Apple Inc. v. SpaceTime3D, Inc.

Apple Inc. v. SpaceTime3D, Inc. The Federal Circuit affirmed the Board across the board: claims 1-13 remained not proven unpatentable, and claims 14-18 remained unpatentable. The court upheld the Board's claim constructions, its refusal to consider Apple's reply-stage browser-caching theory and evidence, and its obviousness fact findings. The decision reinforces that IPR petitioners cannot use reply evidence and new prior art to supply a missing claim limitation, even when responding to a post-institution claim-construction dispute. Affirmed. Each party bears its own costs. For claims 1-13, the court affirmed the construction of "the rendered first webpage" as the rendered version from which the corresponding image was captured, relying on the claim's antecedent structure and the specification. Substantial evidence supported the Board's finding that the prior art did not teach displaying that previously rendered version, rather than rendering the webpage anew after user selection. The Board did not abuse its discretion by excluding Apple's reply-stage browser-caching evidence because it introduced a new theory and new prior art to fill a gap in the petition. For claims 14-18, the court agreed that "the first webpage" is broader than "the rendered first webpage" and does not require the same previously rendered version. The court also affirmed the Board's findings that the asserted art taught a window in a 2D space and the claimed foreground/background relationship in the 3D space. § 103 claim construction waiver / forfeiture non-precedential § 103 claim construction waiver / forfeiture non-precedential § 103 claim construction waiver / forfeiture