Apple Inc v. Haptic Inc

1. Case Identification

• Case #: IPR2024-01475
• Patent #: 9,996,738
• Filed: September 30, 2024
• Petitioner(s): Apple Inc.
• Patent Owner(s): Haptic Inc.
• Challenged Claims: 1-2, 4-5, 8-11

2. Patent Overview

• Title: SYSTEM AND METHOD FOR CONTROLLING A TERMINAL DEVICE
• Brief Description: The ’738 patent discloses a system for controlling a terminal device by detecting user gestures, such as knocks, on a mounting surface. A sensor housed within a casing detects vibrations from the surface, which are then processed to generate commands for the device (e.g., knocking on a wall to adjust a thermostat).

3. Grounds for Unpatentability

Ground 1: Obviousness over Murakoshi, Stewart, and Sachs - Claims 1-2, 4-5, 8-11 are obvious over Murakoshi in view of Stewart and Sachs.

• Prior Art Relied Upon: Murakoshi (Application # 2014/0191963), Stewart (Patent 4,744,249), and Sachs (Application # 2009/0265671).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Murakoshi taught a general system for controlling a device by detecting taps on a vibratory surface using an accelerometer but lacked specific implementation details. Stewart allegedly supplied these details by teaching a robust method for mounting an accelerometer within a case using a bracket assembly and attaching that case to a surface with case mounts. Sachs further supplemented this combination by teaching methods for processing motion sensor data from taps by identifying specific data features—such as defined peaks (large-magnitude pulses), the timing between peaks, and a defined time period after the last peak—to reliably recognize a gesture.
  • Motivation to Combine: A POSITA would combine Murakoshi with Stewart to implement a known and reliable mechanical mounting solution for the accelerometer, ensuring it was fixed to accurately detect vibrations without interference. The POSITA would then be motivated to incorporate Sachs's teachings to implement efficient and established techniques for interpreting tap patterns from the vibration data. This approach allows for more dependable gesture recognition by segmenting signals into specific features instead of comparing entire raw waveforms.
  • Expectation of Success: Petitioner asserted a high expectation of success, as the combination involved applying a known mounting technique (Stewart) to a known gesture-detection system (Murakoshi) and using conventional signal processing methods (Sachs), which would yield predictable and improved results.

Ground 2: Obviousness over Li and iFixit - Claims 1-2, 8-10 are obvious over Li in view of the iFixit report.

• Prior Art Relied Upon: Li (Application # 2015/0123949) and iFixit (an iPhone 6 teardown report published September 2014).
• Core Argument for this Ground: This ground was presented as mirroring the Patent Owner's infringement contentions in co-pending litigation.
  • Prior Art Mapping: Petitioner contended that Li taught using an accelerometer within an electronic device—explicitly suggesting an iPhone—to detect taps on the device's outer surface to control its functions. The iFixit teardown report provided the necessary structural details of an iPhone 6, showing an accelerometer mounted on a logic board that is, in turn, fixed inside the phone's housing. Petitioner argued this combination disclosed the claimed housing, sensor, and mounting surface relationship as construed by the Patent Owner.
  • Motivation to Combine: A POSITA seeking to implement Li's gesture detection method in an iPhone, as Li suggested, would be naturally motivated to consult a public reference like the iFixit report. Such a report would allow the POSITA to understand the internal component layout, including the location and mounting of the existing accelerometer. Using the iPhone's existing hardware, as detailed in iFixit, represented a simple, efficient, and obvious way to implement Li's system without adding new components.
  • Expectation of Success: There was a reasonable expectation of success because Li expressly suggested its system for use in an iPhone, and iFixit confirmed that the necessary components (an accelerometer, logic board, and housing) were already present and arranged in a manner suitable for implementing the claimed invention.
• Additional Grounds: Petitioner asserted additional obviousness challenges, including adding Orr (Application # 2015/0348554) to the Murakoshi combination for cloud-based processing, and adding Sachs to the Li-iFixit combination to further detail signal processing methods.

4. Key Claim Construction Positions

• Petitioner contended the term "engagement means" in claim 1 is a means-plus-function term under 35 U.S.C. §112(f). It argued the term should be construed based on the specific structures disclosed in the specification, such as an adhesive or mechanical fasteners, and a corresponding "transmission portion" that connects the sensor to the attachment means.
• Petitioner also argued that the terms "routing module," "processing module," and "output module" are means-plus-function terms subject to §112(f). Petitioner asserted these are generic, nonce terms that do not recite sufficient, definite structure for performing their claimed functions. These constructions were central to mapping the specific hardware structures disclosed in the prior art to the claim limitations.

5. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under Fintiv, asserting that the co-pending district court litigation in the Northern District of California is in its early stages. It contended that the scheduled trial date of September 2025 is likely to be delayed beyond the one-year statutory deadline for a Final Written Decision, citing the court's median time-to-trial statistics. Therefore, Petitioner argued that the IPR would resolve the patentability issues more efficiently than the district court action.

6. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-2, 4-5, and 8-11 of the ’738 patent as unpatentable.