Apple Inc v. SpaceTime3D Inc

1. Case Identification

• Case #: IPR2023-00343
• Patent #: 9,304,654
• Filed: December 13, 2022
• Petitioner(s): Apple Inc.
• Patent Owner(s): SpaceTime3D, Inc.
• Challenged Claims: 1-19

2. Patent Overview

• Title: System and Method for Displaying a Timeline Associated with a Plurality of Applications
• Brief Description: The ’654 patent describes a three-dimensional (3D) graphical user interface designed to allow a user to navigate a virtual space containing organized groups of application windows. The system simulates a 3D environment on a two-dimensional (2D) display and features a timeline for interacting with and managing multiple applications.

3. Grounds for Unpatentability

Ground 1: Claims 1-5, 7-8, 10-13, 15-17, and 19 are obvious over Anthony in view of Hanggie.

• Prior Art Relied Upon: Anthony (Application # 2005/0091596) and Hanggie (Application # 2005/0088447). Petitioner asserted that these references could be combined in either order to render the same result, referring to the combined system as "HAC".
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Anthony taught the core concept of a 3D, chronologically ordered timeline for displaying and navigating visual representations of data objects (e.g., files, folders). Anthony disclosed that a user could select an object to launch an associated application. Hanggie taught a compositing window manager for rendering a 3D desktop that supported legacy 2D applications. Crucially, Hanggie disclosed application windows with standard user controls (e.g., maximize, minimize) and the ability to switch between 2D and 3D display modes to conserve resources. Petitioner contended that the combined HAC system taught displaying interactive application windows (from Hanggie) within a navigable 3D timeline (from Anthony), thereby meeting the limitations of independent claims 1, 10, and 19.
  • Motivation to Combine: A POSITA would combine Anthony and Hanggie to enhance the usability of Anthony’s timeline. Implementing Hanggie's well-understood application windows and controls within Anthony's organizational structure would provide a more intuitive and powerful user interface, leveraging the benefits of both systems for a predictable improvement in functionality.
  • Expectation of Success: Petitioner asserted a high expectation of success because Anthony and Hanggie disclosed highly similar computer system architectures, relied on the same 3D graphics software (e.g., Direct3D®, OpenGL®), shared a common inventor and assignee, and were directed to the same field of 3D user interfaces.

Ground 2: Claims 6, 9, 14, and 18 are obvious over Anthony and Hanggie in view of Matthews.

• Prior Art Relied Upon: Anthony (Application # 2005/0091596), Hanggie (’447 application), and Matthews (Application # 2006/0107229).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground added the teachings of Matthews to the HAC system to address claims related to displaying a desktop image and using web browser applications. Petitioner argued that Matthews disclosed a method for applying a 3D transformation to a work area, which included an "image of a desktop" with open application windows, to reveal other information. This directly mapped to limitations in claims 6 and 14 requiring the display of a fourth image being an image of a desktop. Furthermore, Matthews provided Internet Explorer as an example of an application, allegedly rendering claims 9 and 18 (requiring a web browser application) obvious.
  • Motivation to Combine: The motivation was exceptionally strong and direct, as Matthews explicitly stated its invention was designed for use with Hanggie’s compositing window manager system and cited the Hanggie application number. A POSITA would therefore have been directly instructed to combine Matthews with the HAC system to predictably add functionality for managing desktop clutter and revealing hidden information via 3D transformations.
  • Expectation of Success: Success was predictable because Matthews was designed to integrate with the foundational system disclosed in Hanggie, ensuring compatibility and foreseeable results.

4. Key Claim Construction Positions

• Petitioner noted that the parties agreed upon the construction of two terms in co-pending litigation, which were adopted for the purposes of the petition:
  • 3D space: a virtual space defined by a three-dimensional coordinate system.
  • 2D space: a finite graphical area defined by a two-dimensional coordinate system.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be inappropriate under both 35 U.S.C. §325(d) and §314(a).
  • §325(d) (Advanced Bionics): Petitioner contended that the examiner did not issue any prior art rejections during prosecution and that there was no evidence the examiner ever considered Anthony, Hanggie, or Matthews. The failure to consider this allegedly material prior art, Petitioner argued, constituted a material error that this inter partes review (IPR) could correct.
  • §314(a) (Fintiv): Petitioner asserted that all relevant Fintiv factors favored institution. The core arguments were that the petition's merits were compelling, a stay had been requested in the parallel district court case, the court’s trial schedule was uncertain and subject to delay, the litigation was in its early stages, and Petitioner stipulated it would not pursue the same invalidity grounds in district court if the IPR were instituted.

6. Relief Requested

• Petitioner requests institution of an IPR and cancellation of claims 1-19 of Patent 9,304,654 as unpatentable.