a "first" microprocessor in the base, which combines them with position sensor data to reduce the number of wires running between the grip and the base.

3. Grounds for Unpatentability

Ground 1: Claims 1-12 are obvious over Hardi in view of Brandt.

  • Prior Art Relied Upon: Hardi (European Application # 0501906A1) and Brandt (Patent 6,550,562).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hardi disclosed all elements of the independent claims except for a second microprocessor in the grip assembly. Hardi taught a joystick with a single microprocessor in the base that aggregates signals from both base-located position sensors and hard-wired grip buttons. Brandt taught a modular "smart handle" containing a microprocessor that aggregates signals from multiple grip buttons and outputs them over a single serial communication link. Petitioner asserted that substituting Brandt's smart handle for Hardi's simple two-button handle would supply the missing grip microprocessor and the "interconnect device" (Brandt's serial link).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSA) would combine Hardi and Brandt to expand the functionality of the joystick (allowing for more buttons as taught by Brandt) while adhering to the known design goal of minimizing wires across the pivot point, a solution taught by both references. The combination would also improve modularity, another objective suggested by Brandt.
    • Expectation of Success: A POSA would have a high expectation of success, as this combination involved the simple substitution of one known type of handle (Hardi's) with another known, more advanced handle (Brandt's) to achieve the predictable result of increased functionality with minimized wiring.

Ground 3: Claims 1-12 are obvious over Brandt in view of Rosenberg.

  • Prior Art Relied Upon: Brandt (Patent 6,550,562) and Rosenberg (Application # 2002/0097223 A1).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Brandt taught a grip assembly with a microprocessor that aggregates button and position signals for output to a downstream controller. Brandt further taught that its controller functions could be divided and that position signals could be routed directly to the downstream controller. However, Brandt did not explicitly place a second, signal-aggregating microprocessor in the joystick base. Rosenberg, from the related field of video game joysticks, taught locating a microprocessor in the joystick base, "closely coupled" to the position sensors, to process sensor signals locally. Petitioner argued that implementing Brandt's teaching of divisible controllers by adding Rosenberg's base microprocessor would result in the claimed invention. The base microprocessor would receive position sensor data directly and receive the serialized grip button data from Brandt's grip microprocessor, thereby meeting all claim limitations.
    • Motivation to Combine: A POSA, seeking to implement Brandt’s modular design, would be motivated to use Rosenberg’s architecture. Placing a microprocessor in the base, as taught by Rosenberg, to handle local sensor inputs aligns with the known design goals of minimizing wire wear across the flexing joint and improving modularization. Rosenberg explicitly taught the divisibility of microprocessor functions and the use of a serial bus to connect them.
    • Expectation of Success: A POSA would expect success in this combination, as it involved applying a known design principle (local processing via a base microprocessor from Rosenberg) to a system (Brandt) that explicitly contemplated divisible controller functions.

  • Additional Grounds: Petitioner asserted two additional grounds contingently. Ground 2 added Rytter (Patent 5,042,314) to the Hardi/Brandt combination to teach a "separable electric wiring harness," in case the Board construed "interconnect device" to require disengageability. Ground 4 similarly added Rytter to the Brandt/Rosenberg combination for the same contingent purpose.

4. Key Claim Construction Positions

  • Petitioner argued that several key terms should be given their plain and ordinary meaning, including "communicate with" and "microprocessor."
  • "interconnect device": This term was central to the petition. Petitioner argued that during prosecution, the Applicant added this term to overcome rejections without providing a clear definition. Based on the specification and its functional description, Petitioner proposed the construction: "a device that accepts a serial communication stream to connect two other devices." This construction requires serial communication, which Petitioner argued was disclosed in the prior art (e.g., Brandt's three-wire link), but does not inherently require that the device be disengageable.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 1-12 of Patent 7,456,828 as unpatentable under 35 U.S.C. §103.