PTAB

IPR2018-00791

Microsoft Corp v. IPA Technologies Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Navigating Network-Based Electronic Information Using Spoken Input with Multimodal Error Feedback
  • Brief Description: The ’021 patent describes systems and methods for processing user queries based on spoken natural language input. The system uses a platform of distributed software agents to search remote electronic data sources and includes techniques for resolving errors or ambiguities by soliciting additional user input through various modalities.

3. Grounds for Unpatentability

Ground 1: Anticipation over Moran - Claims 1, 15, 20, 22-23, 27, 40-41, 46, 59-60, 65, 70, 72, 85-86, 90, 100, 103-104, 109, and 122-123 are anticipated by Moran.

  • Prior Art Relied Upon: Moran et al., Multimodal User Interfaces in the Open Agent Architecture (1997) (“Moran”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Moran, a printed publication authored in part by two inventors of the ’021 patent, discloses every element of the challenged claims. Moran describes an agent-based, multimodal user interface operating under the same Open Agent Architecture (OAA) platform disclosed in the ’021 patent. Petitioner asserted that Moran teaches a method for speech-based navigation of remote electronic data sources (e.g., online databases, web sources) by receiving a spoken request from a user, rendering an interpretation of the request using speech recognition and natural language agents, and constructing a query. Moran further discloses handling ambiguity by soliciting additional input from the user in non-spoken modalities (e.g., pen gestures) without requiring the user to first request that modality, refining the query based on this input, and transmitting the retrieved data back to a client device.

Ground 2: Obviousness over Moran - Claims 1, 15, 18, 20, 22-23, 27, 40-41, 46, 59-60, 65, 68, 70, 72, 85-86, 90, 103-104, 109, and 122-123 are obvious over Moran.

  • Prior Art Relied Upon: Moran.
  • Core Argument for this Ground:
    • Prior Art Mapping: As an alternative to anticipation, Petitioner argued that to the extent any claim element is not explicitly disclosed, it would have been obvious from Moran’s own teachings. For instance, if Moran is found not to explicitly teach "constructing at least part of a navigation query," Petitioner contended that creating a query based on an interpretation of a user's spoken request is an obvious, necessary step to retrieve information from a data source.
    • Motivation to Combine (within a single reference): A person of ordinary skill in the art (POSITA), motivated to implement Moran's system, would have naturally and obviously included functionalities like formal query construction to achieve the system's stated goals of information retrieval. Similarly, soliciting additional input via different modalities was presented as an obvious design choice for a multimodal system designed to handle ambiguity and improve user-friendliness.
    • Expectation of Success: A POSITA would have reasonably expected success in implementing these minor variations, as they represent well-understood techniques to achieve the functionalities described in Moran.

Ground 3: Obviousness over Moran in view of Burns - Claims 1, 15, 18, 20, 22, 27, 40, 46, 59, 65, 68, 70, 72, 85, 90, 103, 109, and 122 are obvious over Moran in view of Burns.

  • Prior Art Relied Upon: Moran and Burns (Patent 5,454,106).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Moran provides the primary framework of an agent-based, multimodal system for information retrieval. Burns, which discloses a database retrieval system using natural language, supplies teachings for handling ambiguous queries. Specifically, Burns teaches converting parse results into a database query and resolving ambiguity by presenting the user with what the system "understands" via a graphical display, such as a schema or a menu of options, for further interaction. Petitioner mapped these teachings to claim limitations requiring the system to solicit additional input by presenting a menu or a list of data source portions that match an initial query.
    • Motivation to Combine: A POSITA would combine Burns’s specific error-correction and user-feedback mechanisms with Moran’s flexible OAA system to solve the known problem of ambiguity in natural language processing. Moran explicitly encourages a "mix-and-match" approach of incorporating pre-existing components into its agent-based architecture. A POSITA implementing Moran's system would have been motivated to look to known solutions like Burns to improve query resolution and system usability.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination. Integrating Burns's known methods for query refinement and graphical feedback into Moran's modular, agent-based platform would be a predictable arrangement of old elements to perform their known functions, yielding no more than the expected result of a more robust multimodal interface.

4. Key Claim Construction Positions

Petitioner stated that its invalidity arguments do not depend on claim construction disputes, and for the purpose of the petition, it adopted the constructions proposed by the Patent Owner in related district court litigation.

  • "navigation query": "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."
  • "electronic data source": "source of information in numerical form that can be digitally transmitted or processed and that is implemented on or by means of a computing device."
  • "rendering an interpretation of the spoken request": "determining a meaning of the spoken request using a computing device, such as that provided by extracting speech data from acoustic voice signals or data and linguistically parsing the speech data."
  • "constructing [at least part of] a navigation query based upon the interpretation": "combining or arranging elements of (at least part of) the navigation query based upon the interpretation."

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1, 15, 18, 20, 22-23, 27, 40-41, 46, 59-60, 65, 68, 70, 72, 85-86, 90, 103-104, 109, and 122-123 of the ’021 patent as unpatentable.