PTAB

IPR2024-01117

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 discloses methods for interacting with a touch-screen device where a user experience is altered based on touch gestures. The claimed inventions generally relate to detecting gestures and triggering user interface functions, such as blurring background objects or displaying menus, based on the magnitude of those gestures.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Ahn and Chaudhri - Claims 2 and 27 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 a mobile device with a touch screen that displays objects (e.g., a clock widget and icons) and detects a gesture (a "touch and drag" operation) to display a menu from the edge of the screen. Ahn also illustrates that opening this menu blurs the background clock widget. However, Ahn does not explicitly teach varying the amount of blur based on the progress of the gesture. Petitioner contended that Chaudhri ’842 supplies this missing element by teaching the use of changing "optical intensity" (e.g., transparency, brightness, or blur) to provide visual feedback to a user about their progress in completing a gesture. The combination therefore renders obvious claim 2’s limitation of blurring an object based on a change in the magnitude of a gesture. For claim 27, Ahn was alleged to teach displaying a menu when a drag gesture’s distance magnitude increases above a threshold.
    • Motivation to Combine: Petitioner asserted that a person of ordinary skill in the art (POSITA) would combine these references to improve user interface usability. A POSITA implementing the blurred background effect shown in Ahn would naturally look to known techniques, like those in Chaudhri ’842, to provide users with continuous sensory feedback during a gesture. Applying Chaudhri ’842’s teachings on progressive optical intensity changes to Ahn’s system was argued to be a predictable solution to the known problem of enhancing user feedback.
    • Expectation of Success: A POSITA would have had a high expectation of success because the combination involves applying a known user interface feedback technique (from Chaudhri ’842) to a standard mobile device interface (from Ahn) to achieve the predictable result of improved user interaction.

Ground 1B: Obviousness over Ahn, Chaudhri, and Hinkley - Claims 25, 65, 66, 101, 104, 117, and 122 are obvious over Ahn in view of Chaudhri ’842 and Hinkley.

  • 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: This ground adds Hinkley to address limitations in various dependent claims related to gesture duration and multi-functional inputs. Petitioner argued Hinkley teaches using both distance and duration thresholds for gestures to trigger menus (addressing claims 25, 66, and 101). For instance, Hinkley discloses activating a "bezel menu" only after a finger touches the bezel for a predetermined duration (e.g., ½ second). Hinkley also explicitly teaches distinguishing between a short "tap" and a longer "tap-and-hold" on an icon to trigger different actions, such as performing a default function versus displaying a secondary "radial menu." This was argued to render claim 65 obvious. The combination was also alleged to teach displaying menus in virtual layers (claim 104), displaying menus with associated information (claim 117), and ceasing the display of a menu with a "window shade movement" (claim 122).
    • Motivation to Combine: Petitioner contended that a POSITA seeking to enhance the gesture-based interface of the Ahn/Chaudhri ’842 system would be motivated to incorporate Hinkley's teachings. Hinkley provides established solutions for adding more complex and efficient interactions on a touch screen, such as differentiating gestures based on duration. Adding Hinkley's techniques for distinguishing between taps and tap-and-holds would allow for a more robust and feature-rich user interface, a well-known goal in the field.
    • Expectation of Success: A POSITA would expect success in adding Hinkley’s duration-based gesture recognition to the Ahn/Chaudhri ’842 combination. The integration was presented as a predictable combination of known UI elements to create a more capable, yet still intuitive, interface on a mobile device.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate under both 35 U.S.C. §325(d) and §314(a).
  • Advanced Bionics (§325(d)): Petitioner contended that the Examiner committed a material error by allowing the claims without considering the primary prior art reference, Ahn, which was never cited during prosecution.
  • Fintiv (§314(a)): Petitioner argued against denial based on parallel litigation because the district court case is in its infancy, no trial date is set and the median time-to-trial is significantly longer than the IPR timeline, a motion to stay the litigation will be filed, and the merits of the petition are compelling.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 2, 25, 27, 65, 66, 101, 104, 117, and 122 of Patent 10,656,754 as unpatentable.