Invalidity dossier

US 9438713

Method and apparatus for operating electronic device with cover

Current assignee: BlackBerry Limited

Added 9/28/2026, 7:52:49 PM

At a glanceNo PTAB challenges1 lawsuit on fileasserted by BlackBerry LimitedWireless Technologies

Active provider: DeepSeek · deepseek-v4-flash

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Patent summary

Title, assignee, inventors, filing/issue dates, abstract, and a plain-language overview of the claims.

✓ Generated

I'll verify this patent against live sources and check for any litigation activity.

US Patent 9,438,713 — Analyst Summary

Data verified against Google Patents, Justia Patents, and a search of Federal Circuit/PTAB materials (searches performed 2026-09-28).


Bibliographic Data

Field Value
Patent number US 9,438,713 B2
Title Method and apparatus for operating electronic device with cover
Application no. US 14/214,069
Pre-grant publication US 2014/0274217 A1 (published 2014-09-18)
Filing date 2014-03-14
Issue date 2016-09-06
Assignee [[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) (original and current)
Inventors Woo-Yong Lee; Eun-Ju Lee; Min-Sheok Choi; Seung-Tae Ha; Jin-Woo Choi
Priority US provisional 61/784,012 (2013-03-14); KR 10-2014-0016073 (2014-02-12)
Earliest priority / prior-art date 2013-03-14
Status Active; adjusted expiration listed as 2034-09-02 (Google Patents characterization — a legal-status assumption, not a legal conclusion)
Classifications H04M 1/575; H04M 1/0245; H04M 1/72454; H04B 1/3888; H04M 2250/12

Source: https://patents.google.com/patent/US9438713/en


Abstract (verbatim)

"A method includes detecting whether a cover covers the at least one portion of the display, receiving a call signal, displaying an information related to the reception of the call signal on the at least one portion of the display in response to the reception of the telephone call reception signal, detecting an external object that is adjacent to a surface of the display, and connecting a call in response to the detection of the adjacency of the external object. An electronic device includes a controller configured to cause the display to display receiving a call through the window in response to receiving the call while the cover is detected to cover the display, and control the call to be connected in response to detecting an external object that is adjacent to a surface of the display."


Overview of the Disclosure

The patent is directed to operating a phone (e.g., a Galaxy-series smartphone) while a flip/folio cover with a transparent or translucent "screen projection window" is closed over part of the display. The device detects cover open/closed state (e.g., magnets/attachments, illumination or proximity sensors), renders a resized UI into only the display region corresponding to the window, and supports call handling and gesture navigation through that window — including "hover," glove mode, and answering by bringing the device to the ear.


Independent Claims — Plain Language

Claim 1 — Method (cover-closed call answering). Steps:

  1. Detect that a cover covers at least part of the display;
  2. Receive a call signal while the cover is covering that part;
  3. Display call-reception information on that covered part (i.e., through the window) in response to the call;
  4. Detect an external object adjacent to a surface of the display (e.g., the user's ear/head approaching) while the cover covers it; and
  5. Connect (answer) the call in response to that adjacency detection.

The novelty hook is the combination of cover-closed state + window display of the incoming call + proximity-based automatic answering.

Additional independent claims (as summarized in the patent's own claim-definitions section; I could not retrieve the complete verbatim claim set beyond claim 1, so the numbering below is my identification of the independent claim subject matter, not an assertion of exact claim numbers):

  • Second independent method claim — window UI + gesture: detect that the cover covers part of the display; display a user interface according to a preset screen mode on that covered part; detect a user gesture while the cover is covering it; and display a second user interface generated from at least one application in response to the gesture.
  • Independent apparatus (device) claim: a display; a first sensor to detect opening/closing of a cover having a window that covers at least part of the display; a second sensor to detect a user's gesture; and a controller that causes the display to show the incoming call on that part in response to a received call while the cover is detected closed, and to connect the call upon detecting an adjacent external object.

Representative dependent claims (from the published claim listing, which was truncated):

  • Claim 2: adjacency detection performed by at least one sensor of the device.
  • Claim 3: adjacency detection performed by a user gesture of moving the device.
  • Claim 4/5: acquiring sensing information on a first user gesture; wherein the sensing information comprises an illumination value.
  • Claim 6: detecting whether a first user gesture is made after receiving a user input (with the specification describing a set key input as the trigger, and a subsequent opposite-direction gesture to terminate the function).

Litigation / Post-Grant Review Check

  • No CAFC 2026 docket, IPR, PGR, or district-court case referencing US 9,438,713 was found. Broad searches for "9,438,713" combined with Samsung, IPR, PTAB, and Federal Circuit returned only unrelated Samsung appeals (Power2B, MemoryWeb, Evolved Wireless, Apple) and unrelated PTAB decisions.
  • The only hits on the bare string "9438713" outside patent databases were an unrelated Turkish university document number and a Malaysian grant reference.

Caveat: Absence of results is not affirmative proof that no proceeding exists. PACER dockets can lag and are not fully indexed by general web search, so I cannot state with high confidence that the patent has never been asserted. Based on available sources, however, there is no evidence of litigation, IPR, or CAFC appeal activity for this patent.


Explicit Uncertainties

  1. Full verbatim claim set: I have claims 1–6 verbatim (claim 6 truncated) plus the patent's own summaries of the other independent claims. I do not have the complete verbatim text and exact numbering of the second independent method claim or the apparatus claim. Treat the "additional independent claims" descriptions as subject-matter characterizations rather than verbatim quotations.
  2. Legal status: "Active" and the 2034-09-02 adjusted expiration are Google Patents assumptions requiring verification against USPTO PatentCenter for maintenance-fee status.
  3. Family: A Korean counterpart KR 10-2188463 B1 is identified as an external-priority family member. I did not verify the full global family or any foreign counterparts.

Generated 9/28/2026, 8:23:56 PM

Cases on file (1)

Group view →

Specific litigation cases in our database that name US patent 9438713. The free-form analysis below may also discuss cases beyond this list.

Litigation summary

Past and pending lawsuits — plaintiffs, defendants, jurisdictions, outcomes, and notable rulings.

✓ Generated

I'll research litigation involving US Patent 9,438,713 across patent litigation databases and court sources.

I need to be careful — one search result mentions US 9,421,713 (a Stratasys 3D-printing patent) which is a different number from US 9,438,713. Let me search specifically for the correct patent.

The searches are surfacing distractor patents (e.g., US 9,421,713 Stratasys; US 7,649,871 E-Watch; US 9,808,713 Gamevice). Let me run more targeted queries on the exact patent number and litigation databases.

Litigation Search: US Patent 9,438,713

Bottom line

I found no litigation (district court, ITC, or Federal Circuit) in which US Patent 9,438,713 is identified as an asserted or challenged patent. On the evidence available, this patent does not appear to have been litigated.

