DCT

2:22-cv-00049

SpaceTime3D Inc v. LG Electronics Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: SpaceTime3D, Inc. v. LG Electronics Inc., et al., 2:22-cv-00049, E.D. Tex., 02/10/2022
  • Venue Allegations: Venue is alleged to be proper against LG Electronics U.S.A., Inc. based on its maintenance of regular and established places of business in the Eastern District of Texas, and against LG Electronics Inc. as a foreign corporation.
  • Core Dispute: Plaintiff alleges that Defendant’s smartphones and tablets infringe patents related to three-dimensional graphical user interfaces that allow users to manage and switch between open applications.
  • Technical Context: The technology addresses methods for improving user interaction on devices with limited screen sizes by switching between a two-dimensional view of an active application and a three-dimensional, navigable view of multiple open applications.
  • Key Procedural History: The complaint alleges that Defendant had pre-suit knowledge of the asserted patent family, citing instances where Defendant’s own patent applications were rejected by the U.S. Patent and Trademark Office over publications that matured into the patents-in-suit. This allegation forms the basis for the willfulness claim.

Case Timeline

Date Event
2005-09-13 Earliest Priority Date for all Patents-in-Suit
2007-06-04 SpaceTime3D releases public beta of its browser technology
2014-04-01 LG allegedly receives notice of '018 parent patent during its own patent prosecution
2014-05-01 LG allegedly receives notice of '048 patent during its own patent prosecution
2014-11-04 U.S. Patent No. 8,881,048 Issues
2016-01-01 Beginning of infringement period for Accused Products running Android OS 5-8
2016-04-05 U.S. Patent No. 9,304,654 Issues
2016-09-01 LG allegedly receives further notice of patent family during its own patent prosecution
2017-07-04 U.S. Patent No. 9,696,868 Issues
2022-02-10 Complaint Filed

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

U.S. Patent No. 8,881,048 - "System and Method for Providing Three-Dimensional Graphical User Interface"

The Invention Explained

  • Problem Addressed: The patent describes conventional graphical user interfaces (GUIs) as inefficient, particularly on devices with limited screen space, processing power, and battery life (Compl. ¶24). Users must perform tedious steps like repetitive mouse clicks to open, close, hide, or overlap applications on a finite-sized "desktop," which wastes time and complicates task management (’048 Patent, col. 1:45-56).
  • The Patented Solution: The invention provides a GUI that allows a user to switch between interacting with a single application in a traditional two-dimensional (2D) space and viewing images of multiple applications in a three-dimensional (3D) virtual space (’048 Patent, col. 2:57-65). This system captures the output of various computer sources (e.g., webpages, applications) and presents them as objects in a navigable 3D environment, creating a visual history of the user's session without replacing the previous output (’048 Patent, Abstract; col. 2:20-24).
  • Technical Importance: This method of managing applications was presented as particularly advantageous for ultra-mobile personal computers ("UMPC"), which were constrained by small displays and limited processing capabilities (Compl. ¶28).

Key Claims at a Glance

  • The complaint asserts independent claim 8 (Compl. ¶56).
  • Essential elements of Claim 8 include:
    • A system with a display screen, input device, processor, and memory module.
    • The memory module has executable code to:
    • Receive first and second inputs from a user, corresponding to first and second webpages.
    • Display a portion of the first webpage on a first object and the second webpage on a second object within a 3D space, with the first object in the foreground and the second in the background.
    • This display process involves rendering the webpages, capturing images of them, and "texturing" the images onto the respective objects.
    • Receive a user interaction on the first image.
    • In response, replace the 3D view of objects with a 2D window containing the rendered first webpage.
  • The complaint notes its infringement description is illustrative, reserving the right to assert other claims (Compl. ¶57, fn. 8).

