PTAB

IPR2018-00791

Microsoft Corporation 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: Navigating Network-Based Electronic Information Using Spoken Input with Multimodal Error Feedback
  • Brief Description: The ’021 patent describes a method and system for navigating electronic data sources using spoken natural language. The system processes a user's spoken request, constructs a navigation query to retrieve information from remote network servers, and employs multimodal feedback mechanisms to resolve errors or ambiguities in the user's input.

3. Grounds for Unpatentability

Ground 1: Anticipation by Moran - Claims 1, 15, 20, 22-23, 27, 40-41, 46, 59-60, 65, 70, 72, 85-86, 90, 103-104, 109, and 122-123 are anticipated under 35 U.S.C. §102 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 1997 publication whose authors include two inventors of the ’021 patent, discloses every element of the challenged claims. Moran describes an agent-based system using the Open Agent Architecture (OAA) that accepts multimodal inputs, including spoken natural language, to access information from distributed data sources like remote databases and websites. Petitioner asserted that Moran’s system performs speech-based navigation by receiving a spoken request, rendering an interpretation using speech recognition and natural language agents, and constructing a logical query. Moran also allegedly discloses soliciting additional input to resolve ambiguities (e.g., asking a user to identify a hotel when context is unclear) and refining the query based on that input, including using non-spoken modalities like pen gestures. Finally, Moran describes transmitting the retrieved information from remote sources back to a user's 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, and 122-123 are obvious over Moran.

  • Prior Art Relied Upon: Moran (1997).
  • 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 in Moran, it would have been obvious to a Person of Ordinary Skill in the Art (POSA) based on Moran's teachings. For instance, a POSA would have understood that retrieving information based on natural language input necessarily involves constructing a query operable with the target data source. Similarly, it would have been an obvious design choice to solicit additional input in a non-spoken modality (e.g., gestures, typing) to resolve errors in a spoken request, as this would make a multimodal interface more intuitive and user-friendly.
    • Motivation to Combine (for §103 grounds): The motivation was to implement the teachings of Moran to achieve its stated goals. A POSA would have been motivated to implement any missing but conventional steps, such as query construction or using alternative input modalities for error correction, to create a functional and efficient system as described by Moran.
    • Expectation of Success (for §103 grounds): A POSA would have had a high expectation of success because these modifications involved applying known techniques and simple design choices to improve the operation of Moran’s system.

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 (1997) and Burns (Patent 5,454,106).
  • Core Argument for this Ground:
    • Prior art Mapping: Petitioner contended that if Moran is viewed as not teaching certain claim elements, particularly those related to error correction and user feedback, Burns supplies these missing elements. Burns discloses a database retrieval system that uses natural language and explicitly addresses query ambiguity by presenting the user with what the system "understands" via a graphical display, such as a menu or a list of matched database elements. The user can then interact with this display (e.g., via mouse click) to refine or correct the query. This directly teaches the limitations of soliciting additional input by presenting a menu or a list of matching data portions, as recited in several dependent claims.
    • Motivation to Combine (for §103 grounds): A POSA would combine Moran and Burns because they are analogous arts addressing multimodal/natural language interfaces. A POSA would have been motivated to supplement Moran's flexible OAA framework with the specific, well-known error correction and query refinement techniques from Burns to create a more robust and user-friendly system. Moran itself encourages a "mix-and-match" approach of incorporating pre-existing components and legacy systems via its agent architecture.
    • Expectation of Success (for §103 grounds): A POSA would have a reasonable expectation of success in combining the references. The OAA framework in Moran was expressly designed to facilitate the integration of different functional agents, making the incorporation of Burns's database navigation and error-correction logic a predictable implementation.

4. Key Claim Construction Positions

  • Petitioner stated it would adopt the constructions proposed by the Patent Owner in a related district court case for key terms, arguing the claims are unpatentable even under the Patent Owner's own interpretations.
    • "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."
    • "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.