DCT

1:19-cv-01101

Princeps Interface Tech LLC v. Apple Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:19-cv-01101, D. Del., 06/14/2019
  • Venue Allegations: Venue is alleged to be proper in the District of Delaware because Defendant Apple Inc. maintains a "regular and established place of business" in the district, specifically citing an Apple Store in Newark, Delaware, and has allegedly committed acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s iPhones, iPads, and iPods, which run the iOS operating system, infringe a patent related to multifunctional, programmable input devices.
  • Technical Context: The technology concerns user interface design for compact electronic devices, specifically methods for providing versatile data entry on a small-profile keyboard by using selectable modes and levels to change key functions.
  • Key Procedural History: The complaint does not mention any prior litigation, Inter Partes Review (IPR) proceedings, or licensing history related to the patent-in-suit. The complaint does, however, include several paragraphs preemptively arguing that the patent's claims are directed to patent-eligible subject matter and are not abstract ideas.

Case Timeline

Date Event
2001-09-20 Patent Priority Date ('963 Patent)
2004-03-09 Issue Date, U.S. Patent No. 6,703,963
2019-06-14 Complaint Filing Date

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

U.S. Patent No. 6,703,963 - Universal Keyboard

The Invention Explained

  • Problem Addressed: The patent identifies several drawbacks with traditional QWERTY keyboards in the context of increasingly miniaturized electronic devices. These problems include their large size, which is incompatible with single-hand operation; a key layout not optimized for rapid data entry; and a typically singular functionality (alphanumeric input) that is insufficient for modern devices requiring more versatile controls. (’963 Patent, col. 1:37-2:23).
  • The Patented Solution: The invention is a "multifunctional input device" that uses a layered system of "functional modes" and "domain levels" to expand the capability of a limited number of physical keys. (’963 Patent, Abstract). A user can select a high-level "functional mode" (e.g., Alphanumeric, Telephone, Calculator), and within that mode, select a "domain level" (e.g., letters "A-L," letters "M-X," or punctuation). This selection reassigns the values of the programmable input keys, with a "function-specific display" associated with each key indicating its current purpose. (’963 Patent, col. 3:55-4:19).
  • Technical Importance: The invention offers a method to overcome the physical constraints of small devices by making a compact set of keys serve multiple, customizable purposes, thereby increasing input versatility without increasing the device's physical footprint. (Compl. ¶15).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 60. (Compl. ¶23).
  • Independent Claim 1 (Device Claim) recites an information input device comprising:
    • a functional mode control for selecting a first functional mode of operation.
    • a domain control for selecting one of multiple domain levels within the functional mode.
    • a plurality of input keys, separate and distinct from the domain control, assigned to the domain-level values.
    • a function-specific display indicating a domain-level value associated with each input key.
  • Independent Claim 60 (Method Claim) recites a method of operating an information input device, comprising the steps of:
    • first selecting a functional mode of operation.
    • second selecting, through the domain control, a domain level within the selected functional mode.
    • actuating one or more of the input keys, where the input keys and domain control are simultaneously presented.
  • The complaint also asserts dependent claims 2, 3, 9, and 12 and reserves the right to assert others. (Compl. ¶23, ¶33).

III. The Accused Instrumentality

Product Identification

The accused instrumentalities are "iPhones, iPads and iPods with an operating system such as the iOS operating system." (Compl. ¶23).

Functionality and Market Context

The complaint alleges these devices are "information input devices" that infringe the ’963 Patent. (Compl. ¶23). The infringement theory appears to focus on the software-based keyboard within the iOS operating system, which allows users to switch between different character sets (e.g., letters, numbers, symbols). The complaint highlights Defendant's large annual revenues as evidence of the commercial importance of its products. (Compl. ¶30). The complaint does not, however, provide a detailed technical description of how the accused iOS keyboard operates.

IV. Analysis of Infringement Allegations

The complaint states that "preliminary and exemplary claim charts" are provided in an Exhibit A-1, but this exhibit was not filed with the complaint. (Compl. ¶23). As such, a detailed claim chart analysis is not possible based on the provided documents. The narrative infringement theory is that Apple's devices, by incorporating the iOS software keyboard, meet all the limitations of the asserted claims. (Compl. ¶23).

