IP Law Daily, PATENT—Fed. Cir.: PTAB’s obviousness finding affirmed in computer photo display patent dispute, (Dec 19, 2025)

By Kevin M. Finson, J.D.

Claims relating to display of photographs based on the location they were taken were properly found obvious by the PTAB because the factual findings about the teachings of the prior art were supported by substantial evidence in the form of expert testimony.

MemoryWeb, LLC failed to show any error in a Patent Trial and Appeal Board ruling determining that challenged claims of its patent directed to tagging digital files with location information were unpatentable as obvious in view of prior art, U.S. Court of Appeals for the Federal Circuit has held. The Board had properly relied on expert testimony and was not required to perform claim construction when it had determined that adopting the moving party’s proposed construction would not alter the obviousness analysis (MemoryWeb, LLC v. Samsung Electronics Co., Ltd., No. 2024-1322, (E.D.N.Y. Dec. 19, 2025)).

MemoryWeb, LLC was the owner of U.S. Patent No. 11,163,823 (the ’823 patent), which was “directed to computer-implemented methods and systems for managing and displaying digital files, such as photographs.” The patent described tagging photographs with various information and included a “location view” which identified within an interactive map the locations where digital files were taken or originated. Samsung Electronics Co, Ltd. (Samsung) petitioned for post-grant review of claims 1-34 on the ground of obviousness in view of several prior art references, including two references which described the Apple iPhoto ’09 program. The Patent Trial and Appeal Board (PTAB) found all of the challenged claims unpatentable. MemoryWeb appealed.

Prior art. MemoryWeb argued that the Board erred in finding that the prior art references disclosed the displaying of the claimed location view “responsive to a second input” and that the Board ought to have performed an inherency analysis.

The Federal Circuit found that the arguments made by Samsung below did not actually invoke inherency, but instead simply interpreted the prior art reference to read that selecting the “Places” tab on the source pane in iPhoto could lead to either the “browser view” or the “world view,” which was argued to be equivalent to the “location view” described in the ’823 patent. This understanding of the prior art was supported by expert testimony, so the court found no error.

Claim construction. MemoryWeb argued that the Board erred by declining to construe the term “responsive to.” The court found that the Board’s factual findings that the claims would be obvious even under MemoryWeb’s proposed construction obviated the need for construction of that term.

The Federal Circuit affirmed decision of the Board.

The Case is No. 24-1322.

Judge: Schall, A.

Attorneys: Angelo Christopher (Nixon Peabody LLP) for MemoryWeb, LLC. Christopher Dryer (Fish & Richardson PC) for Samsung Electronics Co., Ltd.

Companies: MemoryWeb, LLC. ; Samsung Electronics Co., Ltd.

Cases: Patent FedCirNews USPTO