Valve Corporation v. Electronic Scripting Products, Inc.

1. Case Identification

• Case #: IPR2018-01032
• Patent #: 8,553,935
• Filed: October 10, 2018
• Petitioner(s): Valve Corporation
• Patent Owner(s): Electronic Scripting Products, Inc.
• Challenged Claims: 1-21

2. Patent Overview

• Title: Method and System for Determining Pose of a Manipulated Object
• Brief Description: The ’935 patent relates to a system for determining the absolute pose (position and orientation) of a manipulated object in a three-dimensional environment. The system uses a photodetector and a relative motion sensor, both mounted on the object, to track a plurality of external light sources having known, fixed locations in world coordinates.

3. Grounds for Unpatentability

Ground 1: Claims 1-21 are obvious over Maeda

• Prior Art Relied Upon: Maeda (a 2004 symposium paper titled "Tracking of User Position and Orientation by Stereo Measurement of Infrared Markers and Orientation Sensing").
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Maeda alone discloses all limitations of the challenged claims. Maeda describes a user-wearable helmet (the “manipulated object”) equipped with stereo cameras (“photodetector”) and an orientation sensor composed of gyro, geomagnetic, and inertial sensors (“relative motion sensor”). The onboard cameras track fixed infrared light-emitting diode (LED) markers (“predetermined light sources”) in the environment to determine position, while the orientation sensor measures changes in orientation. Petitioner asserted that Maeda’s system processes both the light data from the cameras and the motion data from the orientation sensor to determine the helmet’s full 6-degree-of-freedom (6DOF) pose with respect to world coordinates.
  • Key Aspects: Petitioner contended that Maeda’s teachings directly map to the independent method and system claims (1 and 12). For dependent claims, Petitioner argued Maeda teaches using IR LEDs (claim 4), arranging them in a predetermined non-linear pattern (claims 2-3, 14-15), coupling the system to a head-mounted display (HMD) (claims 5, 17), and defining pose using quaternions, which are a mathematical equivalent to the claimed Euler angles (claims 6, 18).

Ground 2: Claims 11 and 21 are obvious over Maeda in view of Welch-HiBall and/or Applicant Admitted Prior Art (AAPA)

• Prior Art Relied Upon: Maeda, Welch-HiBall (a 2001 journal article), and Applicant Admitted Prior Art (AAPA) from the ’935 patent specification.
• Core Argument for this Ground:
  • Prior Art Mapping: This ground specifically addressed claims 11 and 21, which recite a manipulated object selected from a group including wands, 3D mice, and other handheld tools. Petitioner argued that while Maeda discloses a helmet as the manipulated object, Welch-HiBall and AAPA explicitly teach using handheld objects like wands, probes, and 3D mice for pose tracking in virtual and augmented reality systems. Welch-HiBall describes the "HiBall" tracking system, where sensors are mounted on handheld tools to determine their pose by tracking fixed overhead LEDs.
  • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSA) would have been motivated to apply Maeda’s hybrid tracking method (combining optical and inertial data) to the handheld input devices taught in Welch-HiBall. Both references address the same technical problem of pose tracking in virtual/augmented reality and are from the same field of endeavor; Maeda even cites related work by the author of Welch-HiBall. Combining them would have been a predictable solution to improve user interaction in the applications described in both references, such as using a tracked wand to manipulate a 3D map.
  • Expectation of Success: A POSA would have had a high expectation of success. Welch-HiBall describes a functioning optical tracking system for handheld objects, and Maeda explicitly teaches a method for fusing optical data with inertial data. Combining these known elements to create a hybrid-tracked handheld device was presented as a predictable integration yielding no unexpected results.

4. Key Claim Construction Positions

• "Manipulated Object": Petitioner argued this term should be given its plain and ordinary meaning and should not be construed to exclude a head-mounted sensor system. The ’935 patent specification explicitly describes an embodiment where "glasses" are the manipulated object, supporting the inclusion of wearable items.
• "Photodetector": Proposed to mean a device that detects light, explicitly including devices like CCD or CMOS cameras. This construction was asserted to be consistent with the ’935 patent’s disclosure and the use of cameras in cited prior art.
• "Relative motion sensor": Should be construed to include at least an inertial sensing device, such as an accelerometer or gyroscope, as described in the specification.
• "World coordinates": Proposed to mean "a three-dimensional coordinate system with an origin situated in the real environment," distinguishing it from coordinate systems that move with the object (e.g., image or object coordinates).

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under §325(d) would be inappropriate. The core reasoning was that the primary prior art references, Maeda and Welch-HiBall, were never substantively considered by the Examiner during the original prosecution of the ’935 patent or its predecessors. Petitioner asserted that the mere inclusion of a different article by Welch in an Information Disclosure Statement (IDS) does not mean the specific teachings of Welch-HiBall relied upon in the petition were previously evaluated.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-21 of the ’935 patent as unpatentable.