PTAB

IPR2024-00458

Microsoft Corp v. LiTL LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and method for streamlining user interaction with electronic content
  • Brief Description: The ’818 patent is directed to a graphical user interface (GUI) for a computer system, such as a convertible laptop, that is configurable between multiple physical modes. The system detects the current physical configuration (e.g., laptop mode vs. easel mode) and automatically selects and displays a corresponding view or user interface from a plurality of available views.

3. Grounds for Unpatentability

Ground 1: Claims 1-4 and 11-14 are obvious over Pröll in view of Martinez

  • Prior Art Relied Upon: Pröll (German Application Publication DE10331185A1) and Martinez (Patent 6,137,468).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Pröll taught a convertible laptop with a 360-degree hinge that could detect its configuration. Specifically, Pröll disclosed a switch to detect when the display was rotated more than 180 degrees relative to the keyboard, at which point the keyboard would be automatically blocked (making it inoperable). This met the claim limitations requiring detection of a first configuration where the keyboard is operable and a second where it is inoperable. Petitioner asserted Martinez taught altering the display of a data processing system by reorganizing on-screen content, such as arranging windows in a "tile or cascading fashion" or arranging icons in a preselected manner, in response to a physical trigger (a "shake" gesture). This provided the claimed "plurality of views" as different ways of organizing content.
    • Motivation to Combine: A POSITA would combine the teachings to improve the user experience of Pröll’s device. Instead of using Martinez’s shake gesture, a POSITA would have been motivated to use Pröll's existing hinge rotation sensor as the trigger to change the GUI organization. This would provide a more user-friendly interface tailored to the device's configuration, such as displaying a touch-optimized view with reorganized icons (from Martinez) when the keyboard is blocked and the device is used as a tablet (per Pröll).
    • Expectation of Success: A POSITA would have a reasonable expectation of success because both references described laptop computers, and implementing Martinez’s software-based GUI changes in response to Pröll’s existing hardware sensor would involve predictable programming techniques.

Ground 2: Claims 1-4 and 11-14 are obvious over Pröll in view of Preppernau

  • Prior Art Relied Upon: Pröll (German Application Publication DE10331185A1) and Preppernau (a 2007 Microsoft Press book titled Step By Step Windows Vista).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner again relied on Pröll for the convertible laptop that detects its configuration and keyboard operability. Preppernau was introduced to teach numerous, well-known methods for organizing visual content within the popular Windows Vista operating system. Petitioner argued that Preppernau disclosed multiple distinct "views" in the form of different content organizations, including: a "Favorites Center" for organizing web links, a "Quick Tabs" display showing thumbnails of all open web pages in a grid, and various taskbar functions for arranging application windows (e.g., "Cascade," "Show Windows Stacked," "Show Windows Side By Side"). These teachings provided multiple examples of a "plurality of views" as different ways of organizing content.
    • Motivation to Combine: A POSITA would have been motivated to implement a popular and feature-rich operating system like Windows Vista (taught by Preppernau) on the convertible hardware disclosed by Pröll. This combination would predictably improve the device's usability, particularly when the keyboard is inoperable. For example, a POSITA would implement one of Preppernau's touch-friendly organizational views (like the "Quick Tabs" grid) to be displayed automatically when Pröll's device detected it was in a tablet or easel configuration.
    • Expectation of Success: Combining a well-known operating system with a target hardware device was a routine task for a POSITA. Preppernau explicitly discussed configuration options for Tablet PCs, making its application to Pröll’s rotatable laptop straightforward and predictable.

4. Key Claim Construction Positions

  • The petition highlighted the term "plurality of views," which the Board, in a prior IPR on the parent ’715 patent, construed as "referring to a plurality of ways of organizing visual representations of computer content." The Board found this was distinct from merely changing display orientation. Petitioner argued that its invalidity grounds, particularly the teachings from Martinez (tiled vs. cascading windows) and Preppernau (Quick Tabs, stacked windows), met this specific construction by disclosing different ways of organizing content, not just reorienting it.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate.
    • §314(a) (Fintiv): Petitioner asserted that the earliest trial date in the parallel district court litigation is January 20, 2026, which is well after the one-year statutory deadline for a Final Written Decision in this IPR. Therefore, concerns of inefficiency and inconsistent rulings are minimal.
    • §325(d): Petitioner argued that the primary prior art reference, Pröll, which forms the basis for all asserted grounds, was never cited or considered by the Examiner during prosecution of the ’818 patent. Martinez was cited in an IDS but never substantively applied. Therefore, the petition raised art and arguments not previously before the USPTO.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-4 and 11-14 of the ’818 patent as unpatentable.