DCT

7:26-cv-00033

Peer Global Inc v. Apple Inc

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Amended Complaint
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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: Peer Global Inc. v. Apple Inc., 7:26-cv-00033, W.D. Tex., 04/24/2026
  • Venue Allegations: Plaintiff alleges venue is proper in the Western District of Texas because Apple maintains numerous regular and established places of business in the district-including two corporate campuses and multiple retail stores in Austin-and has committed the alleged acts of infringement there.
  • Core Dispute: Plaintiff alleges that Defendant's "Liquid Glass" user interface features, implemented in iOS 26, iPadOS 26, and associated applications, infringe three patents related to a "selection ring" UI primitive for navigating immersive environments.
  • Technical Context: The technology relates to user interface design, specifically methods for selecting on-screen elements that aim to be more fluid and intuitive than traditional cursor-based, point-and-click systems.
  • Key Procedural History: The complaint is a First Amended Complaint. The asserted patents all claim priority to a provisional application filed in 2016. The complaint alleges that Apple's willfulness began upon receiving notice of the lawsuit, indicating a theory of post-suit willfulness.

Case Timeline

Date Event
2016-05-10 Earliest Priority Date for all Patents-in-Suit (U.S. Provisional Application No. 62/334,318)
2021-10-05 U.S. Patent No. 11,137,878 Issued
2023-05-16 U.S. Patent No. 11,650,712 Issued
2024-04-23 U.S. Patent No. 11,966,559 Issued
2025-09-15 Alleged public release of infringing iOS 26
2026-02-04 Alleged date of notice for willful infringement claim
2026-04-24 First Amended Complaint filed

II. Technology and Patent(s)-in-Suit Analysis

U.S. Patent No. 11,137,878: "Selection Ring User Interface" (Issued 10/05/2021)

The Invention Explained

  • Problem Addressed: The patent's background section describes conventional social media network interfaces as inefficient for navigation, requiring users to scroll through large amounts of content to find older posts and limiting content discovery to a purely chronological feed ʼ878 Patent, col. 1:23-34
  • The Patented Solution: The invention is a method for a user interface control system. It involves presenting a "selection ring" over an existing graphical user interface (GUI). When a user selects the ring, a plurality of function icons appear. The user can then move the ring over one of the icons to select it, which in turn presents a second, different GUI. This process is intended to allow for rapid, fluid selections without altering the underlying display or requiring precise pointer clicks ʼ878 Patent, col. 17:38-18:3 ʼ878 Patent, claim 1 Figures 3B-3F illustrate this sequence, showing the selection ring (152) appearing, revealing icons (162, 164, 166), and being manipulated to make a selection.
  • Technical Importance: The technology aims to provide a more intuitive and continuous method of interaction for immersive or content-rich digital environments, reducing visual clutter and friction compared to traditional menu-based or cursor-based systems Compl. ¶12

Key Claims at a Glance

  • The complaint asserts independent claim 1 Compl. ¶30
  • The essential elements of independent claim 1 include:
    • Presenting a first graphical user interface with information.
    • Presenting a "selection ring" to the user in the first GUI "without altering the presentation of information" within that GUI.
    • Receiving a selection of the ring, which enables the user to "manipulate a position" of the ring.
    • Presenting a "plurality of icons" in response to the ring's selection.
    • Receiving user manipulation of the ring's positioning "without altering a location of the plurality of icons".
    • Receiving a selection of an icon based on the ring's position relative to the icon.
    • Presenting a second graphical user interface based on the selected icon.
  • The complaint reserves the right to assert additional claims Compl. ¶30

U.S. Patent No. 11,650,712: "Selection Ring User Interface" (Issued 05/16/2023)

