PTAB

IPR2018-00344

Comcast Cable Communications LLC v. Promptu Systems Corp

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method of Voice Recognition Near a Wireline Node of a Network Supporting Cable Television and/or Video Delivery
  • Brief Description: The ’196 patent describes a system for providing voice control in a cable television or video delivery network. The system centralizes speech recognition processing at or near a "wireline node," such as a cable headend, to process voice commands received from multiple user sites via a back channel.

3. Grounds for Unpatentability

Ground 1: Obviousness over Murdock - Claims 1-2, 4-6, 12-13, 27-28, 30-32, and 38-42 are obvious over Murdock.

  • Prior Art Relied Upon: Murdock (Patent 7,013,283).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Murdock alone disclosed all elements of the challenged claims. Murdock taught a cable television system where voice commands from multiple users were transmitted via a "back channel" to a central "remote server computer" (the claimed "wireline node") for speech recognition. Petitioner contended that Murdock's disclosure of multiplexing audio signals from multiple users for transmission to the server inherently required demultiplexing at the server to identify individual user commands. This necessary demultiplexing, a well-known technique, met the "partitioning said received back channel" limitation of independent claims 1 and 27. Murdock’s server then processed the command and returned the requested content, satisfying the "processing" and "responding" limitations.
    • Motivation to Combine (for §103 grounds): Not applicable (single reference ground).
    • Expectation of Success (for §103 grounds): Not applicable (single reference ground).

Ground 2: Obviousness over Murdock in view of Nazarathy or Quigley - Claims 1-2, 4-6, 12-13, 27-28, 30-32, and 38-42 are obvious over Murdock in view of Nazarathy or Quigley.

  • Prior Art Relied Upon: Murdock (Patent 7,013,283), Nazarathy (Patent 6,490,727), and Quigley (Patent 6,650,624).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground asserted that Murdock provided the primary system for centralized voice command processing in a cable network. To the extent Murdock was found not to explicitly teach the "partitioning" of the back channel, Petitioner argued that Nazarathy and Quigley supplied this element. Both Nazarathy and Quigley explicitly taught techniques for managing upstream communications from multiple users in a cable network. Specifically, they disclosed using demultiplexers at the cable headend to separate multiplexed signals (e.g., using Time Division Multiplexing or Wavelength Division Multiplexing) received over the back channel, directly teaching the claimed "partitioning" into identified speech channels.
    • Motivation to Combine (for §103 grounds): A POSITA implementing Murdock’s multi-user voice control system would have been motivated to incorporate the established upstream communication and signal separation techniques of Nazarathy or Quigley. Doing so would solve the known problem of managing multiple user signals, avoiding collisions, and ensuring reliable data transmission, representing a predictable combination of known technologies to improve system performance.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success in combining these references, as it involved applying standard, well-understood network management protocols to a known type of interactive television system.

Ground 3: Obviousness over Julia in view of Nazarathy or Quigley - Claims 1-2, 4-6, 12-13, 27-28, 30-32, and 38-42 are obvious over Julia in view of Nazarathy or Quigley.

  • Prior Art Relied Upon: Julia (Patent 6,513,063), Nazarathy (Patent 6,490,727), and Quigley (Patent 6,650,624).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented Julia as an alternative primary reference that disclosed a system for navigating network-based data using spoken input, explicitly mentioning suitability for home entertainment settings. In Julia, voice commands from multiple users were transmitted over a two-way network (disclosed as potentially including cable television lines) to a remote server for speech recognition processing. Similar to the argument against Murdock, Petitioner contended that combining Julia's system with the explicit demultiplexing techniques taught by Nazarathy or Quigley for cable headends would render the "partitioning" limitation obvious.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Julia's multi-user voice interface with the specific upstream channel management techniques of Nazarathy or Quigley. Julia acknowledged that its system could support simultaneous multiple users, and Nazarathy/Quigley provided known, predictable solutions for implementing such multi-user access on the very cable networks Julia proposed using. This combination would improve the user interface and network efficiency.
    • Expectation of Success (for §103 grounds): Success would be expected, as the combination involved implementing a known voice control application on a standard cable network architecture using established data management protocols.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for claims 5-6 and 31-32 based on combinations of Murdock or Julia with Banker (Patent 5,477,262) or Gordon (Patent 6,314,573) to teach the claimed limitations related to financial transactions, such as assessing and billing for pay-per-view content.

4. Key Claim Construction Positions

  • "wireline node": Petitioner proposed this term should be construed as "a network node providing video or cable television delivery to multiple users over physical wires between the node and the multiple user locations," such as a cable television headend.
  • "back channel": Petitioner argued this term should mean an "upstream communication channel delivering signals from multiple user sites to a central wireline node."
  • "partitioning said received back channel into a multiplicity of...identified speech channels": Petitioner argued for a broad construction of "partitioning" to include any technique for dividing a communication channel into identifiable portions. This was a critical position, as Petitioner contended that the well-known process of demultiplexing, which is the necessary counterpart to the multiplexing disclosed in Murdock, falls within this construction.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-2, 4-6, 12-13, 27-28, 30-32, and 38-42 of the ’196 patent as unpatentable.