LiTL LLC v. HP Inc

I. Executive Summary and Procedural Information

• Parties & Counsel:
  • Plaintiff: Microsoft Corporation (Intervenor-Plaintiff) (Washington)
  • Defendant: LiTL LLC (Intervenor-Defendant) (Delaware)
  • Plaintiff’s Counsel: Richards Layton & Finger, P.A. (with Perkins Coie LLP as Of Counsel)
• Case Identification: 1:23-cv-00120, D. Del., 10/16/2023
• Venue Allegations: Venue is alleged to be proper in the District of Delaware because LiTL LLC initiated the underlying action in this district, thereby submitting to the court's jurisdiction.
• Core Dispute: Intervenor-Plaintiff Microsoft seeks a declaratory judgment that its Windows Operating System does not infringe five patents owned by LiTL, following LiTL's lawsuit against Microsoft's customer, HP Inc., which accused HP products running Windows of infringement.
• Technical Context: The patents relate to the hardware and software of convertible portable computers, specifically focusing on hinge mechanisms that allow multiple display configurations (e.g., laptop and easel modes) and user interfaces that adapt based on the device's physical orientation.
• Key Procedural History: The action arises from a prior suit filed by LiTL against HP Inc. Microsoft, as the supplier of the accused Windows Operating System and having indemnity obligations to HP, has intervened to seek a judgment of non-infringement on its own behalf. Notably, U.S. Patent No. 8,612,888, one of the patents-in-suit, was the subject of an Inter Partes Review (IPR2024-00456) that resulted in the disclaimer of several claims, including Claim 27, the only claim from that patent asserted in the underlying litigation against HP. U.S. Patent No. 10,289,154 underwent an Ex Parte Reexamination, which confirmed the patentability of the asserted Claim 11.

Case Timeline

Date	Event
2008-04-01	Earliest Priority Date for all Patents-in-Suit
2013-12-17	U.S. Patent No. 8,612,888 Issued
2015-04-07	U.S. Patent No. 9,003,315 Issued
2018-01-30	U.S. Patent No. 9,880,715 Issued
2019-05-14	U.S. Patent No. 10,289,154 Issued
2020-02-18	U.S. Patent No. 10,564,818 Issued
2023-02-01	LiTL LLC files original complaint against HP Inc.
2023-10-16	Microsoft Corporation files Complaint in Intervention
2025-04-23	Inter Partes Review Certificate issued for ’888 Patent, disclaiming asserted Claim 27

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

U.S. Patent No. 10,289,154 - Portable computer with multiple display configurations

The Invention Explained

• Problem Addressed: The patent addresses the mechanical limitations of conventional "clam-shell" laptops, whose hinges typically do not permit rotation beyond 180 degrees, and the complexity of early hybrid tablet computers that required cumbersome "arm assembly" mechanisms to reorient the screen (’154 Patent, col. 1:43-66).
• The Patented Solution: The invention is a portable computer with a hinge assembly that allows the display component to rotate relative to the base up to approximately 320 degrees. This enables multiple configurations, including a traditional "laptop mode" and an "easel mode" where the device stands in an inverted "V" shape, without requiring a complex arm mechanism (’154 Patent, col. 2:15-34; Fig. 4). The computer includes an orientation sensor and a "display manager" to automatically reorient and, in some cases, enlarge content on the screen when the mode changes (’154 Patent, col. 2:57-col. 3:13).
• Technical Importance: This design provides greater functional versatility for portable computers, allowing them to serve as both a traditional input device and a passive display or presentation tool with a stable, self-supporting base.

Key Claims at a Glance

• The complaint identifies independent claim 11 as being asserted (Compl. ¶12).
• Claim 11 requires, in relevant part:
  • A portable computer configurable between a first mode (e.g., laptop), a second mode (e.g., easel), and a third mode (e.g., frame).
  • A display component, base, and hinge assembly permitting rotation up to at least 270 degrees from a closed position.
  • An orientation sensor to generate orientation information.
  • A display manager configured to detect the current display mode.
  • The display manager displays content in a first orientation in the first mode and a second orientation (rotated 180 degrees) in the second mode.
  • The display manager is also configured to "enlarge at least some computer content displayed on the display screen when the current display mode transitions from the first mode to the second mode."
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,003,315 - System and method for streamlining user interaction with electronic content

The Invention Explained

• Problem Addressed: The patent identifies user frustration with the increasing complexity and "feature packing" of modern computer interfaces and online services, which can hamper adoption and make ordinary tasks difficult (’315 Patent, col. 2:23-34).
• The Patented Solution: The invention is a streamlined graphical user interface (GUI) method that organizes computer content and operations into a plurality of distinct "views." The system detects the computer's physical configuration (e.g., whether the keyboard is operable in laptop mode versus inoperable in easel mode) and automatically selects and transitions to the appropriate view for that configuration, simplifying the user experience (’315 Patent, col. 17:19-41). This is illustrated in the patent family through a "map" navigation system with "cards" representing different content modes (e.g., Media, Web, Channels) (’315 Patent, Fig. 11-12).
• Technical Importance: This approach ties the software user experience directly to the physical use-case of the hardware, aiming to reduce cognitive load on the user by presenting only relevant interface options for a given configuration.

