DCT
2:17-cv-00469
Uniloc USA Inc v. Apple Inc
Key Events
Complaint
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Uniloc USA, Inc. (Texas) and Uniloc Luxembourg, S.A. (Luxembourg)
- Defendant: Apple Inc. (California)
- Plaintiff’s Counsel: Prince Lobel Tye LLP; Nelson Bumgardner PC
- Case Identification: 2:17-cv-00469, E.D. Tex., 06/02/2017
- Venue Allegations: Plaintiff alleges venue is proper in the Eastern District of Texas because Apple has regular and established places of business in the district, has committed acts of infringement there, and has purposely transacted business in the district.
- Core Dispute: Plaintiff alleges that the "Raise to Wake" feature in certain Apple iPhones and Watches infringes a patent related to a method for waking up an electronic device from an idle state based on detected motion.
- Technical Context: The technology concerns power management in portable electronic devices, using motion sensors to intelligently transition a device from a low-power idle state to an active state upon detecting user interaction.
- Key Procedural History: Subsequent to the filing of this complaint, the asserted patent was the subject of Inter Partes Review (IPR) proceedings at the U.S. Patent and Trademark Office. The resulting IPR certificate, issued November 1, 2021, cancelled numerous claims, including all asserted independent claims (1, 13, and 20). This development fundamentally narrows the scope of the dispute to the remaining asserted dependent claims.
Case Timeline
| Date | Event |
|---|---|
| 2008-10-08 | '646 Patent Priority Date |
| 2014-10-28 | '646 Patent Issue Date |
| 2017-06-02 | Complaint Filing Date |
| 2021-11-01 | IPR Certificate Issued Cancelling Claims |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,872,646 - "METHOD AND SYSTEM FOR WAKING UP A DEVICE DUE TO MOTION," issued October 28, 2014
The Invention Explained
- Problem Addressed: The patent addresses the challenge of maximizing battery life in feature-rich mobile devices, which are often depleted quickly by numerous applications, without degrading the user experience ('646 Patent, col. 1:16-21).
- The Patented Solution: The invention proposes a method where a device in a low-power "idle state" uses a motion sensor, such as an accelerometer, to intelligently determine if it is being picked up for use ('646 Patent, Abstract). The system analyzes motion data to distinguish "real" user-initiated motion from incidental jostles by identifying a "dominant axis" (the axis most affected by gravity) and waking the device upon detecting a significant change related to that axis, thereby reducing user wait time and conserving power ('646 Patent, col. 2:35-51).
- Technical Importance: This method provides a way for devices to remain in a power-saving mode but become instantly available when a user intends to use them, a critical feature for improving the usability of modern portable electronics ('646 Patent, col. 2:38-46).
Key Claims at a Glance
- The complaint asserts independent claims 1 (a method), 13 (a mobile device), and 20 (a system), along with dependent claims 2-6, 8-12, 14-19, and 21-23 (Compl. ¶11). As noted, claims 1, 13, and 20 have since been cancelled by an IPR.
- The essential elements of the primary asserted independent method claim (Claim 1) included:
- receiving motion data from a motion sensor sensing motion along three axes;
- verifying whether the motion data includes one or more glitches and removing them;
- determining an idle sample value for a "dominant axis," defined as the axis with the largest effect from gravity;
- registering a motion of the device;
- determining whether the motion caused a "change in the dominant axis"; and
- waking up the device when the motion indicates such a change.
- The complaint reserves the right to assert additional claims, though the viability of this is impacted by the IPR outcome (Compl. ¶11).
III. The Accused Instrumentality
- Product Identification: The "Accused Infringing Devices" are identified as Apple iPhones (versions SE, 6s, 6s+, 7, 7+, and 7 Red) and Apple Watches (Compl. ¶10).
- Functionality and Market Context: The complaint alleges that these devices incorporate hardware (accelerometers, M9/M10 motion detecting coprocessors) and software (iOS 10.0.x and watchOS versions) that together provide a "Raise to Wake" functionality (Compl. ¶10). This feature is alleged to wake the device from a sleep state when it detects that a user has lifted it (Compl. ¶10, ¶12). The complaint does not provide further detail on the commercial importance of this specific feature beyond its inclusion in Apple's products.
IV. Analysis of Infringement Allegations
The complaint does not provide a claim chart. The following table summarizes the infringement theory for the now-cancelled Claim 1, mapping the claim's requirements to the complaint's narrative allegations.
