DCT

4:22-cv-04553

Google LLC v. Sonos Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 5:22-cv-04553, N.D. Cal., 08/08/2022
  • Venue Allegations: Plaintiff alleges venue is proper in the Northern District of California because Defendant Sonos maintains a "regular and established place of business" in the district, specifically an office in San Francisco, and has committed alleged acts of infringement in the district.
  • Core Dispute: Plaintiff alleges that Defendant’s voice-controlled smart speakers and related products infringe four patents related to multi-device voice command arbitration and seamless wireless device setup.
  • Technical Context: The technologies at issue address common usability challenges in the smart home market: ensuring the correct smart speaker responds to a command in a multi-device environment and simplifying the process of connecting new devices to a home Wi-Fi network.
  • Key Procedural History: The complaint notes a history of collaboration between the parties, including Google’s provision of its Google Assistant software for use in Sonos products, and frames the lawsuit as a response to prior patent litigation initiated by Sonos against Google. Subsequent to the filing of this complaint, Inter Partes Review (IPR) proceedings were concluded for two of the asserted patents. Certificates issued in 2024 indicate that all asserted claims of U.S. Patent Nos. 11,024,311 and 9,812,128 have been cancelled. This development may be dispositive for the causes of action related to these two patents.

Case Timeline

Date Event
2012-04-11 ’615 Patent Priority Date
2014-06-24 ’748 Patent Priority Date
2014-10-09 ’311 and ’128 Patent Priority Date
2017-04-25 ’748 Patent Issue Date
2017-11-07 ’128 Patent Issue Date
2019-05-01 Google Assistant launches on Sonos products
2021-06-01 ’311 Patent Issue Date
2021-06-29 ’615 Patent Issue Date
2022-08-08 Complaint Filing Date
2022-09-29 Inter Partes Review initiated for ’311 Patent (IPR2022-01592)
2022-09-29 Inter Partes Review initiated for ’128 Patent (IPR2022-01594)
2024-06-10 IPR Certificate issues for ’128 Patent, cancelling asserted claims
2024-07-03 IPR Certificate issues for ’311 Patent, cancelling asserted claims

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

U.S. Patent No. 11,024,311 - "Device Leadership Negotiation Among Voice Interface Devices"

  • Patent Identification: U.S. Patent No. 11,024,311, titled “Device Leadership Negotiation Among Voice Interface Devices,” issued June 1, 2021 (Compl. ¶21).

The Invention Explained

  • Problem Addressed: The patent’s background section identifies the potential for user confusion when multiple voice-interface devices are present in a single location, as a user's voice command may be received by several devices simultaneously (’311 Patent, col. 2:1-4).
  • The Patented Solution: The invention proposes a system where multiple electronic devices that detect the same voice input each determine a "value" or "quality score" for the audio they received. The devices then communicate these values to one another, and only the device with the highest score—the designated "leader"—responds to the user, while the other devices remain silent (’311 Patent, col. 3:1-14; Fig. 6). This negotiation avoids duplicative or conflicting responses.
  • Technical Importance: This technology addresses a fundamental usability issue in multi-device smart home ecosystems, aiming to create a more seamless and intuitive user experience.

Key Claims at a Glance

  • The complaint asserts independent claims 1, 10, and 16 (Compl. ¶26). Claim 1, a method claim, includes the following essential elements:
    • Detecting a voice input from a user at a first electronic device.
    • Determining a first value associated with the voice input.
    • Receiving second values associated with the voice input from other electronic devices.
    • Responding to the input only if the first value is higher than the second values.
  • The complaint also asserts dependent claims 2-3, 8-9, 11-12, 14-15, 17-18, and 20 (’311 Patent, col. 35:3-36:13; Compl. ¶24).

U.S. Patent No. 9,812,128 - "Device Leadership Negotiation Among Voice Interface Devices"

  • Patent Identification: U.S. Patent No. 9,812,128, titled “Device Leadership Negotiation Among Voice Interface Devices,” issued November 7, 2017 (Compl. ¶32).

