PTAB

IPR2024-01083

Apple Inc v. Smith Interface Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: GESTURE-EQUIPPED TOUCH SCREEN SYSTEM, METHOD, AND COMPUTER PROGRAM PRODUCT
  • Brief Description: The ’413 patent describes user interfaces for touch-screen devices. The claimed invention relates to invoking menus using gestures that originate from an edge of the display, blurring a portion of the user interface in response to the gesture, and performing different operations based on the duration of a user's contact with a menu item.

3. Grounds for Unpatentability

Ground 1: Obviousness Over Ahn, Chaudhri-842, and Hinkley - Claims 1-3, 7, 9, 10, and 101

  • Prior Art Relied Upon: Ahn (Application # 2008/0207188), Chaudhri-842 (Application # 2007/0150842), and Hinkley (Application # 2011/0209093).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the primary reference, Ahn, discloses the foundational elements of the challenged claims, including an electronic device with a touch screen that displays menus in response to a "touch and drag" gesture originating from an edge of the screen. Ahn further shows blurring a background user interface element (a clock widget) when a menu is opened and teaches that menus can be displayed in a "translucent form," which Petitioner contended implies blurring.
    • To address the limitation of progressively increasing blur as a function of gesture magnitude, Petitioner relied on Chaudhri-842. This reference teaches providing visual feedback during user interface state transitions by changing an object's "optical intensity" (e.g., transparency, blur) in proportion to the user's progress in completing a gesture. Petitioner argued this provides the "how and why" for the progressive blurring claimed in the ’413 patent but only implicitly suggested in Ahn.
    • To meet limitations requiring different operations based on contact duration (e.g., a short tap vs. a long press), Petitioner pointed to Hinkley. Hinkley discloses bezel menus and explicitly teaches distinguishing between a "tap" and a "tap-and-hold" on a menu icon to trigger different actions, such as performing a default function versus opening a secondary radial menu.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine these references for predictable reasons. A POSITA starting with Ahn's edge-swipe menu system would look to Chaudhri-842 to implement the blurring shown by Ahn in a more functional way, specifically to provide a user with intuitive, progressive feedback on their gesture. This was presented as a known technique to improve user experience. Similarly, a POSITA would incorporate Hinkley's teachings to add more sophisticated functionality to Ahn's menus. Using different contact durations (tap vs. tap-and-hold) to trigger distinct operations was argued to be a well-known method for enhancing user interface efficiency without cluttering the screen, making it an obvious modification. The combination was characterized as the application of known UI improvement techniques to a base system to achieve predictable results.
    • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success because the combination involves integrating known, compatible user interface elements to enhance functionality and user feedback in a predictable manner.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under both 35 U.S.C. §325(d) and §314(a).
  • §325(d) (Advanced Bionics): Petitioner contended that the primary prior art reference, Ahn, was never cited by the applicant or considered by the Examiner during prosecution. It was argued that the Examiner allowed the claims based on a material error, mistakenly believing that the progressive blurring features were absent from the prior art, when Ahn and Chaudhri-842 allegedly teach and render them obvious.
  • §314(a) (Fintiv): Petitioner asserted that the Fintiv factors weigh against denial. It was noted that the parallel district court litigation is in its early stages, with no trial date set and significant resources yet to be expended. Petitioner highlighted that the median time to trial in the district is 40.2 months, far exceeding the IPR timeline, and stated its intent to file a motion to stay the litigation.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-3, 7, 9, 10, and 101 of the ’413 patent as unpatentable.