PTAB

IPR2015-01902

Apple Inc v. Core Wireless Licensing SARL

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Text Messaging Device
  • Brief Description: The ’552 patent relates to a user interface for text messaging devices that assists users in selecting the correct ideogram (e.g., Japanese kanji) from multiple candidates generated from a single phonetic input. The system displays the ideogram candidates and provides "further information" beyond the phonetic input, such as definitions or examples, to help a user differentiate between homonyms.

3. Grounds for Unpatentability

Ground 1: Obviousness over iMac Fan - Claims 1-3, 5, 9, 11-13, 15, 19, and 21-22 are obvious over iMac Fan.

  • Prior Art Relied Upon: iMac Fan ("iMac Fan: Introduction and User Guide 2003 Edition" by Mac Fan Books).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that iMac Fan, a 2003 user guide for an Apple personal computer, discloses all limitations of the challenged claims. The guide describes a Japanese input program that, after phonetic "Romaji" or "Kana" input, displays a list of "kanji conversion candidates." To assist user selection, the system displays "additional information regarding meaning and examples of usage" for candidates that have an "i" mark indicated. Petitioner asserted this directly meets the "providing further information" limitation of independent claim 1 and the corresponding limitations in other independent claims.
    • Motivation to Combine (for §103 grounds): As this ground relied on a single reference, Petitioner argued that all claimed features were present in iMac Fan, rendering the claims obvious. It was argued that incorporating the disclosed features into a text messaging context, such as iChat or Mail (also disclosed in iMac Fan), was a well-known and obvious application of the technology.

Ground 2: Obviousness over Tanaka - Claims 1-3, 5, 9, 11-13, 15, 19, and 21-22 are obvious over Tanaka.

  • Prior Art Relied Upon: Tanaka (Japanese Pat. Pub. No. H9-297758).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Tanaka, which discloses a language data processing system for converting phonetic "kana" input to "kanji" characters, teaches every element of the challenged claims. To aid a user in selecting the proper homonym, Tanaka's system "displays the kanji and the explanatory text concerning these kanji" during the conversion process. This "explanatory text," which includes meanings of the kanji characters, was argued to be the claimed "further information." The system's disclosed use on a tablet computer for forming "sentence data" was argued to render its application to text messaging obvious.
    • Motivation to Combine (for §103 grounds): This was presented as a single-reference obviousness challenge. Petitioner argued that applying Tanaka's system to text messaging on a tablet (a disclosed embodiment) was a natural and predictable use given the state of the art.

Ground 3 & 4: Obviousness over Wu, Nishikawa, and Fushimoto - Claims 1-3, 9, 11-13, 19, and 21-22 are obvious over Wu in view of Nishikawa; Claims 5 and 15 are obvious over Wu in view of Nishikawa and Fushimoto.

  • Prior Art Relied Upon: Wu (Patent 7,395,203), Nishikawa (Japanese Pat. Pub. No. H6-75946), and Fushimoto (Patent 5,136,504).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Wu discloses the basic system of the ’552 patent: a portable device that disambiguates phonetic input (e.g., Pinyin) by displaying a list of corresponding Chinese ideograms for selection and incorporation into a text message. During prosecution of the ’552 patent, the applicant distinguished Wu by arguing it lacked the "further information" element. Petitioner argued Nishikawa supplies this missing element by teaching a Japanese input device that displays "identification elements" like "exemplary phrases" or the "meaning of Kanji" to assist users. For Ground 4, Petitioner asserted that Fushimoto teaches the additional limitations of claims 5 and 15 by disclosing an electronic dictionary that displays an indicator (a "SYN/ANT flag") to show when further information (synonyms/antonyms) is available for a selected ideogram.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Wu's phonetic input system with Nishikawa's teaching of providing explanatory information to improve system usability and assist users who are not proficient with the ideograms. Wu itself contemplates the inclusion of "software dictionaries," making the integration of Nishikawa's dictionary-like features a predictable improvement. Adding Fushimoto's indicator flag would be an obvious design choice to enhance user experience by efficiently signaling the availability of more information, a common goal in user interface design.
    • Expectation of Success: Petitioner argued the combination involved applying known user interface solutions to a known problem (selecting correct homonyms from a list). The integration would have been routine and straightforward for a POSITA, with a high expectation of success.

4. Key Claim Construction Positions

  • "further information": For the purposes of the IPR, Petitioner adopted the construction proposed by the Patent Owner in co-pending district court litigation: "information sufficient to differentiate the respective ideogrammatic representation from any others presented for the same phonetic input."
  • "processor means..." / "selecting means..." (claim 21): Petitioner asserted these terms in claim 21 should be construed as means-plus-function limitations under 35 U.S.C. §112, ¶ 6. The claimed functions were argued to be the ordinary meanings of the claim phrases, and the corresponding structure was identified as "processor 10" and its equivalents as described in the ’552 patent specification.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-3, 5, 9, 11-13, 15, 19, and 21-22 as unpatentable.