- Apple Inc. v. Smith Interface Technologies, LLCNo claims unpatentablePTAB · Dec 31, 2025 · IPR2024-01085 · APJ Jameson Lee · IPR · Final written decision
Claims 1–4, 6–10, 17, 19, 22–26, 28–30, 32, 33, 36, 41, 48, 58–62, 64, 65, 67, 69, 70, 73, 77, 82, and 83 were not shown unpatentable under either § 103 ground.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedOther
“The difference between the parties’ positions is solely that Petitioner includes “human-computer interaction” as a relevant degree and “human computer interfaces” as relevant working experience. We need not resolve that difference, because no matter which stated level of ordinary skill is applied, all of our findings and conclusions would be the same and because neither party asserts the other party’s expert is not qualified as an expert. In the Decision on Institution, we adopted Petitioner’s stated level of ordinary skill in the art. Inst. Dec. 9. We continue to adopt Petitioner’s stated level of ordinary skill in the art.5 C.” slip op. at 8
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededOther
“Only those claim terms that are in controversy need to be construed, and only to the extent necessary to resolve the controversy. Realtime Data, LLC v. Iancu, 912 F.3d 1368, 1375 (Fed. Cir. 2019) (“The Board is required to construe ‘only those terms . . . that are in controversy, and only to the extent necessary to resolve the controversy.’” (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999))). Petitioner asserts that “no claim terms need be construed to resolve issues of controversy in the present Petition.” Pet. 2. Patent Owner agrees that “no formal constructions of any claim terms are necessary.” PO Resp. 4. We agree with the parties that no express construction of any claim term is necessary. D.” slip op. at 10
- Expert testimonyPatent owner expert creditedDecided for patent owner
“We agree with Patent Owner (PO Resp. 13) that when Ording refers to user interfaces that are “intuitive and transparent,” “transparent” in that context does not mean optically transparent but something readily understandable, like the preceding word “intuitive.” That makes more sense in context. Patent Owner’s expert, Dr. Mahon, explains that Ording’s paragraph 28, where the phrase “intuitive and transparent” is found, is not concerned with optical transparency, but with increasing user satisfaction with portable devices by offering multifunctional operations on user interfaces based on finger input. Ex. 2012 ¶ 54. Neither Petitioner nor Dr. Cockburn explains why “transparent” in that context should mean optically transparent. We credit the testimony of Dr. Mahon, and reproduce paragraph 28 of Ording below: The various applications that may be executed on the device may use at least one common physical user interface device, such as the touch screen. One or more functions of the touch screen as well as corresponding information displayed on the device may be adjusted and/or varied from one application to the next and/or within a respective application. In this way, a common physical architecture (such as the touch screen) of the device may support the variety of applications with user interfaces that are intuitive and transparent. Ex. 1006 ¶ 28. We credit Dr. Mahon’s testimony that “Ording is addressing [in paragraph 28] user interfaces that are user-friendly and intuitive to navigate and operate.” Ex. 2012 ¶ 55.” slip op. at 33
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation not foundNot shown unpatentableNot shown unpatentable
“The Zlider widget already is the least intrusive in the form as disclosed in the Ramos Paper/Ramos Video, placed off to the side of image content, not above and overlapping with image content. Petitioner’s semitransparency solution is for a self-created problem that otherwise does not exist, i.e., blocking the image by placing the Zlider widget directly over image content in Ording’s device. This is not reasoning with rational underpinning for making the Zlider widget partially semitransparent. Even assuming that the Zlider widget is properly placed directly over a camera image, making the Zlider widget semitransparent does not solve the intrusion problem, because the image and the Zlider widget may obscure each other, as shown in these illustrations provided by Patent Owner: [The illustrations show interference between a semitransparent Zlider widget and an underlying image] In its Reply, Petitioner asserts that it would have been well within the skill level of one of ordinary skill in the art to make adjustments to address a problem caused by such obscuring, such as by making the Zlider widget more visible as shown below: [The illustration shows one way Petitioner asserts one of ordinary skill in the art may apply to solve the obscuring issue (Reply 5–6)] Petitioner’s argument is misplaced. Although there may be graphic display techniques one of ordinary skill in the art may adopt to reduce the visibility problem if the Zlider widget were moved to directly above the image content as Petitioner proposes, that does not cure the problem of lacking a reasonable motivation to place the Zlider widget of the Ramos Paper/Ramos Video directly over image content. Still, there is the least obscuring and the least intrusion with the Zlider widget remaining where it is shown to be in the Ramos Paper/Ramos Video, side-by-side relative to the image content. It is irrational to make a modification that creates a problem, solely on the basis that a solution may be available to reduce the severity of the problem. Indeed, such a strained rationale shows that hindsight has played a part on Petitioner’s contention that a person of ordinary skill in the art would have put the Zlider widget over content as required by the claims.” slip op. at 30
Patent outcomesUS 10,649,580 not shown unpatentableClaim construction§ 103 obviousnesscites Phillips · KSR · GrahamPatents in suitUS 10,649,580 - Luxottica Of America Inc. v. E-Vision Smart Optics, Inc.All claims unpatentablePTAB · Dec 30, 2025 · IPR2024-01072 · APJ John D Hamann · IPR · Final written decision
Claims 1–26 are unpatentable as obvious over the listed prior-art combinations; the Board also denied Patent Owner’s motion to strike.
