PTAB

IPR2019-00921

Motorola Mobility LLC v. Immersion Corp

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Petition
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1. Case Identification

2. Patent Overview

  • Title: HAPTIC FEEDBACK FOR TOUCHPADS AND OTHER TOUCH CONTROLS
  • Brief Description: The ’181 patent discloses devices that provide haptic feedback to a user interfacing with a computer system. The technology involves a touch-sensitive input device, such as a touchscreen, coupled with one or more actuators that impart forces (e.g., vibrations) based on the user's interaction with different regions of a graphical user interface (GUI).

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 6, 8, 14, and 20-21 are obvious over Gemmell in view of Maddalozzo.

  • Prior Art Relied Upon: Gemmell (International Publication No. WO 92/00559) and Maddalozzo (Patent 7,768,501).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gemmell taught a computer system with a haptic touchscreen that provides varied tactile feedback to a user based on interactions with GUI elements. Gemmell disclosed a vibrating mechanism (actuator) to create these effects, enhancing the user interface. However, Gemmell did not explicitly detail a GUI with a first region for cursor control and a second, distinct functional region. Maddalozzo addressed this by disclosing a portable computer with a touchscreen GUI featuring multiple, distinct functional regions. This included a main document area for cursor positioning (a first region) and other regions for different functions like a scroll bar or mode-selection buttons (a second region).
    • Petitioner contended that combining these references would be obvious. A person of ordinary skill in the art (POSITA) would have implemented Maddalozzo's multi-region GUI on Gemmell's haptic feedback system. This combination would result in a device where touching the cursor control region produces one type of haptic feedback, while touching a mode-selection button produces a different haptic effect, thus rendering the limitations of independent claim 1 obvious. Dependent claims were allegedly met by further teachings, such as Gemmell’s disclosure of portable "mobile workstations" (claim 2), the use of a stylus (claim 6), and specific actuator types like a solenoid (claim 14).
    • Motivation to Combine: Petitioner asserted four primary motivations for the combination. First, Gemmell’s general teaching of Windows-based GUIs would prompt a POSITA to consult an analogous reference like Maddalozzo for specific implementation details. Second, strong market demand for feature-rich portable devices would incentivize integrating Maddalozzo’s well-defined word processing GUI with Gemmell's haptic technology. Third, adding tactile feedback to Maddalozzo’s distinct regions would directly further Gemmell's stated goal of improving a user's ability to interact with a GUI by allowing different screen elements to be distinguished by feel. Fourth, the combination was argued to be a predictable application of a known technique (defining functional areas on a touchscreen) to a known system (a haptic device) to achieve a predictable result.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination merely arranged known elements, each performing its established function, to yield a predictable improvement in user interface design.

4. Key Claim Construction Positions

  • The petition identified "touch screen" as the key term with disputed constructions in co-pending district court litigation.
  • 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."
  • Patent Owner's position: "No construction is necessary," or alternatively, "[A] 'display device that allows a user to provide input by touching an area on the device.' A touch screen may include a touch surface, a touch sensor, a local microprocessor, and a display."
  • Petitioner argued that its obviousness analysis was valid under any of these proposed constructions, relieving the Board of the need to resolve the dispute for institution purposes.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that institution would be proper and efficient despite a concurrently filed petition challenging a different subset of claims of the ’181 patent.
  • The petition asserted that denial would be inappropriate because this challenge was unique in its inclusion of dependent claims 6 and 14.
  • Petitioner further argued that substantial overlap in the challenged claims between the two petitions would create efficiencies, allowing for shared depositions and hearings, thereby promoting a just, speedy, and inexpensive resolution.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 6, 8, 14, and 20-21 of the ’181 patent as unpatentable.