PTAB

IPR2019-00513

Unified Patents LLC v. Portal Communications LLC

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1. Case Identification

2. Patent Overview

  • Title: Multimodal, Natural Language Query System and Architecture for Processing Voice and Proximity-Based Queries
  • Brief Description: The ’645 patent discloses a system and architecture for processing a user's voice-based, natural-language query. The system combines the processed query with the user device's location or proximity information to contextually query a database and return streamlined results.

3. Grounds for Unpatentability

Ground 1: Claims 1-30 are obvious over Junqua in view of Julia.

  • Prior Art Relied Upon: Junqua (Patent 6,598,018) and Julia (Patent 6,513,063).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the challenged claims represent an obvious combination of known functions and that the primary prior art references, Junqua and Julia, collectively teach all limitations.
      • Petitioner asserted that Junqua discloses a natural dialog interface for vehicles that performs most of the functions claimed in the ’645 patent. Junqua’s system accepts natural language voice commands (e.g., for navigation), uses a parser to understand semantics, constructs a database search, and generates commands. Crucially, Junqua discloses using contextual information, such as GPS data, to resolve ambiguities. For example, if a user query mentions a "State Street" and multiple exist, Junqua can use GPS information to determine which one the user meant. However, Petitioner contended that Junqua uses this location context only reactively—after an ambiguity has already been identified.
      • To supply the proactive use of location data, Petitioner relied on Julia. Julia teaches a system for accessing network-based information via spoken input. Petitioner highlighted that Julia explicitly discloses resolving potential ambiguities by making reasonable assumptions based on context. For example, if a user asks for "the weather," Julia’s system would assume the user wants local weather information and retrieve it directly, rather than asking the user to clarify their location. Petitioner argued this teaches the principle of proactively using location information to "narrow and streamline" a query before execution, which is the purported inventive concept of the ’645 patent.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Julia’s proactive assumption technique with Junqua’s voice-controlled navigation system to improve its functionality and user experience. The motivation was to solve a known problem (ambiguity and user inconvenience from clarification dialogues) using a known solution from the same technical field (proactively using context to make assumptions). A POSITA would see the benefit of applying Julia's more efficient method to Junqua's system to provide the predictable result of saving time and avoiding unnecessary user interaction.
    • Expectation of Success (for §103 grounds): A POSITA would have had a high expectation of success in this combination. Junqua already provided the necessary technical foundation: a system with natural language processing capabilities and access to contextual GPS data. Integrating Julia's logic would require only a simple and predictable modification of Junqua's process flow—using the available location data during initial query construction, rather than only for post-query ambiguity resolution. Petitioner asserted that since databases are inherently designed to be searched with multiple parameters, adding location data (e.g., GPS coordinates) as a search criterion was well within the ordinary skill in the art.

4. Key Claim Construction Positions

  • "Plug-in": Petitioner argued the term "plug-in," recited in claims such as 3, 11, 13, and 20, should be construed to mean "hardware and/or software that provides functionality to a system." This construction was central to mapping the prior art to the claims. Petitioner supported this position by citing the ’645 patent's specification, which provides examples of both a software "Speech Plug-In for Microsoft Pocket Internet Explorer" and hardware components like an "Identec Solutions iCard III RFID Reader." This broad interpretation allowed Petitioner to argue that the software modules and hardware interfaces described in Junqua and Julia met the "plug-in" limitations of the claims.

5. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §325(d) would be inappropriate. The petition asserted that the primary prior art references, Junqua and Julia, were never considered by the USPTO during the original prosecution of the ’645 patent. Consequently, Petitioner contended that the obviousness ground raised in the petition was based on new, non-cumulative prior art and arguments that presented a different and more compelling case of unpatentability than what the examiner had previously reviewed.

6. Relief Requested

  • Petitioner requests the institution of an inter partes review of claims 1-30 and the cancellation of all challenged claims of the ’645 patent as unpatentable under 35 U.S.C. §103.