DCT

1:24-cv-00729

SoundClear Tech LLC v. Google LLC

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-00729, E.D. Va., 05/01/2024
  • Venue Allegations: Plaintiff alleges venue is proper because Google commits acts of infringement in the district and maintains regular and established places of business, including an office in Reston, Virginia.
  • Core Dispute: Plaintiff alleges that Defendant’s Google Home and Nest smart speakers and the Google Assistant service infringe three patents related to audio signal processing for noise reduction, communication device status notification, and automatic volume control.
  • Technical Context: The technology at issue involves methods for improving voice command recognition and audio output quality in voice-activated devices, particularly in environments with significant background noise.
  • Key Procedural History: The complaint states the patents-in-suit were developed by engineers at JVC Kenwood (“JVCK”), a major audio processing company, and were subsequently acquired by Plaintiff SoundClear.

Case Timeline

Date Event
2011-09-15 U.S. Patent No. 9,031,259 Priority Date
2012-02-20 U.S. Patent No. 9,070,374 Priority Date
2015-05-12 U.S. Patent No. 9,031,259 Issues
2015-06-30 U.S. Patent No. 9,070,374 Issues
2015-12-07 U.S. Patent No. 9,804,819 Priority Date
2017-10-31 U.S. Patent No. 9,804,819 Issues
2024-05-01 Complaint Filed

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

U.S. Patent No. 9,031,259, “Noise Reduction Apparatus, Audio Input Apparatus, Wireless Communication Apparatus, and Noise Reduction Method,” Issued May 12, 2015

The Invention Explained

  • Problem Addressed: The patent’s background section states that conventional noise-canceling functions do not perform well in high-noise environments, failing to satisfy the demand for high-quality voice sound (Compl. ¶19, ¶21; ’259 Patent, col. 1:26-34).
  • The Patented Solution: The invention uses a multi-microphone system to improve noise reduction. First, a “speech segment determiner” identifies whether an incoming sound is human speech. If speech is detected, a “voice direction detector” uses the inputs from at least two microphones to determine the direction from which the voice is coming. This directional information, combined with the speech segment information, is then used by an adaptive filter to perform a more targeted noise reduction process (Compl. ¶20; ’259 Patent, col. 2:43-60, Fig. 1).
  • Technical Importance: This method enables directional audio filtering, which allows a device to focus on a speaker’s voice and more effectively suppress ambient noise coming from other directions, thereby improving clarity in challenging acoustic environments (Compl. ¶21).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 1 (Compl. ¶46).
  • Essential elements of Claim 1 include:
    • A speech segment determiner configured to determine whether a sound from at least one of two microphones is a speech segment and to output speech segment information.
    • A voice direction detector configured to receive the speech segment information and detect a voice incoming direction based on signals from the two microphones.
    • An adaptive filter configured to perform a noise reduction process using the signals from both microphones, based on both the speech segment information and the voice incoming-direction information.

U.S. Patent No. 9,070,374, “Communication Apparatus and Condition Notification Method for Notifying a Used Condition of Communication Apparatus by Using a Light-Emitting Device Attached to Communication Apparatus,” Issued June 30, 2015

The Invention Explained

  • Problem Addressed: The patent addresses the challenge of maintaining clear communication in noisy environments when using devices like handset microphones, where the position relative to the user's mouth is variable and can lead to poor sound quality for noise cancellation (Compl. ¶31; ’374 Patent, col. 1:30-51).
  • The Patented Solution: The invention is a communication apparatus that provides visual feedback to the user about its operational status. The device determines its "communication mode" (e.g., standby or transmitting) and the "pick-up state" of the voice sound (e.g., speech quality). It then uses a control unit to operate a light-emitting device (LED) based on this combined information, signaling to the user whether the device is in a good condition for clear communication (’374 Patent, Abstract; col. 2:11-24).
  • Technical Importance: This system provides real-time, intuitive feedback to users, enabling them to adjust the device's position or their speaking manner to improve audio input quality, which is particularly useful for achieving clear voice transmission in noisy settings (Compl. ¶26, ¶31).

Key Claims at a Glance

  • The complaint asserts at least independent Claim 9 (Compl. ¶59).
  • Essential elements of Claim 9 include:
    • A first pick-up unit to pick up a voice sound.
    • A transmitter unit to transmit the voice sound as a speech signal.
    • A communication-mode switching unit to switch between a standby mode and a transmission mode.
    • A sound pick-up state determination unit to determine a pick-up state of the voice sound.
    • A light emission device to emit light.
    • A control unit to control the light-emitting device based on both the communication mode and the pick-up state.

