Motorola Mobility LLC v. Immersion Corp

1. Case Identification

• Case #: IPR2019-00848
• Patent #: 6,429,846
• Filed: March 20, 2019
• Petitioner(s): Motorola Mobility LLC, Motorola Mobility Holdings LLC
• Patent Owner(s): Immersion Corporation
• Challenged Claims: 1, 3, 5-7, 16, 18, 19

2. Patent Overview

• Title: Haptic Feedback for Touchpads and Other Touch Controls
• Brief Description: The ’846 patent describes devices that interface with computer systems to provide haptic feedback to the user. The technology is particularly directed to adding haptic sensations to touchpads and touch screens on portable computers to assist with targeting and other control tasks within a graphical user interface (GUI).

3. Grounds for Unpatentability

Ground 1: Obviousness over Gemmell, Maddalozzo, and Blouin - Claims 1, 3, 5-7, 16, 18, and 19 are obvious over Gemmell in view of Maddalozzo and Blouin.

• Prior Art Relied Upon: Gemmell (International Publication No. WO 92/00559), Maddalozzo (Patent 7,768,501), and Blouin (Patent 5,977,867).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Gemmell disclosed the foundational concept of a computer system with a touch input device (e.g., a touchscreen) that provides tactile feedback using a vibrating actuator. This high-level disclosure, however, was rendered obvious by the specific implementation details taught in Maddalozzo and Blouin. For independent claim 1, Gemmell’s system was argued to be integrated into a portable computer housing, as Gemmell itself depicted a handheld tablet. Maddalozzo and Blouin further reinforced the obviousness of a portable form factor, given the market trends they described. Petitioner contended Blouin explicitly taught a planar touch surface operative to input a two-dimensional position signal via its resistive screen with X and Y bus bars. Maddalozzo was cited for teaching the use of this position signal to control a cursor in a GUI on a portable device. Finally, Petitioner asserted that Gemmell and Blouin both taught coupling an actuator to the touch input device to output a haptic force based on processor commands, with Blouin clearly showing the actuator directly attached to the touch surface.
  • Motivation to Combine (for §103 grounds): A person of ordinary skill in the art (POSITA) would combine Gemmell’s general haptic system with the specifics from Maddalozzo and Blouin to meet clear market demand for smaller, more functional portable devices. Petitioner argued Gemmell’s high-level disclosure would naturally prompt a POSITA to consult analogous art for known implementation details. A POSITA would look to Maddalozzo for specific GUI features (e.g., word processing) common in the target market and to Blouin for known, efficient hardware solutions (e.g., compact resistive touchscreens with directly attached vibrators). The combination was framed as a predictable application of known technologies to improve a device for a known purpose.
  • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success because the combination involved integrating conventional, well-understood components using known methods to achieve the predictable result of a portable haptic-enabled touchscreen device.

4. Key Claim Construction Positions

• Petitioner asserted that its invalidity arguments were valid under either its own or the Patent Owner’s proposed claim constructions, thereby aiming to obviate the need for a formal construction ruling.
• For the key disputed term “outputting a force directly on said touch input device,” Petitioner proposed a construction of “outputting a force on the touch input device without intervening structure.” Petitioner argued that the direct attachment of a vibrator to a touchscreen surface via adhesive tape, as shown in Blouin, satisfied this construction.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §325(d) would be inappropriate. The core reasoning was that the primary prior art references relied upon in the petition—Gemmell, Maddalozzo, and Blouin—were never before the examiner during the original prosecution of the ’846 patent. Petitioner further noted that the claims were never substantively rejected, meaning the cited art and arguments were entirely new to the U.S. Patent and Trademark Office.

6. Relief Requested

• Petitioner requested the institution of an inter partes review (IPR) and the ultimate cancellation of claims 1, 3, 5-7, 16, 18, and 19 of the ’846 patent as unpatentable.