PTAB

IPR2024-01085

Apple Inc v. Smith Interface Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Devices, Methods, and Graphical User Interfaces for Manipulating User Interface Objects with Visual and/or Haptic Feedback
  • Brief Description: The ’580 patent describes an apparatus and methods for a touch-based graphical user interface. The system performs a zoom operation on a first layer of content based on user interaction with a second, separate layer of content (e.g., a widget), without performing the zoom operation on the widget itself.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Ramos Paper, Ramos Video, and Ording - Claims 1-4, 6-10, 17, 19, 22-26, 28-30, 32-33, 36, 41, 58-62, 64-65, 67, 69-70, 73, 77, and 82-83 are obvious over the combination of these references.

  • Prior Art Relied Upon: Ramos Paper (a 2005 ACM Symposium publication), Ramos Video (a 2007 YouTube video), and Ording (Application # 2008/0094356).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination teaches all elements of the challenged claims. The Ramos Paper and supplemental Ramos Video disclosed a user interface widget called a "Zlider" for touch-sensitive platforms that allows for fluid zooming and sliding. The Zlider is displayed as a semi-transparent second virtual layer with markings (a "Vernier") over a first virtual layer of content (e.g., an image). User interaction with the Zlider, such as varying touch pressure, adjusted the zoom level of the underlying content without zooming the Zlider widget itself. Ording was cited for providing the foundational hardware context of a portable multifunction device, teaching the necessary components recited in claim 1, such as a touch screen, non-transitory memory, processors, and a camera module. Ording also taught the use of semi-transparent user interface objects, such as a virtual click wheel, reinforcing the implementation of the Zlider as a translucent overlay.
    • Motivation to Combine: A POSITA, seeking to implement the Zlider concept from the Ramos Paper, would have naturally consulted the Ramos Video for a functional demonstration. To implement this software widget on a physical device, a POSITA would have looked to prior art like Ording, which detailed the conventional architecture of portable, touch-screen devices. Combining the Zlider widget with Ording's device was presented as a straightforward integration of a novel user interface element onto a well-known hardware platform to achieve the predictable benefit of precise parameter manipulation on a portable device.
    • Expectation of Success: Petitioner asserted that a POSITA would have had a reasonable expectation of success in making the combination. The references were complementary, with Ramos providing the user interface functionality and Ording providing the standard hardware and operating environment. The integration was argued to require only routine skill.

Ground 1B: Obviousness over Ramos Paper, Ramos Video, Ording, and Hayward - Claim 48 is obvious over the combination of these references.

  • Prior Art Relied Upon: Ramos Paper (a 2005 ACM Symposium publication), Ramos Video (a 2007 YouTube video), Ording (Application # 2008/0094356), and Hayward (Application # 2012/0176401).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination in Ground 1A to address the additional limitations of claim 48, which depends from claims 22 and 23 and recites performing a "lighting operation" based on movement of markings on the widget. Petitioner contended that Hayward taught this missing element by disclosing the use of a logical slider on a touch screen to adjust image parameters, specifically demonstrating an adjustment of image contrast (a lighting operation) based on a user's finger sliding across the screen. The argument was that implementing the Zlider from Ramos as the mechanism to control the contrast adjustment from Hayward within the device context of Ording would render claim 48 obvious.
    • Motivation to Combine: The motivation was to improve the functionality of the base device from Ground 1A. Since the Zlider was designed for "high precision parameter manipulation" and Hayward taught using a slider for precise image parameter manipulation, a POSITA would combine these teachings to use the Zlider widget to control lighting parameters like contrast within the device's camera application. This combination was argued to be a predictable use of known techniques to improve device functionality.
    • Expectation of Success: Petitioner contended that deploying a slider for contrast adjustment was a known technique, and using the Zlider from Ramos for this purpose would be a simple substitution yielding predictable results.

4. Arguments Regarding Discretionary Denial

  • §325(d) (Advanced Bionics): Petitioner argued against discretionary denial under the Advanced Bionics framework, stating that institution was strongly favored. The core prior art references and the specific combinations asserted in the petition were not cited during prosecution, nor did the Examiner substantively consider them. Therefore, Petitioner argued that the grounds were new and compelling.
  • §314(a) (Fintiv): Petitioner argued that the Fintiv factors weighed against discretionary denial. It was asserted that the parallel district court litigation was in its early stages, with no trial date set and significant work remaining before trial. Citing median time-to-trial statistics for the Southern District of California, Petitioner predicted a trial would not occur until late 2027, well after a Final Written Decision would issue in this IPR. Petitioner also stated its intent to file a motion to stay the district court case, further strengthening the argument that the IPR would conclude first.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 6-10, 17, 19, 22-26, 28-30, 32-33, 36, 41, 48, 58-62, 64-65, 67, 69-70, 73, 77, and 82-83 of the ’580 patent as unpatentable.