Multi-Patent Capsule: U.S. Patent No. 9,804,819

  • Patent Identification: U.S. Patent No. 9,804,819, “Receiving Apparatus and Control Method,” Issued October 31, 2017 (Compl. ¶32).
  • Technology Synopsis: The patent describes a volume control method for an audio device to prevent sudden, unintentional volume changes. It discloses a system with two states: a "locked state" where the volume is fixed at a "lock value," and a "non-locked state" where the volume can be varied. The system can temporarily switch to the non-locked state to adjust volume in response to specific conditions (e.g., loud ambient noise) and then revert to the locked state (Compl. ¶36, ¶37; ’819 Patent, col. 1:30-40).
  • Asserted Claims: The complaint asserts at least Claim 8 (Compl. ¶80).
  • Accused Features: Plaintiff alleges that Google’s "Ambient IQ" and "Media EQ" features, which automatically adjust the volume of Google Assistant and media playback based on background noise, practice the claimed method of switching between "locked" (user-set volume) and "non-locked" (automatically adjusted volume) states (Compl. ¶84, ¶85, ¶87).

III. The Accused Instrumentality

  • Product Identification: The accused instrumentalities are the “Google Home Products,” which include Google Home, Google Nest Mini (1st Gen), Google Home Mini (1st Gen), Google Home Max, Google Nest Audio, Google Nest Hub, Google Nest Hub Max, Google Nest Hub (2nd Gen.), and the Google Assistant service (Compl. ¶8).
  • Functionality and Market Context: The accused products are voice-activated smart speakers and displays that respond to spoken commands. The complaint alleges that they incorporate a microphone array to capture sound, use a "keyword spotting" algorithm to detect wake words like "Ok, Google," and employ "endpointing" to determine when a user has finished speaking (Compl. ¶48, ¶50, ¶63). The complaint further alleges the use of "neural network adaptive beamforming (NAB)" to identify the direction of the speaker and enhance audio quality by filtering noise (Compl. ¶52, ¶54, ¶73). The devices also feature LED lights to provide visual feedback on their status and include features like "Ambient IQ" that automatically adjust volume based on ambient noise levels (Compl. ¶69, ¶85). The complaint cites an iFixit teardown report to identify specific hardware components, including a "Marvell Avastar 88W8887 WLAN/BT/NFC SOC" chip which it identifies as part of the transmitter unit (Compl. ¶77).

IV. Analysis of Infringement Allegations

9,031,259 Infringement Allegations

Claim Element (from Independent Claim 1) Alleged Infringing Functionality Complaint Citation Patent Citation
a speech segment determiner configured to determine whether or not a sound picked up by at least either a first microphone or a second microphone is a speech segment and to output speech segment information... The computer hardware and software in the Google Home Products that performs "keyword spotting" and "endpointing" to determine whether a sound is a speech segment (e.g., a keyword or voice request) and to output information about that segment. ¶48, ¶50, ¶51 col. 2:18-20
a voice direction detector configured, when receiving the speech segment information, to detect a voice incoming direction... based on a first sound pick-up signal... and a second sound pick-up signal... The "neural network adaptive beamforming (NAB)" algorithm, which allegedly uses signals from the microphone array to detect the direction of the voice audio source. ¶52, ¶54 col. 2:20-27
an adaptive filter configured to perform a noise reduction process using the first and second sound pick-up signals based on the speech segment information and the voice incoming-direction information. The sound processing method in the Google Home Products that allegedly performs noise reduction by filtering noise based on the output from the "endpointing" (speech segment) and "NAB" (direction) processes. ¶55 col. 2:27-32
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether Google's "keyword spotting" and "endpointing" algorithms fall within the patent's definition of a "speech segment determiner," which the specification describes in the context of analyzing vowel formants and frequency spectra (’259 Patent, col. 4:59-65).
    • Technical Questions: The analysis may focus on whether the accused "neural network adaptive beamforming" functions as the claimed "voice direction detector" and "adaptive filter." The court will need to determine if the NAB process, as described in Google's technical papers cited by the complaint, performs the specific steps of first detecting a direction and then using that discrete directional information to control a filter, as required by the claim language.

