Obviousness

Obviousness Analysis of U.S. Patent No. 9,352,229

To: In-house Counsel
From: Senior Patent Analyst
Date: May 09, 2026
Subject: Obviousness Analysis of U.S. Patent No. 9,352,229 B2

I. Introduction

This report provides an analysis of the obviousness of U.S. Patent No. 9,352,229 B2 ("the '229 patent"), titled "Controller for a games console," under 35 U.S.C. § 103. The '229 patent, assigned to Ironburg Inventions Ltd., describes a hand-held game controller with additional, repositioned controls on its rear surface, intended to be operated by the user's middle fingers. This analysis is based on a review of prior art references cited in the patent's file history and other publicly available documents. The core inventive concept of the '229 patent appears to be the placement of elongate, flexible paddle-like controls within channels on the back of the controller to allow for actuation of game functions without removing thumbs from the analog sticks.

II. Analysis of Independent Claims

The '229 patent contains six independent claims, which can be grouped by their core inventive features:

• Claim 1: A hand-held controller with controls on the front and top, and at least one additional control on the back. This additional control is an "elongate member" that is "inherently resilient and flexible" and is at least partially housed within a "respective channel formed in a rear surface of the controller." This control is positioned for operation by a user's middle finger.
• Claim 10: Similar to Claim 1, this claim focuses on a controller with a "mounting plate" on the back that includes at least one channel for an elongate, flexible additional control.
• Claim 14: This claim introduces a "mounting mechanism" on the back of the controller for "detachably securing" the additional elongate control. It specifies a "complementary locking mechanism" for this purpose.
• Claim 18: This claim describes a controller with at least two additional controls on the back, comprising a "first body portion" and at least two integrally formed, flexible "first elongate members."
• Claim 22: This claim is directed to a controller with a detachable "over-grip" on the back.
• Claim 23: This claim focuses on the functionality of the additional control, specifying a "remap device" that allows the user to map the function of a front-facing button to the additional rear control "whilst the controller is in use."

III. Prior Art References and Motivation to Combine

Several prior art references, when combined, would have rendered the claims of the '229 patent obvious to a Person Having Ordinary Skill in the Art (PHOSITA) at the time of the invention. The key references are:

1. U.S. Patent No. 8,641,525 ("Hicks"): Filed by the same inventors and part of the same patent family, Hicks discloses a game controller with rear-mounted paddle-like controls. This reference establishes the basic concept of adding controls to the back of a controller for middle-finger operation.
2. U.S. Patent No. 7,052,414 ("Tsuchida"): Tsuchida discloses a game controller with additional buttons on the underside of the handgrips, specifically for operation by the middle fingers. This demonstrates the motivation to provide additional inputs accessible without removing thumbs from the primary analog sticks.
3. U.S. Patent No. 6,222,525 ("Armstrong"): Armstrong describes a joystick handgrip with programmable switches. This reference is relevant to the remapping functionality described in Claim 23, showing that re-programmable controls were known in the art.
4. U.S. Patent No. 5,831,598 ("Garf"): Garf teaches a game controller with a modular design, allowing for the attachment and detachment of different control components. This is pertinent to the detachability aspect of Claims 14, 18, and 22.

IV. Obviousness Combinations

A. Obviousness of Independent Claim 1

Independent Claim 1 describes a controller with an additional elongate, flexible control on the back, situated within a channel.

• Primary Reference: Hicks ('525) discloses a game controller with paddle-like actuators on the back, which are inherently elongate. While Hicks may not explicitly detail the "resilient and flexible" nature in the exact terms of the '229 patent, this is an inherent quality of the materials typically used for such controls, which a PHOSITA would understand. Hicks also shows these paddles positioned for operation by the user's middle fingers.
• Secondary Reference: Tsuchida ('414) also shows additional buttons on the rear of the controller. A PHOSITA, looking to improve the design of Hicks's paddles for better ergonomics and to prevent accidental actuation, would be motivated to recess them into a "channel" as a natural design choice. This would not only protect the paddles from damage but also guide the user's finger to the correct position. The use of channels or recesses to house buttons and switches is a common and well-established design principle in the field of consumer electronics.
• Conclusion: The combination of Hicks and Tsuchida would have rendered the subject matter of Claim 1 obvious. Hicks teaches the core concept of rear-mounted paddles, and Tsuchida, along with general engineering knowledge, provides the motivation to place these paddles in protective and guiding channels.

B. Obviousness of Independent Claim 14

Independent Claim 14 adds the limitation of a "mounting mechanism for detachably securing" the additional control using a "complementary locking mechanism."

• Primary Reference: The combination of Hicks ('525) and Tsuchida ('414) as established above.
• Secondary Reference: Garf ('598) discloses a modular game controller where different control components can be attached and detached. A PHOSITA, seeking to create a more customizable controller based on the teachings of Hicks, would be motivated to look for ways to make the rear paddles interchangeable or removable. Garf provides a clear example of such a modular design in the context of game controllers. The implementation of a "complementary locking mechanism" (e.g., a catch, tab, or snap-fit) is a well-known and routine mechanical design choice for creating detachable components.
• Conclusion: It would have been obvious to a PHOSITA to make the rear paddles of a controller like the one in Hicks detachable, as taught by the modular design principles in Garf. This would allow for customization, repair, or replacement of the paddles, a clear and predictable benefit.

C. Obviousness of Independent Claim 23

Independent Claim 23 introduces a "remap device" for reassigning button functions to the rear controls "whilst the controller is in use."

• Primary Reference: The combination of Hicks ('525) and Tsuchida ('414), which establishes the concept of a game controller with rear-mounted controls.
• Secondary Reference: Armstrong ('525) teaches a joystick with programmable buttons. The motivation to allow users to customize their control schemes is a long-standing principle in game design and controller manufacturing. A PHOSITA, having developed a controller with extra buttons as per Hicks, would naturally consider making those buttons programmable to enhance user experience and provide a competitive advantage. The ability to remap buttons "in-game" is a logical extension of this programmability, allowing for dynamic adjustments to gameplay. The electronic circuitry required to implement such a remapping function was well within the state of the art at the time of the invention.
• Conclusion: The combination of a controller with rear paddles (Hicks/Tsuchida) and the known concept of programmable/remappable controls (Armstrong) would have rendered Claim 23 obvious. A PHOSITA would have been motivated to combine these features to create a more versatile and user-friendly controller.

V. Summary and Conclusion

The core innovations claimed in U.S. Patent No. 9,352,229 appear to be combinations of known elements from the prior art. The concept of rear-mounted controls for gaming was established by references like Hicks and Tsuchida. The ideas of making these controls detachable for modularity (Garf) and programmable for customization (Armstrong) were also present in the prior art. A person of ordinary skill in the art, faced with the problem of improving game controller design, would have found it obvious to combine these known elements to arrive at the inventions claimed in the '229 patent. Therefore, a strong argument for the invalidity of the independent claims of the '229 patent under 35 U.S.C. § 103 can be made.