Apple Inc v. Qualcomm Inc

1. Case Identification

• Case #: IPR2018-01252
• Patent #: 8,683,362
• Filed: July 2, 2018
• Petitioner(s): Apple Inc.
• Patent Owner(s): Qualcomm Inc.
• Challenged Claims: 1-6, 8-20

2. Patent Overview

• Title: Card Metaphor for Activities in a Computing Device
• Brief Description: The ’362 patent discloses techniques for displaying and manipulating representations of concurrently running applications on an electronic device using a "card metaphor." Each application is represented as a movable and manipulable card, allowing a user to launch, terminate, and navigate between activities in different display modes.

3. Grounds for Unpatentability

Ground 1: Obviousness over Jin and Elias - Claims 1-6 and 8-20 are obvious over Jin in view of Elias.

• Prior Art Relied Upon: Jin (Patent 8,633,900) and Elias (Application # 2007/0177803).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that the combination of Jin and Elias teaches every limitation of the challenged claims. Jin discloses a mobile terminal user interface (UI) that uses a card-based metaphor for managing multiple running applications. It teaches a "single window" (full-screen) mode and various "multi-window" (windowed) modes, such as an opaque stack or a "folding fan" display. Jin explicitly teaches using directional gestures (e.g., a horizontal drag) to navigate through the cards in the windowed mode. However, Petitioner contended that Jin lacks a specific disclosure of a gesture to dismiss or close an application card.

  • Elias remedies this deficiency by teaching a "dictionary of multi-touch gestures" that maps specific gestures to UI commands. Critically, Elias discloses gestures for "exit, i.e., close application," such as a clockwise rotation. Elias also teaches that gesture assignments can be customized, allowing other motions (e.g., a vertical swipe) to be assigned the "close" function. Petitioner argued that implementing Elias's gesture dictionary within Jin's card-based UI would result in a system where a first directional gesture navigates between cards (taught by Jin) and a second, different directional gesture dismisses a card (taught by Elias), thus meeting the core limitations of independent claims 1, 12, and 17.

  • For dependent claims, Petitioner argued the combination also renders obvious the more specific limitations. For instance, the limitation of shifting remaining cards to fill the void left by a dismissed card was argued to be a well-known and obvious design choice for efficient use of limited screen space, as demonstrated in systems like the Windows XP taskbar. Limitations specifying gesture directions (e.g., horizontal for navigation, vertical for dismissal) were argued to be obvious implementations based on Elias's disclosure that gestures are assignable.

  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would be motivated to combine Elias's teachings with Jin's system to add the fundamental and highly desirable functionality of closing an application with a simple gesture. This addition would improve the usability and efficiency of Jin’s UI by reducing screen clutter and freeing system memory, which are well-understood goals in interface design. Adding this feature aligns directly with Jin’s stated objective of enabling "easy transitions between applications."

  • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. Elias describes its gesture dictionary as a software application designed to run in the background while other applications are active. Integrating this software-based functionality into Jin's mobile terminal, which already processes various user inputs and gestures, would be a predictable and straightforward modification involving routine software engineering.

• Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations of Lin (Application # 2009/0271731) and Jiang (Application # 2005/0102638), with one ground also including Elias, but noted these grounds were included in a separate petition.

4. Relief Requested

• Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-6 and 8-20 of Patent 8,683,362 as unpatentable.