DCT

1:24-cv-01283

SoundClear Tech LLC v. Amazon.com Inc

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I. Executive Summary and Procedural Information

  • Parties & Counsel:
  • Case Identification: 1:24-cv-01283, E.D. Va., 07/25/2024
  • Venue Allegations: Plaintiff asserts venue is proper in the Eastern District of Virginia because Defendant Amazon maintains its "HQ2" second headquarters in Arlington, Virginia, which it alleges is a regular and established place of business where development of accused features, such as for Amazon Alexa, occurs. The complaint also cites prior court decisions in the district that have found venue proper for Amazon.
  • Core Dispute: Plaintiff alleges that Defendant’s Amazon Echo, Fire tablet, and Alexa-enabled products infringe three patents related to adaptive voice control, contextual word replacement in voice responses, and touchscreen gesture controls.
  • Technical Context: The technologies at issue relate to user interface methods for smart devices, focusing on how voice assistants and touchscreen apparatuses process user input and adapt their output based on context such as user proximity, input style, or gesture type.
  • Key Procedural History: The complaint states that the patents-in-suit were originally generated by engineers at JVC Kenwood ("JVCK") and were subsequently acquired by Plaintiff. The complaint also references prior litigation involving Amazon in the district to support its arguments for venue.

Case Timeline

Date Event
2011-09-28 U.S. Patent No. 9,223,487 Priority Date
2015-12-29 U.S. Patent No. 9,223,487 Issue Date
2018-03-06 U.S. Patent No. 11,069,337 Priority Date
2018-03-12 U.S. Patent No. 11,244,675 Priority Date
2021-07-20 U.S. Patent No. 11,069,337 Issue Date
2022-02-08 U.S. Patent No. 11,244,675 Issue Date
2024-07-25 Complaint Filing Date

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

U.S. Patent No. 11,069,337 - "Voice-Content Control Device, Voice-Content Control Method, and Non-Transitory Storage Medium," issued July 20, 2021

The Invention Explained

  • Problem Addressed: The patent’s background section describes a scenario where a voice response from a device, while audible to the intended user, may be overheard by and be an "annoyance to" other people nearby (’337 Patent, col. 1:28-34). Simply lowering the volume might make the response "hard to be heard by the user himself" (’337 Patent, col. 1:35-38).
  • The Patented Solution: The invention proposes a system that classifies a user's voice into one of two types (e.g., based on distance or whether it is a whisper). Based on this classification, it generates a different output sentence. For a "second voice," it generates a sentence where "a part of information included in the first output sentence is omitted," thereby shortening the response to be less disruptive while remaining understandable to the user. (’337 Patent, Abstract; col. 2:1-11).
  • Technical Importance: The technology aims to make voice assistants more socially aware by adapting the verbosity of their responses to the user's context, which may enhance privacy and reduce disruption in shared environments (Compl. ¶36).

Key Claims at a Glance

  • The complaint asserts at least independent claim 4 (Compl. ¶59).
  • The essential elements of independent claim 4 include:
    • calculating a distance between a user and a voice-content control device;
    • acquiring a voice spoken by a user;
    • analyzing the voice to classify it as a "first voice" or a "second voice" based on the calculated distance;
    • generating a "first output sentence" for the first voice, and a "second output sentence" for the second voice "in which a part of information included in the first output sentence is omitted"; and
    • adjusting the sound volume of the voice data such that the volume for the first output sentence "differs from" the volume for the second output sentence.

U.S. Patent No. 11,244,675 - "Word Replacement in Output Generation for Detected Intent by Voice Classification," issued February 8, 2022

The Invention Explained

  • Problem Addressed: The patent identifies that a notification from a voice control device may be heard by people other than the user, potentially revealing information the user "wished not to be known by people other than the user" (’675 Patent, col. 1:29-33).
  • The Patented Solution: The invention describes a system that classifies a user's voice (e.g., based on distance calculated by a proximity sensor) into a first or second type. For a "first voice," it generates a response where "at least one word selected among words included in the content information... is replaced with another word." For a "second voice," it generates a response containing the full, un-replaced information. (’675 Patent, Claim 6). This allows for contextual obfuscation of sensitive details.
  • Technical Importance: The technology provides a method for dynamically redacting or altering spoken information to protect user privacy when a device is used in a non-private setting (Compl. ¶43).

Key Claims at a Glance

  • The complaint asserts at least independent claim 6 (Compl. ¶72).
  • The essential elements of independent claim 6 include:
    • calculating a distance between the user and the device using a "proximity sensor" to classify the user's voice as a "first voice" or "second voice";
    • analyzing the voice to detect "intention information";
    • acquiring "notification information" which includes "content information";
    • when the voice is a "first voice," generating a "first output sentence" in which at least one word from the content information is "replaced with another word"; and
    • when the voice is a "second voice," generating a "second output sentence" that includes all of the intention and content information. (Note: A Certificate of Correction dated May 21, 2024, corrects the last clause to read "when the voice is determined to be the second voice," from the original "when the voice is not determined to be the second voice.")