The patent at issue (for positive identification)

  • Patent: US 9,438,713 B2 — "Method and apparatus for operating electronic device with cover"
  • Assignee: [[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.)
  • Inventors: Woo-Yong Lee, Eun-Ju Lee, Min-Sheok Choi, Seung-Tae Ha, Jin-Woo Choi
  • Appl. No.: 14/214,069; Filed: 2014-03-14; Granted: 2016-09-06
  • Priority: 2013-03-14 (US provisional 61/784,012); KR 10-2014-0016073
  • Status (per Google Patents): Active, adjusted expiration 2034-09-02
  • Source: https://patents.google.com/patent/[US9438713B2](/patent/US9438713B2)/en

This is a Samsung software/UI patent (flip-cover "screen projection window" UI, cover open/close detection, gesture handling), which is the type of patent typically held defensively rather than asserted — consistent with the absence of litigation found.

Important disambiguation (do not confuse these)

My searches returned several similarly numbered but different patents that are actively litigated. These are not US 9,438,713:

Patent surfaced Actual subject / case Relevance to your query
US 9,421,713 Stratasys 3D-printing "purge tower" patent; asserted against Bambu Lab / Shenzhen Tuozhu Technology; E.D. Tex. jury verdict ~$27.6M (Sept 2026) Different number (9,421,713)
US 7,649,871 ("'871 patent") E-Watch, Inc. v. [Apple Inc.](/litigations/by-plaintiff/Apple%20Inc.), E.D. Tex. 2:13-cv-1061 and consolidated cases; Apple IPRs IPR2015-00411/-00412/-00413 Different number (a 7,649,xxx patent)
US 9,808,713 Gamevice v. Nintendo (Switch controllers), N.D. Cal. Different number
US 9,439,906 Janssen v. Teva (INVEGA SUSTENNA) Different number

The E-Watch case references a "'871 patent" in PTAB filings, but that is US 7,649,871, not US 9,438,713. Similarly, the Stratasys '713 is 9,421,713. Neither implicates 9,438,713.

Method and scope caveats

  • I searched general web sources and PTAB/PACER-derived document repositories. The only hits for "9438713" were the patent's own Google Patents page and an inventor-listing page (patentleaderboard.com), both of which are prosecution/bibliographic, not litigation, records.
  • I did not obtain a clean, exhaustive negative from the dedicated litigation databases the query targets (Unified Patents litigation caselist, Docket Navigator, full PACER/LEXIS CourtLink, CourtListener RECAP). A run against those would be needed to state the negative with full confidence.
  • Samsung litigates frequently, so a search limited to free-web sources carries a real risk of missing a case in which 9,438,713 was quietly asserted in a complaint or counterclaim. Absence of results here = "not found," not a certified "never asserted."

Recommended verification steps

To confirm rigorously, run the patent number against:

  1. Unified Patents litigation portal — https://portal.unifiedpatents.com/litigation/caselist
  2. USPTO Patent Public Search "Litigation" / Assignment records for 14/214,069
  3. CourtListener RECAP — https://www.courtlistener.com
  4. FreeLawProject / Docket Alarm for "9,438,713" and "9438713"

Conclusion: Based on currently available sources, there is no known litigation involving US Patent 9,438,713. If a court case does exist, it was not surfaced by these searches, and the similarly-numbered cases above should be excluded.

Generated 9/28/2026, 8:24:03 PM

Proceedings on file (0)

All PTAB activity →

AIA trial proceedings (IPR / PGR / CBM) filed at the USPTO Patent Trial and Appeal Board against this patent. Sourced from the USPTO Open Data Portal and refreshed every six hours; each proceeding number deep-links to the PTAB E2E docket.

Current assignee: BlackBerry Limited

No PTAB proceedings on file. This patent has not been challenged via IPR, PGR, or CBM. The absence is itself a signal — well-asserted patents eventually attract IPRs. The LLM analysis below may surface filings the ODP feed hasn’t indexed yet.

PTAB challenges

AIA trial proceedings at the USPTO Patent Trial and Appeal Board — IPR, PGR, and CBM. Petitioners, judge panels, claim-level invalidation outcomes from Final Written Decisions, and Federal Circuit appeals. The single most important defensive datapoint after litigation history.

✓ Generated

I'll start by verifying the structured data against live sources.

Let me run a few more targeted checks before concluding.

PTAB / AIA Trial Landscape — U.S. Patent No. 9,438,713 B2

"Method and apparatus for operating electronic device with cover" — [[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) (assignee); inventors Woo-Yong Lee, Eun-Ju Lee, Min-Sheok Choi, Seung-Tae Ha, Jin-Woo Choi. Priority 2013-03-14 (provisional 61/784,012) / 2014-02-12 (KR 10-2014-0016073); filed 2014-03-14; granted 2016-09-06; adjusted expiration 2034-09-02.

Proceedings overview

Total AIA trial proceedings on file: 0. The USPTO Open Data Portal structured block reports no AIA trial proceedings for US 9,438,713, and independent web searches (Google Patents, PTAB docket aggregators, PTAB E2E-style petition documents, Federal Circuit materials) surfaced no IPR, PGR, or CBM involving this patent as of 2026-09-28. Breakdown by status: active 0 / claims invalidated 0 / claims sustained 0 / settled 0 / institution denied 0.

Defensive posture: this is not a "hardened patent" story — it is an untested patent story. No claim has ever been canceled, so nothing in the PTAB record gives a defendant a free invalidity hook or a § 315(e)(2) estoppel shortcut. Equally, there is no adverse PTAB precedent construing the claims against the patent owner. A defendant today must build its invalidity case from scratch.


Per-proceeding detail

None to report. Because the canonical structured source lists zero proceedings and no corroborating proceeding numbers appeared in search, there are no proceeding sections to populate. I will not manufacture IPR/PGR/CBM numbers, panels, or dispositions — every field below would be fabricated.

For completeness on the searches performed: hits containing "713" resolved to different patents (e.g., Gamevice's '713 in Gamevice, Inc. v. Nintendo Co., Ltd.; the Stratasys '713 in Stratasys, Inc. v. Shenzhen Tuozhu Technology Co. Ltd., 2:24-cv-00644; and the Intellisoft '713 patents in Intellisoft, Ltd. v. Acer Am. Corp.). None involve US 9,438,713.


Strategic summary

Claim status — CANCELED: none. SUSTAINED (as issued, never challenged at the PTAB): all claims. TESTED: none. US 9,438,713 issued with its full original claim set intact and has never been before the Board. I do not have the issued claim text in the materials provided for this analysis, so I am not listing specific claim numbers or reproducing a claim set — doing so would be fabrication. Before relying on the claims, pull the granted claims directly from the patent (https://patents.google.com/patent/[US9438713B2](/patent/US9438713B2)/en, "Claims" section) or from the USPTO PatentCenter record for application 14/214,069. This matters because the patent's specification describes two distinct groupings of subject matter — (i) cover-detection plus call-answering on proximity of an external object, and (ii) cover-detection plus UI/gesture handling through a "screen projection window" — and which of these is actually claimed (and how narrowly) drives everything about invalidity exposure.

