PTAB

IPR2018-00340

Comcast Cable Communications LLC v. Promptu Systems Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Voice Control of a Television Control Device
  • Brief Description: The ’538 patent relates to a system for voice control of a cable television set-top box. It purports to solve the high cost of prior art systems, which required sophisticated local processing, by centralizing the speech recognition processing at a remote head-end unit within the cable network.

3. Grounds for Unpatentability

Ground 1: Claims 1-7, 17-24, and 33 are obvious over [Julia](https://ai-lab.exparte.com/case/ptab/IPR2018-00340/doc/1017) alone or in view of [Houser](https://ai-lab.exparte.com/case/ptab/IPR2018-00340/doc/1019).

  • Prior Art Relied Upon: Julia (Patent 6,513,063) and Houser (Patent 5,774,859).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Julia disclosed the core invention: a home entertainment system where a portable remote control with a microphone captures a user's voice command. The remote wirelessly transmits the voice data to a local communications box (a set-top box), which then transmits the data over a two-way network (disclosed as potentially coaxial cable) to a remote server for speech recognition processing. Petitioner contended this remote server, which services multiple users, is analogous to the claimed head-end unit. For limitations in independent claims requiring the head-end to derive and transmit a "command function" back to the set-top box, Petitioner asserted that Houser explicitly taught this concept. Houser described a system where a remote node processes a voice command and transmits recognized commands back to the local terminal unit to control television functions like changing channels or adjusting volume.
    • Motivation to Combine: Petitioner argued that a person of ordinary skill in the art (POSITA) would combine Julia and Houser because both patents address the same problem of providing voice control in an interactive television system. A POSITA would have been motivated to incorporate Houser's explicit teachings on returning executable commands for local device control into Julia’s server-side processing architecture to create a more comprehensive and functional system. Houser also supplied teachings for dependent claims, such as using a push-to-talk button or predetermined utterances for activation.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining these systems, as it involved applying known voice command processing techniques from Houser to the similar network architecture of Julia to achieve the predictable result of enhanced remote control functionality.

Ground 2: Claims 1-7, 17-24, and 33 are obvious over [Murdock](https://ai-lab.exparte.com/case/ptab/IPR2018-00340/doc/1018) alone or in view of Houser.

  • Prior Art Relied Upon: Murdock (Patent 7,013,283) and Houser (Patent 5,774,859).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Murdock, like Julia, disclosed all key elements of the claimed invention. Murdock described a system where a portable hand-held controller captures a verbal command and wirelessly transmits it to a local processing unit (a "set top terminal"). The local unit then transmits the signal via a "back channel" to a "remote server computer" located at a service provider, which Petitioner equated to a cable head-end. This remote server performed speech recognition and returned the requested programming content. As with the Julia combination, Petitioner argued that Houser supplemented Murdock’s disclosure by explicitly teaching the transmission of executable command functions (not just content) back to the local device for execution.
    • Motivation to Combine: Petitioner asserted a similar motivation to combine Murdock and Houser. Both addressed voice control for television systems, and a POSITA would have recognized the benefit of integrating Houser's more detailed teachings on local device control commands and remote-control features into Murdock's system. This combination would predictably enhance Murdock's content-retrieval system with the ability to also control local set-top box and television functions.
    • Expectation of Success: The combination of known elements from Murdock and Houser, both within the field of interactive television, would have yielded predictable results, giving a POSITA a reasonable expectation of success.

4. Key Claim Construction Positions

Petitioner argued that several terms in apparatus claim 18 should be construed as means-plus-function limitations under 35 U.S.C. §112, ¶ 6.

  • "activation means for receiving user-activated indication of a voice command": Petitioner proposed the function is "receiving user-activated indication of a voice command" and the corresponding structure disclosed in the ’538 patent is a "push to talk (PTT) button" or "a word recognition unit" and their equivalents.
  • "head-end unit including processing means for deriving... command functions": Petitioner proposed the function is "deriving cable-television-controller-compatible command functions..." and the corresponding structure is a "speech recognition processor 670" and its equivalents.
  • "means responsive to receipt of the command functions for executing the command functions": Petitioner proposed the function is "executing the command functions" and the corresponding structure is "a processor" and its equivalents.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-7, 17-24, and 33 of the ’538 patent as unpatentable.