Key Claims at a Glance

• The complaint identifies independent claim 1 as being asserted (Compl. ¶13).
• Claim 1 requires, in relevant part, a method performed by a processor comprising:
  • Displaying a plurality of views of visual representations of computer content.
  • Detecting a current computer system configuration from at least a first configuration where the keyboard is operable and a second configuration where it is inoperable.
  • Selecting one of the plurality of views for display in response to the detected configuration.
  • Transitioning to the selected view.
  • Displaying the selected view.
• The complaint does not explicitly reserve the right to assert dependent claims.

U.S. Patent No. 9,880,715 - System and method for streamlining user interaction with electronic content

• Technology Synopsis: This patent is part of the same family as the ’315 Patent and addresses the same problem of overly complex user interfaces. Its solution is also a streamlined, view-based GUI that is responsive to the device's physical configuration, organizing content to simplify user interaction and navigation (’715 Patent, col. 2:48-61).
• Asserted Claims: Independent Claim 1 (Compl. ¶14).
• Accused Features: The graphical user interface features of Microsoft's Windows Operating System are accused of performing the claimed method (Compl. ¶14).

U.S. Patent No. 10,564,818 - System and method for streamlining user interaction with electronic content

• Technology Synopsis: Also from the same family as the ’315 and '715 patents, this patent describes a method for presenting a customized user interface. The interface is organized into different "views" of content and is designed to be responsive to the physical configuration and I/O profile of the device on which it operates (’818 Patent, col. 1:49-col. 2:1).
• Asserted Claims: Independent Claim 1 (Compl. ¶15).
• Accused Features: The graphical user interface features of Microsoft's Windows Operating System are accused of performing the claimed method (Compl. ¶15).

U.S. Patent No. 8,612,888 - Method and apparatus for managing digital media content

• Technology Synopsis: This patent describes a method and user interface for managing digital media on a streamlined computing device. The system provides different "views" of media content (e.g., "album view," "timeline view") and transitions between them based on user selection and the device's selected I/O profile, which can be tied to its physical configuration (’888 Patent, Abstract).
• Asserted Claims: Independent Claim 27 (Compl. ¶16).
• Accused Features: The user interface features of the Windows Operating System for managing digital media are accused of infringing this patent (Compl. ¶16).

III. The Accused Instrumentality

Product Identification

• Microsoft's Windows Operating System (Compl. ¶8).

Functionality and Market Context

• The complaint identifies graphical user interface features of the Windows Operating System as the basis for the infringement allegations (Compl. ¶11). The relevant functionality is that which is activated when Windows runs on convertible hardware, such as the accused HP laptops. This includes the operating system's ability to detect changes in the physical configuration of the device (e.g., from a laptop mode to a "tent" or "tablet" mode) and to adapt the user interface in response (Compl. ¶¶12-16). Microsoft is a supplier to HP, and its Windows OS is incorporated into the computer products that LiTL originally accused of infringement (Compl. ¶8).

IV. Analysis of Infringement Allegations

The complaint is a declaratory judgment action for non-infringement and does not provide LiTL's detailed infringement allegations or claim charts. The following is a prose summary of LiTL's alleged infringement theory as recited by Microsoft.

No probative visual evidence provided in complaint.

’154 Patent Infringement Allegations

The complaint alleges that LiTL's infringement theory targets the user interface features of the Windows Operating System when running on convertible HP devices (Compl. ¶12). The theory suggests that when a user converts an HP laptop from a standard laptop configuration ("first mode") to an easel or tent configuration ("second mode"), the Windows OS functions as the claimed "display manager." It is alleged that Windows' software detects this change in physical orientation via an "orientation sensor" in the hardware and, in response, automatically rotates the display content by 180 degrees and enlarges at least some content to fit the new screen orientation, thereby meeting the limitations of Claim 11 (Compl. ¶12; ’154 Patent, col. 18:11-25).

