DCT
2:18-cv-00327
Industry Univeristy Cooperation Foundation Hanyang University v. Huawei Devce USA Inc
I. Executive Summary and Procedural Information
- Parties & Counsel:
- Plaintiff: Industry-Univeristy Cooperation Foundation Hanyang University (Republic of Korea)
- Defendant: Huawei Device USA Inc. (Texas), Huawei Device (Shenzhen) Co., Ltd. (China), Huawei Device (Dongguan) Co., Ltd. (China)
- Plaintiff’s Counsel: AGORA Law, LLC
- Case Identification: 2:18-cv-00327, E.D. Tex., 08/13/2018
- Venue Allegations: Venue is alleged to be proper for Huawei Device USA Inc. based on its incorporation and headquarters within the State of Texas and its commission of infringing acts in the District. For the foreign-domiciled Huawei entities, venue is alleged to be proper because they are foreign corporations not resident in the United States and may be sued in any judicial district.
- Core Dispute: Plaintiff alleges that the "One-hand UI" or "one hand mode" feature in certain Huawei smartphones infringes two U.S. patents related to methods for resizing and repositioning a user interface to facilitate one-handed operation.
- Technical Context: The technology addresses a usability challenge for smartphones with large displays, where it can be difficult for a user to reach all areas of the screen with the thumb of the hand holding the device.
- Key Procedural History: The complaint alleges that Plaintiff provided Defendants with notice of the asserted patents via a letter on November 16, 2017, and with claim charts on December 25, 2017. These events are asserted as the basis for Defendants' pre-suit knowledge and willful infringement.
Case Timeline
| Date | Event |
|---|---|
| 2012-06-28 | Earliest Priority Date for '079 and '470 Patents |
| 2014-12-09 | U.S. Patent No. 8,910,079 Issues |
| 2017-07-11 | U.S. Patent No. 9,703,470 Issues |
| 2017-11-16 | Plaintiff sends notice letter to Defendants |
| 2017-12-11 | Defendants respond to Plaintiff's letter |
| 2017-12-21 | Defendants provide a second response to Plaintiff |
| 2017-12-25 | Plaintiff provides claim charts to Defendants |
| 2018-08-13 | Complaint Filed |
II. Technology and Patent(s)-in-Suit Analysis
U.S. Patent No. 8,910,079 - “METHOD OF ADJUSTING AN UI AND USER TERMINAL USING THE SAME,” issued December 9, 2014
The Invention Explained
- Problem Addressed: The patent’s background section identifies the increasing display size of smartphones as a technical problem, noting that it has become "more difficult to manipulate a smart phone with one hand," particularly with the thumb, which is shorter than other fingers (Compl. ¶1; ’079 Patent, col. 1:22-31).
- The Patented Solution: The invention provides a method to adjust a user interface (UI) by receiving touch events in a designated "adjustment area" located in the perimeter of the display. A first type of touch event (e.g., a swipe inward) scales the UI into a reduced form and moves it "toward the final touch position" of the gesture, making it more accessible. A second touch event can scale the UI back into an enlarged form. (’079 Patent, Abstract; col. 4:32-44).
- Technical Importance: This technology offers a gesture-based solution to the ergonomic problem of operating large-screen "phablet" devices with a single hand, a significant usability issue in the smartphone market. (’079 Patent, col. 1:22-31).
Key Claims at a Glance
- The complaint asserts at least independent claim 1 (Compl. ¶33).
- Essential elements of claim 1 include:
- displaying a UI on a display unit of a user terminal having an upper area displaying status information and a lower area displaying a plurality of selectable input receiving units;
- receiving a first and second touching events on an adjustment area positioned in perimeter of the display unit within a preset distance from a bezel of the user terminal;
- in response to the first touching event: determining the first touching event having a first distance between a first initial touch position and a first final touch position; and scaling the UI into a reduced form toward the final touch position of the first touching event;
- in response to the second touch event: determining the second touching event having a second distance between a second initial touch position and a second final touch position; and scaling the UI into an enlarged form towards the final touch position of the second touching event.
- The complaint does not explicitly reserve the right to assert dependent claims.
U.S. Patent No. 9,703,470 - “METHOD OF ADJUSTING AN UI AND USER TERMINAL USING THE SAME,” issued July 11, 2017
The Invention Explained
- Problem Addressed: Like its related patent, the ’470 Patent addresses the difficulty of one-handed manipulation of smartphones as their display sizes increase. (’470 Patent, col. 1:23-31).