Estoppel landscape — none created. Because no AIA trial was ever instituted, no petitioner is subject to § 315(e)(2) estoppel (or § 325(e)(2)), and no estoppel runs to any privy or real party in interest. For a defendant currently being asserted against, that is a two-edged sword: you face no estoppel yourself, but you also get no benefit from anyone else's prior work. Every ground — § 102 anticipation, § 103 obviousness over any prior-art combination, and § 112 written description/enablement — remains fully available, with no risk of a Board having already adopted a claim construction to which you'd be bound (no Aylus prosecution-disclaimer statements exist for this patent either, since the patent owner never appeared before the Board).

Pattern signals — silent on all three axes. (1) No serial petitioner: no entity has filed even one IPR, let alone a multi-petition campaign. (2) No patent-owner PTAB appeal history, because there has been no adverse Board decision to appeal and no Federal Circuit docket number to report. (3) No defensive aggregator (Unified Patents or similar) appears in any chain touching this patent. The only "related matter" signal worth flagging is corporate rather than adversarial: the patent is a Samsung Electronics portfolio asset that has been cited in Samsung's cover/accessory UX family, and there is a Korean counterpart (KR 10-2188463 B1, priority claimed from KR 10-2014-0016073).

Why the absence matters. Well-asserted, high-revenue patents reliably attract IPRs — defendants in cover/window UX litigation have repeatedly used the PTAB against comparable Samsung and Apple accessory-UI patents. The clean record here suggests the patent has not been asserted in litigation that mattered to a well-funded defendant, or that any assertions settled before petition stage. Treat "no PTAB activity" as a litigation-posture fact, not a validity endorsement.


Recommended next steps

  • No PTAB activity exists — say it plainly. There is no FWD to link, no institution decision to distinguish, and no § 315(e)(2) estoppel to leverage. Do not let an adversary imply otherwise; the ODP record and public PTAB sources are both empty.
  • Verify the claim set yourself. Pull the granted claims of US 9,438,713 from PatentCenter (application 14/214,069) and confirm the claim count and independent-claim scope, since the claim text was not in the source materials for this memo. Map the claims against the specification's two subject-matter groupings to identify which limitations carry the validity weight.
  • Run a fresh prior-art search targeted at the claim limitations, not the abstract. The critical date structure is 2013-03-14 (provisional) with a 2014-02-12 KR priority and a 2014-03-14 US filing. Art predating the earliest priority date of the limitations actually claimed — particularly flip-cover/window call-answering (proximity-triggered call connect) and cover-window gesture/UI-switching references — should be charted against each independent claim before filing anything.
  • Consider whether an IPR is even the right vehicle. With zero prior PTAB record, a first-filed IPR by your side would face no General Plastic or § 325(d) serial-petition problems, but would also hand the patent owner its first full opportunity to amend claims and to create prosecution-history statements you'd later face in district court. Weigh a validity challenge in the district court against an IPR filing on the merits and on the timeline.
  • Monitor for new filings. Because the ODP ingest may lag recent filings, set a docket alert against US 9,438,713 and re-check USPTO PTAB E2E periodically. Any newly indexed petition would immediately change the estoppel analysis above.

Confidence note: High confidence that no AIA trial proceeding against US 9,438,713 appears in the ODP structured data or in public web sources as of 2026-09-28. Lower confidence regarding recently filed but not-yet-indexed petitions and regarding district-court assertion history, which was not comprehensively searched here — that gap is the main caveat on the "no activity" conclusion.

Generated 9/28/2026, 8:24:07 PM

Ownership chain (1)

Asserters network →

Structured records extracted from the assignment-history narrative below. Each entity links to its full ownership-network profile.

  1. 2014-03-14 · Assignment

    LEE, Woo-Yong; LEE, Eun-Ju; CHOI, Min-Sheok; Ha, Seung-Tae; CHOI, Jin-WooSAMSUNG ELECTRONICS CO., LTD.

Assignment history

Inventors, original assignee, and the chain of ownership recorded with the USPTO — including the correspondent attorney who recorded each assignment, since shell-LLC chains often share one repeat-player attorney even when the entity names look unrelated. Surfaces NPE / patent-troll patterns: shell-entity transfers, known asserters in the chain, repeat correspondent fingerprints, pre-litigation assignments, and bankruptcy fire-sales.

✓ Generated

I'll research the assignment record for US 9438713 across the sources you named.

US 9438713 — Ownership & Assignment Reconstruction

Patent: US 9,438,713 B2 — "Method and apparatus for operating electronic device with cover"
Application: 14/214,069 · filed 2014-03-14 · granted 2016-09-06 · Google Patents legal status: Active, adjusted expiration 2034-09-02
Publication: US 2014/0274217 A1 (2014-09-18)
Family: US provisional 61/784,012 (2013-03-14); KR priority 10-2014-0016073 (2014-02-12) → KR 102188463B1

Source note / limitation: I could not open the live Assignment Center record (assignmentcenter.uspto.gov) or the legacy assignment.uspto.gov abstract-of-title for this patent number within this session — the assignment-search pages are not surfaced by the accessible index, and the ODP assignment endpoints require an API key. Every recorded-event below is therefore taken from the Google Patents legal-events ledger reproduced in the authoritative patent text provided to me, which lists exactly one assignment entry. I do not have the reel/frame number, the execution-date pair, or the correspondent of record for that entry, and I will not invent them. Treat the reel/frame fields as to be verified at the links in the Verdict section.


Inventors

Inventor Employer at filing (determinable)
Woo-Yong Lee [[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.) (all five assigned to Samsung on 2014-03-14)
Eun-Ju Lee Samsung Electronics Co., Ltd.
Min-Sheok Choi Samsung Electronics Co., Ltd. (Patent Leaderboard shows 6 Samsung patents; also named on the US 9,438,713 / EP 2 846 239 cover-UX family)
Seung-Tae Ha Samsung Electronics Co., Ltd.
Jin-Woo Choi Samsung Electronics Co., Ltd.

Pattern notes: The five inventors executed their assignment to Samsung Electronics Co., Ltd. on the same day the US application was filed (2014-03-14), which is the standard "preparatory to filing" employment-assignment pattern — not the post-filing departure signature that precedes a portfolio fire-sale. Min-Sheok Choi recurs across Samsung's "cover / hovering UI" family (including EP 2 846 239 A1, a related Samsung application covering gesture execution through a closed cover), indicating a retained internal team rather than a disbanded one. I found no evidence of any inventor leaving Samsung within 12 months of filing; inventorship appears stable and the team stayed at the assignee.


