PTAB

IPR2019-00496

Nuance Communications Inc v. MModal Services Ltd

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1. Case Identification

2. Patent Overview

  • Title: Method for Identifying and Replacing Phrases
  • Brief Description: The ’524 patent describes a computer-implemented method for editing a document, such as a medical transcript, by replacing a first written form of a concept (e.g., an abbreviation) with a second, alternative written form (e.g., an expanded phrase) selected by a user.

3. Grounds for Unpatentability

Ground 1: Claims 1, 5, and 9 are obvious over Longé in view of the knowledge of a Person of Ordinary Skill in the Art (POSITA).

  • Prior Art Relied Upon: Longé (Patent 7,881,936)
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Longé taught all limitations of the challenged claims. Longé described a "method for smart editing of speech recognition output" that provided a user with alternative phrases ("N-best hypotheses") to replace an initial phrase in a text document. Petitioner asserted this system inherently involved accessing a document on a computer-readable medium (e.g., RAM or a text buffer) to identify a first phrase. Longé further disclosed identifying a plurality of alternative phrases (e.g., from a word or phrase list) representing alternate forms of a concept, such as replacing a term of profanity with an "acceptable substitute" or an abbreviation with a "longer phrase." Longé also taught displaying these alternatives in a "word choice list" for the user to select from and receiving a user's instruction to replace the original phrase. For dependent claim 5, Petitioner contended Longé taught using "word context" to determine the N-best hypotheses. For dependent claim 9, Petitioner argued it would have been obvious to a POSITA to implement the user selection taught by Longé via a single keystroke, a well-known technique for menu selection at the time.
    • Motivation to Combine (for §103 grounds): Not applicable as this ground relies on a single reference combined with the general knowledge of a POSITA. Petitioner argued a POSITA would have naturally applied common user interface conventions, such as single-keystroke selection, to implement Longé's editing system for efficiency.
    • Expectation of Success (for §103 grounds): A POSITA would have a high expectation of success in implementing Longé's selection mechanism using a single keystroke, as this was a routine and predictable design choice in human-computer interaction.

Ground 2: Claim 9 is obvious over Longé in view of Roberts.

  • Prior Art Relied Upon: Longé (Patent 7,881,936), Roberts (Patent 5,027,406)
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the teachings of Longé from Ground 1, specifically addressing the "single keystroke" limitation of claim 9. While Longé taught selecting a replacement phrase from a list, it did not explicitly disclose a single-keystroke mechanism. Roberts addressed this by teaching a natural language dictation system where a user selects the correct word from a displayed list using "pick-choice" commands. Roberts explicitly disclosed that these commands consist of single keystrokes, such as the function keys 'f1' through 'f9', each corresponding to a word in the choice list.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Longé and Roberts to improve the speed and efficiency of transcription editing. Both references aimed to improve speech recognition and text editing accuracy. A POSITA implementing Longé's system, which required user selection from a list, would have been motivated to look for more efficient selection methods than multiple inputs and would have found the single-keystroke "pick-choice" system in Roberts to be a known and advantageous solution.
    • Expectation of Success (for §103 grounds): The combination would yield predictable results. Integrating a well-understood single-keystroke selection method (Roberts) into a list-based correction system (Longé) was a straightforward application of known user interface principles with no technical barriers.

Ground 3: Claims 1 and 9 are obvious over Lunati in view of the knowledge of a POSITA.

  • Prior Art Relied Upon: Lunati (Patent 8,321,786)

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued Lunati, which disclosed error-checking techniques for electronic text like e-mails, taught the core methodology of claim 1. Lunati described a user entering text on a client station (a first computer-readable medium), which is then checked against a reference file or dictionary on a server (a second computer-readable medium) to identify errors (the "first phrase"). Lunati then displayed "correction options" (the "plurality of phrases") to the user, who could "choose[] his correction option from those displayed" to replace the erroneous text. Petitioner asserted that while Lunati focused on misspellings (e.g., "colection" vs. "collection"), its teachings were analogous to the claimed method and could obviously be applied to other alternative written forms, such as different spellings in different languages (e.g., "color" vs. "colour"), which Lunati also taught by allowing dictionary selection. For claim 9, Petitioner again argued that implementing the user selection via a single keystroke was an obvious design choice for a POSITA.
    • Motivation to Combine (for §103 grounds): Not applicable as this ground relies primarily on a single reference. Petitioner contended that applying Lunati's error-correction method to different types of alternative written forms beyond misspellings was an obvious extension of its teachings.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success in adapting Lunati's spell-check system to handle other predefined mappings between phrases, as the underlying technical mechanism of identifying a string and replacing it from a list is the same.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) for claims 5 and 9 over Lunati in view of Roberts. The motivation was similar to Ground 2: a POSITA would combine Roberts' context-specific and single-keystroke selection techniques to improve the accuracy and efficiency of Lunati's correction interface.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 5, and 9 of the ’524 patent as unpatentable.