U.S. Patent No. 9,223,487 - "Electronic Apparatus, Method of Controlling the Same, and Related Computer Program," issued December 29, 2015

Technology Synopsis

This patent discloses a method for controlling an electronic apparatus via its touchscreen. The invention allows a user to select an object or group of objects by performing a two-finger gesture where the distance between the touch points decreases over time (i.e., a "pinch-in" or "zoom-out" gesture), which defines a rectangular selection area (’487 Patent, Abstract). The method also involves analyzing the vectors of the touch points' movement relative to a line connecting them to confirm the gesture (’487 Patent, col. 2:11-27).

Asserted Claims

The complaint asserts at least independent claim 11 (Compl. ¶83).

Accused Features

The complaint accuses the multi-touch "pinch inward" or "zoom out" functionality available on Amazon’s touchscreen products, such as the Amazon Fire tablets and Amazon Echo Show devices (Compl. ¶¶86, 89).

III. The Accused Instrumentality

Product Identification

The complaint names a broad category of "Amazon Products and Services," including numerous generations of Amazon Echo, Echo Dot, Echo Show, Echo Spot, and Echo Studio devices; Amazon Fire and Kindle Fire tablets; and Amazon Fire TV products (Compl. ¶15). The core accused technologies are the Alexa voice assistant and the touchscreens on enabled devices.

Functionality and Market Context

  • The complaint alleges the accused products incorporate microphones and connect to the Alexa Voice Service (AVS) to process voice commands (Compl. ¶60). It identifies specific features like "Adaptive Content" and "ultrasound motion detection" for determining user proximity, "Voice ID" for user recognition, and "Adaptive Volume" for adjusting response volume or entering a "whisper" mode (Compl. ¶¶61, 63, 66).
  • For touchscreen devices, the complaint highlights the capability to detect multi-touch gestures, specifically citing Amazon's documentation that a user can "pinch inward or outward with two fingers when the screen is magnified" (Compl. ¶86). The "zoom out" function is alleged to be activated when the distance between two fingers decreases (Compl. ¶89).
  • The complaint positions Amazon as the "world's largest online retailer" and a major producer of consumer electronics, underscoring the commercial scale of the accused products (Compl. ¶20).

No probative visual evidence provided in complaint.

IV. Analysis of Infringement Allegations

'337 Patent Infringement Allegations

Claim Element (from Independent Claim 4) Alleged Infringing Functionality Complaint Citation Patent Citation
calculating a distance between a user and a voice-content control device The accused products allegedly use "ultrasound motion detection," "adaptive content," and "SIR beam selection" to detect user proximity and calculate distance. ¶61 col. 19:23-25
acquiring a voice spoken by a user The accused products use microphones to capture voice sounds, which are processed by the Alexa Voice Service (AVS). ¶62 col. 19:26-28
analyzing the acquired voice to classify the acquired voice as either one of a first voice and a second voice based on the distance... The accused products allegedly classify a voice as near or far using the distance-detecting features, or as belonging to a specific person using Voice ID. ¶63 col. 19:28-35
generating... a first output sentence... and a second output sentence... in which a part of information included in the first output sentence is omitted... Amazon's devices allegedly provide different amounts of information based on classification (e.g., personalized results via Voice ID vs. generic results, or more vs. less information for a near vs. far user). ¶67 col. 20:1-9
adjusting a sound volume of voice data... such that the sound volume... differs from the sound volume... of the second output sentence... The accused products allegedly use "Adaptive Volume" to adjust volume based on ambient noise or use a "whisper" voice, which differs in volume and character from a normal response. ¶68 col. 20:10-18
  • Identified Points of Contention:
    • Scope Questions: A central question may be whether Amazon's alleged classification methods, such as recognizing a user via "Voice ID" or detecting a "whisper," satisfy the claim limitation of classifying "based on the distance." The complaint connects these features, but a court may need to determine if the link is direct enough to meet the claim's requirement.
    • Technical Questions: Does providing a "personalized" versus a generic response, or displaying "more or less information," constitute the generation of a "second output sentence in which a part of information... is omitted," as claimed? The analysis may focus on whether information is actively removed from a base sentence or if two distinct sentences are generated independently.

