Apple Inc v. Qualcomm Inc

1. Case Identification

• Case #: IPR2018-01253
• Patent #: 8,683,362
• Filed: July 2, 2018
• Petitioner(s): Apple Inc.
• Challenged Claims: 1-5, 7-20

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 different software activities on an electronic device using a "card metaphor." Each activity is represented by a card, and users can navigate, launch, terminate, and reorder these cards.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lin in view of Jiang - Claims 1-5 and 7-20 are obvious over Lin in view of Jiang.

• Prior Art Relied Upon: Lin (Application # 2009/0271731) and Jiang (Application # 2005/0102638).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that Lin discloses the core user interface (UI) claimed in the ’362 patent. Lin teaches a "book-like UI" for a handheld device where applications and widgets are organized into "pages" of a "virtual book." This UI operates in two primary modes: a "zoom-in view" (analogous to the ’362 patent's full-screen mode), where a single page/application occupies the entire display, and a "stand-up view" (analogous to the windowed/card mode), where multiple pages are displayed simultaneously. Lin further discloses user interactions, including flipping between pages with a horizontal swipe and deleting a page by swiping it downward.

  Petitioner asserted that while Lin provides the UI framework, Jiang supplies the necessary underlying technical implementation that Lin lacks. Jiang teaches a method for manipulating images on a mobile device display using a processor and memory placeholders ("indices") that track the location of each image. Crucially, Jiang discloses that when an image is deleted, the processor automatically shifts the remaining images to fill the empty space, updating their corresponding indices in memory. This directly maps to claim limitations regarding dismissing a card and shifting other cards to fill the void.

  • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would combine Jiang's processor-based object management with Lin's UI to improve Lin's functionality. Lin’s system required a "control mechanism," and a POSITA would find it obvious to implement this using a processor as explicitly taught by Jiang for a similar handheld device context. The primary motivation was to enhance Lin’s UI by adding the well-understood functionality of automatically closing the gap left by a dismissed item (a page in Lin, an image in Jiang) to make more effective use of limited screen space, a common goal in mobile UI design.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involved applying a known backend processing technique (Jiang's image and index management) to a known frontend UI metaphor (Lin's virtual book). Both references operate in the predictable field of handheld device interfaces, and integrating them would yield no more than the expected, predictable result of an efficiently managed card-based UI.

Ground 2: Obviousness over Lin in view of Jiang and Elias - Claims 3, 10, and 19 are obvious over Lin in view of Jiang and Elias.

• Prior Art Relied Upon: Lin (Application # 2009/0271731), Jiang (Application # 2005/0102638), and Elias (Application # 2007/0177803).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground builds upon the Lin and Jiang combination to address claims specifying particular swipe directions (e.g., claim 3 requiring an "upwards" swipe, claim 10 requiring a vertical swipe for one action and horizontal for another). Petitioner argued that the base combination of Lin and Jiang already taught using different directional swipes for different functions (e.g., horizontal for flipping, vertical for deleting). The incremental teaching is supplied by Elias. Elias discloses a "gesture dictionary" that allows a user or system designer to assign or reassign meanings to various gestures. This includes changing the default functions of gestures like swiping up, down, left, or right.
  • Motivation to Combine: A POSITA, seeking to implement the UI taught by Lin and Jiang, would have been motivated to consult a reference like Elias to provide design flexibility and user customization. If Lin taught a "swipe down" to delete, a POSITA would recognize that using a "swipe up" for the same function was a simple, obvious design choice, particularly when references like Elias explicitly taught that such gesture assignments are interchangeable. This modification would be a predictable variation to enhance user experience or accommodate different UI layouts (e.g., where items are stacked vertically).
  • Expectation of Success: The expectation of success was high, as reassigning a function from one swipe direction to another was a well-known and routine practice in UI design at the time. Elias confirms the conventional nature of such modifications, ensuring the result would be predictable.

4. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-5 and 7-20 of the ’362 patent as unpatentable.