PTAB

IPR2018-00474

Google LLC v. IPA Technologies Inc., which is a wholly owned subsidiary of Wi-LAN Technologies Inc., which is a wholly owned subsidiary of Wi-LAN Inc., which is a wholly owned subsidiary of Quarterhill Inc.

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1. Case Identification

2. Patent Overview

  • Title: Speech-Based Navigation with Error Correction
  • Brief Description: The ’021 patent describes methods for navigating electronic data sources using spoken natural language requests. The system uses an Open Agent Architecture (OAA) with multiple software "agents" and includes feedback mechanisms to resolve ambiguities or errors in user requests, potentially by soliciting additional input in a non-spoken modality.

3. Grounds for Unpatentability

Ground 1: 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 publication titled "Multimodal Maps: An Agent-based Approach") and Shwartz (Patent 5,197,005).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Cheyer, which shares inventors with the ’021 patent, discloses the foundational elements of the challenged claims. Cheyer taught a system using the same OAA for processing multimodal user inputs (including speech) to access remote data sources like the World Wide Web. Its agent-based framework included speech recognition and natural language parser agents to interpret a user’s spoken request. However, Petitioner contended that Cheyer did not explicitly detail how to construct a formal database query (e.g., SQL) from the interpreted request. Shwartz was argued to supply this missing element, as it explicitly taught a natural language interface for a database retrieval system that generates a formal database query (a "navigation query") from a user's natural language input to retrieve data.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Cheyer with Shwartz to improve Cheyer’s system. While Cheyer provided the high-level architecture for multimodal interaction, it lacked specifics on database query construction. Shwartz addressed this exact problem by teaching how to generate structured queries from natural language. A POSITA would have looked to a reference like Shwartz to implement the database interaction functionality described conceptually in Cheyer.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining these references. Both operated in the same technical field of natural language interfaces for accessing data. Integrating Shwartz’s well-defined query generation method into Cheyer’s agent-based architecture was a predictable implementation of known technologies to achieve the desired result of robust, speech-based database navigation.

Ground 2: 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 built upon the Cheyer/Shwartz combination and introduced Johnson to address claim limitations related to resolving deficiencies and ambiguities. Petitioner asserted that Johnson specifically taught methods for handling situations where an initial query is ambiguous, such as when a search for "Joe Smith" returns multiple entries. Johnson disclosed resolving this ambiguity by presenting the user with a list of choices in a pop-up window and soliciting additional, non-spoken input (e.g., a selection from the menu) to clarify the user's intent. This teaching was argued to directly map onto claim limitations requiring the system to solicit additional input in a non-spoken modality when a deficiency (like an ambiguous query) is encountered.
    • Motivation to Combine: A POSITA seeking to enhance the Cheyer/Shwartz system would be motivated to incorporate the teachings of Johnson. The combined Cheyer/Shwartz system could still face ambiguous queries. Johnson provided a known, user-friendly solution for this common problem by prompting the user for clarification. Adding this functionality would improve the system's robustness and usability by enabling it to handle ambiguous hits or no-hit scenarios, which are predictable challenges in any database query system.
    • Expectation of Success: A POSITA would have a high expectation of success. Integrating Johnson’s method for ambiguity resolution was a straightforward enhancement. The technique of presenting a menu of options to a user was a well-understood user interface paradigm. Combining this known technique with the Cheyer/Shwartz system would predictably result in a more capable and user-friendly speech navigation system.

4. Key Claim Construction Positions

  • "navigation query": Petitioner noted that the Patent Owner, in related district court litigation, proposed construing this term as "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." Petitioner adopted this construction for the purposes of the IPR petition, arguing that the database requests in the prior art (e.g., the SQL code generated by Shwartz) met this definition. This construction was central to mapping the prior art's database requests to the claimed "navigation query."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the 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.