PTAB

IPR2024-00351

LG Electronics Inc v. Multimedia Technologies Pte Ltd

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Methods and Systems of Displaying Content on a Television
  • Brief Description: The ’040 patent relates to methods and systems for displaying content on an intelligent television. The technology centers on a "global panel" user interface that aggregates and displays a list of various content sources (e.g., live TV, applications, external inputs) with associated descriptive information for user navigation and selection.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kim, Lee-1, and Choi - Claims 1-5, 11-15, and 21 are obvious over Kim in view of Lee-1 and Choi.

  • Prior Art Relied Upon: Kim (Application # 2012/0054794), Lee-1 (Patent 9,008,190), and Choi (Application # 2013/0057764).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kim, which discloses a smart TV interface, teaches the core limitations of independent claims 1, 11, and 21. Kim’s home screen, comprising multiple "card objects" classified by content source, was asserted to be the claimed "global panel." Petitioner mapped Kim’s "BROADCAST," "NETCAST," "APP STORE," and "EXTERNAL DEVICE" card objects to the claimed sources for live television, video on demand, applications, and electrical input, respectively. Petitioner contended Kim also discloses retrieving content information (descriptive text and thumbnails) from memory and displaying it in the panel, and highlighting a selected source.
    • Motivation to Combine: Petitioner asserted a POSITA would combine Kim with Lee-1 because Kim expressly incorporates Lee-1 by reference for its teachings on using thumbnails, which provides necessary implementation details for Kim's system. A POSITA would combine Choi with Kim to improve the user interface for external devices. While Kim discloses a list of external devices, Choi teaches using specific icons and symbols to clearly indicate the connection status of each device (e.g., connected via HDMI), which Petitioner argued was a simple and predictable improvement to Kim’s system.
    • Expectation of Success: Petitioner contended success was predictable because both Kim and Choi describe similar smart TV interfaces and address the common challenge of managing external device inputs. Integrating Choi's connection status icons into Kim's external device list was presented as a matter of routine software programming.

Ground 2: Obviousness over Kim, Lee-1, Choi, and Lee-2 - Claims 2-3, 6, 12-13, 16, and 22 are obvious over Kim in view of Lee-1, Choi, and Lee-2.

  • Prior Art Relied Upon: Kim (Application # 2012/0054794), Lee-1 (Patent 9,008,190), Choi (Application # 2013/0057764), and Lee-2 (Patent 9,398,339).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds Lee-2 to the combination from Ground 1 to address limitations in dependent claims related to user-specific features and favorite channels. For claims 2, 3, 12, and 13, which require identifying a user and retrieving associated settings, Petitioner argued that Lee-2 discloses identifying a specific user (e.g., "B user") and displaying their corresponding "Favorite Channel List," which constitutes a user-specific setting. For claims 6, 16, and 22, which require identifying currently displayed content and selecting a panel based on it, Petitioner mapped this to Lee-2’s disclosure of displaying a "FAVORITE CH" card object that includes and highlights the currently watched channel.
    • Motivation to Combine: Petitioner argued a POSITA would integrate Lee-2's teachings into the primary combination to enhance user convenience. While Kim briefly mentions favorite channels, Lee-2 provides concrete implementation details on how a user can set up, edit, and display a favorite channel list. This makes Lee-2 a natural and logical source for a POSITA seeking to improve the functionality of the system disclosed in Kim.
    • Expectation of Success: Success was expected because both Kim and Lee-2 describe very similar smart TV systems and both contemplate the use of favorite channel lists. Combining Lee-2’s detailed implementation with Kim’s broader system was argued to be a straightforward integration of known elements for a predictable result.

4. Key Claim Construction Positions

  • Petitioner asserted that for the purpose of this proceeding, no claim terms require express construction and should be interpreted according to their plain and ordinary meaning.
  • Petitioner highlighted the construction of "at least one," which appears in several claims. Citing the patent's specification, Petitioner argued the phrase should be interpreted inclusively, meaning "at least one of A, B, and C" covers A alone, B alone, C alone, or any combination of A, B, and C.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv is inappropriate. It cited the early stages of co-pending district court litigation and stipulated that, if review is instituted, it will not pursue in court the specific grounds asserted in the petition or any other grounds that reasonably could have been raised.
  • Petitioner also contended that denial under §325(d) is unwarranted because the asserted prior art and grounds are not cumulative to the art considered during prosecution. Specifically, Petitioner argued the Examiner allowed the claims based on a finding that the prior art did not disclose more than two content sources, a position directly contradicted by the combinations presented in the petition.

6. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-6, 11-16, and 21-22 of Patent 9,510,040 as unpatentable.