DCT

1:10-cv-00258

Ironworks Patents LLC v. Apple Inc

Key Events

Complaint

I. Executive Summary and Procedural Information

Parties & Counsel:
- Plaintiff: MobileMedia Ideas LLC (Delaware)
- Defendant: Apple Inc. (California)
- Plaintiff’s Counsel: Young Conaway Stargatt & Taylor, LLP; Sullivan & Cromwell LLP; Proskauer Rose LLP
Case Identification: 1:10-cv-00258, D. Del., 03/31/2010
Venue Allegations: Plaintiff alleges venue is proper based on Defendant’s sale of accused products at a retail location in Newark, Delaware.
Core Dispute: Plaintiff alleges that Defendant’s smartphone and personal media player products infringe fourteen patents related to mobile device user interfaces, call handling, media management, and data processing.
Technical Context: The technologies at issue cover various functional aspects of modern smartphones and portable media players, a commercially significant sector of the consumer electronics market.
Key Procedural History: The complaint alleges that all patents-in-suit were assigned to Plaintiff on January 11, 2010, and that Defendant was notified of its alleged infringement by letter on February 22, 2010.

Case Timeline

Date	Event
1996-02-06	U.S. Patent No. 5,737,394 Priority Date
1996-09-02	U.S. Patent No. 5,915,239 Priority Date
1998-04-07	U.S. Patent No. 5,737,394 Issued
1999-06-22	U.S. Patent No. 5,915,239 Issued
1999-12-14	U.S. Patent No. 6,002,390 Issued
2000-05-30	U.S. Patent No. 6,070,068 Issued
2001-06-26	U.S. Patent No. 6,253,075 Issued
2002-05-21	U.S. Patent No. 6,393,430 Issued
2002-07-30	U.S. Patent No. 6,427,078 Issued
2002-08-27	U.S. Patent No. 6,441,828 Issued
2002-09-03	U.S. Patent No. 6,446,080 Issued
2003-04-15	U.S. Patent No. 6,549,942 Issued
2004-07-06	U.S. Patent No. 6,760,477 Issued
2006-08-08	U.S. Patent No. Re. 39,231 Issued
2007-12-25	U.S. Patent No. 7,313,647 Issued
2008-03-25	U.S. Patent No. 7,349,012 Issued
2010-01-11	All patents-in-suit assigned to Plaintiff MobileMedia Ideas LLC
2010-02-22	Plaintiff notifies Defendant by letter of alleged infringement
2010-03-31	Complaint Filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 5,737,394 - “Portable telephone apparatus having a plurality of selectable functions activated by the use of dedicated and/or soft keys”

Issued: April 7, 1998

The Invention Explained

Problem Addressed: The patent describes that as portable telephones incorporated more features, accessing them became "cumbersome and lengthy" and often required users to "memorize the correct selection of keys or constantly refer to an instruction manual" (col. 1:36-44, 1:55-58). This indirect access to functions was described as confusing and difficult to use.
The Patented Solution: The invention proposes a telephone apparatus that simplifies user interaction by providing dedicated hardware keys for direct access to primary functions like a "book" or "pad" feature, thereby bypassing nested menus (col. 2:42-46). It also utilizes changeable "soft keys" with functions that adapt to the current operational mode of the phone, with the function of each key indicated on a portion of the display (col. 2:18-24; '394 Patent, Fig. 2B).
Technical Importance: The approach sought to improve usability on feature-rich mobile devices by creating a more intuitive and direct method for users to access a growing number of non-telephony functions.

Key Claims at a Glance

The complaint does not identify specific claims, but Claim 1 is a representative independent apparatus claim.
Essential elements of Claim 1 include:
- A portable telephone apparatus with a plurality of dedicated keys and one or more changeable keys.
- The function of each changeable key changes in response to the selected operational function.
- Means for receiving a first message (voice or text) from a first person while the user is in a telephone conversation with a second person.
- Means for storing the received first message for subsequent retrieval.

U.S. Patent No. 5,915,239 - “Voice-controlled telecommunication terminal”

Issued: June 22, 1999

The Invention Explained

Problem Addressed: The patent addresses the rigidity of prior art voice-control systems for dialing, noting that "the command or identifier has to be given in a form as identical with the stored form as possible" (col. 2:51-54). This required users to remember the exact name format (e.g., "Matthew Herbert Williams" vs. "Williams, Matthew") for the system to work.
The Patented Solution: The invention describes a voice control system where a name (an "identifier") is stored as a series of "sub-identifiers" (e.g., first, middle, and last names) (col. 2:44-48). The system can then dial the correct number even if the user speaks the sub-identifiers in a different order, or speaks only a partial combination of them, making the voice command more flexible and natural (Abstract; col. 2:48-54).
Technical Importance: This technology aimed to make voice dialing, particularly in a hands-free context like a car, more reliable and user-friendly by not requiring exact phrase matching.