U.S. Patent No. 9,304,654 - "System and Method for Displaying a Timeline Associated with a Plurality of Applications"

The Invention Explained

  • Problem Addressed: The patent addresses the same technical shortcomings as its parent patents: the inefficiency of managing multiple applications on computing devices with limited resources (Compl. ¶28; ’654 Patent, col. 2:40-56).
  • The Patented Solution: This invention introduces the concept of a "timeline" for navigating open applications (’654 Patent, Abstract). The system generates images of the output from multiple applications and displays these images within a 3D space. The ordering of these images is based on a "last time" that the processor received user input or interaction with the corresponding application, creating a chronological browsing history (’654 Patent, col. 3:5-13; Compl. ¶81). A user can select an image from the 3D timeline to replace that view with an active, 2D view of the selected application.
  • Technical Importance: The timeline concept provides a chronologically intuitive method for users to switch between tasks and applications, which is particularly useful for managing workflows on mobile devices (Compl. ¶24).

Key Claims at a Glance

  • The complaint asserts independent claim 10 (Compl. ¶81).
  • Essential elements of Claim 10 include:
    • A system for displaying a timeline of applications with a display, input device, processor, and memory.
    • The memory has code to:
    • Receive inputs to open a plurality of applications (e.g., first, second, third).
    • Generate a plurality of images, each corresponding to an output from an application.
    • Display the plurality of images in a 3D space in an order based on the last time the processor received input for and interaction with each corresponding application.
    • The order places one image in the foreground and others in the background.
    • Receive a "fourth input" interacting with one of the images.
    • In response, replace the 3D image view with a 2D view of the application corresponding to the selected image.
    • Receive a "fifth input" interacting with the application in the 2D view.
    • Modify the application-specific data in response to the fifth input.
  • The complaint notes its infringement description is illustrative (Compl. ¶82, fn. 11).

U.S. Patent No. 9,696,868 - "System and Method for Providing Three-Dimensional Graphical User Interface"

  • Technology Synopsis: This patent, part of the same family, is also directed to a GUI for switching between a 2D view of an active application and a 3D view of images of open applications. The asserted claims add specific limitations related to user manipulation of the images within the 3D space, including allowing a user to move the plurality of images and to delete at least one of the images from the 3D space (Compl. ¶¶108, 125-126).
  • Asserted Claims: The complaint focuses on independent claim 10 as illustrative (Compl. ¶108).
  • Accused Features: The "recent apps" feature on LG's devices is accused of infringing by allowing users to scroll through (move) and swipe away (delete) application images from the 3D-style multitasking view (Compl. ¶¶ 125-126).

III. The Accused Instrumentality

Product Identification

The complaint identifies the "Accused Products" as LG's smartphones and tablets running Android OS 5 through 8, sold from at least 2016 to the present (Compl. ¶40). Specific examples cited include the LG Optimus Zone 3, LG K10, and LG G Pad X 10.1 (Compl. ¶13).

Functionality and Market Context

The accused functionality is the graphical user interface for multitasking or switching between applications, often referred to as the "recent apps" screen (Compl. ¶47). On the Accused Products, this feature is invoked to display images of open applications in a three-dimensional, stacked format (Compl. ¶46). The complaint provides a screenshot from an LG Optimus Zone 3, showing an active Clock app in a 2D space and a subsequent view of Chrome, Clock, and Calendar apps as overlapping images in a 3D space (Compl. Fig. 6A). Users can navigate this 3D view and select an image, which replaces the 3D view with the selected application in a 2D space (Compl. ¶46). The complaint also alleges this functionality is promoted in LG's user manuals, providing a screenshot from an LG K10 manual instructing users how to "switch between several open applications" (Compl. Fig. 7).

