PTAB

IPR2024-01084

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 ’578 patent discloses systems and methods for an electronic device with a touch-sensitive display to manage user interfaces. The technology involves launching an application from a home screen and then, based on a second gesture input, either displaying the application in a multitasking interface or replacing the application's interface with the home screen.

3. Grounds for Unpatentability

Ground 1: Obviousness over Shiplacoff - Claims 1-4, 8-18, 22-30, and 34-39 are obvious over Shiplacoff

  • Prior Art Relied Upon: Shiplacoff (Application # 2010/0095240).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Shiplacoff, which discloses a "card metaphor" for navigating applications on a touch-screen device, teaches every limitation of the challenged claims. Shiplacoff describes launching an application from a home screen into a "full-screen mode." In response to a "swipe up" gesture (the "second input"), the system transitions to a "card mode," where the application's user interface is reduced in size and displayed as a card. Petitioner asserted this maps directly to the claimed feature of displaying the application in a "first virtual display layer" that appears at a lesser depth than a "second virtual display layer" (the background). Shiplacoff further teaches that a user can close a card to return to the home screen using a different command, which Petitioner contended meets the limitation of replacing the application with the home screen when the second input does not meet the criteria for entering the multitasking view (e.g., is not a swipe up).
    • Key Aspects: The core of this ground is that well-known UI concepts for multitasking, such as transitioning an application from a full-screen view to a smaller, layered card view via a swipe gesture, were already disclosed in the art by Shiplacoff.

Ground 2: Obviousness over Shiplacoff in view of Nan - Claims 1-4, 8-18, 22-30, and 34-39 are obvious over Shiplacoff and Nan

  • Prior Art Relied Upon: Shiplacoff (Application # 2010/0095240) and Nan (Patent 9,658,766).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on Ground 1 by arguing Nan provides explicit teachings for gesture parameters that Shiplacoff suggests more generally. Nan discloses using "edge gestures" and processing them based on specific factors like length, speed, and hold time to present a corresponding user interface. Petitioner contended that Nan's disclosure of a "gesture handler" that detects a "drag length" (movement) and "hold time" (duration) renders obvious the claimed "movement threshold" and "duration threshold." Combining Nan's specific gesture processing with Shiplacoff's card-based multitasking interface would result in the claimed invention, where a gesture meeting both movement and duration criteria triggers the multitasking view, while a gesture meeting only the movement criteria (e.g., a flick) returns to the home screen.
    • Motivation to Combine: A POSITA would combine Shiplacoff with Nan to improve the user experience of Shiplacoff’s system. Nan explicitly teaches that its edge gesture system improves UI performance by reducing latency and freeing up "valuable real estate" from on-screen controls. These benefits would have been highly desirable for implementing a seamless and efficient multitasking system like the one described in Shiplacoff.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. Both Shiplacoff and Nan relate to gesture-based UI navigation on touch-screen devices. Incorporating Nan's more sophisticated gesture recognition methods into Shiplacoff's UI framework represented a predictable combination of known elements to achieve an improved, but obvious, system.

4. Arguments Regarding Discretionary Denial

  • Fintiv Factors: Petitioner argued against discretionary denial under §314(a), asserting that the parallel litigation in the Southern District of California is in its earliest stages, with discovery just beginning and no trial date set. Citing the district's median time to trial of 40.2 months and Petitioner's intent to file a motion to stay, it was contended that the PTAB's Final Written Decision would issue long before any potential trial, weighing heavily against denial.
  • Advanced Bionics Factors: Petitioner argued against discretionary denial under §325(d), stating that the key prior art was not substantively considered during prosecution. Shiplacoff was merely listed in an Information Disclosure Statement among hundreds of other references and was never applied by the examiner. Nan was never presented to the Office at all. Petitioner asserted that the examiner committed a material error by allowing the claims based on a misunderstanding of Shiplacoff's disclosure, particularly its clear depiction of a reduced-size application view in its figures, which this IPR seeks to correct with new arguments and combinations.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 8-18, 22-30, and 34-39 of Patent 10,649,578 as unpatentable under 35 U.S.C. §103.