DCT

1:19-cv-01425

Princeps Interface Tech LLC v. Motorola Mobility LLC

Log In
Key Events
Complaint

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:19-cv-01425, D. Del., 07/30/2019
  • Venue Allegations: Venue is alleged to be proper for the U.S.-based Lenovo entities because they are Delaware corporations and thus reside in the district. For the foreign parent, Lenovo Group Limited, venue is based on alleged sales and distribution of products throughout the United States, including Delaware.
  • Core Dispute: Plaintiff alleges that Defendant’s "Moto" brand phones, featuring proprietary and third-party keyboard applications on the Android operating system, infringe a patent related to multifunctional, configurable input devices.
  • Technical Context: The technology concerns methods for organizing and presenting multiple character sets and functions on a compact keyboard, a central design challenge for miniaturized electronics like smartphones.
  • Key Procedural History: The complaint notes that the patent-in-suit claims priority from a provisional patent application filed in September 2001. The complaint also preemptively argues that the patent claims are not directed to an abstract idea, anticipating a potential patent-eligibility challenge under 35 U.S.C. § 101.

Case Timeline

Date Event
2001-09-20 '963 Patent Priority Date (Provisional Application Filing)
2004-03-09 '963 Patent Issue Date
2019-07-30 Complaint Filing Date

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

  • Patent Identification: U.S. Patent No. 6,703,963, "Universal Keyboard", issued March 9, 2004 (’963 Patent). (Compl. ¶25).

The Invention Explained

  • Problem Addressed: The patent addresses the limitations of traditional QWERTY keyboards for increasingly small, portable electronic devices. These limitations include the large physical size required for two-handed typing, an inefficient key layout not designed for speed, and a typically singular function (alphanumeric input) that is insufficient for modern multifunction devices. (Compl. ¶27; '963 Patent, col. 1:37-2:23).
  • The Patented Solution: The invention is a "multifunctional input device" that uses a system of "functional modes" (e.g., alphanumeric, telephone) and "domain levels" (e.g., character subsets like 'A-L' or 'M-X') to assign different values to a set of programmable input keys. A display associated with each key indicates its current function based on the selected mode and level, allowing a compact keyboard to handle a wide variety of input types. (Compl. ¶28, quoting '963 Patent, abstract; '963 Patent, col. 2:33-45).
  • Technical Importance: This architecture provided a method for increasing the versatility and data-entry efficiency of input devices on small-profile electronics, a key challenge during the transition to single-hand-operated mobile devices. (Compl. ¶29).

Key Claims at a Glance

  • The complaint asserts independent claims 1 and 60, along with dependent claims 2, 3, 9, and 12. (Compl. ¶38).
  • Independent Claim 1 (Device Claim) Essential Elements:
    • 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 domain-level values.
    • A "function-specific display" indicating the domain-level value associated with each input key.
    • A configuration wherein the input keys and domain control are "simultaneously presented" by the input device.
  • The complaint explicitly reserves the right to assert additional claims. (Compl. ¶48).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are "Lenovo 'Moto' brand phones with proprietary Lenovo Apps and/or third-party Apps with keyboard functionalities and an operating system such as the Android operating system" (Compl. ¶38). The complaint also makes a passing reference to "the Lenovo Galaxy S series devices," though Galaxy S is a product line of a different manufacturer. (Compl. ¶44).
  • Functionality and Market Context: The complaint alleges that the software-based keyboard interfaces on these smartphones perform the functions claimed in the ’963 Patent. (Compl. ¶38). It does not provide specific details on the operation of the accused keyboards but implies that the ability to switch between different character sets (e.g., letters, numbers, symbols) on the touchscreen keyboard infringes the patent. (Compl. ¶38). The complaint alleges Lenovo is a major market participant with substantial revenues. (Compl. ¶45).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint states that detailed infringement allegations are contained in an attached claim chart (Exhibit A-1), which was not included with the filed complaint document. (Compl. ¶38, ¶48). The narrative infringement theory alleges that Lenovo's "Moto" phones, when running keyboard applications, embody the patented system. (Compl. ¶38). The core of this theory suggests that the on-screen keyboard's user interface elements map onto the claimed control and key structures. For example, on-screen buttons that switch between alphabetic, numeric, and symbolic layouts could be alleged to function as the claimed "functional mode control" or "domain control", while the character keys themselves could be alleged to be the claimed "input keys" with an associated "function-specific display".

