DCT

2:12-cv-00265

Rotatable Tech LLC v. Nokia Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 2:12-cv-00265, E.D. Tex., 05/01/2012
  • Venue Allegations: Plaintiff alleges venue is proper because Defendant has transacted business and committed acts of patent infringement within the Eastern District of Texas.
  • Core Dispute: Plaintiff alleges that Defendant’s Lumia 900 smartphone infringes a patent related to methods for selectively rotating graphical user interface windows on a computer display.
  • Technical Context: The technology addresses user interface design for managing and orienting on-screen windows, a foundational concept that gained new relevance with the advent of mobile devices featuring orientation-sensing hardware.
  • Key Procedural History: The complaint was filed on May 1, 2012. Subsequently, a third party, Rackspace Hosting, Inc., filed for an Inter Partes Review (IPR) of the patent-in-suit. The IPR proceeding (IPR2013-00248) concluded with a certificate issued on January 23, 2017, which cancelled all 18 claims of the patent, rendering them unenforceable.

Case Timeline

Date Event
1999-04-20 U.S. Patent No. 6,326,978 Priority Date
2001-12-04 U.S. Patent No. 6,326,978 Issue Date
2012-05-01 Complaint Filing Date
2013-04-12 IPR2013-00248 Filed against '978 Patent
2017-01-23 IPR Certificate Issued, Cancelling all claims of '978 Patent

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

U.S. Patent No. 6,326,978 - "Display Method for Selectively Rotating Windows on a Computer Display"

  • Patent Identification: U.S. Patent No. 6,326,978, "Display Method for Selectively Rotating Windows on a Computer Display," issued December 4, 2001. The patent expired with all claims cancelled on January 23, 2017.

The Invention Explained

  • Problem Addressed: The patent describes that as computer multitasking became common, managing multiple on-screen windows grew "cumbersome." (’978 Patent, col. 2:5-6). It also notes that with the advent of networking, users might receive information "that is not oriented as the user needs or desires," without an easy way to reorient it. (’978 Patent, col. 2:13-17).
  • The Patented Solution: The invention provides a method and system for a user to selectively rotate an individual software window around a chosen point on a display. (’978 Patent, Abstract). The specification describes this being initiated via a graphical "rotation button" or a special cursor, allowing the user to drag the window to a new orientation, as depicted in Figure 2. (’978 Patent, col. 3:40-48; Fig. 2). This rotation can be freeform or limited to predefined angles such as 0, 90, 180, and 270 degrees. (’978 Patent, col. 2:37-39).
  • Technical Importance: The invention sought to provide users with "greater interface flexibility" beyond the standard window manipulation functions of translation and resizing that were prevalent at the time. (’978 Patent, col. 2:21-22).

Key Claims at a Glance

  • The complaint alleges infringement of "one or more claims" but does not specify which ones (Compl. ¶8). The patent contains three independent claims (1, 9, and 14), all of which were ultimately cancelled.
  • Independent Claim 1 (A computer display window):
    • a display portion;
    • a frame surrounding the display portion;
    • means for selectively rotating the window about a rotation point at the discretion of the user;
    • wherein the plane of the window, the plane of rotation, and the rotation point are coplanar.
  • Independent Claim 9 (A method of selectively rotating a computer display window):
    • determining a rotation point;
    • rotating the window about the rotation point at the discretion of the user;
    • wherein the plane of the window, the plane of rotation, and the rotation point are coplanar.
  • Independent Claim 14 (A system for selectively rotating a computer display window):
    • means for determining a rotation point;
    • means for rotating the window about the rotation point at the discretion of the user;
    • wherein the plane of the window, the plane of rotation, and the rotation point are coplanar.

III. The Accused Instrumentality

Product Identification

  • The complaint identifies the Nokia Lumia 900 as an infringing product or system. (Compl. ¶8).

Functionality and Market Context

  • The complaint alleges that the Nokia Lumia 900 infringes the ’978 Patent but does not describe any specific technical functionality of the device. It makes a conclusory allegation of infringement without providing details on how the smartphone’s user interface operates. (Compl. ¶8). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint does not provide specific infringement allegations that map elements of any asserted claim to features of the accused Nokia Lumia 900. The complaint makes only a conclusory allegation that the device infringes "one or more claims of the ’978 patent" (Compl. ¶8). Therefore, a claim chart summary cannot be constructed.