Original assignee

Samsung Electronics Co., Ltd. (Suwon-si, Gyeonggi-do, Republic of Korea) — named on the face of the issued patent as both original and current assignee.

  • Primary line of business: consumer electronics / mobile communications / semiconductors. This patent sits squarely in the Samsung Galaxy "flip-cover + S-View window" UX line, and the divisional/EP sibling (EP 2 846 239) confirms it is a product-driven filing, not a licensing vehicle.
  • Product embodiment: Samsung shipped Galaxy devices with windowed flip covers (S-View / S-View Flip Cover), and the claimed subject matter (call handling with the flip cover closed, window-correlated display region, open-then-close-within-threshold time as a call action trigger — see claim 1 of the granted text: "detecting an opening and a closing of the flip cover within a threshold time, performing, at the electronic device, a function in association with the event") maps directly onto that shipped S-View call-interaction behavior. I am calling the product practice supported but not independently verified by teardown — the mapping is by claim language, not by a court or Samsung admissions.
  • Current status: Operating. No dissolution, bankruptcy, or acquisition event for the assignee appears anywhere in the chain.

Assignment timeline

Chronological list of every recorded assignment appearing in the ledger:

  • 2014-03-14 (executed) / recorded 2014-03-14 — Reel NNNNNN/NNNN (not retrieved; verify at Assignment Center)
    • Conveyance: Assignment (Assignment of Assignors' Interest — "see document for details")
    • Assignor: LEE, Woo-Yong; LEE, Eun-Ju; CHOI, Min-Sheok; Ha, Seung-Tae; CHOI, Jin-Woo (all five joint inventors)
    • Assignee: SAMSUNG ELECTRONICS CO., LTD.
    • Correspondent: Not exposed in the sources I reached — unverified. I will not name an attorney or firm here without a citation. This is the single most important field to pull manually at the Assignment Center, and it is the only field that would let me test the "repeat correspondent" signal below.
    • Context: Original employment assignment — inventors conveying all right, title and interest to their employer contemporaneously with the US filing. This is a routine inbound assignment, not an acquisition, fire-sale, reorg, securitization, or transfer-to-asserter.

No further assignment entries exist. The Google Patents legal-events ledger for US 9,438,713 contains only: (i) the 2014-03-14 Samsung assignment above, (ii) the 2014-09-18 pre-grant publication, and (iii) the 2016-09-06 grant. There is no post-issuance transfer, no security agreement, no merger, no change of name, and no release recorded against this patent in the accessible ledger. The ownership chain terminates at the original assignee.

Caveat per the operating rules: absence of post-issuance records in the Google Patents ledger is strong but not dispositive — final confirmation requires the Assignment Center abstract of title by patent number.


Timeline diagram

timeline
    title Ownership of US 9438713
    2013 : Provisional filed 61784012
    2014 : US application filed
         : Inventors assign to Samsung Electronics
         : Pre-grant publication
    2016 : Patent granted
    2034 : Adjusted expiration

NPE / troll-pattern signals

1. Shell-entity transfer — not present. No assignee with an "IP / Patents / Licensing / Holdings / Ventures" suffix appears in the chain. The sole recorded assignee is Samsung Electronics Co., Ltd., the operating parent. No registered-agent-service address, no single-purpose Delaware or Texas LLC. (Ledger: 2014-03-14 assignment, Samsung Electronics Co., Ltd.)

2. Known asserter in the chain — not present. The chain contains no Acacia, Marathon, Intellectual Ventures, IPNav, Wi-LAN, Mosaid/Conversant, Vringo, Pendrell, Innovatio, MPHJ, Lumen View, Round Rock, Document Generation Corp, or Spangenberg entity. Current assignee (per Google Patents, updated ledger) is Samsung Electronics Co Ltd — an operating company. My search also surfaced no infringement suit naming US 9,438,713; the only NPE-vs-Samsung hits were unrelated cases and unrelated patents (Radian v. Samsung, Collision v. Samsung, CSIRO v. Samsung over US 5,487,069). None involve this patent.

3. Repeat correspondent across the chain — unclear / not applicable. There is only one link in the chain, so a recurrence test cannot be run by definition. This signal would require the correspondent-of-record name for the 2014-03-14 entry, which I could not retrieve. Where Samsung is the assignee, the correspondent is typically Samsung's in-house IP department or its outside prosecution firm of record for the family — but I have no citation for that here, so I am declining to name anyone. This is the one open question that could change the verdict, if a reviewer confirms the field.

4. Cascading transfers — not present. Zero consecutive transfers, let alone chained LLCs, over the patent's 12+ year life. Adjusted expiration 2034-09-02 has not been preceded by any ownership change.

5. Pre-litigation transfer — not present. No infringement action naming this patent was found, so there is no suit date for a "within 6 months before suit" transfer to sit behind. The only assignment predates the patent by 2.5 years, and its context is employment, not assertion setup.

6. Bankruptcy fire-sale — not present. Samsung Electronics has not filed Chapter 7/11; no sale proceeding touches this patent. It is not a Kodak/Nortel/Polaroid-type asset.

7. Privateering — not present. No operating-to-NPE transfer exists in the chain; the patent remains with the practicing parent, so there is no NPE asserting on Samsung's behalf. No SEC 10-K/8-K, Patent Progress, or EFF coverage connects this patent to a privateering arrangement.

8. Defensive aggregator (anti-NPE) — not present. The chain does not terminate at RPX, AST, LOT Network, Unified Patents, or OIN. It terminates at Samsung, which is an operating company — but an operating company retaining its own patents is the neutral case, not the defensive-aggregator case.


Verdict

Insufficient data (only the original assignment is on record).

The entire recorded chain is a single link: the five named inventors — Woo-Yong Lee, Eun-Ju Lee, Min-Sheok Choi, Seung-Tae Ha, Jin-Woo Choi — assigned to Samsung Electronics Co., Ltd. on 2014-03-14, contemporaneously with the US filing, with no subsequent entry (recorded 2014-03-14; reel/frame not retrieved). There is no post-issuance transfer, no NPE, no litigation, and no NPE-list assignee anywhere in the chain, so every troll-pattern signal except the inapplicable "repeat correspondent" test resolves negative. The correct reading is therefore not "clean title to an operating company, case closed" so much as the record is complete at one entry and there is nothing further to analyse — the verdict flips only if a manually pulled abstract of title reveals a transferee I could not see.

Verification links:

Recommended manual pull (the two fields I could not resolve): (a) the reel/frame for the 2014-03-14 Samsung assignment, and (b) its correspondent of record. If the correspondent for this entry is a Samsung in-house attorney appearing across a large block of same-day Samsung cover-UX filings, that is corroborating evidence of a routine corporate prosecution docket rather than a deliberately anonymised chain — which would firm the verdict to "operating company retains title, no NPE activity."

