PTAB

IPR2018-00794

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 system and method for processing queries based on spoken natural language input. The technology is intended to allow relatively naive users to navigate and access data from remote electronic sources, and it incorporates mechanisms to handle errors or ambiguities in the spoken input to construct a complete and valid navigational query.

3. Grounds for Unpatentability

Ground 1: Anticipation over Moran - Claims 1, 27, 46, 72, 90, 109, and various 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 and co-authored by two of the named inventors of the patent, discloses every element of the independent claims. Moran described a multimodal, agent-based system using the same Open Agent Architecture (“OAA”) platform referenced in the ’021 patent. The system was designed to receive spoken natural language requests, interpret them, construct a logical query, and retrieve information from remote, distributed data sources like online databases and websites. Petitioner contended that Moran explicitly taught handling ambiguous or incomplete input by soliciting additional information from the user via different modalities (e.g., pen gestures), thereby refining the query to retrieve the desired information from a remote server and transmit it to a client device.
    • Key Aspects: The core of the argument rested on the fact that Moran described the same OAA framework and addressed the same problems of multimodal, speech-based navigation with error handling as the ’021 patent.

Ground 2: Obviousness over Moran and Kistler - Claims 1, 27, 46, 72, 90, 109, and various dependent claims are obvious under 35 U.S.C. §103 over Moran in view of Kistler.

  • Prior Art Relied Upon: Moran (a 1997 publication) and Kistler and Marais, WebL – a programming language for the Web (1998) (“Kistler”).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that to the extent Moran was found not to teach limitations related to interacting with online scripted interfaces (e.g., web forms), the combination with Kistler would render them obvious. Moran taught a system for retrieving information from general "WWW sources" using an agent-based architecture. Kistler disclosed a specific programming language, WebL, expressly designed for web document processing, including "scraping" webpages, extracting structured information from online forms, and automating interaction with web-based databases.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Moran and Kistler because they are analogous arts addressing user interfaces for information retrieval. Moran's OAA system was explicitly designed to be extensible and to facilitate the "mix-and-match" reuse of pre-existing components to enhance functionality. A POSITA would have been motivated to integrate Kistler's specific web-scraping and form-filling techniques into Moran's general agent framework to improve the system's ability to retrieve data from web-based sources, a stated goal of Moran.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because Moran's architecture was designed for integrating disparate agents and Kistler provided a well-defined toolset for a common problem in the field (web data extraction). The combination would involve a straightforward application of Kistler's methods to enhance Moran's system.

Ground 3: Obviousness over Moran and Burns - Claims 1, 46, 21, and 71 are obvious 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: This ground argued that if Moran was deemed deficient in teaching specific claim elements related to query construction and iterative refinement, Burns supplied the missing teachings. Burns disclosed a database retrieval system that converts natural language input into a database query. Critically, Burns taught a detailed error-correction loop where the system solicits additional user input to resolve ambiguous queries and repeats the query refinement steps until the query is deemed adequate to retrieve the correct information.
    • Motivation to Combine: A POSITA would have been motivated to combine the teachings of Burns with Moran to improve the robustness of Moran's speech-based interface. Moran's system aimed to handle errors, and Burns provided a known, detailed method for doing so in the context of database queries. Moran's encouragement of incorporating pre-existing components and legacy systems would have directly led a POSITA to integrate a known error-correction methodology like that in Burns.
    • Expectation of Success: A POSITA would have reasonably expected to succeed in combining these references. The combination would involve integrating the known error-correction and query refinement loops from Burns into the flexible, agent-based Moran system, which would be a predictable improvement.

  • Additional Grounds: Petitioner asserted further obviousness challenges against numerous dependent claims, which relied on the core teachings of Moran, Kistler, and Burns as applied to specific claim limitations. These included arguments for features like presenting textual or audible requests for additional input, supporting multiple simultaneous users, and storing multimedia content, arguing these were all well-known options or logical extensions in the art.

4. Key Claim Construction Positions

  • Petitioner noted that if claim construction was necessary, the Board should consider the interpretations proposed by the Patent Owner in a related district court case. The key terms addressed were:
    • "navigation query": An electronic query structured to navigate a data source to find desired information.
    • "electronic data source": A source of digital information (e.g., databases, websites, multimedia content) implemented on a computing device.
    • "rendering an interpretation of the spoken request": Determining the meaning of a spoken request using a computing device, such as by linguistic parsing.
    • "constructing [at least part of] a navigation query based upon the interpretation": Combining or arranging elements of a navigation query based on the determined meaning of the spoken request.

5. Relief Requested

  • Petitioner requested that the Board institute an inter partes review and cancel as unpatentable claims 1-4, 14, 16-17, 19, 21, 24, 26-30, 43-49, 61, 63-64, 66-67, 69, 71-75, 87, 89-93, 106-112, 124, and 126 of the ’021 patent.