PTAB

IPR2025-01368

Amazon.com Inc v. SoundClear Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Electronic Apparatus with Touch-Based Gesture Control
  • Brief Description: The ’487 patent relates to a system for selecting objects on a touchscreen using a "pinching" or "inward drag" gesture. The core technology involves detecting the gesture by calculating vectors from initial and subsequent touch points and analyzing the angles between those vectors and a straight line connecting the initial points.

3. Grounds for Unpatentability

Ground 1a: Obviousness over Choi and Hillis - Claims 1, 11, and 12 are obvious over Choi in view of Hillis.

  • Prior Art Relied Upon: Choi (Application # 2010/0090971) and Hillis (Application # 2006/0274046).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Choi taught the fundamental elements of the independent claims, including using an "inward drag event" (pinch gesture) on a touchscreen to define a rectangular area and select objects within it. According to the petition, Choi’s disclosure established that the initial touch points define the opposite corners of this selection rectangle. However, Petitioner contended that Choi lacked the specific mathematical details for how to reliably detect the inward drag gesture. Hillis was asserted to supply this missing teaching by disclosing a precise method for identifying multi-touch gestures. Hillis taught deriving velocity vectors for each touch point, establishing a line segment between them, and calculating the angle between each vector and the line segment to determine if the points were approaching each other in "approximate alignment."
    • Motivation to Combine: A POSITA implementing Choi's pinch-to-select system would combine it with Hillis's gesture detection method for known benefits. Since Choi described a function without a detailed implementation, a POSITA would naturally look to the art for an established method. Hillis provided a known, reliable technique to distinguish a pinch from other gestures (e.g., rotation), thereby improving the accuracy, intuitiveness, and overall user experience of the system described in Choi.
    • Expectation of Success: Petitioner argued a POSITA would have a high expectation of success, as the combination merely involved applying a known mathematical technique (Hillis) to implement a known, desired function (Choi's pinch-to-select) using standard programming skills.

Ground 1b: Obviousness over Choi, Hillis, Ogawa, and McGibney - Claims 2 and 3 are obvious over the combination of Ground 1a in view of Ogawa and optionally McGibney.

  • Prior Art Relied Upon: Choi, Hillis, Ogawa (Application # 2011/0077851), and McGibney (WO 2010/091496).
  • Core Argument for this Ground:
    • Prior Art Mapping: Building upon the combination for claim 1, Petitioner argued that dependent claims 2 and 3 were obvious over the further addition of Ogawa and/or McGibney. These claims added a "moving section" for sliding the selected objects across the screen, which is triggered when the user moves both touch points in substantially the same direction while keeping the distance between them "substantially constant." Petitioner asserted that both Ogawa and McGibney explicitly taught this functionality. Ogawa disclosed moving selected icons when touch points are moved "in the same direction while keeping the space therebetween." McGibney similarly disclosed a two-point slide gesture detected when the touch points "move in one direction" and "maintain[] approximately the same distance apart."
    • Motivation to Combine: A POSITA would combine these teachings to create a more fluid and efficient user interface. After selecting objects with the pinch gesture from Choi/Hillis, allowing the user to immediately move those objects with a sliding motion without lifting their fingers would be a logical and intuitive improvement. This would create a single, continuous gesture for selecting and positioning objects.
    • Expectation of Success: Success was expected because combining selection and moving functionalities was a common design pattern in touchscreen interfaces. Integrating the known slide-to-move gesture from Ogawa/McGibney with the selected object group from Choi/Hillis was a predictable combination of known elements.

Ground 2a: Obviousness over Yach, Westerman-632, and Hillis - Claims 1, 11, and 12 are obvious over Yach in view of Westerman-632 and Hillis.

  • Prior Art Relied Upon: Yach (European Patent # 2,175,354), Westerman-632 (Application # 2008/0309632), and Hillis.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner presented an alternative combination where Yach served as the primary reference. Yach taught selecting objects within a rectangular area defined by two static touch points. Petitioner argued that Yach's system was improved by adding the dynamic "finger pinching" gesture taught by Westerman-632 to trigger the selection, which Westerman-632 described as a more efficient and accurate command. As in Ground 1a, Hillis was relied upon to provide the specific, known mathematical calculations (vector and angle analysis) needed to implement the pinch gesture detection described functionally by Westerman-632.
    • Motivation to Combine: A POSITA would be motivated to modify Yach’s static-touch system to require a dynamic pinch gesture to confirm the user's intent and prevent inadvertent selections. Westerman-632 provided the rationale for this modification. To implement the pinch detection, a POSITA would naturally use a known and reliable method like that disclosed in Hillis.
    • Expectation of Success: The combination involved replacing one known input method (static touch) with another known and superior one (pinch gesture) and using a standard, predictable technique (Hillis) for its implementation, leading to a high expectation of success.
  • Additional Grounds: Petitioner asserted additional obviousness challenges for claim 10 based on combinations of Choi, Hillis, Yeh, and Ording (Ground 1c) and for claims 2, 3, and 10 based on Yach, Westerman-632, Hillis, and various other references (Grounds 2b and 2c).

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3 and 10-12 of Patent 9,223,487 as unpatentable.