PTAB

IPR2022-00885

Samsung Electronics Co Ltd v. MemoryWeb LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: METHOD AND APPARATUS FOR MANAGING DIGITAL FILES
  • Brief Description: The ’823 patent discloses a method and system for managing digital files through a graphical user interface. The system uses a "search-filter view" that allows a user to filter files based on criteria such as people or locations, and then navigate through a series of dedicated views (e.g., people view, person view, detail view) to organize and inspect the files.

3. Grounds for Unpatentability

Ground 1A: Obviousness over iPhoto '09 Manuals - Claims 1-25 and 27-34 are obvious over Pogue in view of Engst.

  • Prior Art Relied Upon: Pogue (David Pogue & J.D. Biersdorfer, iPhoto ’09 The Missing Manual (2009)) and Engst (Adam C. Engst, Visual Quickstart Guide iPhoto ’09 (2009)).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Pogue and Engst collectively describe Apple's iPhoto ’09 software, which allegedly meets the limitations of the independent claims. The software provided a "search-filter view" that allowed filtering of digital files by criteria including "Faces" and "Places." Selecting the "Faces" criterion displayed a "people view" (a "corkboard") with images for multiple individuals. Subsequently selecting a person's image displayed a "person view" containing all photos associated with that person. Selecting a photo within that view could then lead to a "detail view" that displayed the photo enlarged, along with associated metadata and a map image.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would be expressly motivated to combine Pogue and Engst. Both references are user manuals for the exact same software product (iPhoto ’09) and serve as complementary, comprehensive documentation. Combining their teachings provides a complete understanding of the software's established features.
    • Expectation of Success: Success in combining the references was entirely predictable, as they merely document different aspects of a single, existing, and operational software product.

Ground 1B: Obviousness over iPhoto '09 and Belitz - Claim 26 is obvious over Pogue and Engst in view of Belitz.

  • Prior Art Relied Upon: Pogue (2009 manual), Engst (2009 manual), and Belitz (Application # 2010/0058212).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the teachings of iPhoto ’09 from Pogue and Engst. Petitioner asserted that while iPhoto ’09 used simple "red pins" as location indicators on its interactive map, claim 26 requires these indications to be images. Belitz allegedly remedies this deficiency by teaching the display of thumbnail images directly on an interactive geographic map to mark the locations where photos were taken.
    • Motivation to Combine: A POSITA would combine these references by substituting iPhoto '09's simple pins with Belitz's more informative thumbnail images. Petitioner argued this would be a simple substitution of one known map marker type for another to improve usability and provide users with a helpful visual preview of location-specific photos, a known design alternative at the time.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved replacing one known UI element with another functionally analogous UI element to achieve the predictable benefit of enhanced visual information.

Ground 1C: Obviousness over iPhoto '09 and Ripps - Claims 12-14 are obvious over Pogue and Engst in view of Ripps.

  • Prior Art Relied Upon: Pogue (2009 manual), Engst (2009 manual), and Ripps (Application # 2005/0116954).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that claims 12-14 require the display of "relationship information" (e.g., family relationships) associated with a person in the "person view." While iPhoto ’09 organized photos by person, Ripps specifically disclosed a method and system for generating a graphical family tree, which included a user interface for inputting and displaying relationship information between individuals.
    • Motivation to Combine: A POSITA would be motivated to incorporate the family tree and relationship data features from Ripps into the iPhoto ’09 photo management system. This combination would enhance the user experience by providing more informative and "aesthetically pleasing" context for family photos, a common and important use case for such software.
    • Expectation of Success: Success was predictable, as it involved applying a known data visualization technique (a family tree) to a known application domain (photo organization) to achieve the known benefit of richer, more contextual content display.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §314(a) or §325(d) would be inappropriate. The petition asserted that the prior art references and arguments presented were not previously considered by the USPTO. Further, Petitioner contended that under the Fintiv factors, the inter partes review (IPR) should be instituted because the petition was filed early in the parallel district court litigation, well before a Markman hearing or significant discovery had occurred, and that institution would promote judicial efficiency.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-34 of Patent 11,163,823 as unpatentable under 35 U.S.C. §103.