SpaceTime Bests Apple in Dismissal Decision of GUI Patent Infringement Suit

On Thursday, a Waco, Texas federal court denied Apple Inc.’s motion to dismiss certain SpaceTime3D Inc. patent infringement claims. Judge Alan D. Albright ruled that SpaceTime put forward plausible inferences of post-suit willful infringement and that Apple still induces its customers to infringe using accused products including iPhones, iPod Touches, iPads, and Apple Watches.

The case concerns three patents owned by SpaceTime relating to graphical user interface improvement said to make navigating between multiple web pages or apps easier. Specifically, they provide “an interactive computing interface and sorting interface comprising information from real-time and static sources,” the opinion explained.

This February, SpaceTime sued Apple alleging pre- and post-suit indirect and willful infringement. Apple asked SpaceTime to dismiss all of its willful and indirect infringement claims without prejudice, but SpaceTime only agreed to do so with regard to its pre-suit claims.

Turning to Apple’s bid to dismiss the post-suit claims, Judge Albright first opined that SpaceTime sufficiently alleged that Apple knew of the asserted patents and knew or should have known that its conduct amounted to infringement.

As to indirect infringement, the court highlighted complaint allegations that Apple provides instructions that teach infringing uses through its user guide and support website. Overriding Apple’s arguments that the allegations were impermissibly vague, Judge Alright concluded that “SpaceTime has pleaded in several places in its Complaint sufficient factual content that allows this Court to draw the reasonable inference that Apple knowingly induced a third-party to infringe the patent and had specific intent to induce the patent infringement.”

The court noted that though the parties agreed to dismiss SpaceTime’s pre-suit claims, the plaintiff is permitted to amend its complaint and those claims if it is able to elicit sufficient facts during discovery. 

SpaceTime is represented by Susman Godfrey L.L.P.  and Apple by Kelly Hart & Hallman LLP and Gibson, Dunn & Crutcher LLP.