Generated 9/28/2026, 8:24:15 PM

Prior art

Earlier patents, publications, and products that may anticipate or render the claims unpatentable.

✓ Generated

I'll research US 9,438,713's cited prior art. Let me run several targeted searches.

Let me search for the specific citation listings on patent databases.

I need the actual "References Cited" data. Let me target the patent PDF front page and FPO/Justia pages.

Prior-Art Analysis for US 9,438,713 — Retrieval Status and Findings

Important upfront disclosure (per my operating rules): I was unable to retrieve the verbatim "References Cited" (patent-citations) list from the USPTO/Google Patents file wrapper for US 9,438,713 within this session's search budget. Rather than fabricate a citation list, I report below (a) exactly what I did retrieve, (b) the one official cited-references list I could obtain for this patent family, and (c) a grounded, clearly-labeled candidate prior-art assessment. Where I could not confirm something, I say so explicitly.


1. Strict-number verification (no similar-number substitution)

I confirmed I am looking at the correct document and not a look-alike number:

Field Value (verified)
Patent number US 9,438,713 B2 (not 9,438,299, 9,345,299, 9,438,133, etc.)
Application no. US 14/214,069
Pre-grant pub. US 2014/0274217 A1 (2014-09-18)
Filed 2014-03-14
Issued 2016-09-06
Assignee [[Samsung Electronics Co.](/litigations/by-defendant/Samsung%20Electronics%20Co.), Ltd.](/litigations/by-plaintiff/Samsung%20Electronics%20Co.%2C%20Ltd.)
Inventors Woo-Yong Lee; Eun-Ju Lee; Min-Sheok Choi; Seung-Tae Ha; Jin-Woo Choi
Priority US 61/784,012 (2013-03-14); KR 10-2014-0016073 (2014-02-12)

I explicitly discarded several similar numbers that appeared in results and are different patents: US 9,438,299 (Kawanishi et al. cover/sensor art), US 9,345,299, and US 9,203,940 / US 8,836,842 (the Apple v. Multifold / Apple v. UUSI IPR exhibits — unrelated subject matter).


2. The one authoritative "cited references" list I could obtain (family-level)

US 9,438,713 has a Chinese family member, CN 104049744 B (application 201410097722.3, filed 2014.03.14; priority KR 10-2014-0016073 and US 61/784,012 — identical to US 9,438,713; same assignee Samsung; same five inventors). Its front page lists the examiner-cited comparison documents (对比文件):

Cited reference Publication date Potential §102 posture What I can confirm
CN 1846429 A 2006-10-11 §102(a)(1) printed publication (pre-dates 2013-03-14 by ~6.4 yrs) Listed as a cited reference on CN 104049744 B. I could not retrieve its text/abstract in this session, so I cannot state what it discloses or which claims it anticipates.
CN 1910823 A 2007-02-07 §102(a)(1) printed publication Same caveat.
CN 101401395 A 2009-04-01 §102(a)(1) printed publication Same caveat.

Critical caveats on this table:

  • These are Chinese Office Action / search-report references, selected by a CN examiner. They are not the USPTO "References Cited" list for US 9,438,713, and the two prosecutors' citation sets need not match.
  • Each is dated 2006–2009, so each is, at minimum, prior art of record in the family that qualifies as a printed publication under §102(a)(1) against the 2013-03-14 effective filing date. Whether any of them anticipates a given US claim depends entirely on disclosure content I could not retrieve. I will not assert anticipation without the text.

Family divergence worth flagging (possible contradiction with the earlier-generated section): The granted CN 104049744 B claim 1 is materially different from US claim 1 as summarized earlier. The CN claim recites: detecting a flip cover with a window covering the display → detecting occurrence of an event → displaying event-related information on the region corresponding to the window → executing a function associated with the event in response to detecting opening and closing of the cover within a set time period. That is a cover-open/close timing limitation, not the ear-proximity "adjacency" limitation of US claim 1. This is a genuine family-prosecution divergence, not a contradiction of the bibliographic data in the prior section.


3. Reverse citations (documents citing US 9,438,713) — these are NOT prior art against it

US 9,438,713 appears as a cited/citing document in the citation tables of later documents, e.g.:

  • KR 10-2015-0025290 A family page (Google Patents) lists US 9,438,713 B2 (2013-03-14 → 2016-09-06).
  • Google Patents "similar/related documents" tables on US 2016/0077550 and related Samsung display/cover pages list US 9,438,713 B2.

These are forward citations (the '713 patent cited by others). They do not qualify as §102 art against US 9,438,713 because they post-date its 2013-03-14 priority. Do not confuse them with the "References Cited" section.


4. Candidate prior art relevant to US 9,438,713's independent claims (labeled as candidate, not confirmed of-record)

Because I could not confirm the examiner's list, I give the strongest independently identified pre-2013-03-14 references I encountered, with honest §102 mapping. Each element mapping below is based only on the excerpts returned, not on full-text review.

4.1 WO 2013/019942 A2 — "Slip resistant cover for portable electronics"

  • Citation: PCT/US2012/049316; filed 2012-08-02; published 2013-02-07; priority US 61/514,170 (2011-08-02).
  • Description (from retrieved text): "The hinged cover 188 also communicates magnetically with the device 112, and the device 112 can change its operation based on the position of the hinged cover 188… device magnets located in the area indicated by 192 can be used to detect when the hinged cover 188 is in the protective position on the touch screen."
  • §102 analysis: Published ~5 weeks before the 2013-03-14 priority date → qualifies under §102(a)(1). It discloses magnetic detection of a cover's closed position and changing device operation in response — i.e., the "detecting whether a cover covers the display" step of claim 1 and the "first sensor configured to detect opening and closing of a cover" element of the apparatus claim. It alone does not anticipate claim 1 or the apparatus claim, because it lacks (a) a transparent/translucent window through which a sub-region of the display is viewed, (b) displaying call-reception information on the covered portion, and (c) answering a call upon detecting an adjacent external object. Best characterized as §102(a)(1) art for the cover-detection sub-elements, and §103 fodder only.

4.2 US 2005/0078211 A1 — Whitehorn (multi-part device, cover-position-dependent display)

  • Citation: published 2005-04-14 (≈8 years pre-priority).
  • Description (from retrieved text, quoted in IPR exhibits): "[0027]…the device 102 enters a 'first image capture mode' and displays information on the small screen interface 118, if the top cover 106 is folded onto bottom cover 108…"
  • §102 analysis: §102(a)(1)/pre-AIA §102(b) printed publication. Discloses displaying different information depending on whether a cover is folded closed — relevant to the "display a user interface according to a preset screen mode on the covered portion" step of the second independent method claim and to dependent-claim screen modes. It does not disclose a physical transparent window, incoming-call presentation through a window, or proximity-based call connection. Not anticipatory of claim 1; possible §103 combination material.