The Invention Explained

  • Problem Addressed: Similar to the ’311 Patent, this patent addresses the problem of multiple voice-activated devices responding to a single user command, which can "reduce user confusion" (’128 Patent, col. 2:1-4).
  • The Patented Solution: The invention describes a method where multiple devices detect a voice input, each determines a "quality score" for that input, and the devices communicate these scores. The device with the highest score outputs a response, while explicitly requiring that the other devices "forgo outputting an audible response" (’128 Patent, col. 3:8-12; Fig. 6). The specification suggests the quality score can be based on factors like loudness, noise, and distortion (’128 Patent, col. 21:24-30).
  • Technical Importance: This patent, part of the same family as the ’311 Patent, provides a framework for arbitrating control among smart devices to ensure a single, clear response to a user.

Key Claims at a Glance

  • The complaint asserts independent claims 1, 6, and 11 (Compl. ¶37). Claim 1, a method claim, includes the following essential elements:
    • Detecting a voice input at a first electronic device.
    • Determining a quality score for the detected voice input.
    • Communicating the quality score to other devices.
    • Receiving quality scores from the other devices.
    • Outputting a response if its quality score is the highest, while the other devices forgo outputting a response.
  • The complaint also asserts dependent claims 2-3, 5, 7-8, 10, 12-13, and 15 (’128 Patent, col. 35:3-38:25; Compl. ¶35).

U.S. Patent No. 9,632,748 - "Device Designation for Audio Input Monitoring"

  • Patent Identification: U.S. Patent No. 9,632,748, titled “Device Designation for Audio Input Monitoring,” issued April 25, 2017 (Compl. ¶43).
  • Technology Synopsis: This patent addresses the inefficiency of multiple devices in proximity actively monitoring for audio commands. The described solution involves designating a single, "particular computing device" from a group to process audio input, while the other devices in the group "cease processing of audio input" (’748 Patent, Abstract). The designation can be based on factors such as a pre-configured hierarchy of device types (e.g., a headset having priority over a smartphone) or the device's current context (’748 Patent, col. 7:40-51).
  • Asserted Claims: Independent claims 1, 7, and 11 (Compl. ¶48).
  • Accused Features: The complaint alleges that Sonos's voice-controlled products, which coordinate voice monitoring among multiple devices on a network, infringe the ’748 Patent (Compl. ¶¶ 11, 46).

U.S. Patent No. 11,050,615 - "Apparatus and Method for Seamless Commissioning of Wireless Devices"

  • Patent Identification: U.S. Patent No. 11,050,615, titled “Apparatus and Method for Seamless Commissioning of Wireless Devices,” issued June 29, 2021 (Compl. ¶54).
  • Technology Synopsis: This patent addresses the technical challenge of connecting new wireless devices, which may lack screens or keyboards, to a secured Wi-Fi network. The solution involves using an existing "smart wireless device" (e.g., a smartphone) to transmit the necessary WLAN configuration data (network name and password) to the new device via a secondary, short-range communication channel, such as an optical signal from a camera flash or an acoustic signal from a speaker (’615 Patent, Abstract; col. 2:34-42). This "seamless" method avoids manual data entry on the new device.
  • Asserted Claims: Independent claims 1, 11, and 16 (Compl. ¶59).
  • Accused Features: The complaint accuses Sonos audio products that "support commissioning of the device into a system via short-range transmissions" of infringement, referencing Sonos’s instructions for setting up products like the Sonos Roam speaker (Compl. ¶¶ 57, 60).

III. The Accused Instrumentality

Product Identification

  • The complaint identifies two overlapping sets of accused products. The "Accused Voice Products," accused of infringing the ’311, ’128, and ’748 patents, include the Sonos One, Sonos Move, Sonos Roam, Sonos Arc, and Sonos Beam (Compl. ¶¶ 18, 46). The "Accused Player Products," accused of infringing the ’615 patent, include all of the foregoing plus the Sonos One SL, Sonos Roam SL, Sonos Five, and Sonos Ray (Compl. ¶11).

Functionality and Market Context

  • The central accused functionality is the "Sonos Voice Control" feature, which allows users to control Sonos products with voice commands (Compl. ¶11). For the leadership negotiation patents (’311, ’128, ’748), the relevant function is the alleged coordination among multiple voice-enabled Sonos devices on a network to determine which device should respond to a command (Compl. ¶11). For the commissioning patent (’615), the relevant function is the method used to connect new Sonos devices to a user's Wi-Fi network (Compl. ¶¶ 9, 60). The complaint emphasizes Sonos’s own marketing, which states that "the real magic is in the software" (Compl. ¶12). No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

The complaint references claim charts attached as exhibits that were not provided with the complaint document. Accordingly, the infringement theory is summarized below in prose.

