PTAB

IPR2024-00480

Dell Technologies Inc v. LiTL LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Portable Computer with Multiple Display Configurations
  • Brief Description: The ’229 patent discloses a portable computer configurable between multiple modes, including a laptop mode, an easel mode (inverted 'V' shape), and a frame mode (display facing user, keyboard facing down). The computer uses an accelerometer to detect its configuration and a display manager to automatically vary content, such as by enlarging it when transitioning from laptop to easel mode.

3. Grounds for Unpatentability

Ground 1: Obviousness over Lane and Fujinawa - Claims 1-11, 19, 24, and 25 are obvious over Lane in view of Fujinawa.

  • Prior Art Relied Upon: Lane (WO 95/24007) and Fujinawa (Japanese Application # 2006-243137).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lane, a 1995 patent application, discloses nearly all limitations of independent claim 1. Lane teaches a portable computer with a display and base rotatable up to 360 degrees, enabling configurations that Petitioner mapped to the ’229 patent’s claimed laptop, frame, and easel modes. Lane also discloses a "position-indicating mechanism" (a mercury switch) that Petitioner contended a POSITA would recognize as an accelerometer for detecting orientation and disabling the keyboard when not in use. The key limitation Petitioner argued Lane lacks is a display manager that enlarges content upon a mode change. Fujinawa, which discloses a digital photo stand, was asserted to supply this teaching by describing a transition from a "book mode" (showing a photo and editable information) to a "frame mode" where the photo is enlarged to full-screen for better viewing.
    • Motivation to Combine: A POSITA would combine Lane and Fujinawa to improve the user experience of Lane’s device. When transitioning Lane’s computer to a passive viewing mode like easel or frame mode, where the keyboard is inaccessible, a POSITA would be motivated by Fujinawa’s teachings to enlarge media content (like a photo) to full-screen for more comfortable viewing from a distance.
    • Expectation of Success: Petitioner asserted a POSITA would have a high expectation of success, as modifying software to change a display’s content size in response to an orientation change was a straightforward task.

Ground 2: Obviousness over Lane, Fujinawa, and Santoro - Claim 23 is obvious over Lane and Fujinawa in view of Santoro.

  • Prior Art Relied Upon: Lane (WO 95/24007), Fujinawa (Japanese Application # 2006-243137), and Santoro (Patent 6,724,403).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the Lane/Fujinawa combination to address claim 23, which requires a "segmented user interface comprising a plurality of modes of content." Petitioner argued that Santoro teaches this limitation. Santoro discloses a graphical user interface organized into a grid of tiles. Petitioner asserted that these tiles, which can represent higher-level constructs like email folders or disk drives, meet the Patent Owner's own prior construction of "modes of content" from a related case.
    • Motivation to Combine: A POSITA would be motivated to implement Santoro's "easy to use" and "organized" tile-based interface on the Lane computer to facilitate the management of multiple data sources and reduce on-screen clutter, which were known benefits taught by Santoro.
    • Expectation of Success: Petitioner argued success would be expected, as implementing a known graphical user interface paradigm onto a portable computer was well within the skill of a POSITA in the art.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including adding Pröll (German Application # DE10331185A1) to the primary combination to teach connecting to a docking station (for claims 20-21). Alternative grounds were also presented that added MIT (a 2005 CNet article) to teach a single-axle hinge or Wehrenberg (Patent 7,688,306) as an alternative disclosure of a modern solid-state accelerometer.

4. Key Claim Construction Positions

  • “accelerometer” (claim 1): Petitioner proposed this term means a device that identifies the direction of acceleration, particularly gravity, to generate orientation information indicating the computer's display mode.
  • “display orientation module that displays content...” (claim 3): Petitioner argued this is a means-plus-function term under §112 ¶6. The stated function is displaying content in various orientations, and the corresponding structure is "a processor programmed with an algorithm."
  • “means for rotating the display component...” (claim 9): Petitioner argued this is also a means-plus-function term. The function is rotating the display component to transition to frame mode, and the corresponding structure is "a hinge assembly."
  • “segmented user interface comprising a plurality of modes of content” (claim 23): Petitioner adopted the Patent Owner's construction from a parent patent's reexamination, meaning "displaying some information that represents a higher-level construct into which content is grouped."

5. Arguments Regarding Discretionary Denial

  • §325(d) (Same or Substantially the Same Art): Petitioner argued against denial, contending that although the primary reference, Lane, was cited in an Information Disclosure Statement (IDS) during prosecution, it was never substantively examined. Petitioner noted Lane was submitted after the Notice of Allowance and was "buried" among over 200 other references. The secondary references (Fujinawa, Santoro, Pröll, etc.) and the specific proposed combinations were never before the examiner.
  • §314(a) (Fintiv Factors): Petitioner argued against discretionary denial under Fintiv, stating that the anticipated Final Written Decision (FWD) date of July 2025 would occur long before the earliest scheduled co-pending district court trial in January 2026. This timeline mitigates concerns of overlapping issues and weighs heavily against denial.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-11, 19-21, and 23-25 of the ’229 patent as unpatentable.