Intelligent Protection Management Corp v. Cisco Technology Inc

1. Case Identification

• Case #: IPR2025-01589
• Patent #: 8,941,708
• Filed: October 28, 2025
• Petitioner(s): Intelligent Protection Management Corp.
• Patent Owner(s): Cisco Technology, Inc.
• Challenged Claims: 1-19

2. Patent Overview

• Title: Method, Computer-Readable Storage Medium, and Apparatus for Modifying the Layout Used by a Video Composing Unit to Generate a Composite Video Signal
• Brief Description: The ’708 patent discloses a system for controlling video conferencing layouts. The system allows a user to move an object, such as a slider, along an axis to select from a plurality of predefined video layouts associated with different intervals along that axis.

3. Grounds for Unpatentability

Ground 1: Obviousness over Eleftheriadis and Mahemoff - Claims 1, 4, 5, 9-12, 14, and 16-17 are obvious over Eleftheriadis in view of Mahemoff.

• Prior Art Relied Upon: Eleftheriadis (Patent 8,421,840) and Mahemoff (a 2006 publication titled “Ajax Design Patterns: Creating Web 2.0 Sites with Programming and Usability”).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Eleftheriadis disclosed a video conferencing system with various predefined layouts (e.g., standard, enlarged) that a user could select from a drop-down menu. The system then composes a composite video signal based on the selected layout. Mahemoff was presented as teaching that a discrete slider is a well-known and superior alternative to drop-down menus for selecting a value from a fixed list of choices, as it provides better visual indication and is often faster. Petitioner asserted the combination taught all limitations of independent claims 1, 10, 16, and 17 by replacing Eleftheriadis's drop-down menu with Mahemoff's discrete slider.
  • Motivation to Combine: A POSITA would combine these references to improve the user interface of Eleftheriadis. Mahemoff expressly stated the advantages of using a slider over selectors (like drop-down menus), providing a clear reason to replace the less efficient UI element in Eleftheriadis with the more intuitive and visually informative slider from Mahemoff.
  • Expectation of Success: A POSITA would have had a high expectation of success because replacing one known UI control (a menu) with another (a slider) was a routine design choice involving known programming techniques.

Ground 2: Obviousness over Eleftheriadis, Mahemoff, and Koski - Claims 1-12, 14, and 16-19 are obvious over Eleftheriadis and Mahemoff, further in view of Koski.

• Prior Art Relied Upon: Eleftheriadis (Patent 8,421,840), Mahemoff (a 2006 publication), and Koski (Application # 2009/0015568).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground built upon the combination in Ground 1. Petitioner introduced Koski to teach more sophisticated slider functionality, specifically the use of "slider detents" to organize a slider's axis into distinct zones or categories, each with its own set of discrete options. This teaching was mapped to the limitations of dependent claims that recite associating variations of layouts with sub-intervals and providing relationships between positions within an interval and the frame layout (e.g., claims 2, 3, 6-8, and 19).
  • Motivation to Combine: A POSITA, having already been motivated to use a slider, would look to Koski to further enhance its functionality. Koski's method of organizing slider options into logical categories (e.g., a "standard mode" category and an "enlarged mode" category) would be an obvious way to manage and present the different layout options from Eleftheriadis, improving usability.
  • Expectation of Success: The combination was asserted to be a predictable integration of known UI features to achieve a more organized and user-friendly control.

Ground 3: Obviousness over Kikuchi and Eleftheriadis - Claims 1, 4, 5, and 9-17 are obvious over Kikuchi in view of Eleftheriadis.

• Prior Art Relied Upon: Kikuchi (Application # 2010/0302130) and Eleftheriadis (Patent 8,421,840).

• Core Argument for this Ground:

  • Prior Art Mapping: Petitioner asserted that Kikuchi, as the primary reference, taught the core invention: an image display system using a draggable slider to transition between various predefined layouts (e.g., single, dual, quad screen) associated with different intervals along the slider's axis. Eleftheriadis was added to supply the specific context of applying this slider control mechanism to a multi-stream video conferencing environment, which Kikuchi did not explicitly disclose.
  • Motivation to Combine: A POSITA would be motivated to apply the intuitive slider-based layout control system taught by Kikuchi to the video conferencing system of Eleftheriadis. This would allow remote users in a conference to benefit from Kikuchi's user-friendly display controls. Petitioner argued this was a natural step, as video is conceptually a rapid sequence of images.
  • Expectation of Success: Success would be reasonably expected, as the combination involved applying a known GUI from an image display system to the analogous field of video display, which was a mature technology.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Eleftheriadis, Mahemoff, and Kikuchi (Ground 3), and Kikuchi, Eleftheriadis, and Koski (Ground 5), which relied on similar motivations and mappings as the grounds detailed above.

4. Key Claim Construction Positions

• For the purposes of the IPR, Petitioner proposed a construction for the phrase "based on the relationship and the position" in claim 9. Petitioner interpreted this phrase to refer to a relationship between the slider's intervals and their associated layouts, and the detected position of the slider handle on the axis.

5. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial is unwarranted. It stated its intent to utilize the new bifurcated briefing process, per the Director's March 26, 2025 memorandum, to address any arguments for discretionary denial under §325(d) or other factors that the Patent Owner may raise.

6. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-19 of the ’708 patent as unpatentable.