No probative visual evidence provided in complaint.

  • Identified Points of Contention:
    • Structural vs. Functional Interpretation: A primary point of contention may be whether the claim limitations require distinct physical structures, as depicted in the patent’s figures (e.g., separate buttons for "domain control" and "input keys"), or if they can be met by functionally distinct regions of a single, unified touchscreen interface. The claims require input keys that are "separate and distinct from the domain control," which raises the question of whether software buttons on the same screen can meet this limitation.
    • Mapping to iOS: The plaintiff will need to establish a clear mapping between the elements of the iOS keyboard and the patent's claim terms. For example, does tapping the ".?123" key on the iOS keyboard to switch from letters to numbers constitute "selecting one of multiple domain levels" using a "domain control" as defined by the patent? The defense may argue this is a routine software function that does not practice the specific layered architecture claimed.
    • Patent Eligibility: The complaint dedicates significant space to arguing that the claims are not directed to an abstract idea under 35 U.S.C. § 101. (Compl. ¶15-19). This suggests Plaintiff anticipates, and is preemptively rebutting, a defense that the claims merely recite the abstract idea of organizing information and are thus patent-ineligible.

V. Key Claim Terms for Construction

  • The Term: "domain control"

    • Context and Importance: Identifying a "domain control" within the accused iOS interface is fundamental to the infringement allegation. The construction of this term will determine whether a software key (like the iOS key for switching to the numeric/symbol layout) can satisfy a limitation that the patent's figures illustrate as a distinct physical button or switch.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language is functional, describing the element as a control "for selecting one of multiple domain levels." (’963 Patent, cl. 1). This functional description could support an interpretation that is not limited to a specific physical structure.
      • Evidence for a Narrower Interpretation: The patent's specification and figures consistently depict the "domain-level controls" (20) and "domain scrolling controls" (28a, 28b) as hardware buttons physically separate from the main data input keys (30). (’963 Patent, Fig. 5a; col. 3:49-54). This could support a narrower construction requiring a distinct component.

  • The Term: "function-specific display"

    • Context and Importance: The infringement theory must map the iOS keyboard, where characters are displayed on the touch-keys themselves, to the claimed "function-specific display." The viability of this mapping depends on whether the term can be construed to cover an integrated key-and-display element.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification explicitly contemplates a modern touchscreen, stating that displays and keys can be combined into a single element via "touch screens." (’963 Patent, col. 5:37-40). This passage provides strong intrinsic support for construing the term to read on the accused iOS keyboard.
      • Evidence for a Narrower Interpretation: The primary embodiments illustrated in the patent's figures (e.g., Fig. 1, Fig. 5a) show small, individual displays (32) adjacent to each input key (30), not integrated with them. An argument for a narrower construction might frame the "touch screen" mention as a mere alternative suggestion, secondary to the main disclosed embodiment, although the explicit language makes this a more difficult position to sustain.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement. The inducement allegation is based on Apple distributing the accused products and providing "instructional materials" to customers, with knowledge of the patent beginning "at least the time of receiving this Complaint." (Compl. ¶27-28). The contributory infringement allegation asserts that the accused products are material components especially made for infringement and not suitable for substantial non-infringing use. (Compl. ¶29).
  • Willful Infringement: Willfulness is alleged based on Defendant’s continued infringement after having received notice of the patent via the filing of the complaint. (Compl. ¶31).

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

  • A core issue will be one of definitional scope: can claim terms like "domain control" and "input keys", described in the patent’s embodiments as distinct physical hardware, be construed to cover functionally-defined regions of an integrated software keyboard on a single touchscreen? The interpretation of whether software icons can be "separate and distinct" will be particularly critical.
  • The case may also turn on a question of patent eligibility: do the claims, which recite a specific combination of user interface controls to improve device functionality, represent a patentable technical solution, as Plaintiff argues, or do they simply claim the abstract idea of categorizing and displaying data on a generic computer, as Defendant will likely contend?
  • A key evidentiary question will be one of operational mapping: assuming the claim terms are construed broadly enough to cover a software interface, does the iOS keyboard actually operate according to the specific layered "functional mode" and "domain level" architecture required by the claims, or is there a fundamental mismatch in its technical operation?