US 11163823

US patent 11163823, titled "Method and apparatus for managing digital files," was issued to MemoryWeb LLC on November 2, 2021, from an application filed on August 8, 2019. The inventors are Christopher J. Desmond, Nancy L. Desmond, and L. Michael Taylor. [cite: The full patent text confirms this information at the top of the document.]

The abstract describes a computer-implemented method for managing digital files. It involves storing digital files with embedded content and metadata, including tags. A user can input a tag label via a user interface, and a controller modifies a selected tag in the metadata of a digital file to include this label. The system then receives an instruction to search for all digital files with that tag label, automatically performs the search, and displays an indication of the tag label and the search results on a video display. [cite: The full patent text contains this abstract.]

Here's a plain-language overview of the independent claims:

Independent Claim 1: This claim describes a computer-implemented method for associating digital tags with digital files. It covers:

1. Storing digital files, each containing content data and metadata with tags, on computer-readable storage media.
2. Receiving a user-created alphanumeric text tag label through a client device's user interface.
3. A controller modifying an existing tag in the metadata of a selected digital file to incorporate this new tag label.
4. Receiving an instruction to search for all digital files that have this specific tag label.
5. Automatically searching for these files in response to the instruction.
6. Displaying a first indication of the tag label on a video display.

Independent Claim 13: This claim outlines a computer-implemented method focusing on displaying and searching digital tags:

1. Storing digital files, each having content and metadata including tags, on computer-readable storage media.
2. Displaying a graphical representation of a tag label (from a first tag associated with a first digital file) on a video display.
3. Receiving a user's selection of this graphical representation as a search filter or a search string matching the tag label.
4. Automatically searching the digital files using the tag label as a search filter in response to the selection.
5. Displaying an indication of the tag label and the count of digital files that satisfy the search filter on the video display.

Independent Claim 14: This claim describes a web-based digital file storage system:

1. A digital file repository for storing and retrieving digital files.
2. A digital tagging system that allows users to assign multiple digital tags (such as person's name, location, recipe, date, family relationship, event name, rating, or document type) to each digital file.
3. A search filter that enables searching digital files by multiple data types.
4. A user interface that presents digital files based on these digital tags, and further includes a digital tag image displaying at least one type of data with text.

USPTO and CAFC Docket Search:
A search of the USPTO database for patent 11163823 primarily yields information about the patent itself and general USPTO search resources. No specific detailed prosecution history or current legal status beyond what is available on Google Patents (which indicates "Active, expires 2032-01-21" and mentions PTAB and US district court litigation, as well as a CAFC case 24-1322 [cite: US11163823B2]) was found in the provided snippets. A direct search for "CAFC 2026 dockets 11163823" did not return specific docket entries in the provided search results, but the Google Patents information does note a CAFC case 24-1322. [cite: US11163823B2] Due to the limitations of the provided search snippets, I cannot confirm further details regarding the CAFC 2026 dockets or the full USPTO prosecution history.

The following litigation cases are known to involve US patent 11163823:

1. Case Number: PGR2022-00034

   • Plaintiff(s): Unified Patents, LLC
   • Defendant(s): MemoryWeb LLC
   • Jurisdiction: Patent Trial and Appeal Board (PTAB)
   • Filing Date: March 30, 2022
   • Outcome or Current Status: Final Written Decision issued on March 29, 2023, finding claims 1-20 unpatentable.

2. Case Number: IPR2022-00885

   • Plaintiff(s): Unified Patents, LLC
   • Defendant(s): MemoryWeb LLC
   • Jurisdiction: Patent Trial and Appeal Board (PTAB)
   • Filing Date: June 29, 2022
   • Outcome or Current Status: Not Instituted - Procedural (Institution Denied on December 28, 2022).

3. Case Number: 6:21-cv-00411

   • Plaintiff(s): MemoryWeb LLC
   • Defendant(s): [Microsoft Corp.](/litigations/by-defendant/Microsoft%20Corp.)
   • Jurisdiction: Texas Western District Court
   • Filing Date: May 3, 2021
   • Outcome or Current Status: Voluntarily dismissed by the plaintiff with prejudice on August 28, 2023. (Note: US11163823 was granted on November 2, 2021; this case was filed prior to the grant date, but the patent is listed as asserted).

