PTAB

IPR2019-00868

Motorola Mobility LLC 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 ’720 patent relates to computer interface devices, such as touchpads and touchscreens, that provide haptic feedback to a user. The technology aims to solve a perceived problem of existing touch surfaces lacking tactile responses by integrating actuators to generate physical sensations like pulses or vibrations when a user interacts with the device.

3. Grounds for Unpatentability

Ground 1: Claims 10, 13, 15, 16, 19, 25, and 26 are obvious over Gemmell in view of Maddalozzo.

  • Prior Art Relied Upon: Gemmell (PCT Publication # WO 1992/000559) and Maddalozzo (Patent 7,768,501).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gemmell taught a haptic feedback system for various input devices, including a touch screen on a handheld tablet computer. Gemmell’s system used a "vibrating mechanism" to provide varied tactile feedback based on a user's interaction with a graphical user interface (GUI). Petitioner asserted that Maddalozzo, which was not considered during prosecution or reexamination, supplied a key limitation that the Patent Owner previously argued was missing from the prior art: a touchscreen GUI with distinct, non-overlapping regions for different functions. Specifically, Maddalozzo disclosed a "mouse mode" with a first region for cursor positioning and other non-overlapping regions for a scroll bar and mode-selection buttons. Petitioner contended the combination of Gemmell's haptic engine with Maddalozzo's detailed GUI renders independent claim 10 obvious.
    • Motivation to Combine: A POSITA would combine the references because both teach portable computers with touch screens and Windows-based GUIs. Maddalozzo provides a detailed, space-saving GUI implementation that would be a natural and logical improvement to the general GUI concepts described in Gemmell. Furthermore, strong consumer demand for applications like word processing on emerging tablet devices would motivate a POSITA to integrate Maddalozzo’s versatile GUI with Gemmell’s enhanced haptic user feedback.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining the teachings, as it involved the predictable integration of a known haptic feedback system with a known software-based GUI on a conventional portable computer platform.

Ground 2: Claims 10, 13, 15, 16, 19, 25, and 26 are obvious over Gemmell in view of Maddalozzo and Blouin.

  • Prior Art Relied Upon: Gemmell (PCT Publication # WO 1992/000559), Maddalozzo (Patent 7,768,501), and Blouin (Patent 5,977,867).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground reinforced the arguments from Ground 1, with Blouin added primarily to address the limitation of "a touch screen operative to output a first signal comprising coordinates of a contacted location" in claim 10. Petitioner argued that if the signal output in Gemmell (which passes through a driver) were not considered to be directly from the touchscreen, Blouin remedied this by explicitly teaching an analog resistive touchscreen with integrated bus bars that generates x-y coordinate data directly, without external processing. This addition was intended to preemptively counter any narrow interpretation of the claim language by the Patent Owner.
    • Motivation to Combine: A POSITA would be motivated to incorporate Blouin's touchscreen technology into the Gemmell/Maddalozzo device as an obvious design choice. Blouin's analog-resistive screen technology was well-known at the time to be inexpensive, low-power, and compatible with off-the-shelf components, making it a predictable and advantageous choice for a mass-produced portable device like the one described in the primary combination.
    • Expectation of Success: Integrating a well-understood type of touchscreen, such as the analog-resistive screen taught by Blouin, into a portable computer design was a routine engineering task with a high expectation of success.

4. Key Claim Construction Positions

  • Petitioner argued for a specific construction of the term "touch screen," proposing it be defined 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." This construction was important to Petitioner's arguments because it distinguished the screen itself from other system components, aligning with prior art like Blouin that taught a screen directly outputting coordinate signals without an integrated controller.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate despite the filing of a concurrent petition against the same patent. The core reasons provided were that this petition uniquely challenged claims 25 and 26. Petitioner also asserted that the substantial overlap in other challenged claims between the two petitions would create efficiencies if the trials were conducted in parallel, and that the number of grounds presented was not excessive.

6. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 10, 13, 15, 16, 19, 25, and 26 of the ’720 patent as unpatentable.