PTAB

IPR2026-00053

Disney Entertainment & Sports LLC v. Adeia Guides Inc

Title: System and Method for Providing a Graphical User Interface
Brief Description: The ’428 patent describes a computer-implemented system for providing a graphical user interface (GUI) for an application program. The system architecture uses three main components: a "renderer" to display the GUI, a "proxy" that acts as an intermediary, and a "workflow manager" that provides components to the proxy.

Prior Art Relied Upon: Beranek (Patent 6,886,013) and Pleyer (Patent 6,188,401).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Beranek taught the core system of a renderer (a browser) and a client-side proxy that intercepts and dynamically reformats web documents before they are displayed. Beranek’s proxy appears to the browser as a single monolithic program and determines changes required to update the GUI’s layout during execution. Pleyer was asserted to teach the claimed "workflow manager" in the form of its "supervisory application," which communicates document viewers (e.g., HTML files) and UI components (e.g., dialog boxes, controls) via a global script to be rendered.
- Motivation to Combine: A POSITA would combine these teachings to use Pleyer's flexible, script-based method for generating UI components within Beranek’s proxy-based architecture. This combination would enhance Beranek's system by allowing for easier creation and adaptation of new user interfaces, a benefit explicitly taught by Pleyer.
- Expectation of Success: Success was expected because both references addressed the common problem of controlling document presentation on a client browser using well-understood web technologies like proxies, HTML, and scripting languages.

Prior Art Relied Upon: Beranek (Patent 6,886,013), Pleyer (Patent 6,188,401), and Carter (Patent 6,208,336).
Core Argument for this Ground:
- Prior Art Mapping: This ground specifically addressed the limitations in dependent claims 3 and 11 requiring the proxy to enable application components to be modified in a manner "transparent to the renderer." Petitioner argued that while Beranek-Pleyer taught a proxy whose modification activities are hidden from the renderer, Carter taught a system where proxy functionality is transparent in the sense that a user can see and invoke additional features (e.g., adding a spell checker via command classes) through the GUI. Carter's system dynamically constructs the GUI to reflect all available functions, making them visible and selectable by the user via the renderer.
- Motivation to Combine: A POSITA would combine Carter with the Beranek-Pleyer system to provide a consistent and visible user interface for invoking and managing the proxy's underlying modification capabilities. This would increase the system's functionality without burdening the renderer with the implementation details of those features.
- Expectation of Success: Combining Carter's dynamic feature-set configuration with the Beranek-Pleyer architecture was presented as a predictable integration of known software design patterns to improve user interaction.

Prior Art Relied Upon: Ditmer (Patent 6,473,407) and Beranek (Patent 6,886,013).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner asserted that Ditmer disclosed the overall three-tier architecture of the claims: a renderer (client browser/GUI), a proxy (integrated proxy application), and a workflow manager (event monitor server that provides report data). However, Ditmer did not explicitly teach a proxy that determines and executes dynamic changes to the GUI's layout and appearance. Beranek was introduced to supply this missing element, as it explicitly teaches a proxy that reformats HTML documents to dynamically adjust the "look and feel" of the content presented to the user.
- Motivation to Combine: A POSITA would incorporate Beranek’s dynamic formatting proxy into Ditmer's architecture to enhance Ditmer's system. This would allow the data provided by Ditmer’s workflow manager to be presented in a more flexible and tailored format, providing the "enhanced display presentation capability" taught by Beranek.
- Expectation of Success: The combination was argued to be predictable, as both references involve using a proxy to process and format data for display in a client-side browser.

"a renderer to render a graphical user interface (GUI) for an application program" (Claim 9): For the purpose of the IPR, Petitioner applied this term to include software that renders a GUI, such as a DHTML browser, consistent with the patent’s disclosure. This contrasts with Petitioner's litigation position that the term is an indefinite means-plus-function element.
"single monolithic application program" (Claim 9): Petitioner adopted the patent’s description, construing this to mean the proxy appears to the renderer as a single program where all details of its constituent components are hidden from the renderer.
"a workflow manager..." (Claim 9): Petitioner applied this term to software that manages communication between document viewers and UI components and the proxy, consistent with the patent’s description of "workflow manager 216." This again contrasts with a litigation position that the term is an indefinite means-plus-function element.
"...transparent to the renderer" (Claim 11): Petitioner addressed two interpretations. The primary argument in Ground 1 was based on the Patent Owner's interpretation that the renderer is unaware of modifications. An alternative argument, forming the basis of Ground 2, interpreted it to mean the renderer can "see through" the proxy to access additional control options.

Petitioner argued that discretionary denial under 35 U.S.C. §325(d) is unwarranted because the petition raises new arguments and prior art not considered during prosecution. Specifically, Petitioner contended that the Examiner materially erred by listing the Ditmer reference during prosecution but never applying its teachings to the claims.

Petitioner requests institution of an inter partes review and cancellation of claims 1-5 and 9-13 of the ’428 patent as unpatentable.