PTAB

IPR2019-00340

Google LLC v. SpeakWare, Inc.

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1. Case Identification

2. Patent Overview

  • Title: Audio Signal Activated Control System
  • Brief Description: The ’186 patent discloses a sound-activated, universal remote control system for appliances that operates via voice input. The system's purported novelty lies in its ability to conserve power by using two distinct operating modes: a low-power "sound activation mode" and an active "speech recognition mode," switching between them automatically based on the amplitude of a detected audio signal, thus eliminating the need for a manual "talk switch."

3. Grounds for Unpatentability

Ground 1: Claims 1-4, 7-16, and 19-20 are obvious over Salazar in view of Miyazawa, with further support from Bossemeyer.

  • Prior Art Relied Upon: Salazar (Patent 5,802,467), Miyazawa (Patent 5,983,186), and Bossemeyer (Patent 6,012,027).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Salazar taught nearly all elements of the challenged claims, including a universal remote system for controlling appliances that used a voice-activated mode and featured a power-saving "stop mode." However, Salazar's system required a hardware interrupt to exit this mode. Petitioner asserted that Miyazawa supplied the missing feature by disclosing a voice-activated speech recognition system that automatically switched from a low-power "sleep mode" to an active speech recognition mode based on whether the amplitude of an incoming sound signal exceeded a predetermined threshold, all without a physical switch. Bossemeyer was cited as an alternative or supplement for teaching the specific technique of detecting the start of an utterance by monitoring if its amplitude crosses a threshold.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Salazar's remote control system with Miyazawa's power-saving, voice-triggered activation method. The motivation was to improve the power efficiency of Salazar's device—a well-known goal in battery-powered electronics—by incorporating a known solution for hands-free activation. This combination of known elements would yield the predictable result of a more efficient and user-friendly universal remote.
    • Expectation of Success: A POSITA would have a high expectation of success in this combination because both references describe compatible technologies (mode-switching processors, microphones, speech recognition) for the common purpose of voice control and power conservation.

Ground 2: Claim 5 is obvious over Salazar and Miyazawa in view of Oppendahl.

  • Prior Art Relied Upon: Salazar (Patent 5,802,467), Miyazawa (Patent 5,983,186), and Oppendahl (Patent 5,008,954).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground targeted claim 5, which adds a "user-adjustable sound activation sensitivity control." Petitioner argued the base system was taught by the combination of Salazar and Miyazawa. Oppendahl was introduced because it disclosed a voice-operated switch (VOX) system featuring a "VOX sensitivity control" that allowed a user to manually adjust the activation threshold.
    • Motivation to Combine: A POSITA would be motivated to add Oppendahl’s user-adjustable threshold to the Salazar-Miyazawa system to solve the known problem of false triggers in noisy environments or missed triggers in quiet ones. Providing user adjustability is a common design choice for improving the robustness of such systems. This modification would predictably allow a user to fine-tune the device's sensitivity to suit their specific environment.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for other dependent claims by adding single references to the core Salazar and Miyazawa combination. These included challenges based on Reichel (for user-adjustable amplification in claim 6), Clark (for different processor operating frequencies in claim 8), and Douma (for a user-programmable command mode in claims 17-18), each time arguing the addition was a predictable combination of known elements to achieve a desired function.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §325(d) would be inappropriate. It contended that the core prior art references, particularly Salazar and Bossemeyer, were never cited by the Examiner during the original prosecution. Furthermore, while Miyazawa was listed in an Information Disclosure Statement (IDS), it was never subject to substantive analysis by the Examiner. Petitioner maintained that the petition presented new combinations and arguments that had not been previously considered by the USPTO, weighing in favor of institution.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review (IPR) and the cancellation of claims 1-20 of Patent 6,397,186 as unpatentable under 35 U.S.C. §103.