DCT

1:24-cv-01368

VB Assets LLC v. Apple Inc

Log In

I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-01368, D. Del., 03/10/2025
  • Venue Allegations: Plaintiff alleges venue is proper in the District of Delaware because Apple has committed acts of infringement in the district, maintains a regular and established place of business through a retail store in Newark, DE, and has derived substantial revenue from selling its Siri-enabled products in the state.
  • Core Dispute: Plaintiff alleges that Defendant’s Siri voice assistant and related products infringe seven U.S. patents concerning cooperative conversational voice interfaces, natural language understanding, and voice-contextual advertising.
  • Technical Context: The technology at issue involves conversational artificial intelligence, which enables more natural, human-like voice interactions with digital devices, a cornerstone of the modern smart device market.
  • Key Procedural History: The complaint alleges a multi-year history of pre-suit negotiations between 2012 and 2014, during which Apple allegedly made multiple offers to buy or license the patent portfolio after conducting due diligence, which may be central to the allegations of willful infringement.

Case Timeline

Date Event
2001 VoiceBox Technologies founded
2006-10-16 Earliest Priority Date for ’681, ’765, ’249, ’341 Patents
2007-02-06 Earliest Priority Date for ’176, ’536, ’097 Patents
2010-10-19 U.S. Patent No. 7,818,176 Issued
2011-10 Apple releases its first Siri Products
2011-12-06 U.S. Patent No. 8,073,681 Issued
2012-07 Apple allegedly begins negotiations to buy or license the VoiceBox patents
2013-08-20 U.S. Patent No. 8,515,765 Issued
2014-09 Alleged negotiations between Apple and VoiceBox conclude
2014-11-11 U.S. Patent No. 8,886,536 Issued
2016-02-23 U.S. Patent No. 9,269,097 Issued
2019-05-21 U.S. Patent No. 10,297,249 Issued
2019-12-17 U.S. Patent No. 10,510,341 Issued
2025-03-10 First Amended Complaint Filed

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

U.S. Patent No. 8,073,681 - “SYSTEM AND METHOD FOR A COOPERATIVE CONVERSATIONAL VOICE USER INTERFACE,” Issued December 6, 2011

The Invention Explained

  • Problem Addressed: Traditional computer speech-recognition systems were rigid and forced users to adhere to a limited set of structured prompts, which hindered widespread adoption and intuitive use (Compl. ¶12; ’249 Patent, col. 1:29-50).
  • The Patented Solution: The invention describes a system that mimics cooperative human conversation by using both short-term context from the current dialogue and long-term knowledge about the user. This allows the system to identify the context of a user's utterance, disambiguate words with multiple meanings, and generate a syntactically appropriate response, enabling a more natural, free-form interaction (’249 Patent, col. 2:13-48).
  • Technical Importance: This approach allows a voice user interface to move beyond simple command-and-control and engage in more flexible, context-aware dialogue, making the technology more accessible and powerful for complex tasks (Compl. ¶¶12, 27).

Key Claims at a Glance

  • The complaint asserts independent claim 25 (Compl. ¶50).
  • Claim 25 requires, in essence:
    • A voice input device configured to receive an utterance containing words with different meanings in different contexts.
    • A conversational speech engine with one or more processors configured to:
      • Accumulate short-term shared knowledge about the current conversation.
      • Accumulate long-term shared knowledge about the user from past conversations.
      • Identify a context for the utterance from both the short-term and long-term knowledge.
      • Establish an intended meaning for the utterance within that context to disambiguate the user's intent.
      • Generate a grammatically or syntactically adapted response based on the established meaning.
  • The complaint reserves the right to assert additional claims (Compl. ¶50).

U.S. Patent No. 8,515,765 - “SYSTEM AND METHOD FOR A COOPERATIVE CONVERSATIONAL VOICE USER INTERFACE,” Issued August 20, 2013

The Invention Explained

  • Problem Addressed: Voice interactions can be inefficient if the system treats every user utterance as the start of a new, user-directed command, failing to recognize different conversational dynamics (Compl. ¶12; ’249 Patent, col. 1:29-50).
  • The Patented Solution: The invention introduces the concept of conversational roles. The system determines whether a user has a "leader role" (e.g., issuing a direct command) or a "supporter role" (e.g., asking for information or initiating a process). Based on this role, the system generates a response with a format adapted to the conversational dynamic, such as limiting the user's next input to simple clarifications if they are in a "supporter role" (Compl. ¶32).
  • Technical Importance: This technology allows a voice assistant to manage conversational turn-taking more effectively, guiding the user through multi-step processes or providing concise information without requiring a new, fully-formed command at each step (Compl. ¶¶77-78).