- The Patented Solution: The method described is similar to that of the ’079 Patent. It involves receiving touch events in a perimeter adjustment area to resize the UI. A first touch event scales the UI to a reduced form, and a second touch event scales it to an enlarged form. A subtle but potentially significant distinction is that the scaling is performed "according to the first touching event," rather than specifically "toward the final touch position." (’470 Patent, Abstract; col. 8:45-67).
- Technical Importance: This patent provides a refined approach to solving the one-handed usability problem for large-screen mobile devices.
Key Claims at a Glance
- The complaint asserts at least independent claim 14 (Compl. ¶51).
- Essential elements of claim 14 include:
- displaying a UI on a display unit of a user terminal having an upper area displaying status information and a lower area displaying a plurality of selectable input receiving units; and
- receiving a first and second touching events on an adjustment area positioned in a perimeter of the display unit within a preset distance from a bezel on the user terminal;
- in response to the first touching event: determining the first touching event having a first distance between a first initial touch position and a first final touch position; and scaling the UI into a reduced form according to the first touching event;
- in response to the second touch event: determining the second touching event having a second distance between a second initial touch position and a second final touch position; and scaling the UI into an enlarged form according to the second touching event.
- The complaint does not explicitly reserve the right to assert dependent claims.
III. The Accused Instrumentality
Product Identification
- The complaint identifies infringing "Accused Products" as Huawei's Mate series (e.g., Mate 9), P series (e.g., P8/P10 lite, P10 Plus, P20 pro), and Honor series (e.g., Honor 8) smartphones (Compl. ¶¶27, 45).
Functionality and Market Context
- The accused functionality is a feature referred to in user guides as "One-hand mode," "One-hand UI," or "One-hand layout" (Compl. ¶¶34-36). This feature enables a user to shrink the active screen area into a "Mini screen view" to make the device easier to operate with one hand (Compl. p. 10). The complaint alleges this mode is activated by swiping on the virtual navigation bar or from the bottom corners of the screen (Compl. pp. 11-12). The complaint identifies the accused products as "smart phones" but does not provide further detail on their market context (Compl. ¶27).
IV. Analysis of Infringement Allegations
'079 Patent Infringement Allegations
| Claim Element (from Independent Claim 1) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| displaying a UI on a display unit... having an upper area displaying status information... and a lower area displaying a plurality of selectable input receiving units | The accused smartphones display a standard UI with status icons at the top and navigation/application icons at the bottom. | ¶34 | col. 3:31-38 |
| receiving a first and second touching events on an adjustment area positioned in perimeter of the display unit within a preset distance from a bezel... | The "one hand mode" is activated by a first touch event (a swipe) on the virtual navigation bar or screen corner, and a second touch event (another swipe or tap) deactivates it. The complaint identifies the swipe area as the "adjustment area." A user guide screenshot for the Huawei P10 Plus shows activation by swiping on the virtual navigation bar (Compl. p. 11). | ¶35, ¶36 | col. 4:10-17 |
| in response to the first touching event: ...scaling the UI into a reduced form toward the final touch position of the first touching event | When a user performs the activation swipe, the UI is scaled down into a "Mini screen view." A user guide for the Mate 9 states "The screen will shrink to the bottom left or right corner" (Compl. p. 10). | ¶34 | col. 4:36-40 |
| in response to the second touch event: ...scaling the UI into an enlarged form towards the final touch position of the second touching event | The user can return to the normal, full-size screen by a second gesture, such as tapping outside the mini-screen or swiping again on the navigation bar. | ¶35 | col. 4:40-44 |
'470 Patent Infringement Allegations
| Claim Element (from Independent Claim 14) | Alleged Infringing Functionality | Complaint Citation | Patent Citation |
|---|---|---|---|
| displaying a UI on a display unit... having an upper area displaying status information... and a lower area displaying a plurality of selectable input receiving units | The accused smartphones display a standard UI. | ¶52 | col. 3:9-16 |
| receiving a first touching event on an adjustment area positioned in a perimeter of the display unit within a preset distance from a bezel on the user terminal; receiving a second touching event | The complaint alleges activation/deactivation of "one hand mode" via first and second touch events (swipes) on the virtual navigation bar or screen corner. A screenshot from a P8 Lite user guide shows a diagram of a swipe on the virtual navigation bar to change the layout (Compl. p. 12). | ¶54 | col. 4:5-13 |
| in response to the first touching event: ...scaling the UI into a reduced form according to the first touching event | The UI is scaled down to a "Mini screen view" in response to the user's swipe gesture. | ¶52, ¶53 | col. 8:56-61 |
| in response to the second touch event: ...scaling the UI into an enlarged form according to the second touching event | A second gesture restores the UI to its full, enlarged size. | ¶53, ¶54 | col. 8:62-67 |
- Identified Points of Contention:
- Scope Questions: A primary question will be whether the accused products' "virtual navigation bar" or "bottom... corner" areas, where the swipe gestures are performed, meet the definition of an "adjustment area positioned in perimeter of the display unit" as required by the claims. The defense may argue that the claimed area is distinct from a standard navigation bar.
