PTAB

IPR2013-00216

Applied Voice & Speech Technologies Avst v. IPVX Patent Holdings Inc

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1. Case Identification

2. Patent Overview

  • Title: Telephone Answering Device Linking Displayed Data with Recorded Audio Message
  • Brief Description: The ’576 patent discloses methods for a telephone answering device that automatically answers calls, stores voice messages, and displays caller-identifying information. A user can selectively retrieve a specific voice message by viewing the linked caller data, either on the device itself or on a remote access device that receives the caller information.

3. Grounds for Unpatentability

Ground 1: Anticipation - Claims 3, 4, 18, and 19 are unpatentable under 35 U.S.C. §102(b) as anticipated by Ertz.

  • Prior Art Relied Upon: Ertz (Patent 5,003,577).
  • Core Argument
    • Prior Art Mapping: Petitioner argued that Ertz discloses every element of the challenged claims by teaching a voice mail service system that provides visual, selective retrieval of voice messages using a remote computer terminal. This terminal functions as the claimed "remote access device," receiving message headers (the "first signals") that identify the caller via a data connection. Ertz's system links these headers to the corresponding stored voice messages and allows a user to select a header on the visual interface to trigger playback of the linked message over a voice connection. Petitioner asserted that the display of headers with caller information (name, extension) and the ability to select one for playback inherently teaches the limitations of storing, displaying, linking, and selectively retrieving messages upon user demand.

Ground 2: Anticipation - Claims 3, 4, 18, and 19 are unpatentable under 35 U.S.C. §102(b) as anticipated by Kamel.

  • Prior Art Relied Upon: Kamel ("PX: Supporting Voice in Workstations," an IEEE article from Aug. 1990).
  • Core Argument
    • Prior Art Mapping: Petitioner asserted that Kamel’s "PX Answering Machine," implemented as a software application on a networked workstation, anticipates the challenged claims. Kamel's system automatically answers calls, records messages, and displays a message log with caller names ("Message From") on a visual user interface. This display of caller data constitutes receiving "first signals." The workstation itself, which can access voice files from a local disk or a shared remote file server, functions as the "remote access device." Petitioner argued that because a user can select a caller's name from the list (point and click) to play the corresponding voice message, the system necessarily links the caller identity to the message and enables selective retrieval.

Ground 3: Obviousness - Claims 3, 4, 18, and 19 are obvious over Jachmann in view of Ertz.

  • Prior Art Relied Upon: Jachmann (Patent 4,853,952) and Ertz (Patent 5,003,577).

  • Core Argument

    • Prior Art Mapping: Petitioner argued that Jachmann discloses a voice messaging system (VMS) coupled to a telephone that stores voice messages and transmits text messages with caller information to a remote station for display, where the station functions as a remote access device. To the extent Jachmann's limited two-line display and non-real-time data transfer do not meet certain limitations (e.g., simultaneous display of multiple callers or retrieval "upon user demand"), Ertz supplies these features. Ertz teaches a comprehensive graphical user interface for a VMS that allows a user to view a list of message headers and select any of them for immediate playback.
    • Motivation to Combine: A POSITA would combine Jachmann's VMS with Ertz's superior visual interface to improve the system's usability and efficiency. Ertz’s interface provides a more comprehensive and intuitive way to manage voice messages than Jachmann's limited display, addressing a well-understood need for better user interaction with then-contemporary voicemail systems.
    • Expectation of Success: Combining a known graphical user interface (Ertz) with a known VMS (Jachmann) was a straightforward integration of established computer-telephony technologies. A POSITA would have had a high expectation of success, as the combination would predictably result in an improved visual voicemail system.

  • Additional Grounds: Petitioner asserted additional anticipation challenges based on Coleman (a 1988 article) and obviousness challenges based on Coleman in view of Ertz and Kamel, and Cohen (Patent 4,837,798) in view of Ertz, Kamel, Coleman, Schmandt, or Riley.

4. Key Claim Construction Positions

  • "remote access device": Petitioner argued, based on the patent's prosecution history and specification, that this term should be construed as a device that does not require separate voice and data channels to communicate with the answering device. This device could be portable or non-portable and either physically separated from or in close proximity to the main answering unit.
  • "such that said first signals are available upon user demand": Petitioner contended this phrase, which was added during prosecution to distinguish over Jachmann, should be construed to encompass methods where a user initiates an action, such as placing a telephone call to the answering device, to retrieve the caller information. Petitioner argued this construction is consistent with all of the patent’s disclosed embodiments for remote access.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 3, 4, 18, and 19 of the ’576 patent as unpatentable.