PTAB

IPR2024-00352

LG Electronics Inc v. Multimedia Technologies Pte Ltd

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Intelligent Television and Methods for Displaying Content
  • Brief Description: The ’174 patent discloses a television user interface, termed an "application panel interface," that includes a navigation bar and a content area. In response to a user's directional inputs on the navigation bar, the system displays different types of information in a "first content panel" or a "second content panel" within the content area.

3. Grounds for Unpatentability

Ground 1: Obviousness over Woods - Claims 1-14 are obvious over Woods.

  • Prior Art Relied Upon: Woods (Application # 2010/0262938).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Woods discloses all limitations of the challenged claims. Woods teaches a media guidance application for a television that includes a functions menu bar (analogous to the claimed navigation bar) and an adjacent function options region (analogous to the claimed content panel). In Woods, when a user provides a directional input to move a focus indicator in the menu bar from one item (e.g., "cast") to another (e.g., "detailed description"), the list of options displayed in the options region changes accordingly. Petitioner asserted this directly maps to the claimed method of receiving a directional input that causes a "first content panel" (the cast list) to be replaced by a "second content panel" (the detailed description list) within an "application panel interface." Woods further discloses retrieving this information from memory and displaying it on the television.
    • Motivation to Combine (for §103 grounds): Not applicable, as this is a single-reference ground. Petitioner contended that Woods alone renders the claims obvious.
    • Expectation of Success (for §103 grounds): Not applicable.

Ground 2: Obviousness over Woods and Istvan - Claims 6, 8, and 14 are obvious over Woods in view of Istvan.

  • Prior Art Relied Upon: Woods (Application # 2010/0262938), Istvan (Application # 2002/0060750).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground supplements the teachings of Woods to address claims requiring specific panel types, namely "favorite" (claims 6, 14) and "search" (claim 8) panels. While Woods suggests the possibility of such features, Istvan explicitly discloses a television user interface with a menu bar that includes distinct "favorites" and "search" options. Petitioner argued that Istvan provides clear evidence that these were well-known and conventional features for media guide menu bars at the time.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Istvan's conventional menu options with Woods' interface to improve user experience. Adding "favorites" and "search" functions, as explicitly taught by Istvan, would provide users with quick and predictable access to desirable and commonly used features within the Woods system.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success in adding these common UI elements to Woods' menu bar, as it represented a straightforward integration of known features to yield a predictable result.

Ground 3: Obviousness over Woods and Machida - Claims 1-14 are obvious over Woods in view of Machida.

  • Prior Art Relied Upon: Woods (Application # 2010/0262938), Machida (Application # 2007/0047920).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses the potential argument that the claimed "first content panel" and "second content panel" must be predetermined, distinct panel types. Machida teaches an interface where a single display area is used to exclusively display different, predefined operational panels (e.g., a "linear content operation panel" and an "interactive content operation panel") based on the context. Petitioner argued that Machida teaches the specific concept of swapping between different, predetermined panel types within a single defined area.
    • Motivation to Combine (for §103 grounds): A POSITA, seeking to implement the panel-changing functionality suggested by Woods, would have been motivated to use the known technique taught by Machida. Using predetermined panels allows for a more precise, uniform, and consistent UI design and can improve performance by allowing panels to be loaded into memory for faster switching, yielding the predictable result of a more robust and user-friendly interface.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success in applying Machida's technique of using interchangeable, predefined panels to implement the functionality of Woods' system, as it was a known design choice for achieving a consistent user interface.
  • Additional Grounds: Petitioner asserted that claims 6, 8, and 14 are also obvious over the combination of Woods, Machida, and Istvan, relying on the combined teachings detailed in the grounds above.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv is inappropriate. The co-pending district court litigations are in early stages, and no motion to stay has been filed. Crucially, Petitioner stipulated that if the IPR is instituted, it will not pursue in District Court the specific grounds asserted in the petition, or any other ground that was raised or could have been reasonably raised in the IPR. Petitioner also argued that denial under §325(d) is not warranted because the asserted prior art and arguments are not cumulative to those considered during prosecution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of the ’174 patent as unpatentable.