PTAB

IPR2024-01043

Amazon.com Inc v. Nokia Technologies Oy

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: User Interfaces for Device State Transition
  • Brief Description: The ’741 patent relates to user interfaces for electronic devices, specifically allowing a user to interact with an application to determine its state, function, or utility while the device remains in a locked mode, without fully activating the application.

3. Grounds for Unpatentability

Ground 1: Claims 1-20 are obvious over Hassan in view of Nirhamo

  • Prior Art Relied Upon: Hassan (Application # 2007/0180492) and Nirhamo (Application # 2006/0246955).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Hassan taught the core limitations of independent claims 1, 11, and 17. Hassan disclosed a mobile device with a "locked state" that prevents normal access but allows limited interaction with permitted applications. In this state, Hassan’s device displayed icons for applications (e.g., email) or for functions within an application (e.g., reply, forward). A user could select these icons to initiate a task without fully unlocking the device, thereby determining the application's function or utility (i.e., whether a task was permitted) without its full activation. Petitioner asserted that Nirhamo, which is also directed to user interfaces for portable devices, supplied the additional features recited in the dependent claims. Specifically, Nirhamo taught common UI functionalities such as highlighting a selected object to provide user feedback, dimming unavailable or incompatible icons to indicate their status, and using a touchscreen for user input.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Nirhamo's conventional UI features with Hassan’s locked-mode system to create a more intuitive and user-friendly interface. Providing visual feedback like highlighting selected icons and dimming unavailable ones were common design principles to improve usability. Similarly, incorporating a touchscreen was a known and predictable method for improving mobile devices like the one disclosed in Hassan.
    • Expectation of Success: A POSITA would have had a high expectation of success in this combination. The integration involved applying standard, well-understood UI elements (highlighting, dimming, touchscreens) to a known system, which would yield predictable results without changing the fundamental operation of either reference.

Ground 2: Claims 1-20 are obvious over Becker in view of Nirhamo

  • Prior Art Relied Upon: Becker (Patent 7,689,939) and Nirhamo (Application # 2006/0246955).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Becker independently taught the limitations of the independent claims. Becker disclosed a personal computer that enters a "screen saver" mode, which Petitioner equated to the claimed "locked mode." While in this mode, Becker allowed limited user interaction with a softphone application to handle incoming calls. The system displayed a graphical user interface (GUI) with selectable button objects (e.g., "Answer," "Hold") that the user could interact with to determine the function of the application without disabling the screen saver. This interaction did not fully activate the application, as only a restricted set of features was available. As in Ground 1, Petitioner relied on Nirhamo to teach the additional UI features of the dependent claims, such as highlighting, dimming, and touchscreen interaction.
    • Motivation to Combine: The motivation to combine Becker and Nirhamo was parallel to that for the Hassan combination. A POSITA would have been motivated to apply Nirhamo's common UI improvements to the system in Becker. For example, highlighting the "Answer" button upon selection would provide essential feedback, and integrating a touchscreen was a known technique to improve user interaction with computer applications.
    • Expectation of Success: Success was predictable because the combination involved applying routine UI enhancements to Becker's screen saver interface. The result was simply a more modern and intuitive version of Becker's system, achieved through the use of known techniques to produce predictable outcomes.

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on Hassan alone (for claims 1, 5-7, 10-11, 15, 17, and 19) and Becker alone (for the same subset of claims), arguing these references inherently taught or suggested the claimed subject matter without combination.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under Fintiv is not warranted. The parallel district court litigation was initiated recently (late 2023), and no trial schedule has been set, making it highly likely that a Final Written Decision (FWD) in this IPR would issue well before any potential trial. Petitioner also contended that denial under 35 U.S.C. §325(d) is inappropriate because none of the asserted prior art references were cited or considered during the original prosecution of the ’741 patent.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of the ’741 patent as unpatentable under 35 U.S.C. §103.