PTAB

IPR2018-00792

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 discloses systems and methods for navigating remote electronic data sources using spoken natural language queries. The invention focuses on processing these queries through a distributed, agent-based platform and employing multimodal feedback mechanisms to resolve errors or ambiguities in the user's spoken input to construct a valid navigation query.

3. Grounds for Unpatentability

Ground 1: Anticipation over Moran - Claims 1, 27, 46, 72, 90, 109, 127, 130 and numerous dependent claims 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 printed publication available more than one year before the ’021 patent's filing date, discloses every limitation of the challenged claims. Moran’s system receives spoken commands ("a spoken request"), uses speech recognition and natural language understanding agents to determine meaning ("rendering an interpretation"), and combines multimodal inputs via a Modality Coordination agent to form a "composite" query in a high-level logical language ("constructing a navigation query"). The system accesses remote data sources like online databases and, if an initial query is ambiguous, solicits further input from the user via non-spoken modalities like pen gestures to correct the query ("soliciting additional input... in a non-spoken modality").
    • Key Aspects: Petitioner emphasized that two of the five authors of the Moran reference are also named inventors on the ’021 patent. This fact, combined with the disclosure of the same Open Agent Architecture (OAA) platform in both the reference and the patent, was presented as strong evidence that Moran describes the claimed invention.

Ground 2: Obviousness over Moran - Claims 1, 27, 46, 72, 90, 109, 127, 130 and numerous dependent claims are obvious under 35 U.S.C. §103 over Moran.

  • Prior Art Relied Upon: Moran (a 1997 publication).
  • Core Argument for this Ground:
    • Prior Art Mapping: As an alternative to anticipation, Petitioner contended that to the extent any claim limitation is not explicitly disclosed in Moran, it would have been obvious to a person of ordinary skill in the art (POSITA) based on Moran's own teachings. For instance, creating a structured "navigation query" from an interpreted user request is an obvious and necessary step to implement the information retrieval function central to Moran's system.
    • Motivation to Modify: A POSITA would be motivated to make any minor modifications to Moran’s system to achieve its stated goals of creating an intuitive and effective multimodal interface. For example, automatically soliciting clarifying input in a different modality to resolve ambiguity is a simple and obvious design choice to make the system more user-friendly and less burdensome, a key objective of Moran.
    • Expectation of Success: A POSITA would have had a high expectation of success in implementing such features, as they represented predictable solutions to known problems in human-computer interaction and were logical extensions of the system Moran described.

Ground 3: Obviousness over Moran in view of Burns - Claims 1, 27, 46, 72, 90, 109, 127, 130 and numerous dependent claims are obvious under §103 over Moran in view of Burns.

  • Prior Art Relied Upon: Moran (a 1997 publication) and Burns (Patent 5,454,106).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that the combination of Moran and Burns teaches all challenged claim limitations. Moran provides the foundational agent-based, multimodal system architecture. Burns, which discloses a database retrieval system using natural language, supplies the specific implementation details for query construction and error resolution that might be considered implicit in Moran. Burns specifically details a system that resolves ambiguous queries by parsing input, comparing it to database elements, displaying partially matched results to the user, and then using user feedback to refine or construct a new, successful database query.
    • Motivation to Combine: A POSITA would combine the references because they are analogous art. Moran's OAA framework explicitly encourages a "mix-and-match" approach to incorporate pre-existing components. A POSITA seeking to build a robust version of Moran's system would be motivated to incorporate the proven error-correction and query-refinement loops from Burns to handle the inevitable ambiguities of natural language input when interacting with structured databases.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success, as Moran's agent-based system was designed for such integration. Combining Burns's well-known methods for database interaction with Moran's flexible architecture would be a predictable implementation that yields no unexpected results.

4. Key Claim Construction Positions

  • Petitioner argued for adopting claim constructions for key terms that the Patent Owner had previously proposed in related district court litigation, asserting these constructions support its unpatentability arguments.
  • For "navigation query", the proposed construction was "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 construction is broad enough to encompass the "composite query" described in Moran and the "database query" in Burns.
  • For "constructing [at least part of] a navigation query based upon the interpretation", the proposed construction was "combining or arranging elements of (at least part of) the navigation query based upon the interpretation." This helps map the prior art's process of building a query from parsed user input to the specific claim language.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that the primary prior art references, Moran and Burns, were not applied against the claims during the original prosecution of the ’021 patent. Petitioner asserted this fact weighs against a discretionary denial under 35 U.S.C. §325(d), as the challenge is based on art and arguments that the U.S. Patent and Trademark Office had not previously considered.

6. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1, 5-7, 25, 27, 31-33, 42, 46, 50-52, 62, 72, 76-78, 88, 90, 94-96, 105, 109, 113-115, 125, and 127-132 of Patent 6,742,021 as unpatentable.