PTAB

IPR2015-00078

Plantronics Inc v. Callpod Inc

Key Events

Petition

petition Intelligence

Title: Mobile Conferencing and Audio Sharing Technology
Brief Description: The ’445 patent discloses a conferencing system designed to improve upon prior art by allowing multiple participants to use individual wireless devices, such as headsets, connected to a central audio mixer. The mixer is configured with a "summer" to sum audio inputs from different interfaces and a "divider" to divide the sum equally to provide an "equalized audio output" to all participants.

Prior Art Relied Upon: McMillen (Application # 2005/0286443) and Peters (Application # 2003/0012148).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that McMillen teaches the core architecture of the claimed invention. McMillen discloses a conferencing system with a central "hub" (an audio mixer) that connects to multiple local "conferencing nodes" and a remote voice communication system, thereby providing the required "at least three audio interfaces." McMillen’s system supports full duplex communication and uses wireless technologies like Bluetooth. To the extent that McMillen does not explicitly disclose the claimed "summer and a divider" mixing algorithm, Peters teaches this exact method. Peters describes an audio mixer that operates on a simple sum-and-divide algorithm (e.g., (A+B)/2) to combine audio signals from multiple callers.
- Motivation to Combine: A POSITA would combine Peters' well-known sum-and-divide mixing algorithm with McMillen's conferencing system as an obvious design choice. Implementing a standard, simple mixing algorithm like that in Peters would be a predictable way to achieve the audio mixing functionality required by McMillen’s system to produce valid, undistorted output signals.
- Expectation of Success: Combining these familiar elements would predictably yield a functioning conferencing system with undistorted audio output, as it involves applying a known mixing technique to a known type of system.

Prior Art Relied Upon: McMillen (Application # 2005/0286443), Peters (Application # 2003/0012148), and Yoakum (Application # 2004/0058674).
Core Argument for this Ground:
- Prior Art Mapping: This ground builds upon Ground 1 to address claims requiring the use of a "wireless headset." While McMillen suggests its nodes can use a headset, Yoakum explicitly teaches a conferencing system that connects via Bluetooth to multiple audio subsystems implemented as wireless headsets.
- Motivation to Combine: A POSITA would combine Yoakum's teaching of wireless headsets with the McMillen/Peters system to provide users with increased mobility. Petitioner contended that the interchangeability of free-air speakers/microphones with headsets was well-known, making this a simple and obvious substitution to achieve a known benefit.

Prior Art Relied Upon: Bell (Patent 6,405,027) and Peters (Application # 2003/0012148).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner presented this as an alternative primary ground, noting that Bell has an earlier priority date than McMillen. Bell teaches a mobile handset configured to act as a central hub for a group call, connecting wirelessly (e.g., via Bluetooth) to other local devices and to a remote device over a cellular or PSTN network. Bell's handset includes a baseband section with a DSP and microprocessor for mixing audio signals from the various connected devices. As in Ground 1, Peters supplies the explicit teaching of a sum-and-divide mixing algorithm.
- Motivation to Combine: The motivation is identical to that in Ground 1. A POSITA would have found it obvious to implement the well-known sum-and-divide mixing from Peters into Bell's conferencing system to combine audio signals predictably and without distortion.
- Key Aspects: This ground ensures the unpatentability argument stands even if the patent owner were to swear behind the McMillen reference date.
Additional Grounds: Petitioner asserted an additional obviousness challenge against claims 9, 12, 14, and 16-19 based on the combination of Bell, Peters, and Yoakum, relying on a similar rationale of substituting Yoakum’s wireless headsets into Bell's base system for improved mobility.

"mixes": Petitioner proposed this term be construed as "combines audio inputs according to the operation of the claimed summer and divider." This construction renders the term's inclusion largely redundant, as the claims already recite the specific summer and divider operations.
"equalized audio output": Proposed as "an output that has been amplified or de-amplified." This construction is based on the specification's definition, which ties equalization to the process of summing inputs and dividing the sum by the number of interfaces.
"module": Proposed as "a packaged functional hardware unit designed for use with other components," based on a standard technical dictionary definition (IEEE) and context from the specification. This construction is relevant for claims reciting a "conferencing module."

Petitioner requests the institution of an inter partes review and cancellation of claims 1-20 of the ’445 patent as unpatentable.