Samsung Electronics Co Ltd v. Immersion Corp

1. Case Identification

• Case #: IPR2018-01499
• Patent #: 7,969,288
• Filed: August 6, 2018
• Petitioner(s): Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
• Challenged Claims: 18

2. Patent Overview

• Title: Force Feedback System Including Multi-Tasking Graphical Host Environment and Interface Device
• Brief Description: The ’288 patent relates to a software architecture for managing force feedback commands from multiple concurrently running application programs. The technology purports to resolve conflicts that arise when different applications simultaneously send competing force sensation commands to a single haptic interface device.

3. Grounds for Unpatentability

Ground 1: Claim 18 is obvious over Rosenberg in view of Greanias

• Prior Art Relied Upon: Rosenberg (International Publication No. WO 97/21160) and Greanias (Patent 5,157,384).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Rosenberg taught a force feedback system for a multi-tasking Graphical User Interface (GUI) where different applications could issue force commands. Rosenberg disclosed storing force profiles in memory and recognized the need for a prioritization scheme to handle conflicting commands from concurrently running applications. However, it did not specify how to prioritize. Petitioner asserted that Greanias supplied this missing element by teaching a standard method for identifying the single "active" application program—the one with input focus—among multiple running programs. The combination of Rosenberg’s force feedback system and Greanias’s active-application management method allegedly disclosed all limitations of claim 18.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the references to implement Rosenberg's priority scheme for conflicting force commands in a logical and effective manner. Petitioner contended it would have been obvious to assign the highest priority to the "active" application as taught by Greanias, since that is the application receiving the user's direct input and attention at any given moment. This combination represented a predictable solution to a known problem.
  • Expectation of Success: Petitioner argued that a POSITA would have had a high expectation of success, as the combination involved applying a well-known technique for managing application states (from Greanias) to improve the functionality of a known force feedback system (from Rosenberg).

Ground 2: Claim 18 is obvious over Schuler II in view of Greanias

• Prior Art Relied Upon: Schuler II (International Publication No. WO 97/25657) and Greanias (Patent 5,157,384).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner alleged that Schuler II taught a tactile feedback system where multiple running applications could generate distinct force effects, described as "torque profiles," which were stored in a database and associated with each application. These profiles could be accessed via an Application Programming Interface (API). Like in Ground 1, Greanias provided the teaching of determining which of the multiple concurrently running applications is the active one. The combination of Schuler II’s application-specific force profiles and Greanias’s active-application detection method was argued to render claim 18 obvious.
  • Motivation to Combine: The primary motivation asserted was to improve usability for visually impaired users, a group explicitly mentioned by Schuler II. Petitioner argued a POSITA would recognize that receiving simultaneous force feedback from multiple applications would be confusing and disorienting for a user who cannot see which application window is generating the force. A POSITA would therefore be motivated to modify Schuler II's system to selectively generate force effects only from the active application, mitigating this confusion. Greanias provided the known method to identify that active application. A secondary motivation was to prevent the generation of spurious force effects from inactive, occluded background windows that could interfere with the user's interaction with the active foreground window.
  • Expectation of Success: Petitioner claimed success would be expected, as filtering system outputs based on a known application state (active versus inactive) was a common and predictable design choice used to enhance user experience.

4. Key Claim Construction Positions

• Petitioner noted that in parallel district court litigation, the parties had agreed on constructions for key terms, which it adopted for the purposes of the IPR petition. These constructions were central to linking the patent’s language to the teachings of the prior art.
• "is active": The parties agreed this term means "has input focus".
• "active application program": The parties agreed this term means "application program having input focus".
• These constructions were critical to Petitioner’s argument, as Greanias explicitly teaches determining which application has "input focus" to designate it as the active program to which all input data is directed.

5. Relief Requested

• Petitioner requests institution of an inter partes review (IPR) and cancellation of claim 18 of the ’288 patent as unpatentable under 35 U.S.C. §103.