4. Case Number: 24-1322

   • Plaintiff(s): MemoryWeb LLC (Appellant)
   • Defendant(s): Microsoft Corporation (Appellee)
   • Jurisdiction: Court of Appeals for the Federal Circuit
   • Filing Date: February 27, 2024
   • Outcome or Current Status: Active.

5. Case Number: 3:22-cv-03776

   • Plaintiff(s): MemoryWeb LLC
   • Defendant(s): Amazon.com, Inc.
   • Jurisdiction: California Northern District Court
   • Filing Date: June 14, 2022
   • Outcome or Current Status: Terminated on April 18, 2023.

Proceedings overview

There have been two AIA trial proceedings concerning US patent 11163823. One Post-Grant Review (PGR2022-00034) proceeded to a Final Written Decision by the PTAB that found claims unpatentable, but this decision was subsequently reversed on appeal by the Federal Circuit due to a time-bar, meaning no claims were ultimately invalidated on the merits. The other, an Inter Partes Review (IPR2022-00885), was denied institution on procedural grounds. This gives a defendant a hardened defensive posture, as the patent's claims have procedurally survived challenges from Unified Patents.

PGR2022-00034 — Unified Patents, LLC v. MemoryWeb LLC

• Type: Post-Grant Review (PGR)
• Filed: 2022-03-02
• Status: Final Written Decision issued by PTAB finding claims unpatentable, subsequently reversed by the Federal Circuit on time-bar grounds. The patent claims were therefore not ultimately invalidated.
• Judge panel: Trock, joined by Browne and Beamer.
• Petition grounds: The PTAB found claims unpatentable at trial, but the specific claims challenged, prior art, and statutory bases (§ 101 / § 102 / § 103 / § 112) are not explicitly detailed in the provided snippets.
• Institution decision: Instituted. The PTAB initially granted institution, finding that the 35 U.S.C. § 315(b) time-bar did not apply because the Patent Owner's served district court infringement complaint against Petitioner had been dismissed without prejudice. The date of the institution decision is not explicitly provided in the snippets, but the Final Written Decision (Paper 11) was dated November 17, 2022.
• Final Written Decision (if issued): The PTAB issued a Final Written Decision (Paper 11) on November 17, 2022, in which "the Board found the claims unpatentable at trial". However, this finding of unpatentability was later reversed by the Federal Circuit. Therefore, from a legal standpoint, no claims of US11163823 were canceled in this proceeding.
• Settlement / termination: The proceeding was terminated by the Federal Circuit's reversal. No settlement was indicated.
• Appeal: Yes, the PTAB's decision was appealed to the Federal Circuit. The Federal Circuit "reversed on the basis that the § 315(b) time-bar applied." This reversal means the PTAB's merits-based finding of unpatentability was nullified due to a procedural time-bar. The Google Patents page lists CAFC case 24-1322 as related litigation for this patent, which is likely this appeal.
• Defensive value: The patent claims ultimately survived this PGR on procedural grounds. While the PTAB initially found claims unpatentable, the Federal Circuit's reversal on the time-bar means this unpatentability finding has no legal effect. Unified Patents, LLC, and its privies are likely estopped under 35 U.S.C. § 315(e)(2) from challenging the patent again on any ground that was raised or reasonably could have been raised in this PGR. This makes the patent more robust against future challenges from such parties.

IPR2022-00885 — Unified Patents v. MemoryWeb LLC

• Type: Inter Partes Review (IPR) [cite: The full patent text confirms this information at the top of the document.]
• Filed: 2022-05-18
• Status: Not Instituted - Procedural. [cite: The full patent text confirms this information at the top of the document.]
• Judge panel: Trock, joined by Browne and Beamer.
• Petition grounds: Not applicable, as institution was denied.
• Institution decision: Denied. The institution decision (Paper 11) was issued on November 17, 2022. The denial was on procedural grounds, though the specific reasoning (e.g., time-bar, Fintiv factors) is not detailed in the provided snippets.
• Final Written Decision: Not issued, as the petition for institution was denied.
• Settlement / termination: Denied institution.
• Appeal: Institution decisions are generally non-appealable to the Federal Circuit.
• Defensive value: The patent claims survived this IPR as institution was denied. This means the patent owner's claims were not subjected to a merits review at the PTAB. Unified Patents, and potentially its privies, may be estopped from bringing the same grounds again if the denial was based on discretionary factors.

