PTAB

IPR2024-01114

Apple Inc v. Smith Interface Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: DEVICES AND METHODS FOR NAVIGATING BETWEEN USER INTERFACES
  • Brief Description: The ’754 patent relates to user interfaces for touch-screen devices. It discloses methods where a user interaction, such as a continuous gesture, can trigger graphical user interface changes, including progressively blurring background objects based on a change in the magnitude of the detected gesture.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ahn and Chaudhri - Claims 2, 27-30, 32-36, 38, 40, 42-44, 46, 47, 52, 54, 57, and 59 are obvious over Ahn in view of Chaudhri ’842.

  • Prior Art Relied Upon: Ahn (Application # 2008/0207188) and Chaudhri ’842 (Application # 2007/0150842).
  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Ahn discloses the fundamental system challenged in independent claim 2: a mobile communication terminal with a touch screen, memory, and processor that displays objects (e.g., a clock widget and icons on a standby screen) and detects a gesture. Specifically, Ahn teaches that a "touch and drag operation" initiated at an edge of the screen can display a menu. Critically, Ahn’s figures illustrate that when a menu is opened, a background object (the clock widget) becomes blurred. However, Ahn fails to describe the purpose of this blurring or teach that its intensity should vary based on the progression of the gesture.

      Petitioner contended that Chaudhri ’842 supplies this missing teaching. Chaudhri ’842 addresses providing visual feedback during transitions between user interface states. It explicitly teaches varying the "optical intensity" of user-interface objects—which includes blur, transparency, and brightness—as a continuous function of a user's progress in completing a predefined gesture. Petitioner argued that combining these references renders the key limitation of the ’754 patent obvious: blurring an object "based on a change in a magnitude of the gesture." A person of ordinary skill in the art (POSITA) would have understood Ahn’s menu-opening gesture as a transition between UI states and would have applied Chaudhri ’842’s teachings to progressively blur Ahn's background clock widget as the user performs the drag gesture, thereby providing continuous visual feedback.

    • Motivation to Combine: Petitioner asserted several motivations for a POSITA to combine the teachings of Ahn and Chaudhri ’842.

      • A POSITA would combine the references because Chaudhri ’842 provides the exact implementation details and rationale for the blurring effect that Ahn illustrates but leaves unexplained.
      • A POSITA would combine the references to improve the usability of Ahn’s interface. Applying Chaudhri ’842’s technique for providing continuous feedback on gesture progress would make Ahn's menu system more intuitive.
      • The combination reflects the application of a known design principle ("focus and context"), where blurring de-emphasizes background elements to focus the user's attention on a newly active foreground element, such as the menu in Ahn.
      • Varying the blur progressively as a function of gesture magnitude would have been one of a limited number of predictable design choices for implementing the blurring effect shown in Ahn.

    • Expectation of Success: Petitioner argued a POSITA would have had a high expectation of success. The combination involves applying a known technique for providing visual feedback (Chaudhri ’842) to a known gesture-based interface (Ahn) to achieve the predictable result of improved usability and user feedback, without requiring any modification to the underlying systems.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate under both 35 U.S.C. §325(d) and §314(a).
  • §325(d) (Advanced Bionics): Petitioner asserted that institution is strongly favored because the primary prior art reference, Ahn, was never cited by the applicant or considered by the examiner during prosecution. Therefore, the specific combination of Ahn and Chaudhri ’842 was not before the U.S. Patent and Trademark Office, and the claims were allowed based on a material error regarding the patentability of features that were, in fact, well-known.
  • §314(a) (Fintiv): Petitioner contended that the Fintiv factors weigh heavily against denial. The parallel district court litigation is in its earliest stages, with no trial date set and discovery in its infancy. Citing district court statistics, Petitioner argued that the median time to trial (40.2 months) is significantly longer than the statutory deadline for a Final Written Decision (FWD), making it highly likely the IPR would conclude before a trial. Furthermore, Petitioner stated its intent to file a motion to stay the litigation, and argued the compelling merits of the petition favor institution.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 2, 27-30, 32-36, 38, 40, 42-44, 46, 47, 52, 54, 57, and 59 of Patent 10,656,754 as unpatentable.