PTAB

IPR2024-01256

Apple Inc v. Smith Interface Technologies LLC

Key Events
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 ’727 patent discloses methods for manipulating user interface objects on a touch-screen device. The technology involves detecting a user gesture and, in response, modifying the display by moving a first object and applying a visual effect, such as a blur, to a second object based on a "distance magnitude" of the gesture.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ahn and Chaudhri ’842 - Claims 1-6, 10-14, 16, and 17 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 renders the challenged claims obvious. Ahn was asserted to teach a mobile device with a touch screen where a "touch and drag" gesture from an edge displays a menu. Critically, Ahn’s figures illustrate that this action blurs a background object, such as a clock widget, including portions not physically obscured by the new menu. However, Ahn does not describe the mechanics of this blurring effect in detail. Chaudhri ’842 was asserted to remedy this deficiency by teaching methods for providing dynamic visual feedback during user interface state transitions. Specifically, Chaudhri ’842 describes progressively changing the "optical intensity" (e.g., transparency, brightness, blur) of an object as a function of the user's progress in completing a predefined gesture, such as a drag.
    • Petitioner contended that combining these teachings results in the core invention of the ’727 patent. Applying Chaudhri ’842’s progressive feedback method to Ahn’s system would mean progressively increasing the blur on Ahn’s clock widget as the user performs the drag gesture to open the menu. This directly maps to the key limitation of independent claim 1, which requires that "a magnitude of the blur itself, and not a magnitude of an area of the touch screen that is blurred, is increased as a function of an increase in the distance magnitude" of the gesture. The combination teaches progressively blurring a fixed-area object (the clock widget) in response to the gesture’s movement. Dependent claims were argued to be obvious as they recite additional known UI features, such as positioning objects (claim 2, 3), detecting gestures on an object (claim 4), and modifying an object's size or color (claims 11-14), which were all disclosed or suggested by the prior art as simple design choices.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would have been motivated to combine the references to improve the user experience, a shared goal of both documents. A POSITA implementing Ahn's user interface, which shows a blur effect but lacks implementation details, would naturally look to known techniques for providing dynamic user feedback. Chaudhri ’842 provides an explicit solution by teaching how to vary optical intensity based on gesture progress. A POSITA would combine Chaudhri ’842’s teachings with Ahn to provide users with clear, continuous feedback during the gesture, thereby making the interface more intuitive and responsive. This was presented as a predictable application of a known technique to improve a known system.
    • Expectation of Success: A POSITA would have had a high expectation of success in this combination. The integration involved applying well-understood software principles for graphical user interfaces to achieve the predictable result of enhanced visual feedback during a common user interaction (opening a menu with a gesture).

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate under both 35 U.S.C. §325(d) and §314(a).
  • Regarding §325(d), Petitioner asserted that the Advanced Bionics framework favors institution because the Examiner did not substantively consider Ahn, Chaudhri ’842, or their combination during prosecution. Petitioner noted that while the references were cited in an Information Disclosure Statement, the Examiner explicitly cautioned that no factual findings were made regarding the specific content of the numerous documents cited in the IDSs, and thus the arguments presented in the petition were not previously considered and rejected.
  • Regarding §314(a), Petitioner argued that the Fintiv factors weigh strongly against denial. The parallel litigation in the Southern District of California was in its infancy, with no invalidity contentions served and discovery just beginning. Citing the district’s median time-to-trial of over 40 months, Petitioner contended a Final Written Decision (FWD) from the PTAB would issue long before any potential trial. Furthermore, Petitioner stated its intent to file a motion to stay the district court litigation, which, if granted, would further militate against denial.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) of claims 1-6, 10-14, 16, and 17 of the ’727 patent and cancellation of those claims as unpatentable.