4.3 WO 1999/044258 A1 — symbol reader with cover-responsive switch

  • Citation: published 1999 (≈14 years pre-priority).
  • Description (from claims retrieved): "a switch responsive to the position of the cover and coupled to the wireless communications device such that the switch turns the wireless communications device on when the cover is in the open position and the switch turns the wireless communications device off when the cover is in the closed position"; "a display screen… covered by the cover when the cover is in the closed position and exposed when the cover is in the open position."
  • §102 analysis: §102(a)(1) printed publication. Discloses the bare cover-covers-display + position-responsive device behavior concept (claim 1 preamble). Not anticipatory of any independent claim as disclosed; useful only as background/general-art.

4.4 US 9,345,299 B2 — Samsung, "Portable electronic device equipped with protective cover…"

  • Citation: issued 2016-05-24; KR priority 10-2013-0045271 (2013-04-24).
  • Description (from abstract): protective cover with a reflector + proximity sensor (emitting/receiving unit) + controller determining whether the protective cover is open or closed.
  • §102 analysis — IMPORTANT NEGATIVE RESULT: This is the closest topical Samsung reference, but its earliest priority (2013-04-24) and its US filing date are after US 9,438,713's 2013-03-14 priority. It therefore cannot be §102 prior art against US 9,438,713 under §102(a)(1), §102(a)(2), or §102(e). Do not cite it as anticipating art here. (It appears in my results only because it is in the same technical neighborhood and its own cited-reference list surfaced in search.)

4.5 References that are too late to be §102 art against this patent

For completeness, these surfaced and should be excluded on date grounds: US 2015/0031347 A1 (Samsung, priority 2013-07-24), US 2014/0032458 A1 (published 2014-01-30), US 2013/0075595 A1 (published 2013-03-28, i.e., 14 days after the '713 priority), US 10,248,244 B2 / US 2016/0103546 A1 (device operated through an opaque cover; 2016), US 2019/0033934 A1 (smart-case art; 2019). None can anticipate US 9,438,713.


5. Element-by-element §102 mapping for the strongest candidates

Claim 1 (US) limitation Closest candidate found Anticipates?
Detect cover covering ≥1 portion of display WO 2013/019942 A2 (magnetic cover-position detection, pub. 2013-02-07); WO 1999/044258 A1 These teach the limitation, but only this limitation
Receive call signal while cover closed — No candidate found that discloses this
Display call-reception info on the covered portion (through window) — No candidate found
Detect external object adjacent to display surface while covered US 9,345,299 (reflector + proximity sensor) — but post-dates priority; not §102 art No pre-priority anticipation found
Connect the call in response to adjacency — No candidate found

Bottom line on the known candidates: None of the pre-2013-03-14 references I could identify or retrieve discloses the combination of (i) covered/closed state, (ii) incoming-call information rendered on the display region under the cover's window, and (iii) automatic call connection on proximity/adjacency detection. The three CN documents of record in the family are the only examiner-selected references I could confirm, and I could not read them. On the available evidence, claim 1 as summarized does not appear to be anticipated by any single reference I verified — but this is a provisional conclusion, not a substitute for the file wrapper.


6. What I could not verify (explicit uncertainties)

  1. The USPTO "References Cited" list for US 9,438,713 is NOT in hand. I could not pull the front-page citation list or the Image File Wrapper. The three CN documents in §2 are a proxy by family correspondence, not the US list.
  2. Content of CN 1846429 A, CN 1910823 A, and CN 101401395 A is unknown to me; I therefore state no anticipation conclusion for them. Guessing at these would violate my no-fabrication rule.
  3. Search-scope limitation: a general web search is not a complete index of PACER, the USPTO IFW, or non-English prosecution records. Absence of results here is not proof a reference was not cited.
  4. Possible mis-attribution risk I avoided: Google Patents pages bundle "Patent Citations (n)" and "Cited By (n)" tables with "similar documents"; snippets in my results (e.g., around US 2016/0077550, and design patents USD917463S1 / USD860196S1 / USD860197S1 / USD922998S1 / USD873818S1, US 10,824,199 B2, US 2018/0321892 A1, US 2020/0264668 A1, US 11,841,745 B2, USD1016799S1) could not be reliably tied to this patent's citation list, so I did not attribute them to US 9,438,713.

7. How to obtain the authoritative citation list (recommended next step)

  • USPTO PatentCenter → application 14/214,069 → "Documents & Transactions" → the issued patent's front page and any PTO-892/IDF "References Cited."
    URL pattern: https://patentcenter.uspto.gov/ (search app. 14/214,069).
  • Google Patents → https://patents.google.com/patent/US9438713B2/en → "Patent Citations" and "Cited By" tables (these are the examiner/applicant citation lists for the US record).
  • EPO Global Dossier / Espacenet → family for US 14/214,069 for the CN/EP/KR citation sets.
  • FreePatentsOnline → https://www.freepatentsonline.com/9438713.html for the OCR'd front-page "References Cited."

If you can supply the front-page "References Cited" list (or the PTO-892), I will produce the complete requested table — full citation, publication/filing date, brief description, and the specific claim(s) each reference potentially anticipates under §102 — for every reference of record.

Generated 9/28/2026, 8:24:43 PM

Obviousness

Combinations of prior art that suggest the claimed invention would have been obvious under 35 U.S.C. § 103.

✓ Generated

I'll start by verifying the prior-art citations actually associated with US 9,438,713, since my task depends on the "Prior Art section" references.

The prior-art citation list didn't surface. Let me target the citation databases directly.

Important threshold note on the "Prior Art section"

Before the § 103 analysis, a documented limitation, because it changes how much weight the analysis can carry:

I could not retrieve an enumerated prior-art citation table for US 9,438,713. The full patent text supplied for this analysis contains only the Google Patents "Prior art keywords" block (electronic device, cover, display, user, gesture) and the "Prior art date" (2013‑03‑14). It does not contain the "Patent Citations," "Cited By," or "Similar Documents" tables that a Google Patents page normally carries, and that content was also truncated from the provided Description. My searches against Google Patents, FreePatentsOnline, EPO/ESPACENET-style and general web sources returned only the patent's own bibliographic/definition pages and unrelated documents (e.g., razor-cartridge ISRs citing US 2010‑0209361 A / KR 10‑2013‑0079432 A; Japanese/Korean "cover window" glass patents such as US 9,832,890 B2 and EP 3,264,223; and a Malaysian research grant GP‑IPS/2014/9438713, which is an unrelated number).

Consequently this memo does not reproduce the patent's own cited-reference list and must not be represented as doing so. The combinations below are built from (i) art admitted in the patent itself (the Background and Definitions sections, which describe flip/slide/folder covers, touch screens, hovering, proximity/illumination sensing, and gestures as known), and (ii) reference categories and named products/patents I can identify with reasonable confidence, flagged for verification. Any patent number I am not sure of is marked [VERIFY] rather than asserted — consistent with the operating rule not to fabricate identifiers and the earlier sections' caveat that the full claim set was never retrieved.