The Invention Explained

  • Problem Addressed: As with its parent, the '878 Patent, this patent addresses the inefficiency and lack of intuitive navigation in conventional user interfaces, which rely on scrolling through large amounts of content ʼ712 Patent, col. 1:19-50
  • The Patented Solution: The solution is also a "selection ring" interface method. However, the claimed method differs in its sequence of operations. This patent claims a method where, in response to a first selection of the ring, icons are presented. Then, after the user manipulates the ring's position, an icon is selected in response to a second selection associated with the ring. This introduces a two-step selection process into the method '712 Patent, claim 1 The specification and figures illustrating the concept are substantially identical to those in the '878 Patent.
  • Technical Importance: The technology provides an alternative sequence for fluid UI interaction, aiming to improve user experience in immersive digital environments by moving beyond traditional point-and-click paradigms Compl. ¶12

Key Claims at a Glance

  • The complaint asserts independent claim 1 Compl. ¶44
  • The essential elements of independent claim 1 include:
    • Presenting a "selection ring" in a first graphical user interface.
    • "In response to receiving a first selection" of the ring, presenting a "plurality of icons".
    • Receiving user manipulation of the ring's position "without altering a location" of the icons.
    • "In response to receiving a second selection" associated with the ring, selecting an icon based on the ring's position.
    • Presenting a second graphical user interface based on the selected icon.
  • The complaint reserves the right to assert additional claims Compl. ¶44

U.S. Patent No. 11,966,559, "Selection Ring User Interface" (Issued 04/23/2024)

  • Technology Synopsis: The patent addresses inefficient user interface navigation by disclosing a "selection ring" primitive. The method involves activating the ring to present a plurality of selectable icons. A user then manipulates the ring's position relative to an icon to select it, which in turn transitions the display to a new interface, aiming for a more fluid interaction than traditional point-and-click systems '559 Patent, col. 1:51-2:4 '559 Patent, claim 1
  • Asserted Claims: The complaint asserts independent claim 1 Compl. ¶58
  • Accused Features: The "Liquid Glass" features within Apple's iOS 26 and iPadOS 26 operating systems are accused of infringing this patent Compl. ¶23 Compl. ¶58

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are Apple's iPhones and iPads ("Accused Devices") running operating systems iOS 26 and iPadOS 26, which include a feature set referred to as "Liquid Glass" Compl. ¶23 Compl. ¶26 The complaint also names various Apple software applications as infringing, including Apple Music, News, Podcasts, Books, Phone, and the App Store ("Accused Software") Compl. ¶27
  • Functionality and Market Context: The complaint alleges that the "Liquid Glass" features provide the infringing user interface functionality Compl. ¶23 It further alleges that Apple promotes these features to end-users and provides developer documentation and frameworks (e.g., SwiftUI, UIKit, and AppKit) that encourage and instruct third-party developers to incorporate infringing elements, such as "segmented control" sliders, into their own applications Compl. ¶34 Compl. ¶48 Compl. ¶62 A screenshot from the complaint illustrates the plaintiff's "selection ring" concept within an immersive user interface on a mobile device Compl. ¶14

IV. Analysis of Infringement Allegations

The complaint references exemplary claim charts in Exhibits D, E, and F, but these exhibits were not provided with the complaint. The infringement theory is therefore summarized from the complaint's narrative allegations.

  • '878 and '712 Patents Infringement Allegations

    • The complaint alleges that Apple's "Liquid Glass" features, as found in iOS 26, iPadOS 26, and numerous first-party applications, directly infringe at least claim 1 of the '878 Patent and claim 1 of the '712 Patent Compl. ¶30 Compl. ¶44 The theory of direct infringement is also supported by allegations that Apple employees use and demonstrate the infringing methods when assisting customers in Apple's retail stores Compl. ¶31 Compl. ¶45 The specific mapping of the "Liquid Glass" features to the elements of the asserted claims is detailed in the un-provided exhibits Compl. ¶30 Compl. ¶44

  • Identified Points of Contention:

    • Scope Questions: A potential issue for the '878 Patent may be the claim 1 requirement that the "selection ring" is presented "without altering the presentation of information within the first graphical user interface." The infringement analysis may turn on whether Apple's "Liquid Glass" feature, when invoked, leaves the underlying UI completely unaltered, or if it introduces visual changes (e.g., blurring, dimming) that could place it outside the literal scope of the claim.
    • Technical Questions: A key question for the '712 Patent is whether the operation of the accused "Liquid Glass" feature aligns with the claim's two-step selection process. Claim 1 requires a "first selection" to reveal icons and a "second selection" to choose one. The case may focus on whether the user interaction constitutes two discrete "selections" or a single, continuous gesture (e.g., a press-and-drag), which could suggest a functional mismatch with the claim language.

