PTAB

IPR2017-01856

Unified Patents Inc v. 602531 British Columbia Ltd

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1. Case Identification

2. Patent Overview

  • Title: User Interface for Predictive Text Entry
  • Brief Description: The ’124 patent describes a user interface for a predictive text entry system. The purported invention focuses on two key features: (1) managing the display to show either a digital keyboard or a list of completion candidates, but not both at once, and (2) generating a new, refined list of completion candidates based on a user’s prior selection from an earlier candidate list.

3. Grounds for Unpatentability

Ground 1: Obviousness over Fukushima, Capps, and Witten - Claims 1-11, 16-18, and 37-40 are obvious over Fukushima in view of Capps and Witten.

  • Prior Art Relied Upon: Fukushima (Patent 5,724,457), Capps (Patent 5,367,453), and Witten (The Reactive Keyboard (1992)).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Fukushima taught the foundational system for predictive text entry, including receiving a partial text entry (e.g., "t") and displaying a corresponding list of completion candidates (e.g., "take", "talk"). However, Fukushima did not teach the key limitations that led to allowance: interchangeably displaying a keyboard and a search list, and performing a further search based on a selected candidate. Petitioner asserted that Capps supplied the missing element of interchangeably displaying either a digital keyboard or a correction list (analogous to a completion list) to conserve screen space. It was argued that Witten taught the concept of a "further search," where selecting a completion candidate (e.g., "Reactive") updates the display to show a new list of predictions that are continuations of the selected term (e.g., "Reactive-Keyboard").
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine these references to improve the user experience, a common goal in interface design. Adding Capps's interchangeable display to Fukushima's system would make it more effective on devices with limited screen space. Incorporating Witten's "further search" functionality would enhance input speed and efficiency by reducing the number of characters a user must manually type, directly furthering the stated goals of the Fukushima system.
    • Expectation of Success: Petitioner contended that a POSITA would have a high expectation of success, as combining these known software features for text entry systems would require only predictable programming modifications and yield foreseeable improvements in usability.

Ground 2: Obviousness over Schroeder and Witten - Claims 19-21 are obvious over Schroeder in view of Witten.

  • Prior Art Relied Upon: Schroeder (Patent 5,797,098) and Witten (The Reactive Keyboard (1992)).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented Schroeder as a strong alternative primary reference to Fukushima. Schroeder was argued to teach an improved user interface for mobile phones that provides word completion, including displaying candidate words (e.g., "PLEASE," "PLEAD") in response to a partial text entry ("PLE"). As with Fukushima, Schroeder allegedly lacked the teaching of generating a new list of completion candidates based on a previously selected candidate. Petitioner asserted that Witten supplied this limitation by teaching that after a user selects a word, the system generates a new set of predictions based on that selection to continue the text entry.
    • Motivation to Combine: A POSITA would combine Witten's predictive functionality with Schroeder's system to further Schroeder's stated goal of "speeding up input" on handheld devices. By allowing a user to chain selections together rather than typing more characters, the combination would reduce manual input and increase efficiency.
    • Expectation of Success: The combination was portrayed as a straightforward integration of a known predictive text feature (Witten) into an existing word completion system (Schroeder). Petitioner argued this would involve minimal, well-understood software modifications and would predictably result in a faster text entry system.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including grounds where Fukushima was combined individually with Witten (for the "further search" feature) or Capps (for the interchangeable keyboard/list feature). Another ground added Flinchem (Patent 6,307,548) to the main combination to explicitly teach the simultaneous display of a keyboard and a candidate list for certain claims.

4. Key Claim Construction Positions

  • Petitioner argued for constructions of several terms to support its obviousness arguments. The most significant proposed construction related to the phrase "displaying / activating" or "not displaying / deactivating" the digital keyboard or search list.
    • Petitioner asserted that the broadest reasonable interpretation of this language, based on the specification, encompasses both automatic and manual user actions for swapping between the keyboard and the list display. This construction was critical for applying references like Capps, which explicitly teaches a user manually selecting a keyboard icon to hide the suggestion list and display the keyboard, thereby mapping directly onto the claim limitations under Petitioner’s proposed construction.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-21 and 36-41 of Patent 7,681,124 as unpatentable under 35 U.S.C. §103.