PTAB

IPR2018-00474

Google LLC v. IPA Technologies Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Speech-Based Navigation of Electronic Data
  • Brief Description: The ’021 patent describes methods for navigating electronic data using spoken natural language requests. The system uses an Open Agent Architecture (OAA) to process requests, resolve ambiguities through user feedback, and retrieve information from remote network servers.

3. Grounds for Unpatentability

Ground 1: Obviousness over Cheyer and Shwartz

Claims 1, 2, 5, 7-10, 17, 19, 20, 24-26, 72, 73, 76, 78-81, 87-89, and 130 are obvious over Cheyer in view of Shwartz.

  • Prior Art Relied Upon: Cheyer (a 1995 article, "Multimodal Maps: An Agent-based Approach") and Shwartz (Patent 5,197,005).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Cheyer disclosed most limitations of the challenged claims. Cheyer described a multimodal system using the OAA framework for speech-based navigation of remote data sources, such as the World Wide Web. Cheyer’s system received spoken requests (e.g., "How far is the restaurant from this hotel?"), used speech recognition and natural language agents to interpret the request, and employed domain agents to send database requests. However, Petitioner contended that Cheyer did not explicitly detail how to construct the "navigation query" sent to the database. Shwartz, which addresses natural language interfaces for database retrieval, allegedly supplied this missing element by teaching the generation of a formal database query (e.g., SQL code) from an interpreted natural language request to retrieve information.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Shwartz with Cheyer to implement the database interaction functionality that Cheyer described at a high level. Shwartz provided a known, practical solution for constructing the database queries needed to make Cheyer’s system fully operational, thereby enabling the retrieval of specific information from a remote database based on the user’s spoken request.
    • Expectation of Success: The combination involved applying a known query-generation technique (Shwartz) to a known agent-based architecture (Cheyer) to achieve the predictable result of retrieving data. This was argued to be a straightforward implementation.

Ground 2: Obviousness over Cheyer, Shwartz, and Johnson

Claims 1, 2, 5, 7, 11-13, 15-20, 22-26, 72, 73, 76, 78, 82-89, 127-129, 131, and 132 are obvious over Cheyer in view of Shwartz and Johnson.

  • Prior Art Relied Upon: Cheyer, Shwartz, and Johnson (Patent 5,748,974).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground incorporated the Cheyer and Shwartz combination from Ground 1 and added Johnson to address claim limitations related to resolving ambiguities after an initial data source navigation. While Cheyer disclosed soliciting user input to resolve ambiguity (e.g., clarifying "this hotel" with a gesture), Johnson was argued to provide more specific teachings. Johnson described a multimodal system that, upon encountering ambiguity (e.g., multiple "Joe Smiths" in a database search), would solicit additional input by presenting a list of options in a pop-up menu. This taught resolving a deficiency by prompting the user for non-spoken input (a menu selection) after a first navigation attempt returned an ambiguous result.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Johnson's teachings into the Cheyer/Shwartz system to enhance its robustness and user-friendliness. Johnson provided a well-understood method for handling common database search problems like multiple hits or no hits, which was a logical and desirable improvement for Cheyer's system. Presenting a menu of choices was a simple and effective way to clarify user intent.
    • Expectation of Success: Integrating a menu-based clarification mechanism (from Johnson) into the combined Cheyer/Shwartz system was a predictable design choice. It involved combining known user interface techniques to solve a known problem, with a high expectation of successfully improving the system's ability to handle ambiguous queries.

4. Key Claim Construction Positions

  • Petitioner addressed the term "navigation query" which appears in numerous independent claims. For the purposes of the petition, Petitioner adopted the Patent Owner's proposed construction from related district court litigation: "an electronic query, form, series of menu selections, or the like; being structured appropriately so as to navigate a particular data source of interest in search of desired information." This adoption was critical to Petitioner's argument that the database requests in Cheyer and the generated SQL code in Shwartz met this limitation.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 2, 5, 7-13, 15-20, 22-26, 72, 73, 76, 78-89, and 127-132 of the ’021 patent as unpatentable.