PTAB

IPR2024-01116

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 describes user interface methods for touch screen devices. The claimed invention involves detecting a gesture and, before the gesture is completed, blurring a background object based on a change in the magnitude of the gesture being detected.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ahn and Chaudhri - Claims 2, 27, 186, 187, 189, 191, 192, 197, 199-204, 225, and 230 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 the combination of Ahn and Chaudhri ’842 rendered all challenged claims obvious. Ahn was asserted to teach a mobile device with a touch screen where a user can perform a "touch and drag" gesture, such as a swipe from an edge, to display a menu. Critically, Ahn’s figures illustrated that when such a menu is displayed, a background object (e.g., a clock widget on the standby screen) becomes blurred. However, Ahn did not explicitly detail the mechanism or purpose of this blurring effect.

      Petitioner contended that Chaudhri ’842 supplied the missing details. Chaudhri ’842 taught methods for improving user feedback during transitions between user interface states on a touch screen device. It explicitly described transitioning the "optical intensity" (e.g., transparency, brightness, blur) of user interface objects as a function of a user's progress in completing a gesture. This provided sensory feedback, helping the user understand the effect of their action. Petitioner argued that applying Chaudhri ’842’s teaching of progressively changing an optical property based on gesture magnitude to Ahn's system, which already showed a blur effect, would directly arrive at the claimed invention: blurring an object based on a change in a gesture's magnitude before its completion. For dependent claims, Ahn was argued to teach displaying a menu after a gesture's distance exceeds a threshold (Claim 27) and initiating gestures from the screen's edge (Claim 186). Chaudhri '842's teachings on linear changes in optical intensity mapped to limitations requiring a continuous increase in blurring (Claim 186.d).

    • Motivation to Combine (for §103 grounds): Petitioner presented four primary motivations for a Person of Ordinary Skill in the Art (POSITA) to combine the references. First, a POSITA would combine Chaudhri ’842 with Ahn to provide the specific implementation details for the blurring effect that Ahn illustrated but failed to explain. Second, applying Chaudhri '842's method of providing continuous visual feedback during a gesture was a known technique to improve the usability of Ahn's gesture-based menu system. Third, using effects like blur and transparency to manage "focus and context" (i.e., drawing user attention to the active element) was a well-known UI design principle that Chaudhri '842's techniques would advance in Ahn's interface. Fourth, progressively varying the blur as a function of gesture magnitude was one of a limited number of simple, predictable ways to implement the effect shown in Ahn's figures.

    • Expectation of Success (for §103 grounds): Petitioner argued a POSITA would have had a reasonable expectation of success because combining the references involved applying known UI techniques (progressive feedback from Chaudhri ’842) to a known UI system (gesture-based menus from Ahn) to achieve the predictable result of improved usability and user feedback.

4. Arguments Regarding Discretionary Denial

  • §325(d) (Advanced Bionics): Petitioner argued that discretionary denial under §325(d) would be improper. It was asserted that the primary prior art reference, Ahn, was never cited or considered by the Examiner during prosecution. Furthermore, the specific combination of Ahn and Chaudhri ’842, which directly addresses the feature the Examiner found patentable (blurring based on gesture magnitude), was not previously considered, meaning the Board would be reviewing the combination for the first time.
  • §314(a) (Fintiv): Petitioner argued that the Fintiv factors weighed against discretionary denial. It was noted that the parallel district court litigation was in its infancy, with no invalidity contentions served and discovery just beginning. Petitioner stated its intent to file a motion to stay the litigation. Citing court statistics for the Southern District of California, Petitioner projected a median time to trial of 40.2 months, placing any trial long after the statutory deadline for a Final Written Decision in the IPR.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 2, 27, 186, 187, 189, 191, 192, 197, 199-204, 225, and 230 of the '754 patent as unpatentable.