PTAB

IPR2018-00340

Comcast Cable Communications, LLC v. PROMPTU SYSTEMS CORPORATION

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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 in a cable television network. It describes a method where a user's voice command is captured by a remote control, transmitted to a set-top box, and then relayed to a central head-end for speech recognition processing, with a resulting command function sent back to the set-top box for execution.

3. Grounds for Unpatentability

Ground 1: Claims 1-7, 17-24, and 33 are obvious under 35 U.S.C. §103 over Julia alone or in view of Houser.

  • 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 all essential elements of the challenged claims. Julia described a system with a portable remote control (voice input device 102) that captures a voice command via an integrated microphone and, upon user activation, wirelessly transmits it to a local communications box (104), which can be a set-top box. This box then transmitted the voice data across a network to a remote server (108) for server-side speech recognition. Petitioner asserted this remote server, which processed the command and returned a responsive command function (e.g., an interactive menu) to the set-top box for execution, corresponded to the claimed head-end unit.
    • Motivation to Combine: A person of ordinary skill in the art (POSA) would combine Julia with Houser because both related to voice control in television systems and addressed the same problem. Petitioner argued that while Julia taught the core architecture, Houser explicitly disclosed that its remote processing node could serve a plurality of users on a time-sharing basis. Houser also taught specific remote-control features (e.g., PTT switches, voice activation commands) that were well-known and would have been obvious enhancements to Julia's system to improve functionality.
    • Expectation of Success: A POSA would have had a reasonable expectation of success in combining the known elements from Julia and Houser to achieve the claimed system, as it involved applying predictable solutions to a known problem.

Ground 2: Claims 1-7, 17-24, and 33 are obvious under §103 over Murdock 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 contended that Murdock also disclosed the claimed invention. Murdock described a portable "program control device" (110) with a microphone and push-button that functioned as a remote control. This device wirelessly transmitted a captured voice command to a local processing unit (120), such as a set-top terminal. The terminal then relayed the command via a back channel to a "remote server computer" (130) located at the service provider (i.e., the head-end), which performed speech recognition. The server then retrieved content and transmitted it with corresponding command functions back to the local unit for execution and display.
    • Motivation to Combine: The motivation to combine Murdock with Houser was argued to be the same as for Julia. A POSA would recognize the benefits of incorporating Houser's explicit teachings on multi-user remote processing and advanced remote-control features into Murdock’s architecturally similar system to yield predictable results.
    • Expectation of Success: Combining Murdock's fundamental system with Houser's specific and known features was presented as a straightforward integration of established technologies that would have a high expectation of success.

4. Key Claim Construction Positions

  • The petition asserted that several terms in apparatus claim 18 should be construed as means-plus-function limitations under 35 U.S.C. §112. These constructions were central to Petitioner's argument that the prior art disclosed corresponding structures for performing the claimed functions.
  • "activation means" (claim 18): Petitioner proposed the function of "receiving user-activated indication of a voice command" is performed by the structure of a "push to talk (PTT) button" or "a word recognition unit" disclosed in the ’538 patent’s specification.
  • "processing means" (at head-end, claim 18): Petitioner proposed the function of "deriving cable-television-controller-compatible command functions" is performed by the disclosed structure of a "speech recognition processor 670".
  • "means responsive to receipt of the command functions" (at controller, claim 18): Petitioner proposed the function of "executing the command functions" is performed by the disclosed structure of "a processor".
  • "transmission means" (at remote, claim 18): Petitioner proposed the function of "wirelessly transmitting a signal representing the voice command" is performed by the structure of a "transmitter 224," such as an RF or infrared transmitter.

5. Relief Requested

  • Petitioner requested institution of an inter partes review (IPR) and cancellation of claims 1-7, 17-24, and 33 of Patent 7,260,538 as unpatentable.