PTAB

IPR2024-01119

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. The technology involves methods for navigating between different user interface states and displaying various interface elements using gestures, with associated visual feedback like blurring background objects or moving objects at different speeds based on user input.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ahn and Chaudhri-842 - Claim 2 is 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 disclosed a mobile device with a touch screen that displays menus in response to a "touch and drag" gesture. Crucially, Ahn illustrated that opening a menu causes a background object (a clock widget on the standby screen) to become blurred. However, Ahn did not specify how to implement this blurring effect in response to the gesture. Petitioner contended that Chaudhri-842 supplied this missing detail by teaching methods for providing visual feedback during user interface state transitions. Chaudhri-842 disclosed that varying the "optical intensity" of UI objects based on the progress of a user's gesture provides helpful feedback. Petitioner asserted that blurring is a form of changing optical intensity and that the combination of Ahn's blurred widget with Chaudhri-842's gesture-progressive feedback rendered claim 2 obvious.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Chaudhri-842 with Ahn to provide a known solution for a missing implementation detail in Ahn's system. While Ahn showed a blurring effect, Chaudhri-842 explained the benefit and method of linking such an effect to the magnitude of a user's gesture to improve UI feedback. This combination represented the application of a known technique (gesture-based visual feedback) to improve a known system (Ahn's UI), a predictable step for a POSITA.
    • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved integrating conventional UI feedback principles into a standard mobile device interface, both of which were well-understood technologies.

Ground 2: Obviousness over Ahn, Chaudhri-842, and Shiplacoff - Claims 1 and 208-216 are obvious over Ahn and Chaudhri-842 in view of Shiplacoff.

  • Prior Art Relied Upon: Ahn (Application # 2008/0207188), Chaudhri-842 (Application # 2007/0150842), and Shiplacoff (Application # 2010/0095240).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Ahn/Chaudhri-842 combination by adding Shiplacoff's teachings on managing multiple active applications on a mobile device. Shiplacoff disclosed a "card" metaphor for multitasking, where a user could perform a swipe gesture to switch between a full-screen application view and a "card mode" for navigating among active applications. This functionality mapped directly to the dependent claims' limitations regarding multitasking interfaces, home screens, and displaying different virtual layers. For independent claim 1, Petitioner argued Shiplacoff met the limitation of moving a second UI element faster than a first. Shiplacoff described dragging a first card (first element) at the speed of the user's finger, which caused other cards (second elements) to quickly "snap" into place to fill the resulting gap, necessarily moving at a greater speed.
    • Motivation to Combine: A POSITA would be motivated to add Shiplacoff's card-based multitasking system to the Ahn/Chaudhri-842 device to provide a well-established and efficient solution for navigating between multiple applications, a common requirement for mobile devices that Ahn did not detail. Shiplacoff's teachings provided a user interface paradigm that directly addressed multitasking on devices with limited screen space.
    • Expectation of Success: Integrating a known multitasking UI from Shiplacoff into the mobile device framework of Ahn and Chaudhri-842 would have been a predictable and straightforward task for a POSITA, with a high expectation of success.

4. Arguments Regarding Discretionary Denial

  • §325(d) (Advanced Bionics): Petitioner argued against discretionary denial because the primary prior art reference, Ahn, was never cited by the applicant or considered by the Examiner during prosecution. Petitioner asserted that the claims were allowed based on a material error, as the Examiner believed the "blur" feature linked to gesture magnitude was novel, whereas the Ahn and Chaudhri-842 combination explicitly taught and rendered this feature obvious.
  • §314(a) (Fintiv): Petitioner contended that the Fintiv factors weighed against discretionary denial. Key arguments included that the parallel district court litigation was in its very early stages, with no trial date set and a median time-to-trial in the venue (40.2 months) extending far beyond the statutory deadline for a Final Written Decision (FWD). Furthermore, Petitioner stated its intent to file a motion to stay the litigation and emphasized the compelling merits of the invalidity grounds presented in the petition.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1, 2, and 208-216 of Patent 10,656,754 as unpatentable.