PTAB

IPR2019-01666

HTC Corp v. Motiva Patents LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless Video Game System for Detecting Motion
  • Brief Description: The ’659 patent discloses a motion-tracking system designed to measure the position and orientation (pose) of one or more active transponders. The system is intended for applications such as physical rehabilitation and exercise, where it trains a user to manipulate the transponders along a specific trajectory by providing interactive and sensory feedback.

3. Grounds for Unpatentability

Ground 1: Anticipation over Nishitani - Claims 45, 46, and 48 are anticipated by Nishitani under 35 U.S.C. §102.

  • Prior Art Relied Upon: Nishitani (Application # US 2001/0015123).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Nishitani disclosed every element of the challenged claims. Nishitani described a wireless video game system for a music game that used one or more baton-like handheld controllers to detect a user’s motion. Independent claim 45 was allegedly met because Nishitani’s controller included an accelerometer, memory, a processing system, a wireless transmitter/receiver for communication with a remote processing system (a personal computer), user input buttons, and output devices (LEDs, a display, and a vibrator) for providing feedback. The remote computer processed motion data from the controller to proportionally control a virtual object (an animated performer) on a display. Dependent claim 46 was allegedly met by Nishitani’s express disclosure that a user may hold two controllers, one in each hand. Dependent claim 48 was met because Nishitani’s sensors could detect orientation (e.g., gyroscopic position, inclination), and the system provided feedback to the user based on this motion data.

Ground 2: Anticipation over Rosenberg - Claims 45, 46, and 48 are anticipated by Rosenberg under 35 U.S.C. §102.

  • Prior Art Relied Upon: Rosenberg (WO 97/12337).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Rosenberg, which described a force-feedback interface for computers and video games, anticipated the challenged claims. For independent claim 45, Rosenberg disclosed a handheld interface device (e.g., joystick or stylus) with sensors, including accelerometers, to detect motion and orientation. This device communicated wirelessly with a remote host computer system (such as a Nintendo or Sony game console) and contained its own microprocessor, memory, user input buttons, and output actuators for providing force feedback. The host system used the sensor data to proportionally control a virtual object (e.g., a cursor or virtual race car) on a remote display. For dependent claim 46, Rosenberg taught that multiple interface devices could be coupled to a single host computer for multi-player games. For dependent claim 48, Petitioner argued that Rosenberg disclosed determining the orientation (angle) of the user object and providing corresponding force feedback based on that orientation information.

Ground 3: Obviousness over Horton in view of Woolston - Claims 45, 46, and 48 are obvious over Horton in view of Woolston under 35 U.S.C. §103.

  • Prior Art Relied Upon: Horton (Patent 5,615,132) and Woolston (Patent 6,162,123).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Horton, a system for 3D position and orientation tracking, formed the base system. Horton disclosed a movable object (e.g., a data glove) containing accelerometers, a processor, memory, and a wireless transceiver that communicated with a remote simulation processor for virtual reality applications. The movable object could also receive feedback signals (audio, video) from the remote processor. Petitioner argued that Horton disclosed most elements of claim 45 but did not expressly disclose a user input device on the exterior of the movable object. Woolston, which described a video game system with a handheld "sword apparatus," supplied this missing element by teaching a switch on the controller for user input.
    • Motivation to Combine: A POSITA would combine Horton and Woolston because both related to tracking handheld devices in virtual reality environments to provide feedback. A POSITA would have been motivated to modify Horton’s data glove to include user input switches, as taught by Woolston, to provide necessary game functions like pausing or making menu selections, which are essential for a functional video game controller. Adding such common input mechanisms to Horton's tracking device would be a simple and logical improvement.
    • Expectation of Success: Petitioner argued there was a reasonable expectation of success because adding pushbuttons or switches to a controller was a common, predictable, and well-established method for providing user input to computer systems long before the ’659 patent’s priority date. The integration was a matter of routine engineering.

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 45, 46, and 48 of the ’659 patent as unpatentable.