• Identified Points of Contention:
  • Scope Questions: A potential point of contention may be the claim element "enlarge at least some computer content." The analysis may question whether the automatic re-scaling of the Windows UI upon changing orientation constitutes "enlargement" as contemplated by the patent, or if it is merely a reformatting of existing content.
  • Technical Questions: The analysis may raise the question of what specific "computer content" is alleged to be enlarged. Does the complaint provide evidence that icons, text, or video are actively enlarged beyond a simple re-scaling to fit the new aspect ratio, as required by the claim?

’315 Patent Infringement Allegations

The complaint indicates that LiTL's infringement theory for the ’315 patent also focuses on the functionality of the Windows OS on convertible devices (Compl. ¶13). The theory appears to map the claimed method steps to Windows' behavior when switching between laptop and tablet/tent modes. It is alleged that Windows "detect[s] a current computer system configuration" by determining whether the keyboard is operable (laptop mode) or inoperable (tent mode). In response, Windows is alleged to "select[] one of the plurality of views for display," for example by switching from the standard desktop interface to its "Tablet Mode" interface, which presents a different layout and functionality, thereby performing the claimed method (Compl. ¶13; ’315 Patent, col. 26:17-41).

• Identified Points of Contention:
  • Scope Questions: A central dispute may be the construction of the term "view." Does the Windows "Tablet Mode" constitute a separate "view" that is "selected," or is it a modification or adaptation of the primary desktop "view"?
  • Technical Questions: What evidence does the underlying complaint (as referenced by Microsoft) provide that Windows performs a "selection" from a "plurality of views," as opposed to applying a different set of display rules to a single, persistent underlying interface?

V. Key Claim Terms for Construction

"enlarge at least some computer content" (’154 Patent, Claim 11)

• Context and Importance: The definition of this term is critical because the core functionality of Windows' tablet mode involves reorienting and re-scaling the display. Practitioners may focus on this term because Microsoft could argue that re-scaling to fit a new orientation is technically distinct from the affirmative "enlargement" required by the claim.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent specification states that when transitioning to the easel mode, "the display may automatically adjust to 'full screen view' (i.e., the displayed image or video is displayed on the full screen size, rather than in a window) to allow for comfortable viewing" (’154 Patent, col. 14:64-68). This could support a reading where changing from a windowed view to a full-screen view constitutes enlargement.
  • Evidence for a Narrower Interpretation: The term is used in the claim in addition to, and distinct from, the rotation of content. This suggests "enlarge" requires more than the resizing inherent in a 180-degree rotation. A defendant might argue it requires a specific element (like an icon or menu) to become larger relative to the overall display, not just as part of a general re-scaling.

"selecting one of the plurality of views for display" (’315 Patent, Claim 1)

• Context and Importance: This term is central to the accused method. The dispute will likely hinge on whether Windows' transition between desktop and tablet modes is a "selection" of a different "view." Practitioners may focus on this term because if "Tablet Mode" is merely a feature set applied to the main desktop, and not a separate "view," the accused method may not be performed as claimed.
• Intrinsic Evidence for Interpretation:
  • Evidence for a Broader Interpretation: The patent family provides numerous examples of distinct "views," such as a "home view," "channel view," "album view," and "page view" (’818 Patent, Fig. 9). LiTL may argue that the functional and visual differences between Windows' desktop and tablet modes are significant enough to qualify them as distinct "views" consistent with these examples.
  • Evidence for a Narrower Interpretation: A defendant could argue that the patent's "views" are discrete, content-specific interfaces (e.g., a media player view vs. a web browser view). In contrast, Windows' desktop and tablet modes could be framed as two different operational shells for the same underlying content and applications, suggesting it is not a "selection" between distinct "views" of content.

VI. Other Allegations

The complaint is for declaratory judgment of non-infringement and does not contain allegations of indirect or willful infringement.

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

• A central issue will be one of procedural finality: What is the legal effect of the Inter Partes Review certificate disclaiming the asserted Claim 27 of the ’888 patent? This development may render Microsoft's request for a declaratory judgment of non-infringement on that patent moot, potentially narrowing the scope of the litigation at an early stage.
• A key question of claim scope will be: Can the term "enlarge," as used in the ’154 patent, be construed to cover the automatic re-scaling and reformatting of a graphical user interface when a device's orientation changes, or does it require a more specific act of magnification distinct from adapting to a new screen layout?
• The case may also turn on a technical and definitional question: Does the Windows operating system's shift between "desktop mode" and "tablet mode" constitute the claimed act of "selecting one of the plurality of views," or is it a functional adaptation of a single, persistent user interface, creating a potential mismatch with the specific steps required by the asserted claims of the '315 patent family?