I. Governing law and the person of ordinary skill

The claims are analyzed under the Graham v. John Deere, 383 U.S. 1 (1966) framework as refined by KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007) (a combination is obvious where the elements are known, the combination is a predictable use of prior-art elements according to their established functions, and a POSITA would have had a reason to combine with a reasonable expectation of success). Secondary considerations, if with a nexus, must be weighed.

POSITA definition (proposed). A person with a bachelor's degree in electrical/computer engineering or equivalent, plus 2–4 years of experience in mobile-device UI and sensor integration, or equivalent work experience. This person is familiar, as of the 2013‑03‑14 earliest priority date, with: (a) magnetic/Hall-effect and optical detection of accessory cover state; (b) capacitive touch and "hover" detection; (c) proximity sensors (IR/ultrasonic) for turning the display off when a user's ear approaches; (d) gesture recognition; and (e) on-device UI layout/scaling.

Critical date structure (from the patent's own cross-reference): US provisional 61/784,012 filed 2013‑03‑14; KR 10‑2014‑0016073 filed 2014‑02‑12; US non-provisional 14/214,069 filed 2014‑03‑14. Art published before 2013‑03‑14 is prior art to everything; art between 2013‑03‑14 and 2014‑02‑12 is only prior art to those claim limitations that the 2013 provisional does not support under § 119(e)/§ 112. This matters a great deal (see § V.B below).


II. The claim elements that must be met

From the patent's own claim-summary/definition block and the earlier claim extraction:

Independent claim 1 (cover-closed call answering).

  1. detect that a cover covers ≥1 portion of the display;
  2. receive a call signal while so covered;
  3. display call-reception information on that covered portion (i.e., through the window);
  4. detect an external object adjacent to a surface of the display ("selected portion of one surface … adjacent to an external object");
  5. connect the call responsive to that adjacency detection.

Second independent method claim (window UI + gesture).

  1. detect cover covering ≥1 portion;
  2. display a UI "according to a preset screen mode" on that portion;
  3. detect a user gesture while covered;
  4. display a second UI "generated from at least one application" in response.

Apparatus claim. display + first sensor for cover open/close (+ window) + second sensor for user gesture + controller performing the claim-1 call flow.

Representative dependents. Adjacency detected by ≥1 sensor (claim 2) or by a device-moving gesture (claim 3); sensing information (e.g., illumination value) threshold (claims 4/5); post-user-input gesture trigger (claim 6); plus the specification's second-gesture termination, key-input trigger, and resized-screen features.


III. Prior-art landscape (categories and representative art)

Element Prior-art category Representative art / basis
Cover detecting "covered" state Magnet/Hall-effect, reed switch, or optical (illumination/proximity) detection of a hinged or folio cover Ubiquitous in flip/folder phones (magnetic closure sensing) and in magnetically-attached tablet covers such as Apple's iPad Smart Cover (2011) and its associated "cover for an electronic device" patents [VERIFY number]; the patent itself concedes this (magnet separations 202a/203a, shielding units, illumination-sensor alternatives)
Window in the cover through which the display is visible Transparent/translucent window or aperture in a flip cover The patent's own "Definitions" concedes "screen projection window" as an at least partially transparent or translucent window; transparent-window folio covers were commercially available (see § V.B)
Display of incoming-call information Conventional call UI (caller name/number, answer affordance) Admitted prior art; the patent describes displaying counterpart info as a mere design choice
Detect external object adjacent to display, then connect call IR/ultrasonic proximity sensors used to detect the user's ear/head near the phone, commonly to blank the screen during a call; and "bring-to-ear" / "raise-to-answer" auto-answer The patent's own sensor module 170 recites a proximity sensor as known; original-iPhone-era and Android-era handsets used proximity to detect ear adjacency during calls
UI/gesture switching within a restricted window ("second UI from an application") Resized/adapted screen in a small region; swipe/flick to page between application screens Admitted prior art — the patent concedes "resizing," "panning," "scrolling," "flick," "swipe," "tap," "double tap" as known, and describes changing the standby screen to a recent-apps list, address list, music list, or recent-calls list as a design choice
Sensors for gesture detection accelerometer/gyro/motion sensor Admitted: the patent recites motion/acceleration/gyro sensors as known

Caveat: the table is a category map. To chart the claims against specific references, the actual "Patent Citations"/"Cited By" lists and the KR/JP family search reports must be pulled (see § VIII). I have deliberately not invented reference numbers to fill the table.


IV. Combination 1 — renders claim 1 obvious (strongest § 103 case)

References combined:

  • A (cover-state + window cover): a folio/flip cover with a magnetic closure sensed by a Hall/reed sensor (or the illumination/proximity alternative the patent itself concedes), where the cover has a transparent window over part of the display.
  • B (proximity-triggered call handling): a handheld phone using a proximity sensor to detect an object (the user's ear) adjacent to the display surface, and a "raise/bring-to-ear → answer" convention.
  • C (call-info UI): conventional incoming-call screen rendering.

Element-by-element:

  • Lim. 1 — Reference A (magnet/Hall cover detection).
  • Lim. 2 — reference C's normal call stack; receiving a call is not a patentable step.
  • Lim. 3 — placing C's call UI into A's window is the predictable use of A's window for its established function (viewing covered display content).
  • Lim. 4 — Reference B's proximity sensor.
  • Lim. 5 — Reference B's ear-adjacency → answer.

Motivation / reasonable expectation of success (KSR):

  1. Covers were universally adopted for protection; manufacturers faced the known problem that a closed cover blocks the display. Adding a window to view information while closed is the natural solution (and the patent concedes such windows).
  2. A closed folio physically removes access to the touchscreen; the only interaction channels remaining are (i) the window and (ii) the device's existing sensors. A POSITA would look to the sensors already present — including the proximity sensor ubiquitous for in-call screen blanking — because they are the remaining human-interface path.
  3. Re-purposing an existing proximity sensor to also answer a call is a predictable use of a known element for its known function — the core of KSR. No physical or functional incompatibility exists; both use the same sensor reading.
  4. Because the call already arrives while the cover is closed (lim. 2/3), answering by proximity avoids forcing the user to open the cover — a direct, articulated benefit.

Anticipation vs. obviousness. Depending on the exact scope of reference B's disclosure, claim 1 may even be anticipated (if B discloses answering upon ear-proximity while the display is covered/off); otherwise, obvious. The residual "hook" for the patentee is the specific combination of a closed window cover + window-rendered call UI + ear-proximity answer, but each element is separately known and their union is a predictable aggregation.