RulingsFinal written decision- Skill levelSkill level petitioner adoptedDecided for petitioner
“In our Decision on Institution, we adopted the definition Petitioner proposes for one having ordinary skill in the art at the time of the invention of the ’960 patent. Dec. on Inst. 10. Namely, we found that one of ordinary skill in the art “would have had at least a bachelor’s degree in mechanical or manufacturing engineering; mechatronics; electrical engineering plus coursework in mechanical engineering, manufacturing engineering, or mechatronics; or a similar technical degree,” and “at least 2 years of experience designing eyewear and/or consumer electronics,” and that “[w]ork experience could substitute for formal education and additional formal education could substitute for work experience.” Id. (citing Pet. 10–11 (citing Ex. 1003 ¶ 28)) (alteration in original). Patent Owner proposes a different definition for one of ordinary skill in the art, but does not specifically address any deficiencies in Petitioner’s proposed definition. PO Resp. 6. Because Petitioner’s definition of the level of skill in the art is consistent with the ’960 patent and the asserted prior art, we maintain it for purposes of this Final Written Decision. See Okajima v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001); In re GPAC, 57 F.3d at 1579; In re Oelrich, 579 F.2d 86, 91 (CCPA 1978). Our analysis herein, however, does not turn on which of the parties’ definitions we adopt.” slip op. at 8
- Claim Construction › Threshold & procedure › Whether a term needs construction (O2 Micro)No construction neededPlain and ordinary meaningOther
“Here, neither party sets forth any term for claim construction. Pet. 11; PO Resp. 5–6; Pet. Reply 1–2. We determine that we do not need to construe any term to resolve the disputes between the parties. Nidec Motor Corp. v. Zhongshan Broad Ocean Motor Co., 868 F.3d 1013, 1017 (Fed. Cir. 2017) (quoting Vivid Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999)) (“[W]e need only construe terms ‘that are in controversy, and only to the extent necessary to resolve the controversy.’”). We afford the claim terms their plain and ordinary meaning.” slip op. at 9
- Obviousness (§103) › Analogous artAnalogous artDecided for petitioner
“A reference qualifies as prior art for a determination under § 103 when it is analogous to the claimed invention. In re Clay, 966 F.2d 656, 658 (Fed. Cir. 1992). “Two separate tests define the scope of analogous prior art: (1) whether the art is from the same field of endeavor, regardless of the problem addressed, and (2) if the reference is not within the field of the particular problem with which the inventor is involved.” In re Bigio, 381 F.3d 1320, 1325 (Fed. Cir. 2004) (citing In re Deminski, 796 F.2d 436, 442 (Fed. Cir. 1986)). Below we focus on the first of these tests. “We determine the field of endeavor ‘by reference to explanations of the invention’s subject matter in the patent application, including the embodiments, function, and structure of the claimed invention.’” Netflix, Inc. v. DIVX, LLC, 80 F.4th 1352, 1359 (Fed. Cir. 2023) (quoting In re Bigio, 381 F.3d at 1325)). We agree with Petitioner and find that the ’960 patent is in the field of eyewear and consumer electronics. Pet. 13. The ’960 patent discloses that its “subject matter is directed to electronic eyewear modules and systems to be worn by a wearer, whereby an electronic eyewear system with a docking station can be easily joined with a plurality of electronic application modules.” Ex. 1001, 1:66–2:4; Pet. 9. We also agree with Petitioner that the ’960 patent acknowledges “a need for a single pair of fashionable eyewear capable of . . . utilizing one or more of a multitude of different application devices while the wearer is wearing the eyewear.” Ex. 1001, 1:59–62; Pet. Reply 13. Patent Owner argues that “[t]he ’960 [p]atent pertains to the field of wearable embedded electronics, namely ‘commercial eyewear comprising electronics.’” PO Resp. 24 (citing Ex. 1001, 1:24–25). We view the parties’ descriptions of the field of the ’960 patent to be substantively the same.” slip op. at 25
- Obviousness (§103) › Motivation to combine / reasonable expectation of successMotivation foundReasonable expectation foundDecided for petitioner