Key Claims at a Glance

  • The complaint asserts independent claim 10 (Compl. ¶71).
  • Claim 10 requires, in essence:
    • A speech engine configured to receive a natural language utterance corresponding to a conversation type.
    • A processor configured to determine the conversation type based on whether the user has a "leader role" or a "supporter role."
    • A response builder configured to generate a response with a format based on the determined conversation type.
    • The format is adapted to limit the user's future input to "interjecting queries or requests for clarification" if the user has the "supporter role."
  • The complaint reserves the right to assert additional claims (Compl. ¶71).

Multi-Patent Capsule: U.S. Patent No. 10,297,249

  • Patent Identification: U.S. Patent No. 10,297,249, “SYSTEM AND METHOD FOR A COOPERATIVE CONVERSATIONAL VOICE USER INTERFACE,” Issued May 21, 2019 (Compl. ¶34).
  • Technology Synopsis: The patent claims a method of facilitating natural language responses by using short-term knowledge generated from both voice and non-voice (multi-modal) device interactions, such as a user touching a screen while speaking (Compl. ¶35). The system also compares and filters inputs from multiple input devices (Compl. ¶35).
  • Asserted Claims: Claim 1 (Compl. ¶101).
  • Accused Features: The complaint alleges that Siri infringes by using multi-modal inputs, such as onscreen awareness, to generate short-term knowledge to understand and respond to user requests (Compl. ¶¶104-106).

Multi-Patent Capsule: U.S. Patent No. 10,510,341

  • Patent Identification: U.S. Patent No. 10,510,341, “SYSTEM AND METHOD FOR A COOPERATIVE CONVERSATIONAL VOICE USER INTERFACE,” Issued December 17, 2019 (Compl. ¶37).
  • Technology Synopsis: The patent claims a system that facilitates responses by utilizing both short-term and long-term knowledge. It specifically includes expiring items of short-term knowledge after a time period and accumulating at least some of that expired knowledge into the long-term knowledge base (Compl. ¶38).
  • Asserted Claims: Claim 10 (Compl. ¶118).
  • Accused Features: The complaint alleges that Siri accumulates short-term and long-term knowledge, expires short-term items, and uses this combined knowledge to determine context and generate responses (Compl. ¶¶121-122).

Multi-Patent Capsule: U.S. Patent No. 7,818,176

  • Patent Identification: U.S. Patent No. 7,818,176, “SYSTEM AND METHOD FOR SELECTING AND PRESENTING ADVERTISEMENTS BASED ON NATURAL LANGUAGE PROCESSING OF VOICE-BASED INPUT,” Issued October 19, 2010 (Compl. ¶40).
  • Technology Synopsis: The patent claims a system for selecting and presenting advertisements in response to a natural language voice utterance. The system interprets the user's words, establishes a context, selects an advertisement relevant to that context, and presents it to the user (Compl. ¶41).
  • Asserted Claims: Claim 27 (Compl. ¶134).
  • Accused Features: The complaint alleges that when users make requests (e.g., "Siri, play music"), Siri establishes a context and presents advertisements, such as an offer for a free trial of Apple Music (Compl. ¶¶138, 148-149).

Multi-Patent Capsule: U.S. Patent No. 8,886,536

  • Patent Identification: U.S. Patent No. 8,886,536, “SYSTEM AND METHOD FOR DELIVERING TARGETED ADVERTISEMENTS AND TRACKING ADVERTISEMENT INTERACTIONS IN VOICE RECOGNITION CONTEXTS,” Issued November 11, 2014 (Compl. ¶43).
  • Technology Synopsis: The patent claims a system for providing promotional content related to a conversational interaction. It specifically involves receiving a second utterance that relates to a first one, identifying requests within that second utterance associated with different applications, and then determining and presenting promotional content related to those requests (Compl. ¶44).
  • Asserted Claims: Claim 43 (Compl. ¶161).
  • Accused Features: The complaint alleges Siri provides promotional content in response to multi-utterance, multi-application user requests (Compl. ¶¶164-165).

Multi-Patent Capsule: U.S. Patent No. 9,269,097

  • Patent Identification: U.S. Patent No. 9,269,097, “SYSTEM AND METHOD FOR DELIVERING TARGETED ADVERTISEMENTS AND/OR PROVIDING NATURAL LANGUAGE PROCESSING BASED ON ADVERTISEMENTS,” Issued February 23, 2016 (Compl. ¶46).
  • Technology Synopsis: The patent claims a method for interpreting a user's natural language utterance based on a previously presented advertisement. Specifically, it involves determining whether a pronoun in the user's utterance refers to the product, service, or provider associated with that advertisement (Compl. ¶47).
  • Asserted Claims: Claim 1 (Compl. ¶177).
  • Accused Features: The complaint alleges that Siri provides an advertisement and then interprets subsequent user utterances containing pronouns based on the context of that advertisement (Compl. ¶¶180-181).

