DCT
3:22-cv-02956
Apple Inc v. Li
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Apple Inc. (California)
- Defendant: Chian Chiu Li (California)
- Plaintiff’s Counsel: Shook, Hardy & Bacon L.L.P.
- Case Identification: 3:22-cv-02956, N.D. Cal., 05/18/2022
- Venue Allegations: Venue is alleged to be proper in the Northern District of California as the defendant is domiciled in the district and a substantial part of the events giving rise to the claim occurred there.
- Core Dispute: Plaintiff Apple Inc. seeks a declaratory judgment that its products, including various iPhone and iPad models, do not infringe Defendant Chian Chiu Li's patent related to methods for presenting information on an electronic device.
- Technical Context: The technology concerns user interface methods for mobile devices, specifically for waking a device from a low-power or idle state to display content based on a sequence of user actions involving physical movement and gaze detection.
- Key Procedural History: This action follows a prior lawsuit filed by the defendant against Apple on April 5, 2022, asserting infringement of the same patent. The defendant voluntarily dismissed that case without prejudice on May 17, 2022, one day before Apple filed this declaratory judgment complaint. The plaintiff alleges that this history, combined with pre-suit communications dating back to June 9, 2021, creates a reasonable apprehension of future litigation, warranting a judicial declaration of non-infringement.
Case Timeline
| Date | Event |
|---|---|
| 2014-03-18 | ’564 Patent Priority Date |
| 2020-02-03 | Application for ’564 Patent Filed |
| 2021-05-25 | ’564 Patent Issued |
| 2021-06-09 | Defendant allegedly notifies Plaintiff of infringement |
| 2022-04-05 | Defendant files original infringement complaint against Plaintiff |
| 2022-05-17 | Defendant voluntarily dismisses original complaint |
| 2022-05-18 | Plaintiff files this declaratory judgment complaint |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 11,016,564 - System and method for providing information
- Patent Identification: U.S. Patent No. 11,016,564, "System and method for providing information," issued May 25, 2021.
The Invention Explained
- Problem Addressed: The patent describes a problem where the "idle time" of electronic devices like smartphones is underutilized. Users may be reluctant to wake a device from a power-saving standby mode without a specific purpose, and conventional methods for displaying content (like advertisements) during active use can be intrusive or disruptive. (’564 Patent, col. 1:36-50, 2:1-4).
- The Patented Solution: The invention proposes a multi-step method to present information on an idle device in a less intrusive manner. First, the device detects a physical "act" from the user, such as shaking or tapping the device. Only after detecting this act does the device engage its gaze detection system to determine if the user is looking at the screen. If both the physical act and the user's gaze are confirmed, the device then presents content. (’564 Patent, Abstract; col. 2:37-44). This sequential process is illustrated in patent figures such as FIG. 7, which shows the device waiting for a tap (134) before proceeding to detect the user's gaze (136).
- Technical Importance: This two-factor trigger was designed to improve power efficiency by avoiding continuous, power-intensive gaze monitoring, activating it only after an initial physical input suggests user intent. (’564 Patent, col. 7:9-13).
Key Claims at a Glance
- The complaint seeks a declaratory judgment of non-infringement of independent claims 1, 8, and 14. (Compl. ¶6, ¶33).
- The essential elements of independent claim 1 are:
- detecting an act made by a user involving physical contact with the electronic device or physical movement of the electronic device when a display of the electronic device has an idle screen or a screen in standby mode, inactive mode, or screen-saver mode;
- performing gaze detection only after detecting the act;
- ascertaining whether the user looks at a direction toward the electronic device;
- determining whether the user is recognized via a recognition mechanism; and
- presenting a plurality of content items when the user is recognized via the recognition mechanism and it is ascertained that the user looks at a direction toward the electronic device.
- The complaint notes that independent claims 8 and 14 recite limitations similar to those in claim 1. (Compl. ¶33).
III. The Accused Instrumentality
Product Identification
- Numerous iPhone and iPad Pro models featuring the "Unlock with Face ID" function are identified as the "Accused Devices." (Compl. ¶¶6-7).
Functionality and Market Context
- The complaint centers on the operation of Apple's Face ID, a biometric authentication system. Apple alleges that its devices do not perform the steps required by the asserted claims. (Compl. ¶30). Specifically, Apple asserts that its devices do not perform "gaze detection" or "ascertain" a user's look in the manner described and claimed in the ’564 Patent. (Compl. ¶¶30-31). The complaint also addresses the defendant's contention that the presentation of content like text messages and emails after a device is unlocked satisfies the final limitation of claim 1, arguing that this functionality does not meet the claim requirements. (Compl. ¶32).
IV. Analysis of Infringement Allegations
No probative visual evidence provided in complaint.
Apple’s complaint seeks a declaration of non-infringement. The table below summarizes Apple's stated bases for why the Accused Devices do not meet the limitations of claim 1.
