Motorola Mobility LLC v. Immersion Corp

1. Case Identification

• Case #: IPR2019-00870
• Patent #: 7,969,288
• Filed: March 22, 2019
• Petitioner(s): Motorola Mobility LLC and Motorola Mobility Holdings LLC
• Patent Owner(s): Immersion Corporation
• Challenged Claims: 18

2. Patent Overview

• Title: Force Feedback System Including Multi-Tasking Graphical Host Environment and Interface Device
• Brief Description: The ’288 patent describes an architecture for a host computer that allows multiple concurrently running application programs to interface with a force feedback device without conflicts by managing force effects based on which application is active.

3. Grounds for Unpatentability

Ground 1: Obviousness over Rosenberg and Greanias - Claim 18 is obvious over Rosenberg in view of Greanias.

• Prior Art Relied Upon: Rosenberg (International Publication No. WO 97/21160) and Greanias (Patent 5,157,384).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Rosenberg disclosed all elements of claim 18 except for explicitly determining which of a plurality of concurrently running applications is "active." Rosenberg taught a force feedback system for a graphical user interface (GUI) where multiple application windows can be displayed, each associated with different, predetermined force effects stored in memory. Rosenberg further disclosed that when multiple applications issue conflicting force commands, a priority scheme is used to resolve the conflict. However, Rosenberg did not base this priority on which application has user focus. Greanias, in contrast, was cited to cure this deficiency, as it explicitly taught a system for a multi-tasking environment (like Microsoft Windows) that determines which of several concurrently running applications is the "active" one to which all user input is directed.
  • Motivation to Combine: A POSITA would combine Greanias's teaching of identifying an active application with Rosenberg’s force feedback system to solve a known problem. When Rosenberg’s system encounters conflicting force commands from multiple applications, a POSITA would have looked for a logical way to prioritize them. Greanias provided a known method for determining which application is active (i.e., receiving the user’s attention and input). A POSITA would have been motivated to assign a higher priority to the force commands from the active application, as this is the application the user is directly interacting with, thereby providing a more intuitive and useful user experience.
  • Expectation of Success: A POSITA would have had a high expectation of success because both Rosenberg and Greanias described systems operating within a standard multi-tasking GUI environment like Microsoft Windows, making their teachings compatible and their integration straightforward.

Ground 2: Obviousness over Schuler II and Greanias - Claim 18 is obvious over Schuler II in view of Greanias.

• Prior Art Relied Upon: Schuler II (International Publication No. WO 97/25657) and Greanias (Patent 5,157,384).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Schuler II disclosed a method for providing force effects (described as "torque profiles") to a user in a multi-tasking environment where different applications have their own associated force effects. Schuler II taught that a database of torque profiles, which represents the force effects, is stored in memory and can be part of an application program, with different profiles corresponding to different applications. The system could access these profiles via an application programming interface (API). Similar to the Rosenberg combination, Petitioner argued Schuler II did not explicitly teach determining which application is active and generating a signal based on that determination. Greanias was again relied upon for its teaching of identifying the single active application among multiple concurrently running programs.
  • Motivation to Combine: The primary motivation argued was to improve Schuler II’s system for visually impaired users. Schuler II recognized its technology could help physically impaired people interface with computers without needing sight. However, in a multi-tasking environment, the active application is typically indicated visually (e.g., the topmost window). A visually impaired user could not perceive this cue and would be confused by receiving haptic feedback from multiple applications simultaneously. A POSITA would be motivated to modify Schuler II's system to generate force effects associated only with the currently active application—as determined by the method taught in Greanias—to mitigate this confusion and improve the system's usability for its intended users.
  • Expectation of Success: Success would have been expected as the combination involved implementing a known technique (determining the active application from Greanias) into another system (Schuler II) operating in the same conventional multi-tasking environment to solve a predictable problem.

4. Key Claim Construction Positions

• Petitioner noted that the parties in a related district court litigation had agreed on the construction of key terms. Petitioner adopted these constructions for the IPR proceeding.
• "is active": The parties agreed this term means "has input focus."
• "active application program": The parties agreed this term means "application program having input focus."
• These constructions were central to Petitioner's arguments, as they equated "active" status with receiving user input, a concept explicitly taught by Greanias as the basis for identifying the primary application in a multi-tasking environment.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claim 18 of the ’288 patent as unpatentable under 35 U.S.C. §103.