PTAB

IPR2014-01109

Universal Remote Control Inc v. Universal Electronics Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Displaying a User Interface for a Remote Control Application
  • Brief Description: The ’930 patent discloses a hand-held electronic device, such as a universal remote control, with a graphical user interface. The technology allows a user to define and store multiple, distinct lists of "favorite" channels, where each list is associated with a specific controllable home appliance (e.g., a TV, a cable box), and enables a single user input to both select the appliance to be controlled and display the associated list of favorites.

3. Grounds for Unpatentability

Ground 1: Obviousness over Realistic in view of Evans - Claim 1 is obvious over Realistic in view of Evans.

  • Prior Art Relied Upon: Realistic (a 1989 Universal Remote Control Owner's Manual) and Evans (Patent 4,825,200).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the Realistic manual, published by Tandy Corporation for a universal remote control, disclosed all functional elements of claim 1. Realistic taught a remote capable of controlling multiple devices (e.g., TV, VCR) and featured a "favorite-channel" function allowing a user to program a separate list of up to 32 favorite channels for each of the controllable devices. Critically, Petitioner asserted that Realistic taught the core limitation of the claim by stating that when a user presses the "SELECT" key to change devices, the corresponding "favorite-channel list becomes active for any device that you select." This showed that the same input used to select the device mode also selected the associated favorites list. Evans, a patent assigned to the same company (Tandy), disclosed the underlying architecture for such a reconfigurable remote, including a microprocessor, RAM, and LCD display, and explained that its functions were implemented via executable instructions.
    • Motivation to Combine: Petitioner contended a person of ordinary skill in the art (POSITA) would have been motivated to combine the references because they originated from the same company and addressed the same technology. A POSITA would have found it obvious and a matter of routine implementation to build the remote described in the Realistic user manual using the programmable microprocessor-based architecture taught by Evans.
    • Expectation of Success: A POSITA would have had a high expectation of success in implementing the known software features described in the Realistic manual on the well-understood hardware architecture disclosed in Evans, as this represented a predictable application of existing technologies.

Ground 2: Obviousness over ProntoEdit in view of Realistic - Claim 1 is obvious over ProntoEdit in view of Realistic.

  • Prior Art Relied Upon: ProntoEdit (a 2000 user guide for a remote control configuration tool) and Realistic (a 1989 Universal Remote Control Owner's Manual).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that ProntoEdit, a user guide for a Philips software tool for creating custom user interfaces for the "Pronto" remote, taught a system where an interface is organized by "Devices" which contain "Panels" of on-screen buttons. The tool allowed any button to be configured to "jump to" or display any panel. This provided the framework for a customizable remote. Realistic, as in the first ground, taught the useful and desirable feature of having a separate list of favorite channels for each controllable device. Petitioner asserted that combining these teachings rendered claim 1 obvious.
    • Motivation to Combine: A POSITA using the highly flexible ProntoEdit configuration tool to design a custom remote interface would have been motivated to implement the well-known and convenient feature of device-specific favorite channels taught by Realistic. Petitioner argued that it would have been a simple and obvious design choice to use ProntoEdit to program a single button that both selects a device for control and, as its corresponding action, jumps to a panel displaying that specific device's favorite channel list.
    • Expectation of Success: Because the ProntoEdit tool was specifically designed to enable this type of user interface customization (linking button presses to panel displays), a POSITA would have had a very high expectation of success in implementing the functionality from Realistic.

4. Key Claim Construction Positions

  • Petitioner argued for a specific construction of the key claim phrase: "accepting input into the hand held device that specifies... that the hand held device is to be placed into a mode to control at least one of a plurality of home appliances and, in response, using the input to select at least one of the plurality of lists of favorite channels."
  • Petitioner asserted this language requires that the single, same user input which places the device into a mode to control a specific appliance must also, in response, automatically cause the selection of the favorite channel list associated with that specific appliance. This interpretation was argued to be central to the obviousness analysis and consistent with the patent's prosecution history, where the applicant distinguished prior art based on this "same input" functionality.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claim 1 of Patent 7,831,930 as unpatentable under 35 U.S.C. §103.