IV. Analysis of Infringement Allegations

U.S. Patent No. 8,881,048 Infringement Allegations

Claim Element (from Independent Claim 8) Alleged Infringing Functionality Complaint Citation Patent Citation
a system for providing a three-dimensional (3D) graphical user interface, comprising: a display screen; an input device for receiving at least one input from an end user; a processor module... and a memory module... The Accused Products are systems that include a display screen (e.g., 4.5" touchscreen), an input device (capacitive touchscreen), a processor (e.g., Qualcomm MSM8909), and memory (RAM/flash). ¶58-62 col. 7:35-42
...executable code for the processor module to; receive at least first and second inputs from an end user; receive first and second webpages from at least one source... wherein the first and second inputs are website address corresponding to said first and second webpages... A user enters two different website addresses (e.g., "netflix.com" and "lg.com") into the preloaded Chrome browser, which receives the corresponding webpages from servers. ¶64-66 col. 4:41-54
display at least a portion of the first webpage on a first object within a 3D space on the display screen, and at least a portion of the second webpage on a second object within the 3D space... The Chrome browser displays multiple open tabs in a stacked, overlapping view that creates a 3D effect. Figure 11 illustrates stacked tabs for netflix.com and lg.com (Compl. Fig. 11). ¶67 col. 3:1-4
...capturing first and second images of [] at least a portion of the first webpage and [] at least a portion of the second webpage... and texturing the first image on the first object and the second image on the second object, the first object being displayed in a foreground... and the second object being displayed in a background... The system generates images of the webpages for the tab view. The complaint alleges that in the stacked view, one tab (lg.com) is in the foreground and another (netflix.com) is in the background. ¶69-70 col. 3:31-37
and display additional information, comprising: receiving an interaction by the end user on the first image; replacing the first and second objects within the 3D space with a window within a two-dimensional (2D) space... wherein the window includes the rendered first webpage... The user taps on one of the stacked tabs in the 3D view, which then replaces the tab view with a full-screen, 2D view displaying the selected webpage. Figure 12 illustrates this transition (Compl. Fig. 12). ¶71-72 col. 3:57-65

U.S. Patent No. 9,304,654 Infringement Allegations

Claim Element (from Independent Claim 10) Alleged Infringing Functionality Complaint Citation Patent Citation
a system for displaying a timeline... comprising: a display device; at least one input device; at least one processor... and a memory device comprising executable code for: The Accused Products are systems that include a display screen, touchscreen input device, processor, and memory containing the operating system and applications. ¶83-87 col. 7:35-42
receiving a plurality of inputs... opening said plurality of applications... comprising at least first, second, and third applications... A user provides inputs to open at least three applications, such as Chrome, Clock, and Calendar. Figure 17 shows these three applications open in 2D views (Compl. Fig. 17). ¶89-90 col. 9:1-12
displaying on said display device said timeline... comprising; generating a plurality of images... and displaying said plurality of images within a three-dimensional space... in an order based on a last time that... processor received... input and a last interaction... The "recent apps" feature generates and displays images of the open applications in a 3D stacked view. The complaint alleges this stack is ordered chronologically based on last input and interaction. Figure 19 shows this 3D view (Compl. Fig. 19). ¶94-96 col. 3:5-13
...such that a first one in said order is displayed in a foreground... and second and third ones... are displayed in a background... The stacked view in the "recent apps" feature displays one application image in the foreground with others receding into the background. ¶96 col. 3:57-65
allowing said user to modify... comprising: receiving a fourth input... interacting with one of said plurality of images...; replacing said plurality of images... with one of said... objects corresponding to one of said plurality of applications within a two-dimensional space... A user taps on one of the application images in the 3D stack (e.g., Calendar). This action replaces the 3D stack view with the active, 2D view of the selected application. Figure 20 illustrates this transition (Compl. Fig. 20). ¶97-98 col. 4:41-54
receiving a fifth input... interacting with said one of said first, second, and third objects within said two-dimensional space; and modifying said one of said first, second, and third application-specific data in response to said fifth input. The user interacts with the active 2D application (e.g., by clicking on dates in the Calendar), which modifies the application's data and display. ¶99-100 col. 4:55-63

