Apple Inc v. CText IP LLC

1. Case Identification

• Case #: IPR2025-01112
• Patent #: 9,246,857
• Filed: July 7, 2025
• Petitioner(s): Apple Inc.
• Patent Owner(s): Ctext IP LLC
• Challenged Claims: 1-18

2. Patent Overview

• Title: Correlating Conversations in a Messaging Environment
• Brief Description: The ’857 patent discloses methods and systems for managing multiple, intertwined conversations within a single messaging interface. The technology uses visual cues, such as distinct background colors, to associate messages with specific conversations and focuses on modifying a visual element of the message entry location to match the visual cue of the currently selected "active" conversation.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 5-9, and 13-17 are obvious over Chang.

• Prior Art Relied Upon: Chang (Patent 9,130,893).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Chang, a single prior art reference, discloses every limitation of the challenged claims. Chang describes a mobile messaging application that displays multiple conversations (e.g., a "group chat area" and a "private chat area") within a single "chat window." To solve the problem of users losing track of conversations, Chang teaches using different visual elements, such as distinct background colors, to distinguish between the different chat areas. Critically, Petitioner asserted that Chang discloses the key limitation added during prosecution of the ’857 patent: upon a user selecting a conversation (e.g., by tapping the private chat area), Chang’s system changes a visual element (the background color) of the message input window to match the visual cue (the background color) of the newly active conversation.
  • Motivation to Combine (for §103 grounds): Not applicable as this ground is based on a single reference. Petitioner contended that a person of ordinary skill in the art (POSITA) would have recognized that Chang’s teachings render the claims obvious.
  • Expectation of Success (for §103 grounds): Not applicable.

Ground 2: Claims 10-12 and 18 are obvious over Chang, Oh, and Stochosky.

• Prior Art Relied Upon: Chang (Patent 9,130,893), Oh (Application # 2014/0143684), and Stochosky (Patent 9,965,132).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Chang provides the foundational messaging system with visually distinct conversations. Oh is added to address limitations related to multi-user interactions across different devices, as it teaches sending "link information" between mobile terminals so that a recipient on a second device can also see the correlation between messages. Stochosky is added for its teachings on user customization, disclosing a messaging component that allows users to control the visual characteristics (e.g., text style, bubble color) of messages displayed on their device, which maps to claims concerning user preferences defining visual cues.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Chang with Oh to improve the messaging system by ensuring all participants in a conversation, not just the sender, could visually distinguish between different threads. This addresses a known problem of confusion in group chats. A POSITA would further incorporate Stochosky's teachings to enhance user experience by allowing each user to define their own preferred visual styles for incoming and outgoing messages, rather than being forced to use a sender-defined or system-defined format.
  • Expectation of Success (for §103 grounds): Petitioner asserted a high expectation of success, as the references all operate in the same technical field of mobile messaging and address related problems. Combining their known techniques—visual organization, data transmission for synchronization, and user interface customization—would have been a predictable implementation for a POSITA.

Ground 3: Claims 1-2, 4-5, and 15-16 are obvious over Oh.

• Prior Art Relied Upon: Oh (Application # 2014/0143684).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was presented as an alternative based on a broader claim construction allegedly asserted by the Patent Owner in co-pending litigation. Petitioner argued that if "changing a visual element of the message entry location" is construed broadly to include changing display text (e.g., from "iMessage" to "Reply") or displaying a linking line, then Oh alone renders the claims obvious. Oh discloses a system where user selection of a prior message to reply to triggers the display of "context-linking items," such as a line connecting the old message to the new one or displaying the recipient's name in the text entry field.
  • Motivation to Combine (for §103 grounds): Not applicable as this ground is based on a single reference.
  • Expectation of Success (for §103 grounds): Not applicable.

4. Key Claim Construction Positions

• Petitioner stated that for its primary arguments, no specific claim constructions are required.
• However, for Ground 3, Petitioner relied on a broader construction of the claim phrase "changing a visual element of the message entry location upon receipt of the first indication to match a first visual cue" which it contended the Patent Owner asserted in parallel litigation. This broader construction would cover non-identical but related visual changes, such as displaying a recipient's name in a text box in response to a user selecting that recipient's message, which Petitioner argued is disclosed by Oh.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial would be improper. It asserted that denial under General Plastic is unwarranted as this is the first petition filed against the ’857 patent.
• Denial under §325(d) (Advanced Bionics) was argued to be inappropriate because none of the asserted prior art references (Chang, Oh, Stochosky) or the proposed combinations were presented to or considered by the USPTO during the original prosecution.
• Petitioner contended that the Fintiv factors strongly favor institution, as the parallel district court litigation is in its earliest stages, with no scheduling order entered, no trial date set, and no discovery or claim construction proceedings having commenced.

6. Relief Requested

• Petitioner requests the institution of an inter partes review (IPR) and the cancellation of claims 1-18 of Patent 9,246,857 as unpatentable.