The infringement theory for the ’311 and ’128 patents is that Sonos’s multi-room audio systems with Sonos Voice Control practice the claimed leadership negotiation methods. When a user issues a command in the presence of multiple Sonos devices, the complaint alleges these devices perform a process to select a single device to respond. This process is alleged to meet the claim limitations of determining a value or quality score for the received audio, communicating that information between devices, and having only the device with the superior score respond to the user (Compl. ¶¶ 24, 35).

  • Identified Points of Contention:
    • Scope Questions: A central question for the ’311 and ’128 Patents is whether the mechanism used by Sonos Voice Control to arbitrate responses constitutes a "determination of a value" or "quality score" as contemplated by the patents. The dispute may focus on whether Sonos uses any metric related to acoustic quality (e.g., signal-to-noise ratio) or a different logic entirely (e.g., proximity determined by signal strength, or a pre-designated primary device).
    • Technical Questions: The complaint does not provide technical details on how Sonos's leadership arbitration works. A key factual question will be what data, if any, is communicated between Sonos devices during this process. The analysis will depend on whether Sonos devices engage in the peer-to-peer score comparison described in the patents or use an alternative architecture, such as designation by a master device or a cloud-based controller.

V. Key Claim Terms for Construction

  • The Term: "quality score" (’128 Patent) / "value associated with the voice input" (’311 Patent)
  • Context and Importance: This term is the central element of the patented arbitration method. Its construction will define the type of information Sonos devices must be shown to calculate and exchange to infringe. Practitioners may focus on this term because its scope—whether it is limited to specific acoustic metrics or can broadly cover any data used for arbitration—will be critical to the infringement analysis.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The use of the general phrase "value associated with the voice input" in claim 1 of the ’311 Patent could support an argument that the term covers any data point used in the leadership decision, not just one tied to acoustic fidelity (’311 Patent, col. 36:6).
    • Evidence for a Narrower Interpretation: The specification provides specific examples of what a "quality score" may entail, including "loudness or amplitude of the sample, presence or absence of noise (e.g., cross-talk, hissing) and corresponding level, presence or absence of distortion (e.g., echo)," and "frequency profile" (’311 Patent, col. 21:24-30). A defendant may argue these examples limit the term's scope to metrics of acoustic clarity.

VI. Other Allegations

  • Indirect Infringement: The complaint alleges induced infringement for all four patents. The allegations are based on Sonos promoting its Sonos Voice Control feature and providing instructions to customers on how to use the accused commissioning features, allegedly encouraging infringing acts (Compl. ¶¶ 27, 38, 49, 60). Contributory infringement is also alleged, on the basis that the accused products are specially adapted for infringing use and are not staple articles of commerce (Compl. ¶¶ 28, 39, 50, 61).
  • Willful Infringement: Willfulness is alleged for all four patents. The basis for willfulness is alleged knowledge of the patents and infringement occurring "by no later than the filing of this action," followed by continued infringement (Compl. ¶¶ 29, 40, 51, 62).

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

  • Dispositive Impact of IPRs: The most critical issue in this case is the post-filing cancellation of all asserted claims of the ’311 and ’128 patents through Inter Partes Review. A central question will be whether the causes of action related to these patents can proceed, which is highly improbable given the cancellation of the underlying property rights.
  • Evidentiary Burden for Technical Operation: For the remaining ’748 and ’615 patents, the case will likely turn on the specific, evidence-backed technical implementation of Sonos’s software. For the ’748 patent, what is the precise mechanism by which one Sonos device is designated to monitor for voice commands while others stand down? For the ’615 patent, what is the exact protocol and medium (e.g., acoustic, Bluetooth, optical) used for device commissioning, and does it align with the claims?
  • Definitional Scope of Commissioning: A key legal question for the ’615 patent will be the construction of "short-range transmissions." The patent focuses on optical and acoustic embodiments to solve the problem of devices lacking traditional input methods. The viability of this claim may depend on whether the court construes this term broadly to cover other technologies like Bluetooth Low Energy, or narrowly to the specific out-of-band solutions disclosed in the specification.