PTAB

IPR2019-00112

Apple Inc v. Qualcomm Inc

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1. Case Identification

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 activities on an electronic device using a "card metaphor." Each activity is represented as a movable and manipulable on-screen card, allowing a user to launch, terminate, reorder, and navigate among various concurrent activities.

3. Grounds for Unpatentability

Ground 1: Obviousness over Anzures, Elias, Jiang, and Nickerson - Claims 1-3, 5, 8, 9, and 11 are obvious over the combination of four prior art references.

  • Prior Art Relied Upon: Anzures (Patent 9,772,751), Elias (Application # 2007/0177803), Jiang (Application # 2005/0102638), and Nickerson (Application # 2005/0240618).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the primary reference, Anzures, disclosed the foundational system of the challenged claims. Anzures taught a portable multifunction device with a touch screen that operated in at least two display modes: a full-screen mode and a "windowed" card-based mode. In this windowed mode, Anzures displayed multiple cards representing web pages or other documents, with one primary card fully visible and at least a portion of an adjacent card also visible. Petitioner asserted that Anzures taught navigating these cards via horizontal swipe gestures, which directly mapped to the claimed method of responding to a directional contact by changing a card's position.
    • Motivation to Combine: Petitioner contended that a person of ordinary skill in the art (POSITA) would have been motivated to augment the Anzures system with the teachings of Elias, Jiang, and Nickerson to arrive at the claimed invention.
      • A POSITA would combine Anzures with Elias to enhance user interface efficiency. While Anzures disclosed deleting a card by tapping an icon, Elias taught a gesture dictionary that runs in the background to recognize predefined gestures (e.g., a clockwise swipe) for common commands like closing an application. Integrating Elias’s dictionary would provide Anzures users with a more fluid and powerful gesture-based method for dismissing cards, a predictable improvement to the system's usability.
      • A POSITA would further incorporate Jiang to solve a problem not addressed by Anzures: the visual void left after a card is dismissed. Jiang explicitly disclosed a method for manipulating images on a mobile display where, upon deletion of one image, the remaining images automatically shift to fill the empty space. A POSITA would apply this known technique for managing gridded content to Anzures’s card layout to maintain a clean, organized, and user-friendly interface, which was a simple and obvious design choice.
      • Finally, a POSITA would integrate Nickerson to enable the concurrent operation of distinct applications as claimed. Anzures suggested its cards could display "other structured documents," but Nickerson provided a concrete implementation, teaching how to embed various document types (e.g., Microsoft Word, PDF) within a single browser framework, each supported by different software. A POSITA would use Nickerson’s teachings to modify Anzures so that each card could represent a distinct, concurrently running application (e.g., a word processor, a PDF viewer), not just different web pages.
    • Expectation of Success: Petitioner argued that a POSITA would have a high expectation of success in making this combination. The proposed modifications involved the straightforward application of known user interface principles and software architecture to a compatible base system. This integration would produce only predictable results and would not require undue experimentation.
  • Additional Grounds: Petitioner noted that challenges to other claims of the ’362 patent, based on combinations including Jin, Lin, Jiang, and Elias, were presented in separate, related petitions (IPR2018-01252 and IPR2018-01253).

4. Arguments Regarding Discretionary Denial

  • Petitioner presented a substantial argument that discretionary denial under the General Plastics factors would be inappropriate, despite the existence of two other pending inter partes review (IPR) proceedings against the same patent. The core of the argument was that this third petition was necessary due to the Patent Owner’s litigation conduct—specifically, its refusal to clarify an alleged earlier invention date for the ’362 patent. This uncertainty created a risk that the prior art in the earlier petitions might be disqualified, compelling Petitioner to file this petition with different, earlier-dated prior art references to ensure its invalidity contentions remained viable.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-3, 5, 8, 9, and 11 of the ’362 patent as unpatentable.