PTAB

IPR2018-01501

Samsung Electronics Co Ltd v. Immersion Corp

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Key Events
Petition
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 to provide haptic feedback to a user. The technology is primarily directed to touch-input devices, such as touchpads and touchscreens on portable computers, that use actuators to generate tactile sensations in response to user interactions with a graphical user interface (GUI).

3. Grounds for Unpatentability

Ground 1: Obviousness over Gemmell and Maddalozzo - Claims 1-3, 6, 8, 14, and 20-21 are obvious over Gemmell in view of Maddalozzo.

  • Prior Art Relied Upon: Gemmell (International Publication No. WO 92/00559) and Maddalozzo (Patent 7,768,501).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gemmell taught a general system for providing haptic feedback on a touch-sensitive input device. Gemmell’s system used a vibrating mechanism (actuator) to provide varied tactile feedback based on a user's interaction with different GUI elements (e.g., icons, buttons) on a screen. However, Gemmell did not explicitly detail a GUI with distinct regions for cursor control versus other functions. Maddalozzo was argued to supply this missing detail, disclosing a portable computer with a touchscreen GUI featuring distinct, programmable functional regions. These regions included a main document area for cursor positioning, a scroll bar region, and a mode-select region with graphical buttons. Petitioner asserted that implementing Maddalozzo’s detailed multi-region GUI within Gemmell’s haptic feedback framework would have been obvious. This combination would result in the device of independent claim 1: a haptic feedback device with a touchscreen, an actuator, a first region for cursor positioning, and a second region for a different control functionality, where different haptic effects are associated with each region.
    • Motivation to Combine: Petitioner presented several motivations for a person of ordinary skill in the art (POSITA) to combine the references. First, a POSITA starting with Gemmell’s disclosure of a haptic system for a Windows-based GUI would have been motivated to consult analogous art like Maddalozzo for specific implementation details of such an interface on a portable device. Second, strong market demand for more functional and user-friendly tablet computers would have driven a POSITA to integrate Maddalozzo’s advanced word-processing GUI into Gemmell’s haptic system to create a more desirable product. Third, the combination represented a predictable path to enhancing usability—a primary goal of Gemmell—by allowing users to distinguish between different on-screen controls through tactile feedback.
    • Expectation of Success: A POSITA would have had a high expectation of success because the combination involved applying a known user interface design (Maddalozzo) to a known haptic feedback system (Gemmell). Each element would perform its known function to achieve the predictable result of an improved tactile user interface.

4. Key Claim Construction Positions

  • The petition identified one key disputed term, "touch screen," while noting agreement on several others.
  • Petitioner proposed a construction for "touch screen" as "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."
  • Patent Owner’s asserted position in related litigation was either that "No construction is necessary" or a slightly narrower definition that "may include a touch surface, a touch sensor, a local microprocessor, and a display."
  • Petitioner argued that its obviousness contentions were valid and demonstrable under any of the proposed constructions, thereby reducing the need for the Board to resolve the dispute.

5. Key Priority Date Contention

  • Petitioner dedicated significant argument to contending that the ’181 patent was not entitled to its earliest claimed priority date.
  • The core of this argument was an alleged lack of written description support in the earlier applications of the priority chain for key limitations of the challenged claims. Specifically, Petitioner argued that the earlier specifications failed to describe a "touch screen" that comprises a first region for cursor positioning and a second, distinct region for a different control functionality.
  • Petitioner asserted that the correct "Critical Date" for the challenged claims is January 19, 2000, the filing date of the ’737 application. This assertion was fundamental to the petition, as it established both Gemmell (published 1992) and Maddalozzo (filed 1998) as qualifying prior art under 35 U.S.C. §102.

6. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §325(d) would be inappropriate. It was asserted that Maddalozzo was new prior art that had not been considered during the original prosecution. Although Gemmell was cited to the examiner, it was allegedly "buried" within a list of over 600 references and was not substantively analyzed or applied against the claims, meaning the core arguments in the petition were not previously presented to the Office.
  • The petition also noted the concurrent filing of a second IPR against the ’181 patent. Petitioner argued for institution of both petitions, reasoning that any burden is offset by efficiencies from parallel proceedings and that the instant petition uniquely challenges dependent claims 6 and 14.

7. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-3, 6, 8, 14, and 20-21 of the ’181 patent as unpatentable.