  • Identified Points of Contention:
    • Scope Questions: A central issue may be whether the term "input keys", described in the patent's embodiments as physical buttons, can be construed to read on the software-defined, non-physical key representations on a touchscreen. A related question is whether software-based interface elements on a single, flat screen can be considered "separate and distinct" components as required by claim 1's "domain control" limitation.
    • Technical Questions: A key factual question will be whether the accused keyboards' method of switching between character sets (e.g., via a "?123" key) maps to the patent's specific architecture of "functional modes" and "domain levels". The complaint does not provide the specific evidence or mapping required to assess whether the operation of an Android keyboard aligns with the distinct control structure recited in the claims.

V. Key Claim Terms for Construction

  • The Term: "domain control"

    • Context and Importance: Claim 1 requires a "domain control" that is "separate and distinct from the ... input keys." The construction of this term is critical because on a touchscreen keyboard, the control for switching character sets (e.g., a "?123" key) is an on-screen button visually similar to the character keys. Practitioners may focus on this term because if the "domain control" is construed to be just another type of "input key", then the "separate and distinct" limitation would not be met.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification describes the control's function—"selecting the desired domain level" (e.g., '963 Patent, col. 4:20-22)—without strictly limiting its physical form, which may support interpreting any UI element that performs this function as the "domain control".
      • Evidence for a Narrower Interpretation: The patent figures consistently depict the "domain control" (20) as a physically separate column of buttons, distinct in location and appearance from the main grid of "input keys" (30). (e.g., '963 Patent, Fig. 1, Fig. 5a). This could support a narrower construction requiring a greater degree of separation than what is present on a typical soft keyboard.

  • The Term: "input keys"

    • Context and Importance: The patent was filed in 2001 and its figures primarily depict a device with physical, depressible buttons. The accused products are modern smartphones with capacitive touchscreens. The case may turn on whether the software-defined areas on a touchscreen that a user touches to enter a character constitute "input keys" under the patent.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The specification states that the displays, which are associated with the input keys, can be made from "touch screens (thereby combining the screens/displays ... and keys/controls ... into a single element)." ('963 Patent, col. 5:35-40). This language explicitly contemplates a touchscreen implementation and could support construing "input keys" to include non-physical, screen-based keys.
      • Evidence for a Narrower Interpretation: The claim language recites "a plurality of input keys, separate and distinct from the domain control," and the detailed description repeatedly refers to actuating "buttons." (e.g., '963 Patent, col. 6:23). This could be argued to imply a physical structure that is absent in a purely software-based keyboard on a uniform glass surface.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Lenovo provides "instructional materials and/or services" that encourage customers to use the accused keyboard functionalities in an infringing manner. (Compl. ¶¶42-43). It also alleges contributory infringement on the basis that the accused devices are "material components" for practicing the patent and are not "staple article[s] of commerce suitable for substantial non-infringing use." (Compl. ¶44).
  • Willful Infringement: Willfulness is alleged based on knowledge of the '963 Patent and its infringement acquired "since at least the time of receiving this Complaint." (Compl. ¶46). The complaint does not allege any pre-suit knowledge.

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

  1. A core issue will be one of definitional scope: can claim terms like "input keys" and "domain control", which are rooted in a 2001-era patent illustrating a physical device, be construed to cover the purely software-based, integrated elements of a modern touchscreen keyboard?
  2. A second central issue will be one of technical and factual mapping: does the operational logic of the accused Android and Lenovo keyboards, particularly the function for switching between character sets, align with the patent’s specific architecture of "functional modes" and "domain levels" that are selected by a "domain control" that is "separate and distinct" from the "input keys"?
  3. Finally, a threshold question will be one of patent eligibility: as anticipated by the plaintiff's own complaint (Compl. ¶¶30-34), the court will likely have to determine whether Claim 1 is directed to a specific improvement in human-computer interface technology or to the patent-ineligible abstract idea of organizing and displaying information on a keyboard.