Key Claims at a Glance

The complaint does not identify specific claims, but Claim 4 is a representative independent device claim.
Essential elements of Claim 4 include:
- A voice controlled device.
- Means for storing telephone numbers and at least one corresponding identifier.
- The identifier comprises a plurality of "sub-identifiers."
- Means for storing the sub-identifiers.
- Means for receiving an identifier in voice form and selecting a telephone number in response to a voice command comprising at least two of the stored sub-identifiers.

Multi-Patent Capsule: U.S. Patent No. 6,253,075 - “Method and apparatus for incoming call rejection”

Issued: June 26, 2001 (Compl. ¶11).
Technology Synopsis: Based on the title, this patent relates to methods and systems for rejecting incoming calls on a device.
Asserted Claims: The complaint does not specify asserted claims (Compl. ¶¶26-30).
Accused Features: The complaint accuses the iPhone 3G and iPhone 3GS models (Compl. ¶28).

Multi-Patent Capsule: U.S. Patent No. 6,427,078 - “Device for personal communications, data collection and data processing, and a circuit card”

Issued: July 30, 2002 (Compl. ¶12).
Technology Synopsis: Based on the title, this patent concerns a multi-function personal communication device.
Asserted Claims: The complaint does not specify asserted claims (Compl. ¶¶31-35).
Accused Features: The complaint accuses the iPhone 3G and iPhone 3GS models (Compl. ¶33).

Multi-Patent Capsule: U.S. Patent No. Re. 39,231 - “Communication terminal equipment and call incoming control method”

Issued: August 8, 2006 (Compl. ¶13).
Technology Synopsis: Based on the title, this patent relates to methods for controlling incoming calls on communication terminals.
Asserted Claims: The complaint does not specify asserted claims (Compl. ¶¶36-40).
Accused Features: The complaint accuses the iPhone 3G and iPhone 3GS models (Compl. ¶38).

Multi-Patent Capsule: U.S. Patent No. 6,002,390 - “Text input device and method”

Issued: December 14, 1999 (Compl. ¶15).
Technology Synopsis: Based on the title, this patent concerns methods and systems for text input on a device.
Asserted Claims: The complaint does not specify asserted claims (Compl. ¶¶46-50).
Accused Features: The complaint accuses the iPhone 3G, iPhone 3GS, and iPod touch models (Compl. ¶48).

Multi-Patent Capsule: U.S. Patent No. 6,070,068 - “Communication terminal device and method for controlling a connecting state of a call into a desired connection state upon a predetermined operation by a user”

Issued: May 30, 2000 (Compl. ¶16).
Technology Synopsis: Based on the title, this patent relates to user-initiated control over the state of a telephone call.
Asserted Claims: The complaint does not specify asserted claims (Compl. ¶¶51-55).
Accused Features: The complaint accuses the iPhone 3G and iPhone 3GS models (Compl. ¶53).

Multi-Patent Capsule: U.S. Patent No. 6,393,430 - “Method and system for automatically recording music data files by using the hard drive of a personal computer as an intermediate storage medium”

Issued: May 21, 2002 (Compl. ¶17).
Technology Synopsis: Based on the title, this patent relates to systems for recording music files.
Asserted Claims: The complaint does not specify asserted claims (Compl. ¶¶56-62).
Accused Features: The complaint accuses the iPhone 3G, iPhone 3GS, iPod touch, iPod nano, iPod classic, and iPod shuffle models (Compl. ¶58).

Multi-Patent Capsule: U.S. Patent No. 6,441,828 - “Image display apparatus”

Issued: August 27, 2002 (Compl. ¶18).
Technology Synopsis: Based on the title, this patent relates to an apparatus for displaying images.
Asserted Claims: The complaint does not specify asserted claims (Compl. ¶¶63-67).
Accused Features: The complaint accuses the iPhone 3G, iPhone 3GS, iPod touch, and iPod nano models (Compl. ¶65).