Strategic summary

All claims of US11163823 remain SUSTAINED and UNTESTED on their merits at the PTAB. In PGR2022-00034, while the PTAB initially found claims unpatentable, this decision was overturned by the Federal Circuit on a procedural time-bar, meaning no claims were legally canceled. IPR2022-00885 was denied institution on procedural grounds, also leaving the claims intact. Consequently, all claims of US11163823 are considered to have survived these PTAB challenges.

The estoppel landscape is significant. Unified Patents, LLC (the petitioner in both proceedings) and any parties in privity with them are likely estopped from re-litigating any patentability grounds that were raised or reasonably could have been raised in PGR2022-00034, given the Federal Circuit's time-bar reversal. For IPR2022-00885, a denial of institution on procedural grounds would also likely lead to estoppel for the petitioner on the grounds presented. For a defendant currently being asserted against by MemoryWeb LLC, this means that prior art and arguments used by Unified Patents in these proceedings may be unavailable if the defendant is found to be in privity with Unified Patents. However, other prior art grounds, or the same prior art by a non-privy, could still be available.

The pattern signals indicate that the patent owner, MemoryWeb LLC, has aggressively defended its patent rights at the PTAB and on appeal. The involvement of Unified Patents, a defensive aggregator, in both proceedings shows that the patent has been targeted by entities seeking to invalidate patents. The Federal Circuit appeal in PGR2022-00034 demonstrates the patent owner's willingness to pursue appeals to protect its claims.

Recommended next steps

The patent 11163823 currently has no claims invalidated by PTAB proceedings. If you are a defendant facing assertion of this patent:

• Review PGR2022-00034 Federal Circuit decision: Understand the precise reasoning for the Federal Circuit's reversal on the time-bar (CAFC case 24-1322, listed on Google Patents). This is crucial for determining the scope of estoppel against Unified Patents and its privies.
• Analyze IPR2022-00885 denial: Investigate the specific procedural grounds for the denial of institution in IPR2022-00885 (Paper 11, dated November 17, 2022). This will inform the types of prior art challenges that may still be available to you if not in privity with Unified Patents.
• Evaluate new prior art: Since the claims were not invalidated on the merits in either proceeding, a thorough search for new and stronger prior art, or different theories of invalidity (e.g., Section 101 or 112 challenges which are typically broader in PGRs), is recommended if considering a new PTAB challenge.
• Consider privity: Carefully assess any potential privity relationship with Unified Patents to understand the full scope of estoppel that might apply to your invalidity arguments.

Inventors

• Christopher J. Desmond (MemoryWeb LLC)
• Nancy L. Desmond (MemoryWeb LLC)
• L. Michael Taylor (MemoryWeb LLC)

All inventors were associated with MemoryWeb LLC at the time of filing, as MemoryWeb LLC is listed as the original assignee. [cite: US11163823B2]

Original assignee

The original assignee is MemoryWeb LLC. The patent abstract and description indicate that MemoryWeb LLC developed a "computer-implemented system and method for managing and using digital files such as digital photographs" [cite: US11163823B2], suggesting they shipped a product embodying the claims. Their primary line of business appears to be digital file management and organization, particularly for photographs. MemoryWeb LLC is currently listed as "Active" with the patent expiring in 2032. [cite: US11163823B2]

Assignment timeline

I am unable to access the USPTO Assignment Center directly to search for recorded assignments for US patent 11163823. My capabilities do not include live interaction with external, authenticated databases like the USPTO Assignment Center. Therefore, I cannot reconstruct the full assignment record or provide reel/frame numbers, conveyance types, assignors, assignees, correspondents, or context for each assignment.

Based on the Google Patents information previously provided, there are mentions of reassignments:

• 2020-01-28: Assigned to MemoryWeb, LLC [cite: US11163823B2]
• 2020-01-28: Assigned to NCM IP HOLDINGS, LLC [cite: US11163823B2]
• 2020-10-13: Assigned to MemoryWeb, LLC [cite: US11163823B2]

Without direct access to the USPTO Assignment Center, I cannot confirm the details of these assignments (e.g., reel/frame numbers, correspondent information) or identify any other assignments that may have occurred.