’646 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| receiving motion data from a motion sensor in a device, the motion sensor sensing motion along three axes | The accused devices incorporate hardware such as accelerometers and M9/M10 motion detecting coprocessors. | ¶10 | col. 8:31-33 |
| verifying whether the motion data includes one or more glitches and removing the one or more glitches from the motion data | The complaint does not provide sufficient detail for analysis of this element. | N/A | col. 8:34-36 |
| determining an idle sample value for a dominant axis of the device, the dominant axis defined as the axis with a largest effect from gravity among the three axes... | The accused devices allegedly operate by "using dominant axis gravity-related data." | ¶12 | col. 8:37-45 |
| registering a motion of the device based on the motion data from the motion sensor | The accused devices provide a "Raise to Wake functionality" that responds to detected motion. | ¶10 | col. 8:46-48 |
| determining whether the motion caused a change in the dominant axis | The complaint alleges infringement by devices that are "woken up by detected motion" using "dominant axis gravity-related data." | ¶12 | col. 8:49-50 |
| waking up the device when the motion of the device indicates the change in the dominant axis of the device... | The accused devices' "Raise to Wake functionality" wakes the device. | ¶10 | col. 8:51-55 |
No probative visual evidence provided in complaint.
- Identified Points of Contention:
- Technical Questions: A central question is whether the accused "Raise to Wake" algorithm actually performs the steps required by the patent, specifically by identifying a "dominant axis" and triggering a wake-up based on a "change" to that axis. The complaint's allegations are conclusory and lack technical evidence detailing how Apple's functionality operates.
- Scope Questions: The dispute may turn on whether Apple's method of detecting a "raise" motion, even if it uses an accelerometer, falls within the specific sequence of claim limitations. For example, does Apple's system distinguish between a "jostle" and a "real motion" by tracking a change in the primary gravity-aligned axis, or does it use a different heuristic, such as recognizing an acceleration profile that does not require calculating or tracking a "dominant axis"?
V. Key Claim Terms for Construction
- The Term: "dominant axis"
- Context and Importance: This term is the cornerstone of the patented method for differentiating intentional movement from incidental jostles. The infringement analysis for any surviving claims that depend on this term will hinge on its definition.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A party could argue the plain language in Claim 1—"the axis with a largest effect from gravity among the three axes"—is a simple, functional definition that reads on any system that identifies the primary gravity vector ('646 Patent, col. 8:40-42).
- Evidence for a Narrower Interpretation: The specification describes a process of using "long averages of accelerations" to determine orientation and the axis "most influenced by gravity" ('646 Patent, col. 3:45-56). A party could argue this requires a specific calculation method, not just any orientation awareness.
- The Term: "change in the dominant axis"
- Context and Importance: This phrase defines the specific event that triggers the device to wake up. Its construction is critical to determining whether Apple's "Raise to Wake" trigger infringes.
- Intrinsic Evidence for Interpretation:
- Evidence for a Broader Interpretation: A plaintiff might contend that any significant rotational movement that reorients the device relative to gravity constitutes a "change in the dominant axis."
- Evidence for a Narrower Interpretation: A defendant could argue this term requires a discrete computational event where a new axis is designated as dominant, as contemplated by the patent's logic for distinguishing a "real" pickup motion from other movements ('646 Patent, col. 4:21-24, col. 5:4-8).
VI. Other Allegations
- Indirect Infringement: The complaint alleges Apple induces infringement by providing customers with "training videos, demonstrations, brochures, installation and/or user guides" on its websites that instruct on the use of the accused "Raise to Wake" feature (Compl. ¶13).
- Willful Infringement: The allegation of willfulness is based on post-suit knowledge, asserting that Apple will be on notice of the patent "at the latest, [from] the service of this complaint" (Compl. ¶14).
VII. Analyst’s Conclusion: Key Questions for the Case
Viability Post-IPR: The primary question is whether the lawsuit remains viable after the invalidation of all asserted independent claims. The case's survival depends on whether Plaintiff can successfully assert any of the remaining dependent claims and prove they are infringed, which presents a significantly higher procedural and evidentiary bar.
Infringement Mismatch: The core of the technical dispute will be whether Apple’s "Raise to Wake" functionality operates in the manner specifically claimed by the patent. A key evidentiary question is whether Plaintiff can prove that Apple's algorithm calculates a "dominant axis" and triggers a wake-up based on a "change" in that axis, as opposed to using an alternative motion-detection heuristic.
Claim Scope: Should the case proceed on dependent claims, a central legal issue will be the construction of key terms like "dominant axis." The outcome will likely turn on whether these terms are interpreted broadly enough to cover Apple's implementation or are narrowly constrained by the patent's specification to a specific multi-step computational process that Apple may not perform.