PTAB

IPR2018-01469

Samsung Electronics Co., Ltd v. IMMERSION CORPORATION

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1. Case Identification

2. Patent Overview

  • Title: Haptic Feedback for Touchpads and Other Touch Controls
  • Brief Description: The ’720 patent relates to devices that provide haptic feedback to a user interacting with a computer system. The invention addresses the stated problem of conventional touchpads and touchscreens lacking tactile feedback by coupling one or more actuators, such as piezoelectric actuators, to the touch surface to generate pulses, vibrations, or texture sensations.

3. Grounds for Unpatentability

Ground 1: Claims 10, 13, 15, 16, 19, 25, and 26 are obvious over Gemmell in view of Maddalozzo.

  • Prior Art Relied Upon: Gemmell (WO 1992/000559) and Maddalozzo (Patent 7,768,501).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gemmell taught the core concepts of a haptic feedback device, including a computer system with a touch-sensitive input (like a touchscreen) and a vibrating mechanism to provide tactile feedback in response to user interaction with a GUI. However, Gemmell did not explicitly illustrate a detailed GUI. Petitioner asserted that Maddalozzo supplied this missing element, disclosing a portable tablet computer with a sophisticated GUI for a touchscreen. Maddalozzo’s GUI featured distinct, non-overlapping, programmable regions for different functions, such as a main region for cursor control, a scroll bar region, and mode-select buttons. This arrangement, Petitioner contended, directly mapped to the limitations of independent claim 10, which requires a first region for cursor positioning and at least one other non-overlapping control region.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine these references for several reasons. First, because Gemmell taught using a Windows-based GUI, a POSITA would have been prompted to consult an analogous reference like Maddalozzo, which provided detailed implementation examples of such a GUI on a portable device. Second, strong consumer demand for more compact and feature-rich tablet computers would have motivated integrating Gemmell's haptic feedback with Maddalozzo's efficient, space-saving GUI to improve the user experience. The combination was presented as a predictable substitution of a specific UI (Maddalozzo) into a known system (Gemmell).
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the teachings. The integration involved applying known technologies (haptic feedback and advanced GUIs) for their recognized purposes to achieve the predictable result of an enhanced, multi-function, haptic-enabled touchscreen interface.

Ground 2: Claims 10, 13, 15, 16, 19, 25, and 26 are obvious over Gemmell in view of Maddalozzo and Blouin.

  • Prior Art Relied Upon: Gemmell (WO 1992/000559), Maddalozzo (Patent 7,768,501), and Blouin (Patent 5,977,867).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground incorporated all arguments from Ground 1 and added Blouin to further support the limitation in claim 10[a] requiring a touchscreen that outputs a "first signal comprising coordinates of a contacted location." Petitioner argued that even if Gemmell’s disclosure (which includes a touchscreen driver) was deemed insufficient, Blouin explicitly taught an analog resistive touchscreen with integrated bus bars that directly generates x-y coordinate data. This data, in the form of a linear voltage gradient, corresponds to the touch location and requires no significant further processing to be considered a coordinate signal, thus clearly satisfying the claim limitation.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Blouin's touchscreen technology into the Gemmell/Maddalozzo combination as a matter of routine design choice. At the time of the invention, analog-resistive touchscreens like Blouin's were a conventional, inexpensive, and low-power solution. These characteristics made them particularly suitable and an obvious choice for the portable, battery-powered devices described in Gemmell and Maddalozzo.
    • Expectation of Success: Success was expected because incorporating a widely used, off-the-shelf component like an analog-resistive touchscreen into a portable device design was a common and well-understood practice.

4. Key Claim Construction Positions

  • The petition highlighted a dispute over the construction of the term "touch screen" from the co-pending district court litigation.
  • Petitioner's Proposed Construction: "a display device that allows a user to provide input by touching an area on the device, and may include a touch surface, a display, and a touch sensor but not the bezel, chassis or controller."
  • Importance: Petitioner noted the dispute but argued that its obviousness analysis was persuasive under either its proposed construction or the Patent Owner's position that no construction was necessary. This was intended to show that a definitive ruling on the term was not required for a finding of unpatentability.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §325(d) would be inappropriate. The core argument was that the asserted grounds were not substantially the same as art or arguments previously presented to the Office.
  • Specifically, Petitioner emphasized that the primary combination reference, Maddalozzo, was never cited or considered during the original prosecution or the subsequent ex parte reexamination of the ’720 patent, and therefore the petition raised substantial new questions of patentability.

6. Relief Requested

  • Petitioner requested that the Board institute an inter partes review and cancel claims 10, 13, 15, 16, 19, 25, and 26 of the ’720 patent as unpatentable under 35 U.S.C. §103.