Multi-Patent Capsule: U.S. Patent No. 6,446,080 - “Method for creating, modifying, and playing a custom playlist, saved as a virtual CD, to be played by a digital audio/visual actuator device”

Issued: September 3, 2002 (Compl. ¶19).
Technology Synopsis: Based on the title, this patent concerns the creation and management of media playlists.
Asserted Claims: The complaint does not specify asserted claims (Compl. ¶¶68-74).
Accused Features: The complaint accuses the iPhone 3G, iPhone 3GS, iPod touch, iPod nano, iPod classic, and iPod shuffle models (Compl. ¶70).

Multi-Patent Capsule: U.S. Patent No. 6,549,942 - “Enhanced delivery of audio data for portable playback”

Issued: April 15, 2003 (Compl. ¶20).
Technology Synopsis: Based on the title, this patent relates to audio data delivery for portable devices.
Asserted Claims: The complaint does not specify asserted claims (Compl. ¶¶75-81).
Accused Features: The complaint accuses the iPhone 3G, iPhone 3GS, iPod touch, iPod nano, iPod classic, and docking stations such as the Apple Universal Dock (Compl. ¶77).

Multi-Patent Capsule: U.S. Patent No. 6,760,477 - “Method and apparatus for entering data strings including Hangul (Korean) and ASCII characters”

Issued: July 6, 2004 (Compl. ¶21).
Technology Synopsis: Based on the title, this patent relates to methods for text entry.
Asserted Claims: The complaint does not specify asserted claims (Compl. ¶¶82-86).
Accused Features: The complaint accuses the iPhone 3G, iPhone 3GS, and iPod touch models (Compl. ¶84).

Multi-Patent Capsule: U.S. Patent No. 7,313,647 - “Storage and reproduction apparatus”

Issued: December 25, 2007 (Compl. ¶22).
Technology Synopsis: Based on the title, this patent concerns an apparatus for storing and reproducing data.
Asserted Claims: The complaint does not specify asserted claims (Compl. ¶¶87-91).
Accused Features: The complaint accuses the iPod nano and iPod classic models (Compl. ¶89).

Multi-Patent Capsule: U.S. Patent No. 7,349,012 - “Imaging apparatus with higher and lower resolution converters and a compression unit to compress decreased resolution image data”

Issued: March 25, 2008 (Compl. ¶23).
Technology Synopsis: Based on the title, this patent relates to image processing, specifically resolution conversion and compression.
Asserted Claims: The complaint does not specify asserted claims (Compl. ¶¶92-96).
Accused Features: The complaint accuses the iPhone 3G and iPhone 3GS models (Compl. ¶94).

III. The Accused Instrumentality

Product Identification

The complaint accuses Defendant's smartphone models iPhone 3G and iPhone 3GS, as well as personal media player models iPod touch, iPod nano, iPod classic, and iPod shuffle (Compl. ¶2). Certain infringement counts target specific subsets of these products.

Functionality and Market Context

The complaint broadly identifies the accused products as "smartphone devices and personal media players" (Compl. ¶2). It alleges these products "employ MMI patented technology" but does not provide specific technical descriptions of the accused features or how they operate (Compl. ¶9). The complaint notes that Defendant is engaged in the design, manufacture, marketing, and sale of these devices (Compl. ¶2).

IV. Analysis of Infringement Allegations

The complaint does not provide sufficient detail for a technical analysis of infringement for any of the asserted patents. The infringement allegations are conclusory and do not map specific features of the accused products to the elements of any asserted patent claims. No probative visual evidence provided in complaint.

'394 Patent Infringement Allegations

Claim Element (from Independent Claim 1)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
a portable telephone apparatus ... comprising: a plurality of dedicated keys each having at least one respective dedicated function associated therewith;	The complaint does not specify which features of the accused products perform this function.	¶43	col. 2:47-51
one or more changeable keys each having at least one respective changeable function associated therewith...	The complaint does not specify which features of the accused products perform this function.	¶43	col. 2:55-58
means for receiving a first message from a first person while said operator is engaged in a telephone conversation with a second person...	The complaint does not specify which features of the accused products perform this function.	¶43	col. 10:45-51
and for storing the received first message for subsequent retrieval by said operator...	The complaint does not specify which features of the accused products perform this function.	¶43	col. 1:26-32