“We also find persuasive Petitioner’s argument and Dr. Feland’s testimony that Jannard’s “application module for eyewear is one such suitable device in which to incorporate Rosenblatt’s key or its functionality.” Pet. 47 (citing Ex. 1003 ¶ 156). This argument and testimony are consistent with Rosenblatt’s teaching of a wide variety of suitable devices. Compare id. and Ex. 1003 ¶ 156, with Ex. 1007 ¶ 7. Moreover, as Petitioner argues, Rosenblatt teaches that its “key . . . may include a clip or other connecting mechanism for attaching [the] key . . . to an object that the user typically carries,” such as “a user’s wallet, cellular telephone, personal media device (e.g., an iPod), wired headset, wireless headset, watch, bag, belt, article of clothing, or any other suitable object.” Ex. 1007 ¶ 43 (emphasis added). We find persuasive Dr. Feland’s testimony that Jannard’s eyewear system is a carried object like a wired or wireless headset in the context of Rosenblatt’s teaching. See Ex. 1003 ¶ 156; Ex. 1007 ¶ 43. We also find persuasive Dr. Feland’s testimony that incorporating Rosenblatt’s key or its functionality into Jannard’s application module “desirably ‘provid[es] functional fashion having device operation capabilities,’ which is consistent with Rosenblatt recommendations.” Ex. 1003 ¶ 156 (quoting Ex. 1007 ¶ 58) (alteration in original); Ex. 1007 ¶ 58 (“[T]he key may be integrated with operation capabilities.”). We also find persuasive Petitioner’s argument and Dr. Feland’s testimony that one of ordinary skill in the art would have been motivated to incorporate Rosenblatt’s key or its functionality in Jannard’s application module to achieve the benefits disclosed in Rosenblatt, including controlling host devices responsive to wireless communication with Jannard’s application module. Pet. 47; Ex. 1003 ¶ 156. We view this as using a known technique (Rosenblatt’s teaching of incorporating a key or its functionality into an electronic device) to improve a similar device (Jannard’s eyewear and application module with wireless communication for functions) in the same way. See KSR, 550 U.S. at 417 (“[I]f a technique has been used to improve one device, and a person of ordinary skill in the art would recognize that it would improve similar devices in the same way, using the technique is obvious unless its actual application is beyond his or her skill.”); see also Pet. 48; Ex. 1003 ¶ 157.” slip op. at 14
Patent outcomesUS 10,598,960 unpatentableClaim construction§ 103 obviousnesscites Phillips · GrahamPatents in suitUS 10,598,960 - Pgr2025-00069InstitutedPTAB · Dec 23, 2025 · PGR2025-00069 · APJ John A Squires · PGR · Institution
The Director granted institution of PGR2025-00069 after finding the petition showed the required likelihood of success and no non-discretionary consideration warranted denial.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as applicable, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review or post-grant review is granted in the following proceedings: IPR2025-010611 IPR2025-01205 PGR2025-00067 IPR2025-01173 IPR2025-01206 PGR2025-00068 IPR2025-01188 IPR2025-01207 PGR2025-00069 IPR2025-01189 IPR2025-01208 IPR2025-01203 IPR2025-01209 IPR2025-01204 IPR2025-01270” slip op. at 1
NonePatents in suitUS 12,250,564 - Pgr2025-00068InstitutedPTAB · Dec 23, 2025 · PGR2025-00068 · APJ John A Squires · PGR · Institution
Institution was granted in PGR2025-00068 after the Director found the petition met the applicable merits threshold and no other non-discretionary considerations warranted denial.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as applicable, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review or post-grant review is granted in the following proceedings: IPR2025-010611 IPR2025-01205 PGR2025-00067 IPR2025-01173 IPR2025-01206 PGR2025-00068 IPR2025-01188 IPR2025-01207 PGR2025-00069 IPR2025-01189 IPR2025-01208 IPR2025-01203 IPR2025-01209 IPR2025-01204 IPR2025-01270” slip op. at 1
NonePatents in suitUS 12,169,756 - Pgr2025-00067InstitutedPTAB · Dec 23, 2025 · PGR2025-00067 · APJ John A Squires · PGR · Institution
The Director granted institution of PGR2025-00067 after finding the petition showed the required likelihood of success and no non-discretionary consideration warranted denial.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as applicable, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review or post-grant review is granted in the following proceedings: IPR2025-010611 IPR2025-01205 PGR2025-00067 IPR2025-01173 IPR2025-01206 PGR2025-00068 IPR2025-01188 IPR2025-01207 PGR2025-00069 IPR2025-01189 IPR2025-01208 IPR2025-01203 IPR2025-01209 IPR2025-01204 IPR2025-01270” slip op. at 1
NonePatents in suitUS 12,190,198 - Ipr2025-01270InstitutedPTAB · Dec 23, 2025 · IPR2025-01270 · APJ John A Squires · IPR · Director review
The Director granted institution of IPR2025-01270 after finding the petition met the merits threshold and no nondiscretionary considerations warranted denial.