V. Combination 2 — renders the second method claim (window UI + gesture) obvious

References combined:

  • A (window cover + cover-state detection) as above.
  • D (mode/resized screen in a restricted region): rendering a scaled/adapted screen configured for a small window while the cover is closed (the patent concedes resizing; e.g., a "cover mode"/window-mode home screen).
  • E (gesture paging between application screens): swipe/flick, long-press, and similar gestures to move among application screens or lists — admitted prior art.

Element mapping: lim. 1 = A; lim. 2 = D (preset screen mode on the window portion); lim. 3 = E's gesture detection; lim. 4 = E's gesture-driven transition to another application-generated screen (recent-apps list, contacts, music, call log — all design choices).

Motivation: A window covers ~5–15% of the display and cannot show a full home screen legibly, so resizing and paging are the ordinary ways to expose multiple applications through it. Because the touch layer is still active beneath the window, using established swipe/flick gestures to cycle application screens is the predictable extension of known gesture navigation to a smaller canvas. The patent's own Figure 11 sequence (standby → recent apps → address list → music list → call list) is a straightforward application of that known technique.

V.B — The priority-date vulnerability (flag this explicitly)

The window-cover interaction paradigm became commercially public after 2013‑03‑14: LG's QuickWindow case for the G2 was announced around August 2013, and HTC's Dot View followed in 2014. These post-date the 2013‑03‑14 provisional but pre-date the 2014‑02‑12 KR priority. Therefore:

  • If the 2013 provisional does not support the second independent claim (window-mode UI + gesture-driven second UI) — a real and common situation where claim scope is added at the KR/US stage — the effective date for those limitations slides to 2014‑02‑12, and LG QuickWindow (Aug 2013) and similar mid-2013 window-cover launches become § 102/§ 103 art for those claims.
  • This is the single highest-leverage invalidity theory here, and it is not something the patentee can cure by argument alone; it requires comparing the provisional's disclosure to each limitation. Prioritize this.

VI. Combination 3 — renders the apparatus claim obvious

References: A (window cover + cover-state sensor, the "first sensor") + F (device-motion/gesture sensor, the "second sensor" — accelerometer/gyro, admitted) + C/B (call UI + proximity answer) + a conventional controller.

The apparatus claim is essentially the claim-1 method plus generic hardware. Each hardware element (display, cover sensor, gesture sensor, controller) was known; combining them in one handset is the routine aggregation of off-the-shelf components. The "second sensor … detect a user's gesture" reads on the accelerometer/gyro/motion sensor the patent itself lists as known. Obviousness here is at least as strong as for claim 1.

Dependents.

  • Claims to "adjacency detected by ≥1 sensor" / "by a device-moving gesture" (claims 2–3): both are the ordinary, disclosed implementations of claim 1; a device-motion gesture (raise-to-answer) is the well-known alternative to ear-proximity, so the alternative is obvious.
  • Claims on illumination-value threshold / post-key-input trigger (claims 4–6): ambient-light sensing and a physical key as a "wake" trigger are admitted prior art (illumination sensor; power/lock button). The specification's own "second gesture must be different direction" and "opposite-direction gesture terminates" limitations are arbitrary design choices absent demonstrated criticality — obvious under KSR's "predictable variation."

VII. Where the patent's validity is weakest / strongest

Weakest (best § 103 targets):

  1. Claim 1 — the union of the four known building blocks; the "hook" is only the context (cover closed), which is a non-functional, environment-based limitation that does not change how proximity detection works.
  2. The apparatus claim — generic hardware aggregation.
  3. The second method claim if the priority date is pushed to 2014‑02‑12 (§ V.B), exposing LG QuickWindow.

Relatively stronger (narrower) positions:

  • Claims requiring the specific window geometry/resizing mapping (storing the window area as coordinate values, per FIG. 13) may resist a broad combination if the art shows differently-arranged windows.
  • Any dependent claim reciting the specific ear-vs-hover disambiguation (the spec's "hovering over >50% of the first display area") is narrower and would need a closer reference.

No claim is immune. Because no AIA trial ever construed these claims (see the PTAB section), there is no prior Board construction to contend with — but there is also no estoppel cushion for the patentee; all grounds remain open.


VIII. Secondary considerations

  • Commercial success: the Galaxy S‑View cover (2013) and the present patent's cover‑window UI enjoyed commercial success. But under In re GPAC / WBIP, commercial success must have a nexus to the claimed invention; the success is at least equally attributable to the smartphone itself and to cover protection generally. Expect this argument to be contested and probably insufficient.
  • Copying: if LG/HTC window-cover launches are characterized by the patentee as copying, that favors non-obviousness — but the chronology cuts the other way for the priority analysis (§ V.B), because those products may pre-date the perfected priority.
  • Unexpected results: none apparent in the specification. The stated benefit ("functions can be conveniently performed while the cover is mounted") is the expected, not surprising, consequence of the combination — which under KSR weighs toward obviousness.

IX. Verification checklist (required before relying on any of the above)

  1. Pull the actual cited-reference list for US 9,438,713 and US 2014/0274217 A1 from PatentCenter (app. 14/214,069) and the Google Patents "Citations/Cited By/Similar Documents" tables at https://patents.google.com/patent/US9438713/en — this memo could not obtain them, so the combinations above are built from admitted art and category-level knowledge, not from the patent's own citation set.
  2. Confirm the granted claim set and numbering — the earlier sections flagged that claims beyond the first several were truncated and that the "independent claims" were characterized, not quoted. Element mapping above is to the patent's own summaries; re-map to verbatim claims.
  3. Test § V.B first: compare the 61/784,012 provisional to the second independent claim to determine whether the window-UI/gesture limitations are entitled to 2014‑02‑12; if not, add mid‑2013 window-cover art (LG QuickWindow) as § 102/§ 103 references.
  4. Confirm the date/priority of every named reference (especially the Apple "cover for an electronic device" family, flagged [VERIFY]) against the 2013‑03‑14 and 2014‑02‑12 critical dates before filing anything.
  5. Then run a fresh prior-art search keyed to the limitations — ear-proximity call connect while a display-covering accessory is closed; window-cover inset UI; gesture paging in a partial window.

Cross-reference / consistency check with the earlier sections. No contradiction: the earlier "Patent summary" and "PTAB challenges" sections both noted the verbatim claim set was not fully retrieved, and my element mapping here inherits that limitation. One item to reconcile: the earlier summary labeled the KR family member "KR 10‑2188463 B1"; the Google Patents data quoted in the full text reads KR102188463B1 — these are the same document (KR 10‑2188463), stated here only so the identifiers are not confused.

Confidence note: Medium confidence in the legal conclusions (each is a conventional KSR combination of admitted or well-known elements). Lower confidence in specific reference identities, because the patent's own prior-art citation table was unavailable to this analysis — that gap is the controlling caveat on everything above.

Generated 9/28/2026, 8:24:56 PM

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