Vizio Inc v. Multimedia Technologies Pte Ltd

1. Case Identification

• Case #: IPR2024-00722
• Patent #: 9,232,168
• Filed: March 22, 2024
• Petitioner(s): Vizio, Inc.
• Patent Owner(s): Multimedia Technologies Pte. Ltd.
• Challenged Claims: 1-7, 10-15

2. Patent Overview

• Title: Systems and Methods for Providing User Interfaces in an Intelligent Television
• Brief Description: The ’168 patent discloses methods and systems for an intelligent television user interface that adapts its navigation elements. The system determines if a second user interface, triggered by a user selection, has enough space to contain a navigation bar and renders different interface elements (e.g., a horizontal bar vs. a different device like a vertical bar) based on this determination.

3. Grounds for Unpatentability

Ground 1: Claims 1-7 and 10-15 are obvious over Lider in view of the knowledge of a POSITA.

• Prior Art Relied Upon: Lider (Patent 9,158,440)
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Lider disclosed all limitations of the challenged claims. Lider taught a method for displaying information areas (e.g., toolbars) in a graphical user interface (GUI) on a device that can be a television. Lider’s method involved determining the current size of the view and using predetermined size thresholds to decide the maximum number of horizontal or vertical toolbars that could be displayed. For example, if the view size was below a certain pixel threshold, a maximum of one horizontal toolbar could be displayed. Petitioner contended this directly taught the core concept of the ’168 patent: determining if a user interface can contain a navigation bar and rendering it accordingly. If the view could not contain a second horizontal toolbar (because it was below a size threshold), Lider taught displaying a different user interface device, such as a vertical toolbar or a reduced-form display object, which Petitioner argued met the claim limitations.
  • Motivation to Combine (with POSITA knowledge): Petitioner asserted that a Person of Ordinary Skill in the Art (POSITA) would have been motivated to apply Lider's teachings to solve the predictable problem of fitting user interface elements within a limited display area on an intelligent television. Rendering a different, known UI element (like a vertical toolbar) when a primary element (like a second horizontal toolbar) does not fit was presented as a simple substitution of known elements for a predictable result, guided by common sense.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success in implementing these changes because Lider explicitly taught how to display various UI elements (horizontal toolbars, vertical toolbars, windows, panels) and how to use size thresholds to determine which elements could be displayed within a given view.

Ground 2: Claims 1-7 and 10-15 are obvious over Lider in view of Eibl.

• Prior Art Relied Upon: Lider (Patent 9,158,440), Eibl (Application # 2009/0222771)
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the teachings of Lider as the base system for an adaptable GUI on an intelligent television. Petitioner argued that to the extent Lider did not explicitly teach drop-down menus (a feature of dependent claims 7 and 14), Eibl supplied this element. Eibl disclosed an adaptable GUI with various dialogs, explicitly teaching and illustrating multiple types of drop-down menus that present a list of selectable options when activated by a user. The combination, therefore, taught an intelligent television system (Lider) that determines whether to display a horizontal bar, a vertical bar, or a drop-down menu (Eibl) based on context or need.
  • Motivation to Combine: Petitioner argued a POSITA would combine Lider and Eibl to improve the user experience and information density of Lider’s GUI. Lider taught using "other types of information areas besides toolbars," providing an express motivation to incorporate different UI elements. Eibl provided a well-known, space-efficient UI element—the drop-down menu—that would be a natural and logical addition to Lider's system. The combination was presented as the simple substitution of one known UI element (Eibl's drop-down menu) for another (Lider's toolbars) to achieve the predictable result of a more efficient use of display space.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because combining these known GUI elements was a straightforward application of established design principles. Eibl’s teachings on adaptable drop-down menus were directly applicable to Lider’s GUI framework, and implementing them would yield the predictable benefit of improved space efficiency.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under Fintiv would be inappropriate because no motion to stay had been filed in the parallel district court litigation, the litigation was in an early stage, and Petitioner stipulated it would not pursue the same grounds in court. Petitioner also asserted that the petition presented compelling evidence of unpatentability, which should preclude a Fintiv denial.
• Petitioner further argued that denial under §325(d) was not warranted because the challenges presented were not cumulative to the art considered during the original prosecution of the ’168 patent.

5. Relief Requested

• Petitioner requested the institution of an inter partes review and the cancellation of claims 1-7 and 10-15 of the ’168 patent as unpatentable under 35 U.S.C. §103.