RulingsDirector review decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as applicable, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review or post-grant review is granted in the following proceedings:” slip op. at 1
NonePatents in suitUS 12,114,177 - Ipr2025-01209InstitutedPTAB · Dec 23, 2025 · IPR2025-01209 · APJ John A Squires · IPR · Institution
The Director granted institution in IPR2025-01209 after finding the merits threshold met and no other non-discretionary considerations warranting denial.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as applicable, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review or post-grant review is granted in the following proceedings: IPR2025-010611 IPR2025-01205 PGR2025-00067 IPR2025-01173 IPR2025-01206 PGR2025-00068 IPR2025-01188 IPR2025-01207 PGR2025-00069 IPR2025-01189 IPR2025-01208 IPR2025-01203 IPR2025-01209 IPR2025-01204 IPR2025-01270” slip op. at 1
NonePatents in suitUS 11,856,414 - Ipr2025-01208InstitutedPTAB · Dec 23, 2025 · IPR2025-01208 · APJ John A Squires · IPR · Director review
The Director’s notice grants institution in IPR2025-01208 after finding the petitioner met the merits threshold and no non-discretionary considerations warranted denial.
RulingsDirector review decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as applicable, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review or post-grant review is granted in the following proceedings:” slip op. at 1
NonePatents in suitUS 11,974,143 - Ipr2025-01207InstitutedPTAB · Dec 23, 2025 · IPR2025-01207 · APJ John A Squires · IPR · Director review
The Director granted institution of IPR2025-01207 after finding the petition showed a reasonable likelihood of prevailing on at least one challenged claim.
RulingsDirector review decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as applicable, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review or post-grant review is granted in the following proceedings: IPR2025-010611 IPR2025-01205 PGR2025-00067 IPR2025-01173 IPR2025-01206 PGR2025-00068 IPR2025-01188 IPR2025-01207 PGR2025-00069 IPR2025-01189 IPR2025-01208 IPR2025-01203 IPR2025-01209 IPR2025-01204 IPR2025-01270” slip op. at 1
NonePatents in suitUS 12,015,933 - Ipr2025-01206InstitutedPTAB · Dec 23, 2025 · IPR2025-01206 · APJ John A Squires · IPR · Institution
The Director granted institution in IPR2025-01206, finding the petition met the institution threshold and no non-discretionary consideration warranted denial.
RulingsInstitution decision- PTAB / AIA Trials › Institution threshold (reasonable likelihood / more likely than not)InstitutedInstituted
“merits, the petitioner has shown a reasonable likelihood of prevailing with respect to at least one of the claims challenged in the petition, or that it is more likely than not that at least one of the claims challenged in the petition is unpatentable, as applicable, and no other non-discretionary considerations warrant denial of institution. Accordingly, institution of inter partes review or post-grant review is granted in the following proceedings:” slip op. at 1
NonePatents in suitUS 11,950,105
Holdings, summaries, rulings, issues, outcomes, winners and claim constructions shown for a decision were generated by a large language model reading the opinion. They are a guide to the decision, not the decision. Confirm every one against the court's own text before relying on it. Outcomes read from the patent owner’s side. Party names are extracted from the decision and are missing on about 900 short Director denials and scans, which carry the trial number instead.