- Technical Questions: For the ’079 Patent, a key dispute may arise over the limitation "toward the final touch position." The complaint's evidence suggests the accused UI may snap to a predefined corner location rather than moving to a dynamic position determined by the precise endpoint of the swipe (Compl. p. 10). This raises the question of whether a "snap-to-corner" function satisfies the "toward the final touch position" requirement. The '470 Patent's broader "according to the... touching event" language may present a lower hurdle for the plaintiff on this point.
V. Key Claim Terms for Construction
The Term: "adjustment area"
- Context and Importance: The existence and location of this area are prerequisites for infringement. The case may turn on whether the accused products' virtual navigation bar or screen corners, where one-handed mode gestures are initiated, can be properly defined as the claimed "adjustment area." Practitioners may focus on this term because the patent figures appear to show adjustment areas along the sides of the active UI, not necessarily a bottom navigation bar.
- Intrinsic Evidence for a Broader Interpretation: The specification states the areas "can be virtual areas that are not represented by arrows," suggesting they need not be explicitly demarcated visual elements ('079 Patent, col. 4:15-17).
- Intrinsic Evidence for a Narrower Interpretation: The figures consistently depict the adjustment areas (e.g., 200, 202) as being on the left, right, upper, and lower sides of the specific UI element being adjusted (e.g., a pattern unlock grid), separate from what might be a system-level navigation bar ('079 Patent, Fig. 2; col. 4:10-15).
The Term: "scaling the UI into a reduced form toward the final touch position" (from '079 Patent)
- Context and Importance: This term is central to the infringement analysis for the '079 Patent. The phrase suggests a dynamic relationship between the gesture's endpoint and the UI's final location, which may not align with the accused "snap-to-corner" functionality.
- Intrinsic Evidence for a Broader Interpretation: A plaintiff could argue that if a swipe gesture ends anywhere in the lower-left quadrant of the screen and the UI moves to the lower-left corner, it is moving "toward" the final position in a general sense.
- Intrinsic Evidence for a Narrower Interpretation: The specification states, "the final position of the magnified or reduced UI can be determined according to the initial touch point or according to the final touch point," which supports the idea that the specific endpoint of the touch dictates the final placement, not just the general direction ('079 Patent, col. 4:46-49).
VI. Other Allegations
- Indirect Infringement: The complaint alleges that Defendants induce infringement by providing the accused smartphones to customers and end-users with knowledge of the patents and with the intent to cause infringement. This allegation is supported by references to Defendants' user guides, which allegedly instruct users on how to perform the infringing method of activating the "one hand mode" (Compl. ¶¶40-42, 58-60).
- Willful Infringement: The willfulness claim is based on alleged pre-suit knowledge. The complaint states that Defendants received a notice letter on November 16, 2017, and claim charts on December 25, 2017, but continued to engage in infringing activities (Compl. ¶¶28-31, 39, 46-49, 57).
VII. Analyst’s Conclusion: Key Questions for the Case
- A core issue will be one of definitional scope: can the term "adjustment area," which the patent figures depict along the sides of a UI element, be construed to cover the system-level "virtual navigation bar" or screen corners used to activate the one-handed mode in the accused smartphones?
- A key evidentiary question will be one of functional operation: does the accused products' feature, which appears to snap the UI to a predefined corner, meet the '079 Patent's specific requirement of scaling the UI "toward the final touch position," or is there a fundamental mismatch in technical operation that may avoid infringement of that patent's claims? The distinct "according to the... touching event" language in the '470 Patent will likely require a separate factual analysis.