'239 Patent Infringement Allegations

Claim Element (from Independent Claim 4)	Alleged Infringing Functionality	Complaint Citation	Patent Citation
A voice controlled device comprising: means for storing the telephone numbers to be selected, means for storing at least one identifier for each telephone number to be selected,	The complaint does not specify which features of the accused product performs this function.	¶99	col. 1:21-25
wherein the identifier comprises a plurality of sub-identifiers, and the voice controlled device comprises means for storing the sub-identifiers,	The complaint does not specify which features of the accused product performs this function.	¶99	col. 2:44-48
and means for selecting a telephone number in response to a voice command comprising at least two of the plurality of sub-identifiers...	The complaint does not specify which features of the accused product performs this function.	¶99	col. 2:48-54

Identified Points of Contention

Factual Sufficiency: A primary legal question will be whether the complaint's formulaic and conclusory infringement allegations, which lack any mapping of accused product features to claim limitations, satisfy federal pleading standards.
Scope Questions ('394 Patent): The infringement theory raises the question of whether software-generated icons on a touchscreen in the accused iPhones can be read to meet the limitations of "dedicated keys" and "changeable keys," which are described in the patent in the context of physical buttons ('394 Patent, Fig. 2B).
Technical Questions ('239 Patent): What evidence does the complaint provide that the accused iPhone 3GS voice control system operates by storing names as distinct "sub-identifiers" and performing selections based on combinations spoken in any order, as required by the claim, versus an alternative technical approach to voice recognition?

V. Key Claim Terms for Construction

The Term: "changeable key" ('394 Patent, Claim 1)

Context and Importance: This term's construction is critical because the accused iPhones primarily use a touchscreen interface, not the physical button layout depicted in the patent. The infringement analysis may depend on whether a software icon can be considered a "changeable key." Practitioners may focus on this term because the patent's embodiments show physical buttons separate from the display, while the accused products integrate the user input mechanism into the display itself.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The specification refers to these as "soft keys" and states that the display is used to show "indications of the functions associated with the soft keys" (col. 4:8-9). This language could support an interpretation that covers software-based keys whose function is inherently displayed.
- Evidence for a Narrower Interpretation: The patent's figures and description consistently depict "changeable keys 20" as physical buttons located below the "display 18" ('394 Patent, Fig. 2B; col. 4:54-58). This could support a narrower construction limited to physical hardware keys whose function is merely labeled on an adjacent screen.

The Term: "sub-identifier" ('239 Patent, Claim 4)

Context and Importance: The claim requires storing an identifier as multiple "sub-identifiers" and selecting a number based on a spoken combination of them. The viability of the infringement claim may turn on whether the accused voice control system uses such a partitioned data structure and matching logic.
Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: The abstract states the identifier is "divided into one or several sub-identifiers," and the system dials by "pronouncing said sub-identifiers in any order according to a combination or partial combination." This could be argued to cover any system that recognizes and acts upon constituent parts of a name (e.g., first and last name).
- Evidence for a Narrower Interpretation: The detailed description provides the example of an identifier comprising "more than one sub-identifier, i.e. word" and gives the example of "Williams Matthew Herbert" (col. 2:45-46, 2:32-36). This could support a narrower construction requiring the system to explicitly parse and store the name as discrete, recombinable word units.

VI. Other Allegations

Indirect Infringement

The complaint alleges active inducement for several patents, asserting that Defendant provides "step-by-step instructions of how to use the smartphones and personal media players in an infringing manner" through packaged instructions, online manuals, and iTunes software help pages (Compl. ¶¶59, 71, 78).

Willful Infringement

Willfulness is alleged for all fourteen patents. For some, the allegation is supported by the claim that Defendant had "actual notice of infringement" as of the February 22, 2010 letter, and that its infringement thereafter was willful (Compl. ¶¶60, 72, 79). For others, it is pleaded as a general assertion of "deliberate disregard of MMI's rights" (Compl. ¶¶29, 34).

VII. Analyst’s Conclusion: Key Questions for the Case

A core issue will be one of evidentiary sufficiency: will the complaint's infringement allegations, which state legal conclusions without providing specific supporting facts mapping product features to claim elements, survive a challenge under modern federal pleading standards?
A key question will be one of technological scope: can claim terms rooted in the context of 1990s mobile phones with physical buttons, such as "changeable key," be construed to cover the software-driven, touchscreen-based user interfaces of the accused products?
A central evidentiary question will be one of operational method: does the accused voice control functionality operate by storing and combining discrete "sub-identifiers" as required by the '239 Patent, or does it utilize a fundamentally different technical logic for voice recognition that falls outside the claim scope?