PTAB

IPR2018-00289

Apple Inc v. Uniloc Luxembourg SA

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Waking a Device from a Low Power State in Response to Detected Acceleration
  • Brief Description: The ’646 patent relates to a method and system for waking a mobile device from a low-power state in response to detected motion. The system uses a multi-axis motion sensor to establish an "idle sample value" when the device is at rest and wakes the device upon detecting a change along the "dominant axis," which is defined as the axis most affected by gravity.

3. Grounds for Unpatentability

Ground 1: Claims 1, 3, 5-7, 9-11, 13-15, 17, and 20 are obvious over Pasolini, Goldman, McMahan, and Mizell.

  • Prior Art Relied Upon: Pasolini (Patent 7,409,291), Goldman (a 2007 Sun Microsystems publication titled "Using the LIS3L02AQ Accelerometer"), McMahan (Patent 7,204,123), and Mizell (a 2003 IEEE publication titled "Using Gravity to Estimate Accelerometer Orientation").
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of references teaches every limitation of the challenged claims. Pasolini taught the foundational system of using a three-axis accelerometer to detect motion (e.g., being picked up) to wake a portable device from a standby state, including detecting acceleration along the axis most aligned with gravity. Goldman taught specific, robust programmatic techniques for processing accelerometer data, including establishing a rest value (an "idle sample value") to zero out gravity and isolate motion-based acceleration. McMahan taught a method for enhancing sensor accuracy by identifying and removing anomalous data ("glitches") that fall outside an acceptable range. Finally, Mizell taught reducing signal noise by averaging accelerometer samples over a sampling interval to obtain a more accurate representation of gravity, which corresponds to the claimed "average of accelerations."
    • Motivation to Combine: Petitioner asserted a step-wise motivation to build a more robust and accurate motion-detection system. A person of ordinary skill in the art (POSITA) would combine Pasolini's basic wake-up system with Goldman's advanced, programmable accelerometer processing techniques to improve functionality and accuracy. To further enhance the system’s reliability, a POSITA would incorporate McMahan’s well-known technique for glitch removal. To further refine the accuracy of the idle value measurement, a POSITA would also incorporate Mizell's known technique of averaging samples to reduce signal noise.
    • Expectation of Success: A POSITA would have a high expectation of success because each reference represents a known technique for improving accelerometer systems in portable devices. The combination involved applying programmable features, error correction, and noise reduction—all predictable and established engineering practices. Further, Goldman’s techniques were implemented in a known, available product.

Ground 2: Claims 8, 16, and 18 are obvious over Pasolini, Goldman, McMahan, Mizell, and Park.

  • Prior Art Relied Upon: Pasolini (Patent 7,409,291), Goldman (a 2007 Sun Microsystems publication), McMahan (Patent 7,204,123), Mizell (a 2003 IEEE publication), and Park (Patent 7,028,220).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground incorporated the entire combination from Ground 1 to teach the base system for waking a device based on motion detection. To meet the limitations of claims 8, 16, and 18, which require configuring the device to "return to a last active device state," Petitioner added Park. Park taught a portable system that, upon entering a suspend mode, saves system status data and then uses that data to restore the system to its prior state when it wakes up. This directly taught the claimed state-restoration functionality.
    • Motivation to Combine: The motivation to add Park's teachings to the base combination from Ground 1 was to enhance user convenience. A POSITA designing a portable electronic device would seek to improve the user experience by implementing features like state restoration, which eliminates the need for a user to manually re-open applications after the device wakes. Applying Park's method was described as using a known technique to improve a similar device (a portable computing system) in the same way.
    • Expectation of Success: A POSITA would have an expectation of success because Park taught a software-based solution that could be readily implemented using the programmable environment provided by Goldman. This integration was argued to be a straightforward application of a known convenience feature in the art of portable electronics.

4. Key Claim Construction Positions

  • "glitch": Petitioner proposed that under the broadest reasonable interpretation, this term means "a datum that is outside of an acceptable range," based on explicit definitions within the ’646 patent’s specification.
  • "-logic" terms (e.g., "dominant axis logic," "computation logic," "power logic"): Petitioner advanced arguments under two alternative constructions for these key terms, which are central to the invalidity analysis.
    • Primary Construction: The terms should be given their plain and ordinary meaning, encompassing hardware, software, or a combination thereof that performs the recited function.
    • Alternative Means-Plus-Function Construction: In the event the Patent Owner argues these are means-plus-function terms under 35 U.S.C. § 112, sixth paragraph, Petitioner identified the claimed function and the corresponding structure (specific software routines and hardware blocks) disclosed in the ’646 patent’s specification. Petitioner argued that the claims are obvious even under this narrower construction, as the prior art disclosed the necessary structure for performing the identical functions.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1, 3, 5-11, 13-18, and 20 of the ’646 patent as unpatentable.