Microsoft Corp v. LiTL LLC

1. Case Identification

• Case #: IPR2024-00456
• Patent #: 8,612,888
• Filed: January 30, 2024
• Petitioner(s): Microsoft Corporation, HP Inc., Dell Inc., Dell Technologies Inc., ASUSTeK Computer Inc., ASUS Global Pte. Ltd.
• Patent Owner(s): LiTL LLC
• Challenged Claims: 1-9, 15-22, 24-27

2. Patent Overview

• Title: Accessing and Managing Digital Media Libraries on a Streamlined Computing Device
• Brief Description: The ’888 patent describes a "streamlined computing device" configurable into multiple physical orientations (e.g., laptop mode, easel mode), each associated with a selectable I/O profile. The device uses a graphical user interface (GUI) that presents different "views" of digital media content responsive to the device's physical configuration.

3. Grounds for Unpatentability

Ground 1: Obviousness over Reavey, Martinez, and Proctor - Claims 1, 2, 24, 26-27 are obvious over Reavey in view of Martinez and Proctor.

• Prior Art Relied Upon: Reavey (Patent 5,847,698), Martinez (Patent 6,137,468), and Proctor (Application # 2006/0227122).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Reavey disclosed a convertible electronic book with multiple physical configurations (e.g., a laptop-like mode and a flat, two-screen mode), where the device automatically changes its display characteristics based on its physical orientation. This change in configuration constituted a selection of different "I/O profiles." To meet the "plurality of views" limitation, Petitioner contended Martinez taught a system that reorganizes GUI elements, such as windows and icons, into different arrangements (e.g., "tile or cascading fashion") based on sensor input detecting device movement. Proctor was cited for teaching a manual, user-selectable switch to transition between different display modes.
  • Motivation to Combine: A POSITA would combine Reavey's convertible hardware with Martinez's dynamic GUI reorganization to create a more user-friendly interface that adapts to the different screen real estate and input methods available in each physical mode. Adding Proctor's manual switch was argued to be an obvious design choice to provide users with a predictable way to control view transitions, supplementing the automatic switching.
  • Expectation of Success: Petitioner asserted success would be predictable, as the combination merely applied known GUI software techniques (from Martinez and Proctor) to a known convertible hardware platform (Reavey) to achieve improved usability.

Ground 2: Obviousness over Reavey, Martinez, Proctor, and Aldrich - Claims 3-8, 15-17, 20, and 21 are obvious over the combination of Ground 1 in view of Aldrich.

• Prior Art Relied Upon: Reavey (Patent 5,847,698), Martinez (Patent 6,137,468), Proctor (Application # 2006/0227122), and Aldrich (Application # 2006/0265390).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground built upon the base combination of Reavey, Martinez, and Proctor by adding the teachings of Aldrich to address dependent claim limitations. Petitioner argued Aldrich disclosed a file selection interface for sharing photos and videos that could access content from both local storage ("My Computer") and remote sources, such as a third-party online photo account (e.g., Yahoo! Photos). This was alleged to teach limitations related to accessing remote digital content not controlled by the user (claim 3), associating visual representations with a remote service provider (claim 4), and integrating operations from that provider (claim 6).
  • Motivation to Combine: A POSITA would integrate the file-sharing and remote-access functionalities of Aldrich's software into the base device of the primary combination. The motivation was to improve the device's utility by adding the well-known and desirable capability to manage and share both local and online media, a common feature in computing devices at the time.
  • Expectation of Success: Success was expected because Aldrich's software was designed for integration with an operating system or browser on devices like laptops, making its application to the combined Reavey/Martinez/Proctor device straightforward and predictable.

• Additional Grounds: Petitioner asserted additional obviousness challenges, adding Pröll (German Application # DE10331185A1) to the base combination for the "easel mode" limitation of claim 25, and adding Chao (Patent 7,970,240) for limitations related to "timeline views" and updating date information in claims 9, 18-19, and 22.

4. Key Claim Construction Positions

• "plurality of views of digital media content": Petitioner argued this term should be construed as "referring to a plurality of ways of organizing visual representations of computer content," adopting a construction the Board used in a prior IPR involving the ’888 patent (IPR2021-00821). This construction is central to Petitioner's argument that Martinez's disclosure of "tile or cascading" window arrangements meets the limitation.
• Means-Plus-Function ("MPF") Terms: Petitioner contended that claim terms ending in "component" (e.g., "view selector component," "aggregation component," "display component," "storage component," and "execution component") are MPF terms under 35 U.S.C. §112, ¶6. For each term, Petitioner identified corresponding structures from the ’888 patent's specification, such as "a keyboard, touchpad, mouse..." for the "view selector component" and "a display screen" for the "display component."

5. Arguments Regarding Discretionary Denial

• §325(d) (Previously Presented Art/Arguments): Petitioner argued against discretionary denial because its grounds rely on new primary references (Martinez, Proctor, Pröll) not previously considered by the USPTO with respect to the ’888 patent. Further, Petitioner contended that even where previously-cited art was used (Reavey, Aldrich, Chao), it was presented in new combinations and arguments that were not before the Examiner or the Board in the prior IPR filed by Lenovo, which failed on a claim construction issue that this petition directly addresses.
• Fintiv (Parallel Litigation): Petitioner argued that denial under Fintiv would be inappropriate. The earliest trial date in the co-pending district court litigation is January 20, 2026, which is well after the expected Final Written Decision (FWD) deadline for this IPR in August 2025, meaning the IPR would conclude long before trial.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-9, 15-22, and 24-27 of the ’888 patent as unpatentable under 35 U.S.C. §103.