Samsung Electronics Co Ltd v. Hermes IP Management LLC

1. Case Identification

• Case #: IPR2025-00872
• Patent #: 8,855,720
• Filed: April 22, 2025
• Petitioner(s): Samsung Electronics Co., Ltd., and Samsung Electronics America, Inc.
• Patent Owner(s): Hermes IP Management LLC
• Challenged Claims: 1-16

2. Patent Overview

• Title: Setting Idle Screen in Mobile Terminal
• Brief Description: The ’720 patent discloses methods and systems for managing a plurality of customizable screens on a mobile terminal in an idle state. The technology allows a user to select application programs, allocate them as shortcut icons to different screens, and navigate between these screens to set a desired idle screen.

3. Grounds for Unpatentability

Ground 1: Claims 1-16 are obvious over Hawkins in view of Majava

• Prior Art Relied Upon: Hawkins (Patent 7,231,229) and Majava (Application # 2006/0236266).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Hawkins teaches the core features of the challenged claims, including a mobile device user interface with a plurality of screens (called "pages" or "banks") containing user-assignable "favorites buttons" that function as shortcut icons for launching applications. Hawkins also discloses indicators corresponding to the plurality of screens and allows a user to navigate between them. Petitioner contended that Majava supplements Hawkins by teaching the concept of setting a "default" idle page and, for security reasons, automatically reverting to that default page after a period of idle time. The combination of Hawkins's multi-page, customizable shortcut interface with Majava's concept of setting and reverting to a default idle screen renders the claimed invention obvious.
  • Motivation to Combine: A POSITA would combine Hawkins and Majava to enhance the user experience and security of the Hawkins interface. Petitioner asserted that a user of the Hawkins device could leave an application displaying sensitive personal information (e.g., email) open on the screen. A POSITA would be motivated to incorporate Majava's teaching of reverting to a default home screen after a period of inactivity to reduce the risk of accidentally exposing such information, a known problem with a known solution.
  • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination. Hawkins already provided the necessary framework of multiple, re-arrangeable pages. Implementing Majava’s known technique of timing out and reverting to a designated default page would have been a straightforward modification for a person of ordinary skill, yielding the predictable result of enhanced privacy.

Ground 2: Claims 7, 12, and 16 are obvious over Hawkins in view of Majava and Nielsen

• Prior Art Relied Upon: Hawkins (Patent 7,231,229), Majava (Application # 2006/0236266), and Nielsen (Application # 2007/0094596).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was presented as an alternative for claims requiring that the "order of the screens is usable in a circular manner." Petitioner argued that the base combination of Hawkins and Majava provides the multi-page idle screen system. The incremental teaching is supplied by Nielsen, which discloses a mobile interface with multiple "glance module" screens that are "serially accessible." Nielsen explicitly teaches that the display would "serially cycle" through the screens, meaning navigating forward from the last screen returns the user to the first screen, and vice versa.
  • Motivation to Combine: A POSITA would be motivated to add Nielsen's circular navigation to the Hawkins/Majava interface to make screen navigation faster and more efficient. This modification would directly further Hawkins' stated goal of providing "easy access" to features and applications by eliminating the need for the user to reverse direction after reaching the last or first screen in a sequence.
  • Expectation of Success: A POSITA would have a high expectation of success because the Hawkins interface already included multi-directional (left/right, up/down) screen navigation. Implementing Nielsen's well-understood technique for serially cycling in a loop would amount to adding a known feature to an existing, compatible system, which would have been well within the capabilities of a POSITA.

4. Key Claim Construction Positions

• Petitioner asserted that no express claim constructions are necessary and that the claim terms should be given their plain and ordinary meaning. However, Petitioner dedicated significant argument to establishing the contemporary understanding of "idle screen" and "idle state" at the time of the invention.
• Petitioner argued that, based on the prosecution history of the ’720 patent and other prior art, a POSITA would have understood "idle state" to mean a condition where a device is powered on and displaying a screen but is not actively being used for a specific application. An "idle screen" would be the screen displayed in that state, serving as a starting point for using various applications.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §325(d) is inappropriate because none of the prior art references presented in the petition were previously considered by the USPTO during prosecution.
• Regarding potential denial under 35 U.S.C. §314(a) and the Fintiv factors, Petitioner noted a co-pending district court case but reserved the right to substantively oppose any brief on discretionary denial filed by the Patent Owner, consistent with PTAB guidance.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-16 of Patent 8,855,720 as unpatentable under 35 U.S.C. §103.