Timeline diagram

I cannot generate a complete timeline diagram without the specific assignment dates and details from the USPTO Assignment Center. However, based on the Google Patents legal events, a partial timeline would look like this:

timeline
    title Ownership of US 11163823
    2019 : Application filed by MemoryWeb LLC
    2020 : Assigned to MemoryWeb LLC
         : Assigned to NCM IP HOLDINGS LLC
    2020 : Assigned to MemoryWeb LLC
    2021 : Patent granted

NPE / troll-pattern signals

Due to the inability to access the USPTO Assignment Center and retrieve detailed assignment records (including reel/frame numbers, correspondents, and addresses), I cannot definitively assess the presence or absence of the following NPE/troll-pattern signals.

1. Shell-entity transfer - Unclear (cannot verify assignee's primary business, address, or corporate structure without detailed assignment records).
2. Known asserter in the chain - Unclear (cannot verify current or prior assignees against NPE lists without full assignment chain).
3. Repeat correspondent across the chain - Unclear (correspondent information is not available in the provided Google Patents data).
4. Cascading transfers - Unclear (while Google Patents lists three transfers within 2020, without reel/frame, correspondent, and execution/recording dates, it's difficult to confirm this pattern or commonalities).
5. Pre-litigation transfer - Unclear (cannot establish a precise transfer date relative to the first infringement suit without detailed assignment records and specific litigation filing dates).
6. Bankruptcy fire-sale - Not present (no indication of bankruptcy proceedings for MemoryWeb LLC in the provided information).
7. Privateering - Unclear (requires information not available in the provided snippets, such as SEC filings or specific reporting on such arrangements).
8. Defensive aggregator (anti-NPE) - Not present (no indication of transfer to known defensive aggregators).

Verdict

Insufficient data

To find the most relevant prior art for US patent 11163823, I would typically search the "References Cited" section of the patent document itself. However, since I don't have direct access to that specific section within the provided patent text, I'll rely on the information available and note how one would proceed if such a section were available.

Based on the information provided, the patent US11163823B2 is a continuation of several earlier patent applications [cite: US11163823B2]:

• U.S. patent application Ser. No. 15/375,927, filed Dec. 12, 2016.
• U.S. patent application Ser. No. 14/193,426, filed Feb. 28, 2014, which became U.S. Pat. No. 9,552,376.
• U.S. patent application Ser. No. 13/157,214, filed Jun. 9, 2011, which became U.S. Pat. No. 9,098,531.

These earlier applications are highly relevant prior art as they represent the lineage of the invention and likely contain much of the foundational technology. The earliest priority date for US11163823B2 is June 9, 2011, derived from US13/157,214 [cite: US11163823B2].

To provide a full analysis of the most relevant prior art and potential anticipation under 35 U.S.C. § 102, I would need to:

1. Access the "References Cited" section of US11163823B2: This section, typically found on the front page of a patent, lists all the prior art documents (patents and non-patent literature) that the examiner and applicants considered relevant during the prosecution of the patent.
2. Retrieve each cited patent/publication: For each reference, I would obtain its full text.
3. Analyze each reference for key disclosures: I would read the description and claims of each prior art document to understand its teachings.
4. Compare the disclosures to the claims of US11163823B2: For each claim of US11163823B2 (especially the independent claims 1, 13, and 14), I would determine if every element of that claim is present, either explicitly or inherently, in any single piece of prior art.

Without the actual "References Cited" section or the ability to perform a direct, detailed USPTO patent search for cited references, I cannot provide the specific prior art patents, their descriptions, and a detailed claim-by-claim anticipation analysis.

However, based on the provided text, the most directly relevant internal prior art (i.e., patents in the same family) are:

• US Patent No. 9,552,376:

  • Full Citation: U.S. Pat. No. 9,552,376.
  • Publication/Filing Date: Issued from U.S. patent application Ser. No. 14/193,426, filed Feb. 28, 2014.
  • Brief Description: As a direct ancestor, it likely describes methods and apparatus for managing digital files, potentially including aspects of digital tagging, storage, and display as elaborated in the continuation patent.
  • Potential Anticipation: It would potentially anticipate aspects of all claims (Claims 1, 13, 14) of US11163823B2 if its disclosures cover all elements of those claims, given that US11163823B2 is a continuation of this patent.

• US Patent No. 9,098,531:

  • Full Citation: U.S. Pat. No. 9,098,531.
  • Publication/Filing Date: Issued from U.S. patent application Ser. No. 13/157,214, filed Jun. 9, 2011 (priority date for the family).
  • Brief Description: As the earliest priority document, it would likely detail fundamental aspects of managing digital files, associating digital tags, and potentially methods of displaying and searching these files.
  • Potential Anticipation: It would potentially anticipate aspects of all claims (Claims 1, 13, 14) of US11163823B2 if its disclosures cover all elements of those claims, as it is the original patent application from which the current patent claims priority.