'675 Patent Infringement Allegations

Claim Element (from Independent Claim 6) Alleged Infringing Functionality Complaint Citation Patent Citation
calculating a distance between the user and an output-content control device by a proximity sensor to classify the voice... The complaint alleges that features like "ultrasound motion detection," "adaptive content," and "SIR beam selection" function as the claimed "proximity sensor" to determine distance for classification. ¶75 col. 22:10-13
analyzing the acquired voice to detect intention information... The accused products allegedly use Automatic Speech Recognition (ASR) and Natural Language Understanding (NLU) to interpret the user's intent. ¶76 col. 22:14-17
acquiring notification information which includes content information... Amazon Alexa allegedly obtains the relevant output for a user's request, which serves as the notification and content information. ¶77 col. 22:18-21
generating, when the voice is determined to be the first voice, a first output sentence in which at least one word... is replaced with another word It is alleged that when a specific user is recognized (via Voice ID) or is nearby (via Adaptive Content), the system provides a customized response, which the complaint frames as a "replacement" of generic information. ¶78 col. 22:22-28
generating, when the voice is determined to be the second voice, a second output sentence which includes all of the intention information and the content information It is alleged that for a non-primary user or a distant user, the system can provide "unfiltered/non-customized" or "more/additional" information. ¶79 col. 22:29-35
  • Identified Points of Contention:
    • Scope Questions: A critical issue will be whether generating a different, personalized sentence for a recognized user constitutes "replacing" a word as required by the claim. A court may have to decide if this term requires a literal token-swapping operation on a base sentence, which is suggested by figures in the patent (’675 Patent, FIG. 6), or if generating a different sentence suffices.
    • Technical Questions: The complaint's infringement theory for claim 6 appears to rely on the original, uncorrected claim language. The Certificate of Correction alters a key limitation regarding the condition for generating the second output sentence. This raises a question of whether the complaint's allegations align with the asserted claim as it now legally stands.

V. Key Claim Terms for Construction

Term: "replaced with another word" (’675 Patent, Claim 6)

  • Context and Importance: This term is fundamental to the infringement allegation for the '675 patent. The dispute will likely center on whether providing a different set of information (e.g., a personalized calendar entry for User A vs. a generic denial for User B) constitutes "replacement." Practitioners may focus on this term because the patent's specification provides some evidence for a narrower, more technical definition.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The abstract describes generating an output sentence where a word is "replaced with another word when the voice is determined to be the predetermined voice," without specifying the mechanism. A party could argue this supports a functional interpretation where information is effectively swapped out.
    • Evidence for a Narrower Interpretation: The specification includes Figure 6, a table titled "RELATIONSHIP INFORMATION," which explicitly lists a "WORD TO BE REPLACED" and a "REPLACING WORD." (’675 Patent, FIG. 6). This suggests a specific, token-based substitution mechanism, which may support a narrower construction than what the complaint alleges.

Term: "based on the distance" (’337 Patent, Claim 4 & ’675 Patent, Claim 6)

  • Context and Importance: Both lead patents require voice classification to be "based on the distance." The infringement case for both patents hinges on whether Amazon's features like user recognition (Voice ID) or whisper detection can be tied to a distance calculation.
  • Intrinsic Evidence for Interpretation:
    • Evidence for a Broader Interpretation: The term "based on" can be interpreted to require only a loose or indirect relationship. A party might argue that since distance is one of several factors a system could use, any classification that is context-aware could be argued to be related to distance.
    • Evidence for a Narrower Interpretation: The claim language in both patents is specific. The ’337 patent requires "calculating a distance" and then classifying "based on the distance" (’337 Patent, Claim 4). The ’675 patent is even more specific, requiring calculation of distance "by a proximity sensor" (’675 Patent, Claim 6). This language suggests that distance must be a direct input to the classification step, not merely a correlated variable.

VI. Other Allegations

Indirect Infringement

The complaint does not plead separate counts for indirect or contributory infringement. It does, however, include an allegation that Defendants introduce infringing products into the stream of commerce "knowing that they would be used, offered for sale, or sold in this judicial district" (Compl. ¶14), which contains language that could potentially be used to support an inducement theory later in the case.

Willful Infringement

The complaint does not allege that Amazon had pre-suit knowledge of the patents-in-suit. The prayer for relief includes a request for "enhanced damages for willful infringement" (Compl. p. 32), but the factual allegations in the body of the complaint do not provide a basis for such a claim.

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

  1. A central issue will be one of definitional scope: can the act of generating distinct personalized and non-personalized sentences be construed as "replacing" a word, as required by the '675 patent, or does the claim demand a more literal token-swapping operation within a single sentence structure?
  2. A key question of causation will arise: do the accused products' classification methods, such as recognizing a user via Voice ID or detecting a whisper, satisfy the '337 and '675 patents' requirement for classification "based on the distance," or is there a fundamental disconnect between the alleged function and the claimed mechanism?
  3. An evidentiary question for the '487 patent will be whether the accused pinch-to-zoom-out functionality on Amazon's devices performs the specific geometric analysis required by claim 11, particularly the limitations concerning the angles formed by the touch points' vectors of movement.