PTAB

IPR2024-00353

LG Electronics Inc v. Multimedia Technologies Pte Ltd

Log In
Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method for Activating a User Interface Element and Device
  • Brief Description: The ’188 patent discloses a method and device for activating user interface elements on a touch-sensitive display. The invention focuses on distinguishing a "press input" (a touch with force exceeding a threshold) from a standard "touch input" to prevent inadvertent activation and provide an alternative input mechanism.

3. Grounds for Unpatentability

Ground 1: Obviousness over Forstall and Westerman - Claims 1-7 and 10-13 are obvious over Forstall in view of Westerman.

  • Prior Art Relied Upon: Forstall (Application # 2008/0168384) and Westerman (Patent 8,570,290).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Forstall taught a touch-sensitive device that can display and activate user interface (UI) elements. Forstall disclosed distinguishing between different types of touch inputs, such as using touch duration (a "long press") to activate a secondary function, which Petitioner contended was analogous to the ’188 patent's use of force. Westerman was cited as teaching the use of force sensors integrated with a touch display to measure the amount of force applied by a finger, thereby enabling a "press input" functionality. Petitioner asserted that Forstall disclosed all limitations of independent claim 1 except for the use of force to define the "press input." Westerman allegedly supplied this missing element by explicitly teaching the detection of varying force levels to trigger different commands. Dependent claims were argued to be obvious as they recited conventional features, such as displaying a preview (taught by Forstall) or using a mobile device (the context of both references).
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Forstall's UI activation method with Westerman's force-based input detection to improve the user experience. Using force as an input modality was known to be faster and more efficient than the "long press" method taught by Forstall, as it eliminates the need for a user to wait a predetermined duration. This combination would represent a predictable improvement of a known system.
    • Expectation of Success: A POSITA would have had a high expectation of success because integrating force sensors with touchscreens, as taught by Westerman, was a well-understood and common practice at the time of the invention to expand the input capabilities of electronic devices.

Ground 2: Obviousness over Lemay, Westerman, and Kocienda - Claims 1-13 are obvious over Lemay in view of Westerman and Kocienda.

  • Prior Art Relied Upon: Lemay (Patent 8,593,411), Westerman (’290 patent), and Kocienda (Application # 2009/0178009).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lemay, like Forstall, disclosed a touch-sensitive device with a graphical user interface. Lemay taught detecting a finger contact and taking action based on that contact, forming the basis for the claimed system. As in Ground 1, Westerman was used to supply the teaching of a "press input" based on detecting applied force exceeding a threshold. Kocienda was introduced to provide an explicit teaching of activating a UI function in response to a press-type input, further bridging any alleged gap between Lemay/Westerman and the claimed invention. Petitioner contended that the combination of these three references disclosed every limitation of the challenged claims. For instance, Lemay provided the device, Westerman provided the specific "press input" detection, and Kocienda provided the resulting UI activation.
    • Motivation to Combine: A POSITA would combine these references to enhance the functionality of the device disclosed in Lemay. A designer would look to known techniques, such as the force-based input from Westerman, to provide users with more input options. Kocienda’s teachings on UI design would have been a natural and predictable source for a POSITA to consult when implementing such force-based controls, making the claimed combination a matter of applying known design principles to an existing system.
    • Expectation of Success: The combination involved applying known sensor technology (Westerman) and established UI principles (Kocienda) to a conventional touch device (Lemay), and a POSITA would have reasonably expected the resulting system to function as intended.

4. Key Claim Construction Positions

  • "press input": Petitioner argued this term should be construed as "an input detected based on a force applied by a touch object to a touch-sensitive surface that exceeds a predetermined threshold." This construction was asserted to be consistent with the specification's description of distinguishing between a light touch and a harder press. Petitioner contended this construction was critical because it clarified that the invention resided in using the concept of a force threshold, a concept Petitioner alleged was well-known and explicitly taught by the prior art, particularly Westerman.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv would be inappropriate despite a co-pending litigation in the Western District of Texas. Petitioner asserted that the IPR proceeding would be a more efficient and effective vehicle for resolving the patentability questions at issue due to the PTAB's technical expertise. It was further argued that the district court case was not in an advanced state, with a trial date far in the future, and that a stay was likely if the IPR was instituted. Petitioner also contended that the prior art and invalidity arguments presented in the IPR were substantially different and more developed than those currently before the district court, weighing against denial.

6. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-13 of the ’188 patent as unpatentable under 35 U.S.C. §103.