PTAB

IPR2019-00868

Motorola Mobility LLC v. Immersion Corporation

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1. Case Identification

  • Case #: IPR2019-00868
  • Patent #: 7,982,720
  • Filed: March 22, 2019
  • Petitioner(s): Motorola Mobility LLC and Motorola Mobility Holdings LLC
  • Patent Owner(s): Louis B. Rosenberg, et al.
  • Challenged Claims: 10, 13, 15, 16, 19, 25, and 26

2. Patent Overview

  • Title: Haptic Feedback for Touchpads and Other Touch Controls
  • Brief Description: The ’720 patent describes devices that provide haptic feedback to a user interfacing with a computer system. The technology is directed at touch input devices, such as touchpads and touch screens, that use actuators to generate tactile effects in response to user interaction with graphical elements.

3. Grounds for Unpatentability

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

  • Prior Art Relied Upon: Gemmell (PCT 1992/000559) and Maddalozzo (Patent 7,768,501).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gemmell teaches the core components of a haptic feedback system, including a touch screen input device (for a tablet computer) with a vibrating mechanism (actuator) to provide tactile feedback to the user based on interactions with a GUI. However, Gemmell does not detail a specific GUI layout. Petitioner asserted that Maddalozzo, which was not considered during prosecution or reexamination, supplies the missing GUI details. Maddalozzo describes a touch screen GUI for a portable computer that explicitly includes a primary region for cursor positioning within a document and other non-overlapping control regions, such as a scroll bar and mode-select buttons. Petitioner contended that combining Gemmell’s haptic system with Maddalozzo’s GUI layout renders independent claim 10 obvious. For dependent claims, Petitioner argued the combination also teaches the claimed computer types (desktop, handheld per Gemmell), and response to handheld objects like a stylus (per Gemmell).
    • Motivation to Combine: Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Gemmell and Maddalozzo for several reasons. First, since Gemmell proposes using a Windows-based GUI, a POSITA would have been motivated to consult an analogous reference like Maddalozzo, which provides specific implementation details for such a GUI on a portable touch screen device. Second, strong consumer demand for improved user interfaces on tablet computers would have driven a POSITA to integrate Maddalozzo's space-saving and versatile GUI into Gemmell’s haptic system to create a more desirable product. Third, the fundamental similarities between the systems—both being portable devices with touch screens and GUIs—made Maddalozzo's GUI a suitable and exemplary interface for the system described in Gemmell.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references, as it involved integrating a known GUI layout (Maddalozzo) into a known haptic feedback system (Gemmell) to achieve the predictable result of a haptic-enabled, multi-region touch interface.

Ground 1B: Obviousness over Gemmell, Maddalozzo, and Blouin - 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 1992/000559), Maddalozzo (Patent 7,768,501), and Blouin (Patent 5,977,867).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground incorporated the arguments from Ground 1A and added Blouin to strengthen the teaching for limitation 10[a], which requires the "touch screen" to output a "first signal comprising coordinates of a contacted location." Petitioner argued that even if the Patent Owner contended Gemmell's system (which uses a touchscreen driver) does not meet this limitation, Blouin provides a definitive solution. Blouin was argued to teach an analog resistive touch screen with integrated bus bars that directly generate x-y coordinate data in the form of a linear voltage gradient. Petitioner contended this requires no further processing to derive coordinates and thus is undeniably a "first signal" output directly by the touch screen, rendering the limitation obvious.
    • Motivation to Combine: Petitioner asserted a POSITA would be motivated to incorporate Blouin's touch screen technology into the Gemmell/Maddalozzo combination for two primary reasons. First, using a two-dimensional Cartesian coordinate system, as taught by Blouin, was a routine and conventional design choice for a rectangular GUI display at the time of the invention. Second, a POSITA would have recognized the predictable advantages of Blouin's analog-resistive touch screen, which was known to be inexpensive to manufacture and could be paired with off-the-shelf controllers for low power consumption, making it highly desirable for mass-produced portable devices.
    • Expectation of Success: There would have been a high expectation of success, as this combination involved substituting a known component (Gemmell's touch screen) with another well-known and advantageous type of touch screen (Blouin's) to achieve predictable benefits in cost and power efficiency.

4. Key Claim Construction Positions

  • The petition highlighted a disputed construction for the term "touch screen."
  • Petitioner's Proposed 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."
  • Importance: Petitioner's construction, by explicitly excluding the "controller" from the definition of "touch screen," is central to its argument in Ground 1B. It supports the position that a signal processed by a separate driver (as in Gemmell) might not be considered as output by the touch screen itself, thus creating the need for Blouin's direct-output screen to definitively meet the claim limitation. Petitioner maintained, however, that its obviousness arguments prevail under either party's proposed construction.

5. Arguments Regarding Discretionary Denial

  • Arguments against §325(d) Denial: Petitioner argued that discretionary denial based on previously considered art would be inappropriate. Although Gemmell and Blouin were cited during prosecution of the ’720 patent, Petitioner asserted they were "buried" among over 600 references and were not substantively analyzed by the examiner in the context of the issued claims. Crucially, Petitioner emphasized that Maddalozzo is new prior art, never considered by the PTO, that provides the key teachings on GUI layout that the Patent Owner previously argued were missing from the art.
  • Arguments Against Denial for Multiple Petitions: The petition noted the concurrent filing of another IPR petition against the ’720 patent. It argued against denial on this basis by stating that the challenges are not redundant, as the instant petition is the only one to challenge claims 25 and 26. Furthermore, Petitioner argued that substantial overlap in other challenged claims creates an opportunity for efficiency through parallel proceedings with shared discovery and hearings.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 10, 13, 15, 16, 19, 25, and 26 of Patent 7,982,720 as unpatentable.