PTAB

IPR2018-01499

Samsung Electronics Co., Ltd v. Immersion Corporation

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1. Case Identification

2. Patent Overview

  • Title: Force Feedback System Including Multi-Tasking Graphical Host Environment and Interface Device
  • Brief Description: The ’288 patent discloses a system architecture that allows multiple application programs running concurrently in a multi-tasking environment (like Microsoft Windows) to interface with a single force feedback device (e.g., a joystick or mouse) without creating conflicts. The system is designed to manage force effect commands from different applications, ensuring that only the appropriate force sensations are output to the user.

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 disclosed a force feedback system for a graphical user interface (GUI) environment, such as Microsoft Windows, that can run multiple applications concurrently. Rosenberg taught that different graphical objects, including application windows, can have different, predetermined force effects associated with them, with data for these effects (e.g., "force profiles") stored in memory. Rosenberg also described a prioritization scheme for handling conflicting force commands from multiple applications. However, Petitioner contended Rosenberg did not explicitly teach how to determine which application’s commands should receive priority. Greanias was argued to supply this missing element by disclosing a system for a multi-tasking environment that explicitly determines which one of several concurrently running applications is the "active application program" (i.e., the one with input focus) and directs all input data to it.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Rosenberg and Greanias to improve Rosenberg's conflict resolution scheme. Rosenberg recognized that conflicting force commands could be an issue and proposed assigning priorities. A POSITA would have found it an obvious and logical step to assign the highest priority to the force commands from the "active" application, as taught by Greanias, because that is the application receiving the user's attention and input. This would resolve command conflicts in a predictable and user-friendly manner.
    • Expectation of Success: Combining the teachings would involve integrating known software modules (Rosenberg's force feedback management and Greanias's active application determination) within a conventional multi-tasking operating system. Petitioner asserted this would have been a straightforward implementation with a high expectation of success.

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 asserted that Schuler II disclosed a tactilely responsive user interface where a computer runs several applications, each associated with specific "torque profiles" (data sets for force effects). These profiles are stored in a database, which is part of the application program, and are accessible via an Application Programming Interface (API). Like Rosenberg, Schuler II described a system with multiple applications capable of generating distinct force effects. Greanias was again relied upon for its teaching of determining the single active application among multiple concurrently running programs.
    • Motivation to Combine: The primary motivation argued was to enhance accessibility for visually impaired users, a use case explicitly mentioned in Schuler II. For a visually impaired user, receiving force effects from multiple applications simultaneously—including inactive ones—would be "utterly confusing." A POSITA would be motivated to modify Schuler II's system to generate force effects only from the currently active application to mitigate this confusion and improve usability. Greanias provided the known method for determining which application is active. An additional motivation was to prevent spurious force effects from inactive application windows that are occluded by the active window in the foreground.
    • Expectation of Success: Petitioner argued a POSITA would have had a clear expectation of success in combining Schuler II and Greanias. The combination would solve a known problem (user confusion from multiple simultaneous feedback sources) using a known solution (isolating feedback to the active application) in a predictable software environment.

4. Key Claim Construction Positions

  • Petitioner noted that because the ’288 patent had expired, the Phillips standard for claim construction should apply. The parties in a related district court litigation had agreed on the construction of several key terms, which Petitioner argued were dispositive for the IPR.
  • "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."
  • Petitioner contended that these constructions, which link "active" status directly to user "input focus," were critical. The primary prior art references (Rosenberg, Schuler II) disclosed managing force feedback for multiple applications, while Greanias specifically taught how to identify the one application that "has input focus" to direct user input, thereby rendering the claimed invention obvious.

5. Relief Requested

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