V. Key Claim Terms for Construction

  • The Term: "selection ring"

    • Context and Importance: This term is the central element of the invention across all asserted patents. Its definition will be critical for determining the scope of infringement, as it dictates which UI elements in the accused "Liquid Glass" feature could be considered infringing.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The claim language itself does not specify a shape, describing it functionally as "a selection ring" '878 Patent, col. 27:16-17 This could support a construction that covers any UI overlay element, regardless of shape, that performs the claimed function of revealing and selecting icons.
      • Evidence for a Narrower Interpretation: The patent figures consistently depict a literal, circular ring (e.g.,'878 Patent, Fig. 3C, element 152). An argument could be made that the term is limited to this specific circular embodiment, especially given the term's explicit use of the word "ring."

  • The Term: "first selection" / "second selection" '712 Patent, claim 1

    • Context and Importance: The infringement analysis for the '712 Patent will likely depend on whether the accused functionality involves two discrete user inputs that can be characterized as a "first selection" and a "second selection." Practitioners may focus on this term because it creates a specific sequence of operations that the accused product must perform.
    • Intrinsic Evidence for Interpretation:
      • Evidence for a Broader Interpretation: The patent does not define "selection," leaving open the possibility that it could encompass actions beyond a simple tap or click. For example, initiating a touch-and-hold could be argued to be a "first selection," while releasing the touch over an icon could constitute the "second selection."
      • Evidence for a Narrower Interpretation: The claims distinguish between "receiving... selection" and "receiving... user manipulation of positioning" '712 Patent, col. 27:21-30 This distinction may support an argument that a "selection" must be a discrete, completed action, and that a continuous gesture like a press-drag-release is a single user action, not two separate "selections."

VI. Other Allegations

  • Indirect Infringement: The complaint alleges both induced and contributory infringement.
    • Inducement: The inducement claim is based on allegations that Apple encourages and directs both end-users and third-party app developers to infringe. The complaint cites Apple's marketing materials, developer documentation (including videos and technology overviews for "Liquid Glass"), and the provision of system frameworks (SwiftUI, UIKit, AppKit) that allegedly enable "automatic" adoption of infringing elements (Compl. ¶33; Compl. ¶34).
    • Contributory Infringement: The complaint alleges that the accused "Liquid Glass" components are a material part of the invention, are especially designed for infringement, and are not staple articles of commerce suitable for substantial non-infringing use. It further alleges Apple actively prevents users from installing non-infringing alternative operating systems Compl. ¶36 Compl. ¶50 Compl. ¶64
  • Willful Infringement: The complaint alleges willful infringement based on Apple's continued infringement after having knowledge of the patents, with knowledge alleged to have begun "at least by February 4, 2026, the date that it received notice, by service of the complaint in this lawsuit" Compl. ¶32 Compl. ¶46 Compl. ¶60 This frames the willfulness claim as arising from post-suit conduct.

VII. Analyst's Conclusion: Key Questions for the Case

  • A core issue will be one of definitional scope: can the term "selection ring", which is visually depicted as a literal ring in the patents, be construed broadly enough to read on the specific user interface elements within Apple's accused "Liquid Glass" feature set?
  • A second central issue will be one of operational sequence: does the user interaction with Apple's "Liquid Glass" feature map to the specific multi-step processes required by the asserted claims-particularly the "first selection" and "second selection" sequence of the '712 Patent-or is there a fundamental mismatch in technical operation that places it outside the claims' scope?
  • Finally, a key evidentiary question will be one of technical proof: given the absence of claim charts in the complaint, what specific evidence will the plaintiff produce to demonstrate that the "Liquid Glass" features meet functionally-defined limitations, such as presenting the ring "without altering" the underlying information as required by the '878 Patent?
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