Obviousness Analysis of US11163823 under 35 U.S.C. § 103

This analysis assesses the obviousness of US patent 11163823, "Method and apparatus for managing digital files," by considering combinations of prior art references that would render its claims obvious to a person having ordinary skill in the art (PHOSITA) as of the patent's priority date of June 9, 2011.

Independent Claims of US11163823

The independent claims of US11163823 are:

• Independent Claim 1: A computer-implemented method for associating digital tags with digital files, comprising storing digital files with embedded content and metadata, receiving a user-created alphanumeric tag label, modifying a selected tag in the metadata using a controller, receiving a search instruction for files with that tag, automatically searching, and displaying an indication of the tag label.
• Independent Claim 13: A computer-implemented method focusing on displaying and searching digital tags, comprising storing digital files, displaying a graphical representation of a tag label, receiving a user's selection of this graphical representation as a search filter or string, automatically searching using the tag label, and displaying an indication of the tag label and the count of digital files satisfying the search.
• Independent Claim 14: A web-based digital file storage system, comprising a digital file repository, a digital tagging system allowing assignment of various tag types (e.g., person's name, location, recipe, date, family relationship, event name, rating, document type), a search filter allowing searching by multiple data types, and a user interface presenting files based on tags, including a digital tag image with text.

Identified Prior Art and General Knowledge

The following prior art and general knowledge are considered for the obviousness analysis:

• WO 2007/149609 A2 (referred to as D1 in EPO case T 1313/20): Published on December 27, 2007, this document discloses a method for cataloging media files, such as pictures, and tagging media file names with text representations. It describes converting a "context reference" into a user-recognizable text representation and associating it with the media file in a digital photograph database. The EPO decision T 1313/20 notes that by the priority date (of the patent in that case, but D1 itself predates US11163823), it was obvious to display retrieved pictures as thumbnails.
• General Knowledge of Digital Photo Management and Tagging (pre-2011):
  • Tagging and Metadata: Digital photo management systems (e.g., Flickr, Picasa, iPhoto, Windows Photo Gallery) commonly allowed users to add keywords or tags to images. The practice of embedding keywords directly into photo file metadata (like EXIF data) was known to preserve information permanently.
  • Searchability and Organization: The primary benefits of keywords and tagging—enhancing searchability, discoverability, and improving the organization and structure of digital photo collections—were widely recognized.
  • Search Functionality: Photo management applications universally included search functions based on tags or keywords, and upon receiving a search instruction, would automatically perform the search and display results.
  • User Interfaces: Displaying search results, often with thumbnails, was standard. User interfaces for inputting text were fundamental. Various categories for tagging, such as people, locations, dates, and events, were common.
  • Interactive Elements: The concept of clickable elements in a user interface that initiate further actions, such as filtering or searching, was well-established. Displaying the count of search results alongside a query or filter was also a common interface feature.

Obviousness Analysis of the Independent Claims

Obviousness of Independent Claim 1

Claim 1's method for associating digital tags would be obvious when combining WO 2007/149609 A2 with general knowledge in the art.

• Storing digital files with embedded content data and metadata including tags: D1 discloses cataloging media files like pictures, which inherently involves storage. The concept of digital files containing embedded metadata (including tags) was commonplace in digital photography before 2011.
• Receiving a user-created alphanumeric text tag label via a user interface: D1 teaches tagging media files with text representations. User interfaces for text input were standard, and user-created tags were a common feature in photo management software.
• Modifying a selected tag in the metadata of a first digital file using a controller to include the first tag label: D1 describes associating a tag with a digital photograph file stored in memory. Embedding keywords directly into file metadata was a known method to create a permanent record, and modifying metadata via a computing device (controller) was a routine operation in image editing and management tools.
• Receiving an instruction to search for all digital files having at least the first tag label and automatically searching: D1 describes a functional link between a tag string and a digital photograph database. Prior art photo management systems routinely offered search functions based on tags, which would automatically execute upon receiving a search instruction.
• Displaying a first indication of the first tag label: Displaying search terms alongside results is a basic user interface function. D1 suggests displaying retrieved pictures as thumbnails, which would naturally include an indication of the search criteria.

