PTAB

IPR2018-00341

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 voice-controlled cable television system. It purports to address the high cost of prior art systems by locating the complex speech recognition processing at a central network head-end rather than in individual, costly user devices.

3. Grounds for Unpatentability

Ground 1: Obviousness over Julia in view of Houser - Claims 34-35, 37, 40, and 41 are obvious over Julia alone or combined with 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 teaches every element of the challenged independent claims. Julia described a centralized, multi-user "data navigation system" where a portable remote control captures spoken input and wirelessly transmits it to a local set-top box ("communications box"). This set-top box then retransmits the voice data over a network, such as a cable television network, to a "remote server" that performs speech recognition. After processing, the server returns content and instructions to the set-top box for display. Petitioner contended this architecture directly maps to the claimed system of a remote, a set-top box, and a centralized processing station. For dependent claims, Julia was argued to teach a "press to activate" button for the remote (claim 35) and show a remote with a keypad (claim 37).
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Julia with Houser to implement more detailed device-control functionalities. While Julia focused on retrieving content, Houser explicitly disclosed using a similar remote-server architecture to execute specific device commands like changing channels, adjusting volume, and navigating menus. Houser also explicitly taught features like a "press to speak" button and separate transmitters for keypad and voice signals. A POSITA would combine these known features from Houser's analogous system to enhance Julia’s user interface, which was a simple and predictable design choice.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the combination involved applying conventional control features from Houser to the very similar network architecture disclosed in Julia. This would yield the predictable result of a more functional and user-friendly voice control system.

Ground 2: Obviousness over Murdock in view of Houser - Claims 34-35, 37, 40, and 41 are obvious over Murdock alone or combined with 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 the core architecture of the challenged claims. Murdock taught a voice-activated system where a portable "program control device" (the remote) captures a user's verbal command and wirelessly transmits it to a "local processing unit" (the set-top box). The set-top box then transmits the signal over a "back channel" to a "remote server computer" located at the service provider. This centralized server performed speech recognition, determined the requested content, and transmitted it back to the set-top box via a "forward channel." Petitioner argued this system directly read on the limitations of the independent claims. Murdock also disclosed a push-button on the remote to activate voice transmission, mapping to claim 35.
    • Motivation to Combine: The motivation to combine Murdock with Houser was presented as being identical to the motivation for the Julia combination. A POSITA would have found it advantageous to incorporate Houser’s explicit teachings on a wider array of specific device-control commands (e.g., power on/off, VCR control) and detailed remote-control features into Murdock’s system. This combination would predictably improve the functionality and user experience of the system disclosed in Murdock by using known methods from a similar field.
    • Expectation of Success: Success would be expected as the combination merely integrated known functionalities from Houser into the analogous system of Murdock, representing a standard and predictable engineering path to enhance system capabilities.

4. Key Claim Construction Positions

  • "television remote control means" (claim 40): Petitioner argued this term recites sufficient structure (a television remote control) to be understood by its plain meaning. However, as an alternative should it be found to be a means-plus-function term under 35 U.S.C. §112, Petitioner proposed the function of "directly and wirelessly controlling television sets and additionally receiving user voice input and wirelessly transmitting first output..." and the corresponding structure as "a television remote control with a microphone and a wireless transmitter" and equivalents.
  • "television set-top box means" (claim 40): Petitioner asserted this term is not a means-plus-function term because, while it uses the word "means," it recites sufficient structure (a television set-top box) and does not recite a corresponding function. Therefore, it should be given its plain meaning.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 34-35, 37, 40, and 41 of Patent 7,260,538 as unpatentable.