III. The Accused Instrumentality

Product Identification

  • The accused instrumentalities are Apple’s "Siri Products" (Compl. ¶2). This is a broad category defined to include the Siri voice assistant, Apple Intelligence Siri enhancements, operating systems (iOS, iPadOS, etc.), and hardware such as iPhones, iPads, AirPods, Macs, Apple Watch, HomePod, and Apple Vision Pro, as well as the cloud infrastructure that implements Siri (Compl. p. 2, fn. 1).

Functionality and Market Context

  • The accused functionality centers on Siri's ability to process natural language voice commands to perform tasks, answer questions, and control devices (Compl. ¶¶54-59). The complaint alleges that Siri uses both immediate conversational context and stored user data to understand and respond to ambiguous or complex user requests (Compl. ¶¶55-58). The complaint positions Siri as a core feature of Apple's ecosystem, enabling hands-free control and access to a wide range of applications and services (Compl. ¶¶19, 54). A screenshot in the complaint shows Siri's ability to parse a complex command and make corrections, such as "Siri, set an alarm for -- oh wait no, set a timer for 10 minutes. Actually, make that 5," which demonstrates its use of short-term conversational context (Compl. p. 23).

IV. Analysis of Infringement Allegations

’681 Patent Infringement Allegations

Claim Element (from Independent Claim 25) Alleged Infringing Functionality Complaint Citation Patent Citation
a voice input device configured to receive an utterance during a current conversation with a user, wherein the utterance includes one or more words that have different meanings in different contexts Siri Products receive user utterances, such as "Siri, how's the weather," via microphones on devices like the iPhone or HomePod. ¶54 ’249 Patent, col. 2:25-30
a conversational speech engine...configured to: accumulate short-term shared knowledge about the current conversation... Siri's speech engine accumulates knowledge about the current utterance, such as the user's request for weather and the device type that received the request. ¶55 ’249 Patent, col. 4:2-3
accumulate long-term shared knowledge about the user, wherein the long-term shared knowledge includes knowledge about one or more past conversations with the user The speech engine accumulates knowledge about past user conversations, such as the user's voice for speaker identification, prior requests, and location data. ¶56 ’249 Patent, col. 4:3-6
identify a context associated with the utterance from the short-term shared knowledge and the long-term shared knowledge The engine identifies a context, such as the location for a weather request or the timing of an event, based on the combined short-term and long-term knowledge. ¶57 ’249 Patent, col. 4:7-14
establish an intended meaning for the utterance within the identified context to disambiguate an intent... The engine disambiguates the user's intent, such as determining whether an alarm should be AM or PM, or identifying the location for a weather forecast. This is illustrated in a screenshot showing Siri cross-referencing flight details from an email to understand context (Compl. p. 29). ¶58 ’249 Patent, col. 4:15-18
generate a grammatically or syntactically adapted response to the utterance based on the intended meaning... The engine generates a contextually appropriate response, such as providing the weather for a specific location or confirming the time for which an alarm is set. A provided screenshot shows Siri confirming "I changed your alarm to 6:30 AM" (Compl. p. 40). ¶59 ’249 Patent, col. 2:40-48

Identified Points of Contention

  • Scope Questions: A central question may be how the terms "short-term shared knowledge" and "long-term shared knowledge" are defined. The analysis may explore whether data that persists only for a single conversational turn qualifies as "short-term," and whether "long-term" knowledge requires persistence across device restarts or is limited to a specific user's logged-in profile.
  • Technical Questions: The complaint alleges that Siri performs distinct steps of "identifying a context" and then "establishing an intended meaning." A point of contention could be whether Siri's underlying architecture, which may rely on large language models, performs these as discrete, sequential operations as claimed, or as part of a single, integrated probabilistic determination.