Identified Points of Contention

  • Scope Questions: The case may turn on whether the accused features fall within the scope of the patent claims. For example, does the simple visual stacking of browser tabs in Chrome constitute displaying webpages on distinct "objects" within a "3D space" as required by the ’048 Patent? Similarly, does the standard "recent apps" feature of the Android OS constitute the specifically defined "timeline" of the ’654 Patent, which is claimed as being ordered based on both initial input and subsequent interactions?
  • Technical Questions: A key factual question will be how the Android OS on the Accused Products actually orders the application images in the "recent apps" view. The complaint alleges a specific, multi-part chronological ordering based on input and interaction to meet the limitations of Claim 10 of the ’654 Patent (Compl. ¶96). The actual sorting algorithm implemented by the operating system will be a central point of technical discovery.

V. Key Claim Terms for Construction

The Term: "timeline" (’654 Patent, Claim 10)

  • Context and Importance: This term is central to the infringement theory against the "recent apps" feature. Its definition will determine whether a standard "most recently used" list can infringe a claim that recites a "timeline" ordered based on a specific sequence of inputs and interactions.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent specification describes organizing icons in "linear chronological order according to when the objects were presented," which could be read to encompass a simple "most recent first" arrangement (’654 Patent, col. 3:8-12).
    • Evidence for a Narrower Interpretation: The patent repeatedly frames the invention as creating a "visual history of the user's computing session," allowing a user to "travel back in time" by clicking icons on the timeline (’654 Patent, col. 14:26-34). This language may support a narrower construction requiring a more persistent and detailed chronological record than a transient list of recent apps.

The Term: "three-dimensional (3D) space" (’048 Patent, Claim 8; ’654 Patent, Claim 10)

  • Context and Importance: Infringement of the asserted claims in all three patents requires the accused interfaces (both the Chrome tab view and the "recent apps" view) to be a "3D space." The dispute will likely focus on whether a 2.5D graphical effect meets this limitation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification suggests that creating the appearance of depth is sufficient, stating that in some systems a "shadow is drawn beneath these overlapping windows on the desktop to make them appear as if they have depth" (’048 Patent, col. 2:10-12). The complaint's screenshots show such overlapping and perspective effects (Compl. Fig. 11, Fig. 19).
    • Evidence for a Narrower Interpretation: The specification repeatedly refers to a "simulated 3-D Cartesian space" and navigating along x, y, and z coordinates, which may imply a requirement for a true, navigable 3D environment rather than just a visual effect of depth on a 2D plane (’048 Patent, col. 8:10-21).

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement, stating that Defendant provides user manuals and instructions that guide end users to use the Accused Products in an infringing manner (Compl. ¶¶ 76, 103, 129). It specifically points to the LG K10 user manual, which allegedly instructs users on how to "switch between several open applications" using the accused multitasking feature (Compl. ¶47, Fig. 7).
  • Willful Infringement: Willfulness is alleged based on both pre-suit and post-suit knowledge. The complaint alleges pre-suit knowledge by asserting that during the prosecution of its own patents, LG was made aware of the asserted patent family when patent examiners cited SpaceTime3D's published applications in rejections of LG's claims. These events allegedly occurred as early as April 2014, years before the suit was filed (Compl. ¶¶ 50, 133). The complaint also alleges that the filing of the lawsuit itself provides notice for any ongoing infringement (Compl. ¶134).

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

  • A core issue will be one of definitional scope: can the term "timeline," described in the patent with specific criteria for chronological ordering based on inputs and interactions, be construed to cover the standard "most recently used" application list found in the Android operating system?
  • A second key issue will be one of technical interpretation: does the visual effect of overlapping and scaling windows in the accused interfaces constitute a "three-dimensional space" as contemplated by the patents, or does that term require a true, navigable 3D coordinate system that is absent from the accused functionality?
  • A central question for damages will be one of pre-suit knowledge and willfulness: did Defendant's alleged encounters with the asserted patent family during its own patent prosecution provide the requisite knowledge and intent to support a finding of willful infringement and potential for enhanced damages?