9,070,374 Infringement Allegations

Claim Element (from Independent Claim 9) Alleged Infringing Functionality Complaint Citation Patent Citation
a first pick-up unit configured to pick up a voice sound; The first microphone in the accused Google Home Products (Compl. ¶61). ¶61 col. 3:55-56
a transmitter unit configured to transmit the voice sound picked up by the first pick-up unit to outside as a first speech signal; The componentry, including a Marvell SOC, that transmits the captured voice sound (e.g., keyword and query) to Google's servers (Compl. ¶62, ¶64, ¶77). ¶62, ¶64, ¶77 col. 2:13-15
a communication-mode switching unit configured to switch a communication mode between a standby mode... in which the transmitter unit does not transmit the speech signal and a transmission mode... in which the transmitter unit transmits the speech signal; The processor that controls the transmitter unit to either not send (standby) or send (transmission) the voice request to Google's server, based on whether a trigger phrase has been detected (Compl. ¶65). ¶65, ¶67 col. 2:11-13
a sound pick-up state determination unit configured to determine a pick-up state of the voice sound picked up by the first pick-up unit; The hardware and software that perform audio signal processing, such as NAB and speech recognition, to determine the signal characteristics of the captured voice sound (Compl. ¶68). ¶68 col. 2:16-17
a light emission device configured to emit light; and The LEDs on the Google Home Products that indicate device status (Compl. ¶69). ¶69 col. 2:19-20
a control unit configured to control the light-emitting device... based on the communication mode switched by the communication-mode switching unit, and the pick-up state of the voice sound... The microcontroller and LED drivers that allegedly control the LEDs based on both the communication mode (transmitting vs. not) and the determined signal characteristics of the voice sound (Compl. ¶70). ¶70, ¶71 col. 2:19-24
  • Identified Points of Contention:
    • Scope Questions: The dispute may center on whether the process of detecting a keyword and sending audio to a server constitutes "switching a communication mode between a standby mode... and a transmission mode" as understood in the context of the patent, which appears to contemplate a simplex push-to-talk system.
    • Technical Questions: A key technical question will be whether the complaint provides evidence that the LED control logic is based on a combination of both the communication mode and the determined "pick-up state." The complaint's allegation that these components "form a unit" that bases control on both factors may be challenged as conclusory without more detailed evidence of this specific logical link (Compl. ¶71).

V. Key Claim Terms for Construction

From the ’259 Patent (Claim 1)

  • The Term: "speech segment"
  • Context and Importance: This term is foundational to the claim, as its determination triggers the entire voice direction detection and noise reduction process. The complaint alleges this term covers a "keyword," "trigger phrase," or a "voice request" (Compl. ¶48). The construction of this term will determine whether Google's keyword-spotting and endpointing technologies can be considered infringing.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The claim language itself is general, referring to a determiner that decides "whether or not a sound... is a speech segment" (’259 Patent, col. 58:19-22). The abstract uses similarly broad phrasing.
    • Evidence for a Narrower Interpretation: The detailed description repeatedly explains the determination of a speech segment by focusing on the detection of "formants" and frequency spectra characteristic of human vowel sounds (’259 Patent, col. 4:59-65). A defendant may argue this disclosure limits the term to sounds with these specific acoustic properties, rather than any audio signal that activates a keyword spotter.

From the ’374 Patent (Claim 9)

  • The Term: "pick-up state of the voice sound"
  • Context and Importance: This is a crucial input for the claimed "control unit," which must base its control of the LED on this state in conjunction with the "communication mode." The complaint equates this term with the "signal characteristics" determined by Google's NAB and ASR algorithms (Compl. ¶68). Its definition is central to whether the final limitation of the claim is met.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The patent states that the method involves evaluating "speech quality of a speech signal" (’374 Patent, col. 2:31-32), which could be interpreted broadly to encompass various "signal characteristics."
    • Evidence for a Narrower Interpretation: The specification provides specific examples of what determines the "pick-up state," focusing on metrics like the average power of microphone signals and the power ratio of a noise-cancelled signal to the original signal (’374 Patent, col. 7:1-25; FIG. 5). A defendant may argue that "pick-up state" is limited to these specific objective measures of signal quality and noise, not the broader concept of "signal characteristics" determined by ASR.

VI. Other Allegations

  • Indirect Infringement: The complaint does not include specific counts for indirect infringement (e.g., inducement or contributory infringement). The three counts for relief are limited to direct infringement under 35 U.S.C. § 271(a) (Compl. ¶56, ¶77, ¶90).
  • Willful Infringement: The prayer for relief seeks "enhanced damages for willful infringement" (Compl. p. 22, ¶d). However, the body of the complaint does not contain factual allegations typically used to support willfulness, such as assertions of pre-suit knowledge of the patents-in-suit or objective recklessness.

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

  • A core issue will be one of technical mapping: The case will likely require a deep technical analysis of whether the accused systems' advanced, AI-driven processes (e.g., "neural network adaptive beamforming," "keyword spotting") function in the specific, structured manner required by the patent claims. A key question for the court will be whether the complaint's reliance on high-level descriptions from Google's research papers establishes a precise operational correspondence or merely a functional analogy.
  • A second central issue will be one of definitional scope: The dispute may turn on whether claim terms rooted in the context of 2011-era audio processing, such as "speech segment" (described via vowel formants) and "pick-up state" (described via power ratios), can be construed broadly enough to encompass the functionalities of modern smart speaker systems that operate on different principles.
  • Finally, a key evidentiary question will be one of system integration: For the '374 patent, the plaintiff must demonstrate that the accused devices' LED is controlled based on a combination of both the "communication mode" and the "pick-up state." The case may depend on whether discovery reveals evidence of this specific, conjunctive logic in the accused products' control systems, or if these functions operate independently.