PTAB

IPR2018-01500

Samsung Electronics Co Ltd v. Immersion Corp

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Haptic Feedback for Touchpads and Other Touch Controls
  • Brief Description: The ’181 patent discloses devices that interface with computer systems, such as touchpads and touchscreens, and provide haptic feedback to the user. The technology involves using one or more actuators to impart forces, such as vibrations, to a touch surface in response to user interactions within different regions of a graphical user interface.

3. Grounds for Unpatentability

Ground 1: Obviousness over Stephan, Oross, and Blouin - Claims 1-3, 8, 12, and 20-22 are obvious over Stephan in view of Oross and Blouin.

  • Prior Art Relied Upon: Stephan (Patent 5,748,185), Oross (Patent 6,757,002), and Blouin (Patent 5,977,867).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Stephan, Oross, and Blouin taught every limitation of the challenged claims. Stephan disclosed a portable computer with a multi-region touchscreen, where different regions have different functionalities (e.g., a cursor control region and other regions for scrolling or button functions). Stephan also taught using passive tactile feedback, like surface textures, to distinguish these regions. Oross taught a multi-region trackpad that uses an active vibration source (an actuator) to provide a tactile cue when a user interacts with special function regions, distinct from the main cursor control area. Blouin explicitly taught applying a vibrator directly to a touchscreen to provide tactile feedback to the user, noting that its teachings apply to handheld computers and communication devices. The combination of these references allegedly rendered obvious a multi-region touchscreen that uses an actuator to provide haptic feedback.
    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine these references for several reasons. A POSITA would combine Oross’s active vibration feedback with Stephan’s multi-region touchscreen to simplify manufacturing by replacing physical textures with programmable vibrations. This would also allow for adjustable and varied haptic feedback, improving the user experience. Adding a vibrator to a touchscreen was a known technique, as taught by Blouin, being applied to a known system (Stephan's multi-region screen) to achieve the predictable result of providing active haptic feedback.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because combining the references involved applying known techniques (actuators on touch surfaces) to a known device type (multi-region touchscreens) to yield predictable improvements in user feedback and manufacturability.

Ground 2: Obviousness over Stephan, Oross, Blouin, and Beeks - Claims 1-3, 8, 12, and 20-22 are obvious over Stephan in view of Oross, Blouin, and Beeks.

  • Prior Art Relied Upon: Stephan (Patent 5,748,185), Oross (Patent 6,757,002), Blouin (Patent 5,977,867), and Beeks (Patent 6,373,463).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1 and was presented to preemptively address a narrower interpretation of claim 1. Petitioner argued that if claim 1 was interpreted to require that the haptic effect must be provided specifically in response to cursor positioning (not just interaction with other control regions), the teachings of Beeks would render this limitation obvious. Beeks explicitly disclosed a cursor control system with tactile feedback where an actuator provides a vibration when the cursor is positioned over a selectable component in the graphical user interface.
    • Motivation to Combine: A POSITA would be motivated to add the teachings of Beeks to the Stephan-Oross-Blouin combination to provide more comprehensive user feedback. Beeks taught that providing feedback related to cursor movement is useful for minimizing the time a user must look at the screen. This would have been a recognized benefit, motivating a POSITA to incorporate an actuator that provides feedback based on cursor position, in addition to feedback from interacting with other control regions.
    • Expectation of Success: The combination was a predictable integration of known haptic feedback modalities (feedback on region interaction and feedback on cursor position) into a single system, with a high expectation of success.

4. Key Claim Construction Positions

  • Petitioner asserted that its unpatentability arguments prevail under either the Broadest Reasonable Interpretation (BRI) standard or the narrower Phillips standard used in district court. A key disputed term was "touch screen."
    • "touch screen": Petitioner proposed the 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." This construction was central to mapping the prior art, which disclosed touch-sensitive surfaces integrated with displays in portable computers.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under 35 U.S.C. §325(d), stating that the primary references (Stephan and Oross) were either not cited or not substantively considered by the examiner during prosecution of the ’181 patent.
  • Petitioner also addressed the potential for denial based on a concurrently filed IPR petition against the same patent. It argued that institution was still appropriate because this petition challenged unique dependent claims (12 and 22), there was an opportunity for efficiency gains through parallel proceedings, and the number of grounds asserted was not excessive.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-3, 8, 12, and 20-22 of the ’181 patent as unpatentable under 35 U.S.C. §103.