PTAB

IPR2024-00478

Valve Corp v. Immersion Corp

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Petition
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1. Case Identification

2. Patent Overview

  • Title: Haptic Feedback for Input Devices
  • Brief Description: The ’042 patent relates to systems and methods for providing vibrotactile feedback on a touchpad input device. The technology generates "virtual detents" that simulate the feel of mechanical knobs or sliders to make the electronic interface more intuitive, particularly when used to control multiple systems like those in a vehicle.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ichinose and Levin - Claims 1-19 are obvious over Ichinose in view of Levin.

  • Prior Art Relied Upon: Ichinose (Patent 6,819,990) and Levin (Patent 6,686,911).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ichinose disclosed a touchpad on a vehicle steering wheel configured to control a plurality of systems (e.g., radio, navigation, HVAC) and provide general vibrotactile feedback. While Ichinose met the core system requirements, it lacked specific details on the type of feedback. Levin allegedly supplied this missing element by teaching various "force detents" for vehicle control knobs, including feedback that simulates mechanical clicks, which are stored as "detent force profiles." The combination of Ichinose's multi-system touchpad with Levin's specific virtual detent profiles was argued to teach all limitations of the challenged claims.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the references to improve the user interface of Ichinose's system. Both references shared the goal of minimizing driver distraction by providing tactile feedback. Levin explicitly taught that its "force detents" allow a driver to feel a setting change without looking at a display. Petitioner asserted a POSITA would have been motivated to incorporate Levin's more specific and effective feedback methods into Ichinose's touchpad system, especially since Ichinose stated that "other variations" of its feedback device were anticipated.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because both systems were designed for processor-controlled vehicle environments. Levin's "force detents" were executed by a processor based on stored profiles and could be output by various actuators. Integrating these known techniques into Ichinose's processor-controlled system, which already included a suitable actuator, would have been a predictable and straightforward design choice.

Ground 2: Obviousness over Wang and Ichinose - Claims 1-19 are obvious over Wang in view of Ichinose.

  • Prior Art Relied Upon: Wang (WO 02/102616) and Ichinose (Patent 6,819,990).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Wang disclosed a haptic vehicle control system where a driver manipulates virtual controls (knobs, sliders) on a display using a haptic input device that emulates a series of detents. However, Wang did not explicitly describe its haptic input device as a touchpad. Ichinose disclosed using a haptic-enabled touchpad on a steering wheel to control vehicle systems. Petitioner argued that combining Wang's virtual detent system with Ichinose's touchpad input device rendered the claims obvious.
    • Motivation to Combine: A POSITA would have been motivated to implement Wang's generic haptic device as a touchpad, a well-known input device for automotive applications. Petitioner contended this would be a simple substitution of one known element for another to obtain predictable results. By replacing Wang's undefined haptic controller with Ichinose's specific touchpad, a POSITA could create a more familiar and effective vehicle control interface.
    • Expectation of Success: Success would be expected because Wang's system already included actuators and a processor for generating haptic effects, simplifying the integration of Ichinose's actuator-driven touchpad. Using a touchpad to input coordinate signals to control a graphical interface, as in Wang's system, was a routine skill for a POSITA.

Ground 3: Anticipation by Rosenberg-I - Claims 1-19 are anticipated by Rosenberg-I.

  • Prior Art Relied Upon: Rosenberg-I (Patent 6,429,846).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued Rosenberg-I anticipated all claims, particularly under the Patent Owner's claim construction from related district court litigation. Rosenberg-I disclosed a touchpad on a computer that provides haptic sensations, including "pulse sensations" that function as virtual detents to indicate the location of "ticks" for discrete values (e.g., adjusting volume). Rosenberg-I also taught that its haptic effects are generated using stored "force profiles" (incorporated by reference from Rosenberg-II), which meets the "detent profile" limitation. For the "plurality of systems" limitation, Petitioner relied on the Patent Owner's litigation position that this term covers different software applications (e.g., a game and a web browser) running on the same device. Rosenberg-I's touchpad on a computer was disclosed as controlling such a plurality of applications.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 1-19 over Rosenberg-I in view of Goldenberg (Patent 6,636,197) as an alternative to the anticipation ground, arguing that if Rosenberg-I was found not to disclose "detent profiles," Goldenberg explicitly taught them.

4. Key Claim Construction Positions

  • "a plurality of systems": A central part of Petitioner's anticipation argument (Ground 3) relied on the Patent Owner's asserted construction of this term in co-pending district court litigation. Petitioner argued that under the Patent Owner's position—that the term can mean two different software applications running on the same device (e.g., a web browser and a video game)—Rosenberg-I's disclosure of a touchpad controlling multiple applications on a computer met this limitation.

5. Arguments Regarding Discretionary Denial

  • Fintiv Factors: Petitioner argued against discretionary denial under Fintiv, stating that the district court trial is scheduled for late 2025, likely after a Final Written Decision (FWD) in this inter partes review (IPR) would issue. Petitioner also asserted it filed the petition with diligence, that litigation investment has been minimal, and that the IPR challenges all 19 claims whereas the district court case involves only a subset, weighing against denial.
  • Advanced Bionics Factors: Petitioner argued denial under Advanced Bionics was unwarranted because the primary references relied upon (Ichinose, Wang, Rosenberg-I) were not cited or considered during the original prosecution. Although Levin was cited in an Information Disclosure Statement, the examiner never applied it in a rejection or provided any substantive analysis of its teachings. Therefore, Petitioner contended the Office erred by not previously considering the art and arguments presented in the petition.

6. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-19 of the ’042 patent as unpatentable.