PTAB

IPR2013-00248

Rackspace Hosting Inc v. Rotatable Technologies LLC

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1. Case Identification

2. Patent Overview

  • Title: Display Method for Selectively Rotating Windows on a Computer Display
  • Brief Description: The ’978 patent discloses a method and system for selectively rotating a computer display window within a graphical user interface. The window, comprising a frame and a display portion, is rotated about a user-selected rotation point such that the plane of the window and the plane of rotation are coplanar.

3. Grounds for Unpatentability

Ground 1: Obviousness over Martinez and Capps - Claims 1-4, 6-9, 11-14, 16, and 18 are obvious over Martinez in view of Capps.

  • Prior Art Relied Upon: Martinez (Patent 6,137,468) and Capps (Patent 5,345,543).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Martinez taught the core limitations of independent claim 1, including a computer display window with a frame and display portion, and rotation that is coplanar with the window. Martinez’s system rotated the window in response to the physical rotation of the computing device itself. Petitioner asserted that Capps supplied the missing element: a “means for selectively rotating the window…at the discretion of the user.” Capps taught rotating graphical objects by a user selecting a rotation point (a "gravity point") and performing a dragging motion with a pointing device. Capps also disclosed various means for rotation, including rotation buttons (“hand crank” icon), menu commands, and key strokes, which Petitioner mapped to dependent claims 2-4.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would combine the user-initiated rotation method of Capps with the device-responsive rotation system of Martinez. The motivation was to use a known technique (user selection and dragging) to improve a similar device by providing an alternative, more direct method of user control over graphical object rotation.
    • Expectation of Success: Petitioner argued that adding Capps's known method of user-controlled rotation to Martinez's system would have been within the grasp of a programmer and recognized as a straightforward way to improve control of graphical object rotation.

Ground 2: Anticipation by Bruder - Claims 1, 2, 4, 6, 7, 9, 10, 13-14, 15, and 18 are anticipated by Bruder.

  • Prior Art Relied Upon: Bruder (Patent 6,327,393).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Bruder anticipated all limitations of the challenged claims. Bruder disclosed a "deformable window" with a frame surrounding a "region of interest" (the display portion). Critically, Bruder taught a "means for selectively rotating the window...at the discretion of the user" by allowing a user to click and drag a corner of the window with a mouse to rotate it around a center point to a desired angle. Petitioner argued this user action met the claim limitation. Bruder also explicitly showed the rotation occurring in the X-Y plane, satisfying the coplanar limitation. Petitioner further mapped Bruder's disclosure of using a circle symbol as a rotation handle to claim 2 (rotation button) and using a keyboard to define rotation angle to claim 4 (key stroke).

Ground 3: Obviousness over Martinez, Capps, and Photoshop - Claims 5, 10, 15, and 17 are obvious over Martinez in view of Capps, further in view of Photoshop.

  • Prior Art Relied Upon: Martinez (Patent 6,137,468), Capps (Patent 5,345,543), and Photoshop (Adobe Photoshop 5.0 User Guide, a printed publication).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the Martinez and Capps combination from Ground 1. Petitioner introduced Photoshop to supply the teachings for claims requiring a "rotation cursor" and methods of "clicking and holding" while dragging. Photoshop taught that when a user moves a pointer outside a bounding border, it turns into a special "curved, two-sided arrow" cursor for rotation, directly mapping to the limitation of claim 5. Photoshop also described the user action of clicking and dragging to rotate an object, which Petitioner argued taught the "clicking and holding" method steps of claims 10 and 15.
    • Motivation to Combine: Petitioner argued a POSITA would have been motivated to add the user feedback features of Photoshop (like a dedicated rotation cursor) to the Martinez/Capps system. Because all three references address the common problem of rotating graphical objects, it would have been common sense for a programmer to look to a well-known graphics program like Photoshop for conventional methods of user interaction and feedback to improve the usability of the underlying system.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including claims 3, 11, and 16 over Bruder in view of Takano (Patent 5,045,844) to add menu commands and predetermined increment rotation; claims 8, 12, and 17 over Bruder in view of Kreegar (Patent 5,396,590) to add rotation about a point outside the window and toggling between orientations; and claim 5 over Bruder in view of Photoshop to add a rotation cursor.

4. Key Claim Construction Positions

Petitioner proposed constructions for several terms under the broadest reasonable interpretation standard, arguing the inventor did not act as a lexicographer.

  • "computer display window": Proposed as "a window generated by an operating system or an application program." This broad construction was important for applying prior art like Martinez, which taught rotating OS-level windows, and Capps, which taught rotating application-level graphical objects.
  • "means for [selectively] rotating...": Petitioner identified the function as rotating the window at the user's discretion and the corresponding structure from the specification as a rotation button, menu commands, key strokes, or a rotation cursor appearing over the frame. This construction was central to arguing that Martinez alone was insufficient (as its sensors were not a disclosed structure) and that Capps or other references were needed to supply the claimed "means."

5. Relief Requested

  • Petitioner requested that the Board institute an inter partes review of claims 1-18 of the ’978 patent and cancel those claims as unpatentable.