PTAB

IPR2018-00343

Comcast Cable Communications LLC v. Promptu Systems Corp

Key Events

Petition

petition

Title: System and Method of Voice Recognition Near a Wireline Node of a Network Supporting Cable Television and/or Video Delivery
Brief Description: The ’326 patent describes a system for providing voice control within a cable television or similar video delivery network. The technology involves capturing a spoken command at a first user device, transmitting it to a remote networked location for speech processing, and delivering responsive information to a second device.

Prior Art Relied Upon: Murdock (Patent 7,013,283).
Core Argument for this Ground:
- Prior Art Mapping: Petitioner argued that Murdock discloses every element of the challenged claims. Murdock describes an interactive television system where a user issues spoken commands using a wireless handheld controller (the "first device"). The speech information is transmitted wirelessly to a local set-top box and then via a network "back channel" (the "first network path") to a remote server computer for speech recognition. The remote server, acting as the "speech recognition engine," processes the command, retrieves the requested content, and transmits it via a "forward channel" (the "second network path") to the user's television display (the "second device"). Petitioner asserted this architecture directly maps to the limitations of independent claims 1 and 12.
- Key Aspects: Petitioner contended that Murdock alone renders all challenged claims obvious, including dependent claims related to video search, unrecognized state transfer, and user site identification, as these were inherent or obvious implementations of Murdock's system.

Prior Art Relied Upon: Murdock (Patent 7,013,283), Banker (Patent 5,477,262), and Gordon (Patent 6,314,573).
Core Argument for this Ground:
- Prior Art Mapping: This ground addressed dependent claims requiring a "financial consequence." Petitioner argued that while Murdock taught ordering on-demand content which implies a financial transaction, Banker and Gordon explicitly detailed the implementation of such systems. Banker and Gordon both disclosed user interfaces for pay-per-view or subscription services in a cable environment, including assessing a purchase request (e.g., via a "BUY key" or PIN confirmation), communicating the financial consequence to the user, receiving confirmation to create a financial commitment, and subsequently billing the user’s account.
- Motivation to Combine: A POSITA looking to implement the on-demand functionality suggested in Murdock would naturally look to well-known systems like those in Banker and Gordon for guidance on user interfaces and billing. Combining Murdock's voice-command front-end with Banker's or Gordon's established transaction-processing back-end was presented as a straightforward integration of known elements to achieve a predictable result.
- Expectation of Success: Because all references operated in the same field of interactive television and addressed common problems like content delivery and billing, a POSITA would have had a high expectation of success in combining their teachings.

Prior Art Relied Upon: Julia (Patent 6,513,063).
Core Argument for this Ground:
- Prior Art Mapping: As an alternative primary reference, Petitioner argued that Julia also discloses the core invention. Julia describes a system for navigating network data sources using spoken input. A user speaks into a portable remote control (the "first device"), and the voice data is transmitted to a local communications box (e.g., a set-top box) and then over a network to a remote server. The server uses "request processing logic" (the "speech recognition engine") to process the command and retrieve multimedia content, which is then transmitted back across the network to a client display device for viewing (the "second device"). Petitioner asserted this system also met all limitations of the independent claims.
- Key Aspects: Petitioner presented Julia as a complete system that, like Murdock, anticipated the fundamental architecture claimed in the ’326 patent, thereby rendering the claims obvious.
Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 11 and 21 are obvious over Murdock in view of Martin or Blahut (for teaching remote controls with unique identifiers); claims 8-9 and 18-19 are obvious over Julia in view of Banker or Gordon (paralleling the Murdock-based financial consequence argument); and claims 11 and 21 are obvious over Julia in view of Martin or Blahut.

"speech recognition engine" (claims 1 and 12): Petitioner argued this term should be broadly construed as "hardware and/or software used to identify spoken words." This construction was based on the specification's disclosure of various embodiments and general statements that did not limit the engine to a specific technology or device.
"STB" (claims 6 and 16): Petitioner proposed that "STB" means "set-top box" and should be interpreted broadly to refer to a consumer premises device for receiving and processing an audiovisual signal for display. This was based on the specification's interchangeable use of "Set Top Box" and "STB" and its reference to a popular model as merely a "useful example."

Petitioner requests institution of an inter partes review and cancellation of claims 1-9, 11-19, and 21 of Patent RE44,326 as unpatentable.