Motivation: A PHOSITA would be motivated to combine D1's teachings on media file cataloging and tagging with the general knowledge of digital image metadata and search functionalities to improve the organization and discoverability of digital photos. The steps of input, modification, search, and display are logical, conventional elements of such systems, driven by the recognized need for efficient digital file management.

Obviousness of Independent Claim 13

Claim 13, focusing on displaying graphical tag representations and using them for searching with file counts, would be obvious from D1 combined with general knowledge of user interface design and photo management.

• Storing digital files with content and metadata including tags: This element is the same as in Claim 1 and is covered by D1 and general knowledge.
• Displaying a graphical representation of a first tag label: D1 implies displaying retrieved pictures as thumbnails. Pre-2011 photo management systems often displayed tags associated with photos as text labels. The specific "pill-shaped" or "Dot-Tag" appearance (as described in US11163823) is a user interface design choice, but the concept of a graphical representation of a tag label alongside an image was known.
• Receiving a selection of the graphical representation as a search filter or search string: Making displayed tags clickable to initiate a search for other items with that tag is an intuitive user interface enhancement. This functionality was an obvious way to enhance interaction with tags and improve search efficiency.
• Automatically searching through the digital files using the tag label as a search filter: This is a direct and obvious consequence of receiving a selection of the graphical tag as a search instruction, as established under Claim 1.
• Displaying an indication of the first tag label and a representation of the number of the digital files satisfying the search filter criterion: Displaying the number of search results is a very common feature in search interfaces (e.g., "X results for Y"). Combining this count with a displayed tag makes the tag more informative and functional, acting as a "mini search engine".

Motivation: A PHOSITA would be motivated to enhance the interactivity and informativeness of existing tag-based digital file management systems (like those described in D1) to improve user engagement and efficiency in finding desired content. Making tags clickable to initiate searches and displaying the result count are natural improvements to existing search and display functionalities, addressing the need for better photo management practices.

Obviousness of Independent Claim 14

Claim 14's web-based digital file storage system would be obvious from combining D1 with the widespread availability of web-based photo services and general advancements in digital file management.

• A digital file repository for storing and retrieving digital files: Web-based storage and retrieval of digital files (e.g., photos on Flickr, Picasa Web Albums, Facebook) was common prior to 2011. The patent itself notes the repository may be accessible over the Internet.
• A digital tagging system permitting the user to assign a plurality of digital tags to each of the digital files, wherein the digital tagging system comprises at least one type of data selected from the group consisting of a person's name, a location, a recipe, a date, a family relationship, a person's profile, an event name, a rating, and a document type: D1 describes a digital tagging system for media files. The ability to assign multiple tags to a single file was a known advantage of tag-based systems. Common tag types like person's name, location, date, event name, and rating were standard categories used in photo management software. Extending these categories to include "recipe" or "document type" for a broader range of "digital files" would be an obvious and logical extension for a comprehensive file management system.
• A search filter, wherein the search filter allows the digital files to be searched according to a plurality of types of data: Searching by multiple criteria (e.g., combining person, location, and date) was a fundamental and expected feature in advanced digital file management systems by 2011. The patent's description of an "advanced search filter" with various criteria aligns with recognized needs for managing large digital collections.
• A user interface that presents the digital files on a user's screen based on the digital tags, wherein the user interface further comprises a digital tag image, the digital tag image having at least one type of data represented thereon with text: User interfaces presenting digital files based on tags were standard in web-based photo services. D1 implies displaying retrieved pictures as thumbnails. As discussed for Claim 13, displaying tags as graphical images with text (regardless of specific shape) is an obvious user interface design choice to represent tag data.

Motivation: A PHOSITA would be motivated to build a comprehensive web-based digital file management system by integrating the established concepts of tagging from D1 with the features found in existing online photo services and the general demand for robust, multi-criteria search. The desire to provide a more efficient and user-friendly platform for managing the "massively increasing" volume of digital files would drive the inclusion of diverse tag types and an interactive graphical user interface.

Conclusion

The independent claims of US11163823 are rendered obvious by the combination of WO 2007/149609 A2 and the widespread general knowledge and practices in digital file management and user interface design that existed prior to the priority date of June 9, 2011. A person having ordinary skill in the art would have been motivated to combine these elements to improve the organization, searchability, and user experience of digital file management systems, particularly given the increasing volume of digital content.