’765 Patent Infringement Allegations

Claim Element (from Independent Claim 10) Alleged Infringing Functionality Complaint Citation Patent Citation
a speech engine configured to receive a natural language utterance from a voice-enabled device, the natural language utterance corresponding to a conversation type Siri's speech engine receives natural language utterances such as "Siri, heading to work" or "Siri, change my alarm." ¶76 ’249 Patent, col. 2:25-30
determine the conversation type...based on whether a user...has a leader role...or has a supporter role... For an utterance like "Siri, change my alarm," the system determines the user has a "leader role." For an utterance like "Siri, heading to work," the system determines the user has a "supporter role." ¶¶78, 80 ’249 Patent, col. 5:55-67
a response builder configured to generate a response...with a format based on the conversation type Siri generates a response, such as asking a clarifying question when the user is in a "leader role" (Compl. p. 58), or providing a map when the user is in a "supporter role" (Compl. p. 56). ¶¶85, 87 ’249 Patent, col. 6:45-53
wherein the format is adapted to limit the user's future input to interjecting queries or requests for clarification if the user has the supporter role For a "supporter role" utterance like "Siri, heading to work," the system provides a map interface that allegedly limits further input to clarifications, as opposed to open-ended commands. ¶¶84, 85 ’249 Patent, col. 6:45-53

Identified Points of Contention

  • Scope Questions: The dispute may turn on the definitions of "leader role" and "supporter role." The court will need to determine if these terms have a specific meaning in the art or within the patent's specification, and whether Apple's classification of different user intents maps onto those definitions.
  • Technical Questions: A key question will be whether the complaint provides sufficient evidence that Siri's software architecture makes an explicit determination of a "conversation type" as required by the claim. It may be argued that Siri simply executes different subroutines for different types of queries (e.g., a "command" versus a "shortcut") without performing the claimed step of classifying the user's "role."

V. Key Claim Terms for Construction

For the ’681 Patent

  • The Term: "short-term shared knowledge"
  • Context and Importance: The temporal and functional scope of this term is critical. Infringement may depend on whether this knowledge is limited to data from the immediately preceding utterance or if it can persist across several turns within a single, continuous user interaction. Practitioners may focus on this term because its definition distinguishes between a simple request-response mechanism and a true conversational context engine.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The specification of the related ’249 patent describes it as knowledge "about the current conversation" which "may accumulate during a single conversation" (’249 Patent, col. 4:2-3; col. 5:6-8), suggesting it can persist beyond a single turn.
    • Evidence for a Narrower Interpretation: The examples provided in the patent may focus on using context from the immediately prior turn, potentially supporting an argument that the term's scope is temporally limited to the data needed to resolve the very next utterance.

For the ’765 Patent

  • The Term: "leader role" and "supporter role"
  • Context and Importance: These terms are foundational to the infringement theory for the ’765 patent. The outcome will likely depend on whether the ordinary behavior of a voice assistant—responding to a direct command versus providing information for a general query—can be mapped onto these specific, defined roles.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The complaint alleges that a user asking a question like "how do I bake a cake" is in a "supporter role" (Compl. ¶79), while a user giving a command like "change my alarm" is in a "leader role" (Compl. ¶80), suggesting a broad interpretation based on the nature of the user's query (informational vs. imperative).
    • Evidence for a Narrower Interpretation: The patent specification may provide explicit definitions or examples that tie these roles to which party—the user or the system—holds the majority of the information required for a task, which could narrow the scope beyond a simple query/command distinction.

VI. Other Allegations

Indirect Infringement

  • The complaint alleges induced infringement, stating that Apple actively and knowingly encourages infringement by providing user manuals, technical support, and developer tools like SiriKit that instruct users and third-party developers on how to use Siri in an infringing manner (Compl. ¶¶53-54, 75-76). Contributory infringement is also alleged, based on the assertion that Siri Products are especially made for practicing the patented inventions and are not staple articles of commerce suitable for substantial non-infringing use (Compl. ¶¶62, 65).

Willful Infringement

  • Willfulness is alleged based on both pre- and post-suit knowledge. The complaint extensively details alleged pre-suit knowledge stemming from licensing and acquisition negotiations between Apple and Plaintiff's predecessor from approximately July 2012 to September 2014, during which Apple allegedly conducted due diligence on the patents-in-suit and Siri's technology (Compl. ¶¶20-26, 51). Post-suit knowledge is alleged based on the filing of the original complaint in this matter (Compl. ¶52).

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

  • A central issue will be one of definitional scope: can patent claim terms grounded in early conversational computing concepts, such as "short-term shared knowledge" and "leader/supporter role," be construed to read on the complex, integrated functionalities of a modern large language model-driven assistant like Siri?
  • A key evidentiary question will be one of architectural proof: what evidence will emerge from discovery to show that Siri's internal software architecture performs the discrete, sequential steps required by the claims (e.g., first "identifying a context," then "establishing an intent"), as opposed to arriving at a response through a different, holistic computational method?
  • The determination of willfulness will be a highly fact-intensive inquiry, likely turning on documentary and testimonial evidence from the alleged 2012-2014 negotiations regarding what Apple knew about the patents and its own technology, and when it knew it.