PTAB

IPR2018-00593

Fitbit Inc v. Immersion Corp

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems and methods for transmitting haptic messages
  • Brief Description: The ’301 patent discloses a messaging system for mobile devices that communicate by transmitting messages that cause visual and haptic effects. The system uses sensors to detect user interactions with the device (e.g., touch screen input) and device movement (e.g., tilting), which in turn determine the output of corresponding haptic and visual feedback.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kotzin - Claims 1-6, 9-11, 14-17, 21-24, 27-29, and 31 are obvious over Kotzin in view of POSITA knowledge.

  • Prior Art Relied Upon: Kotzin (Application # 2005/0219223).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kotzin discloses the key limitations of the challenged claims. Kotzin describes data transmission between devices based on "contextual characteristics," including movement and touch. For example, Kotzin teaches tilting a first device to simulate pouring virtual water into a second device, with the display on each device changing to reflect the data transfer progress. This tilting action, detected by an accelerometer, meets the limitation of receiving a sensor signal associated with device movement. Kotzin also explicitly discloses using a "vibrator" to provide haptic feedback to the user regarding the data transfer. Petitioner contended that this haptic feedback is inherently based on the same sensor signal (tilting) that initiates and controls the visual data transfer representation.
    • Motivation to Combine (for §103 grounds): This ground relied on a single reference combined with the knowledge of a person of ordinary skill in the art (POSITA). Petitioner argued that even if Kotzin does not explicitly teach varying haptic effects corresponding to the rate of movement, a POSITA would find it obvious to do so. Given Kotzin’s goal of providing an "understandable physical representation" of data transfer, varying the haptic feedback intensity or pattern to match the dynamic visual feedback (e.g., the speed of the virtual water pouring) would have been a simple and predictable design choice.
    • Expectation of Success: A POSITA would have a high expectation of success in implementing haptic feedback tied to sensor data, as accelerometers and vibrator motors were common and well-understood components in mobile devices at the time.

Ground 2: Obviousness over Eid - Claims 27, 28, 29, and 31 are obvious over Eid in view of POSITA knowledge.

  • Prior Art Relied Upon: Eid (Application # 2006/0066569).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Eid, which relates to haptic messaging, teaches the system claimed in independent claim 27. Eid discloses a system where a user ("Alice") can send another user ("Bob") a message containing both a visual component (e.g., an emoticon) and a haptic component (e.g., a vibration corresponding to a "laugh"). Eid further discloses using a GPS sensor to provide location-based haptic alerts, which constitutes a "first sensor signal" for detecting movement. Additionally, Eid describes user interaction, such as pressing a key to select a message, which constitutes a "second sensor signal" for detecting user interaction. Petitioner argued that Eid's processor receives these signals and determines a display change and a haptic effect based on the received message data and subsequent user interaction.
    • Motivation to Combine (for §103 grounds): As a single-reference ground, the motivation was inherent in Eid's disclosure. Eid's system was designed to process various inputs (location, user selection) to generate combined visual and haptic outputs, aligning directly with the architecture of the challenged claims.
    • Expectation of Success: Eid describes a complete system for haptic messaging, indicating that a POSITA would have a clear expectation of successfully implementing a system where a processor determines haptic and visual effects based on sensor signals and received data.

Ground 3: Obviousness over Eid and Beyer - Claims 1, 2, 3, 5, 6, 9, and 10 are obvious over Eid in view of Beyer.

  • Prior Art Relied Upon: Eid (Application # 2006/0066569) and Beyer (Patent 7,031,728).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground combined Eid's haptic navigation features with Beyer's visual navigation interface. Eid discloses using a GPS sensor (a movement sensor) to provide location-based haptic notifications to a user (e.g., a specific vibration when near a point of interest) to minimize distraction. Beyer discloses a location-based communication system that uses a graphical user interface, specifically a map, to display the locations of other users and points of interest. Petitioner argued that Eid provides the core method of determining and outputting a haptic effect based on a movement sensor signal, while Beyer provides the missing or under-emphasized element of determining a visual message (a map display) based on that same GPS sensor signal.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the references to create a more versatile and improved navigation system. Eid itself acknowledges that visual cues are useful in some circumstances but proposes haptics for situations like driving. A POSITA would recognize the benefit of adding Beyer's graphical map display to Eid's haptic system to provide users with the option of either visual or haptic feedback, or both, depending on the context (e.g., visual map for walking, haptics for driving). This combination would be a predictable solution to create a more feature-rich product.
    • Expectation of Success: Integrating a known graphical map display (Beyer) with a known haptic alert system (Eid), both of which are based on standard GPS technology, would have been a straightforward task for a POSITA with a high expectation of success.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-6, 9-11, 14-17, 21-24, 27-29, and 31 of the ’301 patent as unpatentable.