PTAB

IPR2018-00345

Comcast Cable Communications LLC v. Promptu Systems Corp

Log In
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 discloses a multi-user voice control system for audio-visual devices. The system features a speech recognition processor centrally located at or near a "wireline node," such as a cable television headend, to process voice commands received from multiple users over a back channel.

3. Grounds for Unpatentability

Ground 1: Obviousness over Murdock, optionally in view of Nazarathy or Quigley - Claims 14-15, 17, 25-26, 53-54, 61-62, 64, and 66 are obvious over Murdock, alone or combined with 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: Petitioner argued that Murdock, which predates the ’196 patent, discloses all limitations of the challenged claims. Murdock teaches a voice-activated cable television system where voice commands from multiple users are captured by a local device, sent over a "back channel" via a multiplexer to a "remote server computer" for speech recognition, and the server then retrieves and transmits the requested content back to the user. Petitioner asserted that Murdock’s remote server is equivalent to the ’196 patent's "wireline node," and its system processes a "multiplicity of received identified speech channels" to create unique responses for each user, as required by independent claims 14 and 53.
    • Motivation to Combine (for §103 grounds): While arguing Murdock alone renders the claims obvious, Petitioner asserted that if the Patent Owner contested how Murdock handles individual user channels, a person of ordinary skill in the art (POSITA) would combine Murdock with Nazarathy or Quigley. All three references are in the same field of interactive cable networks. Murdock explicitly discloses multiplexing signals from multiple users but is not detailed on demultiplexing. Nazarathy and Quigley both teach well-known demultiplexing techniques at a cable headend to separate signals from multiple users. A POSITA would combine these known techniques with Murdock’s system to ensure reliable processing of individual user commands.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success in implementing the known demultiplexing methods of Nazarathy or Quigley within Murdock's system, as it represented a straightforward application of standard signal processing techniques to yield predictable results.

Ground 2: Obviousness over Julia, optionally in view of Nazarathy or Quigley - Claims 14-15, 17, 25-26, 53-54, 61-62, 64, and 66 are obvious over Julia, alone or combined with 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 also teaches all claimed elements. Julia describes a system for navigating network-based data using spoken input, explicitly mentioning home entertainment and cable television network settings. In Julia, voice commands from multiple users are transmitted across a network to a remote server for speech recognition processing, with the server returning requested content to the specific user. Petitioner mapped Julia's remote server to the claimed "wireline node" and argued its system for handling simultaneous requests from multiple users met the limitations of processing multiple speech channels to provide unique responses.
    • Motivation to Combine (for §103 grounds): The motivation to combine Julia with Nazarathy or Quigley parallels the argument for Murdock. Julia discloses handling requests from multiple simultaneous users but does not detail the multiplexing/demultiplexing method. A POSITA would be motivated to implement the well-understood upstream communication and demultiplexing techniques from Nazarathy or Quigley to efficiently manage multiple user voice streams in Julia's network, thereby improving system performance and reliability.
    • Expectation of Success (for §103 grounds): Combining Julia’s voice interface with the network management techniques of Nazarathy or Quigley was argued to be a predictable combination of known technologies within the same field.

Ground 3: Obviousness over Murdock/Julia combinations in view of Banker or Gordon - Claims 18-19, 55, and 65 are obvious over the primary combinations further in view of Banker or Gordon.

  • Prior Art Relied Upon: The art from Grounds 1 and 2, plus Banker (Patent 5,477,262) and Gordon (Patent 6,314,573).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground targets dependent claims reciting financial transactions (e.g., assessing a financial consequence, billing a user). Petitioner argued that while Murdock and Julia suggest use with video-on-demand and pay-per-view systems, Banker and Gordon explicitly teach the claimed financial steps. Both Banker and Gordon describe interactive television systems where a user can purchase pay-per-view content, which involves assessing a charge ("financial consequence"), displaying it, receiving confirmation ("financial commitment"), and billing the user.
    • Motivation to Combine (for §103 grounds): A POSITA, seeking to implement pay-per-view functionality within the voice-controlled systems of Murdock or Julia, would naturally look to existing, well-known systems like those in Banker and Gordon. Adding the user interface and billing logic from Banker or Gordon to Murdock or Julia would be a logical and desirable extension to enable commercial transactions, a common goal in interactive television.
    • Expectation of Success (for §103 grounds): Integrating established pay-per-view transaction steps into a voice-controlled content selection system would have been a straightforward design choice with a high expectation of success.

4. Key Claim Construction Positions

  • “wireline node”: Petitioner proposed this term means "a network node providing video or cable television delivery to multiple users over physical wires between the node and the multiple user locations." This construction was central to mapping the term to the remote servers in Murdock and Julia.
  • “back channel”: Petitioner proposed this term means "upstream communication channel delivering signals from multiple user sites to a central wireline node." This construction supports the argument that the prior art systems receive user commands in the manner claimed.
  • “partitioning said received back channel into a multiplicity of...speech channels”: Petitioner proposed this phrase means "dividing the received back channel into multiple portions that are each identified with speech commands originating from system users." This broad interpretation was used to argue that the limitation covers well-known demultiplexing techniques, justifying the combinations with Nazarathy and Quigley.

5. Relief Requested

  • Petitioner requested institution of an inter partes review and cancellation of claims 14-15, 17-19, 25-26, 53-55, 61-62, and 64-66 of the ’196 patent as unpatentable.