PTAB

IPR2015-00322

LG Electronics Inc v. ATI Technologies ULC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Control of Background Video on Computer Displays
  • Brief Description: The ’879 patent relates to computer displays and methods for controlling background video. The invention allows a user to adjust attributes of a live video (e.g., a television broadcast) playing in the background while other applications remain overlaid in the foreground and "in focus."

3. Grounds for Unpatentability

Ground 1: Claims 17, 20, 21, and 24 are Anticipated by Chor

  • Prior Art Relied Upon: Chor (Patent 6,141,003).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chor describes an entertainment system with a graphical user interface (GUI) that assists a viewer in navigating television channels. This system, which includes a processor, memory, and a multitasking operating system, presents a "channel bar" GUI that overlays the current television program. Petitioner asserted that Chor’s "channel bar" includes a "Tools" icon which, when selected, causes a control panel to appear while the underlying program continues to play in the background. This functionality was argued to meet the independent claim limitations of providing a control panel for background video while other applications (the channel bar) remain in focus. For the dependent claims, Petitioner contended that Chor discloses collapsing the control panel when another element on the channel bar is selected, thereby teaching the limitation of removing the control panel.

Ground 2: Claims 17, 20, 21, and 24 are Anticipated by Cherrick

  • Prior Art Relied Upon: Cherrick (Patent 5,528,304).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Cherrick discloses an enhancement for on-screen television menus using a picture-in-picture display. The system was alleged to show a banner of adjustment icons (e.g., "SOURCE," "SET-UP," "AUDIO") superimposed over the main television picture. Petitioner argued that when a user selects an icon, such as the "set-up" icon, a corresponding control panel (a list of menus) appears, also overlaying the background video. This was argued to teach providing a control panel while the live video remains in the background and the icon banner application remains "in focus." For the dependent claims, Petitioner contended that Cherrick teaches removing the control panel when another display element is selected, such as when a channel add/delete menu is invoked.

Ground 3: Claims 17, 20, 21, and 24 are Anticipated by Ohyama

  • Prior Art Relied Upon: Ohyama (Patent 5,751,373).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Ohyama discloses a television receiver with a hierarchical menu system for function selection. The system was argued to display a main menu of icons (e.g., "VIDEO," "AUDIO") on one portion of the screen, superimposed on an ordinary television broadcast. When a user selects a main menu icon, Ohyama allegedly displays a subordinate control panel (a sub-menu with specific settings) while the main menu and the background video remain visible. Petitioner asserted this met the limitations of providing a control panel while video remains in the background and the main menu application remains in focus. Petitioner also argued that Ohyama teaches stopping the display of the sub-menu, thereby removing the control panel as required by the dependent claims.

  • Additional Grounds: Petitioner asserted alternative obviousness challenges under 35 U.S.C. §103 over each of Chor, Cherrick, and Ohyama. These grounds argued that if the claim term "storage means" is construed to require partitioned storage areas or multiple memory devices, implementing such a design would have been a simple and obvious modification for a POSITA, as these memory configurations were well-known in the art at the time.

4. Key Claim Construction Positions

  • "storage means" (claims 17 and 21): Petitioner argued this is a means-plus-function term subject to 35 U.S.C. §112, ¶6. The petition asserted that the only corresponding structure disclosed in the ’879 patent for all three instances of "storage means" is a single memory device ("memory 44"). Therefore, Petitioner proposed that the broadest reasonable construction allows a single memory device in the prior art to satisfy the limitations of the first, second, and third "storage means." This construction was central to the anticipation arguments, as it allowed a single memory element in each prior art reference to meet all corresponding claim limitations.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 17, 20, 21, and 24 of the ’879 patent as unpatentable.