  • Identified Points of Contention: Based on the patent’s claims and the general functionality of modern smartphones, several points of contention would have been likely to arise had the case proceeded and the patent remained valid.
    • Scope Questions: A central question would concern the scope of the means-plus-function term "means for selectively rotating the window." The patent discloses user-activated software controls like a "rotation button" or "menu driven commands" as the corresponding structure. (’978 Patent, col. 3:40-42; col. 5:12-16). A dispute would likely focus on whether a smartphone’s automated screen reorientation, which is typically triggered by a hardware-based accelerometer rather than a direct user command on a specific window, could be considered a structural equivalent.
    • Technical Questions: The patent consistently describes rotating a discrete "window" within the larger context of a computer screen, potentially to reveal other windows underneath. (’978 Patent, col. 2:1-6; col. 4:60-63). This raises the question of whether a smartphone's function of reorienting the entire display constitutes "selectively rotating [a] window" as required by the claims, or if this represents a fundamentally different technical operation.

V. Key Claim Terms for Construction

  • The Term: "means for selectively rotating the window" (from Claims 1 and 14)

    • Context and Importance: This is a means-plus-function limitation governed by 35 U.S.C. § 112, ¶ 6 (pre-AIA). Its construction is critical, as infringement would depend on whether the accused device's mechanism for screen rotation is the same as or equivalent to the specific structures disclosed in the patent's specification.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: A plaintiff could argue the claimed function is broad—"selectively rotating the window at the discretion of the user"—and that the user exercises discretion by physically turning the phone. The patent's stated purpose is to provide "greater interface flexibility," which a plaintiff might argue supports a more expansive reading. (’978 Patent, col. 2:21-22).
      • Evidence for a Narrower Interpretation: The specification explicitly discloses the corresponding structures for performing the function as a "rotation button 28," a "rotation cursor," "menu driven commands," or "special key strokes." (’978 Patent, col. 3:40-42; col. 4:1-4; col. 5:12-16). A defendant would argue the claim scope is limited to these specific software-based, user-initiated controls and their equivalents, and does not extend to an automatic, system-wide orientation change driven by a hardware sensor.

  • The Term: "window" (from Claims 1, 9, and 14)

    • Context and Importance: The definition of "window" is central to determining if the patent applies to a modern smartphone interface. Practitioners may focus on this term because the patent's context appears to differ from the accused technology's implementation.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent defines a window in general terms as a GUI generated by an operating system or application program, without an explicit size limitation. (’978 Patent, col. 1:29-32). A plaintiff might argue a full-screen application on a smartphone is merely one type of "window."
      • Evidence for a Narrower Interpretation: The specification and figures consistently portray a "window" as a discrete, bounded element that exists on a larger display, often alongside other windows. (’978 Patent, Fig. 1; col. 2:1-6). The problem solved by the invention—managing cumbersome, overlapping windows—suggests that a "window" is an object smaller than the entire available screen. (’978 Patent, col. 2:4-9).

VI. Other Allegations

  • Indirect Infringement: The prayer for relief seeks judgment for induced and contributory infringement, but the body of the complaint provides no factual allegations to support these claims, such as knowledge or specific actions taken by the Defendant to encourage infringement by others. (Compl., Prayer for Relief ¶a).
  • Willful Infringement: The complaint does not allege willful infringement. It requests a declaration of an "exceptional case" to recover attorneys' fees pursuant to 35 U.S.C. § 285, but it does not plead the facts necessary to support a willfulness claim. (Compl., Prayer for Relief ¶e).

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

The subsequent cancellation of all claims of the ’978 patent is the dispositive event in this dispute. However, analyzing the original complaint as filed reveals the core legal and technical questions that would have shaped the litigation.

  • The Overarching Question: The foremost issue is the legal status of the lawsuit itself. Given that an Inter Partes Review (IPR2013-00248) resulted in the cancellation of all asserted patent claims, the fundamental basis for an infringement action has been eliminated.
  • A Question of Equivalence: A key technical dispute would have been whether the accused smartphone’s automatic, accelerometer-driven reorientation of the entire display is a legal "equivalent" to the patent’s disclosed "means for selectively rotating," which consists of specific, user-activated software controls for manipulating a single window.
  • A Question of Definitional Scope: The case would have also presented a core definitional challenge: can the term "window", as described and depicted in the patent’s context of a desktop computer with multiple, discrete on-screen elements, be construed to read on the full-screen, immersive user interface of a modern smartphone?