U.S. Patent No. 11,016,564 Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Non-Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| 1) detecting an act made by a user involving physical contact with the electronic device or physical movement...when a display of the electronic device has an idle screen... | The complaint does not contest this element but focuses on subsequent limitations. | N/A | col. 10:56-62 |
| 2) performing gaze detection only after detecting the act | The Accused Devices allegedly do not perform "gaze detection" as that term is used in the patent. Apple's argument suggests a distinction between its Face ID authentication and the patent's concept of gaze detection for triggering content. | ¶30 | col. 10:62-68 |
| 3) ascertaining whether the user looks at a direction toward the electronic device | The Accused Devices allegedly do not "ascertain[] whether the user looks at a direction toward the electronic device" as that phrase is used in the patent. This indicates a dispute over the specific meaning and technical implementation of "ascertaining." | ¶31 | col. 4:3-6 |
| 4) determining whether the user is recognized via a recognition mechanism | The complaint does not provide sufficient detail for analysis of this element. | N/A | col. 13:11-13 |
| 5) presenting a plurality of content items when the user is recognized...and it is ascertained that the user looks at a direction toward the electronic device | The Accused Devices allegedly do not meet this limitation because identified content items (e.g., messages, emails) are presented to a user regardless of whether the devices are unlocked by the user. This suggests the presentation is not contingent on the recognition and ascertainment steps as required. | ¶32 | col. 4:46-54 |
- Identified Points of Contention:
- Scope Questions: The complaint repeatedly states that the Accused Devices do not perform certain functions "as that term is used in the ’564 patent" (Compl. ¶¶30, 31). This frames the central dispute as one of claim construction. Key questions will include whether Apple's Face ID authentication process constitutes "gaze detection" and "ascertaining" a look, as those terms are defined by the patent's specification.
- Technical Questions: A primary technical question is whether the sequence of operations in the Accused Devices matches the claimed method. The patent requires a specific sequence: 1) physical act, which then triggers 2) gaze detection, which then allows 3) content presentation. The complaint raises the question of whether Apple's integrated "Unlock with Face ID" feature, which combines device movement with facial authentication, can be mapped onto this discrete, sequential claim structure.
V. Key Claim Terms for Construction
The Term: "performing gaze detection only after detecting the act"
Context and Importance: This sequence is a cornerstone of the invention, allegedly providing power-saving benefits. Apple’s non-infringement defense appears to rely on a distinction between its device's operation and this strict "only after" sequence. Practitioners may focus on this term because it defines the core logic and alleged novelty of the patented method.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue the term simply requires that gaze sensing not be continuously active and be initiated following some physical user interaction, without requiring a strictly delineated "off" then "on" state change.
- Evidence for a Narrower Interpretation: The specification provides support for a narrower view, stating that the "scheme saves energy as a gaze sensing system may be off most of the time unless getting activated upon receiving shaking signals." (’564 Patent, col. 7:9-13). This suggests the gaze detection system is inactive by default and is explicitly triggered by the physical act.
The Term: "ascertaining whether the user looks at a direction toward the electronic device"
Context and Importance: Apple explicitly argues its devices do not perform this step as claimed, making the construction of "ascertaining" critical. (Compl. ¶31). The dispute will likely involve whether the Face ID system's requirement for user attention is equivalent to the patent's concept of "ascertaining" a look.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: An argument could be made that any process that confirms a user's face is oriented toward the device for a successful operation meets this limitation.
- Evidence for a Narrower Interpretation: The specification distinguishes between a user "facing" a device and "gazing" at it, suggesting a more specific meaning. (’564 Patent, col. 12:31-50). It also describes analyzing an image of a user's eye "to decide which direction the user is looking at" to see if "eye sight may fall on the display screen." (’564 Patent, col. 4:1-6). This may support an interpretation requiring more than just general facial presence or orientation, but a specific determination of the user's line of sight.
VI. Other Allegations
- Indirect Infringement: Apple seeks a declaration of non-infringement for indirect infringement, arguing that because there is no underlying direct infringement, it cannot be liable for inducement or contributory infringement. (Compl. ¶¶34-35). Apple further asserts it has not acted with the specific intent necessary for either form of indirect infringement. (Compl. ¶¶34-35).
- Willful Infringement: The complaint seeks a declaration that Apple has not willfully infringed. (Compl. ¶27, Prayer for Relief ¶B). The factual basis for a potential willfulness claim by the defendant is established by the allegation that Apple was "made aware of the ’564 Patent on June 9, 2021." (Compl. ¶8).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the patent's terms "gaze detection" and "ascertaining," which are described in the context of triggering content for an idle user, be construed to read on Apple's "Face ID" system, which is a biometric security feature for device authentication?
- A key evidentiary question will be one of functional sequence: does the operation of the Accused Devices map to the discrete, two-step process required by the claims—a physical act that then and only then triggers a separate gaze detection process—or do Apple's devices employ an integrated function where these actions are not distinct and sequential in the manner claimed by the patent?