Samsung Electronics Co Ltd v. Keyless Licensing LLC

1. Case Identification

• Case #: IPR2025-00527
• Patent #: 10,976,922
• Filed: February 14, 2025
• Petitioner(s): Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
• Patent Owner(s): Keyless Licensing LLC
• Challenged Claims: 1-21

2. Patent Overview

• Title: System and Method for Using Multiple Applications on a Screen of a Device
• Brief Description: The ’922 patent describes a system for touchscreen devices where an on-screen keyboard can be reduced in size. This reduction makes the screen area previously occupied by the full-sized keyboard available for displaying a second application alongside the first.

3. Grounds for Unpatentability

Ground 1: Claims 1-5, 7, 10-14, and 18-21 are anticipated by or obvious over Goktekin.

• Prior Art Relied Upon: Goktekin (Application # 2013/0234945).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Goktekin disclosed all limitations of the challenged claims. Goktekin taught a mobile device with a first application (e.g., translation) and a full-size on-screen keyboard. Pressing a "camera mode key" on the keyboard activated a second application (a camera/OCR module) and simultaneously displayed its interface along with a reduced-size keyboard in the zone previously occupied by the full keyboard. The first application's interface remained visible, resulting in the simultaneous display of all three interfaces.
  • Motivation to Combine (for §103 grounds): To the extent Goktekin's camera text input module was not considered a formal "application," Petitioner argued it would have been obvious to implement it as such. This was presented as a simple design choice, motivated by the desire to use pre-existing camera/OCR application code to maximize resource efficiency.
  • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success, as implementing camera and OCR functions within a standalone application was a well-known and predictable technique.

Ground 2: Claims 1-5, 7, 10-14, and 18-21 are anticipated by or obvious over Koch.

• Prior Art Relied Upon: Koch (Application # 2012/0113023).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Koch disclosed a system where a user gesture (e.g., a de-pinch or tap on a split key) on a full-size keyboard transformed it into a split keyboard. This action simultaneously activated and displayed a second application interface (for tasks like handwriting, drawing, or text editing) in the "center area" created between the two halves of the split keyboard. The original application interface, the new second application interface, and the reduced (split) keyboard were all displayed simultaneously in the keyboard's original zone.
  • Motivation to Combine (for §103 grounds): Similar to the Goktekin argument, Petitioner contended that if Koch’s "center area" functionality was not considered a formal "application," it would have been an obvious design choice to implement it as one. This would leverage existing application structures for functions like drawing or handwriting recognition.
  • Expectation of Success (for §103 grounds): Success was predictable because implementing such functionalities as discrete applications was a common and straightforward practice in mobile device software design.

Ground 3: Claims 2, 6, and 20 are obvious over Goktekin in view of Sirpal.

• Prior Art Relied Upon: Goktekin (Application # 2013/0234945) and Sirpal (Application # 2012/0110486).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner argued that while Goktekin provided the base system of simultaneously displaying two applications and a reduced keyboard, Sirpal supplied the missing teachings for claims 2, 6, and 20. Sirpal explicitly taught switching input focus between two concurrently displayed applications by tapping on their respective interfaces. It also described detailed copy-and-paste functionality between applications, fulfilling the limitation of claim 6.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Sirpal with Goktekin's multi-application display to improve usability. Sirpal's teachings on focus-switching and inter-application data sharing (copy/paste) directly addressed the needs of a user interacting with the multiple applications disclosed by Goktekin, representing a predictable and advantageous improvement.
  • Expectation of Success (for §103 grounds): The combination involved applying Sirpal's known user interface techniques to Goktekin's similar system, which would have been a simple modification of existing components with a high likelihood of success.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Goktekin in view of Vincent (to add search functionality); Goktekin in view of Vincent and Aravamudan (to add typed keywords to a search); Koch in view of Sirpal (to add copy/paste functionality); and Koch in view of Matthews (to add keyboard-activated search functionality).

4. Key Technical Contentions (Beyond Claim Construction)

• Priority Date Challenge: A central contention of the petition was that the ’922 patent was not entitled to its claimed priority date earlier than December 24, 2013. Petitioner argued that none of the 47 earlier-filed provisional applications provided adequate written description under 35 U.S.C. §112 for key claim elements, including activating a second application via a keyboard condition and the simultaneous display of both application interfaces with a reduced keyboard. This later priority date subjected the patent to AIA provisions and qualified references like Goktekin and Koch as prior art.

5. Arguments Regarding Discretionary Denial

• §314(a) (Fintiv): Petitioner argued against discretionary denial under Fintiv by stipulating that, if IPR is instituted, it will not pursue the same grounds, or any grounds that could have been reasonably raised in the IPR, in the parallel district court litigation.
• §325(d): Petitioner contended that denial under §325(d) was unwarranted because none of the prior art references asserted in the petition were considered, let alone relied upon, by the Examiner during the original prosecution of the ’922 patent.

6. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 1-21 of the ’922 patent as unpatentable.