PTAB

IPR2019-00874

Apple Inc v. SpeakWare Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Audio Signal Activated Control System for Appliances
  • Brief Description: The ’186 patent describes a system and method for remotely controlling an appliance using spoken commands. The system operates in a low-power "sound activation" mode and automatically switches to a higher-power speech recognition mode upon detecting a sound that exceeds a predetermined amplitude threshold.

3. Grounds for Unpatentability

Ground 1: Obviousness over Tetsuo and Bissonnette - Claims 1-4, 7-8, 14-18, 41, 43, 49-54 are obvious over Tetsuo in view of Bissonnette.

  • Prior Art Relied Upon: Tetsuo (Japanese Patent Pub. No. JP 2708566) and Bissonnette (WO 94/03020).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Tetsuo, an analogous art reference not considered during prosecution, taught the core invention. Tetsuo disclosed a voice recognition controller for an air conditioner that remains in a low-power standby mode until a volume detection unit detects a spoken input exceeding a prescribed amplitude, at which point it activates a full-power voice recognition unit to process the command. This combination of a standby mode and an active mode directly mapped to the ’186 patent’s claimed low-power "sound activation mode" and "speech recognition mode." Petitioner contended that Bissonnette, which teaches a voice-operated remote control system, provided supplemental teachings for elements like decoding voice templates and using a transmitter to send control codes to an appliance.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine the well-known wireless transmitter technology taught by Bissonnette with Tetsuo's voice-activated control system. This combination represented a simple and predictable design choice to improve convenience by enabling remote, wireless control of the appliance, a common feature in the art.
    • Expectation of Success: A POSITA would have had a high expectation of success because both references operate in the same field of voice-controlled appliances, and integrating a known transmitter was a routine modification.

Ground 2: Obviousness over Tetsuo, Bissonnette, and Stanley - Claims 5-6 and 42 are obvious over Tetsuo and Bissonnette in further view of Stanley.

  • Prior Art Relied Upon: Tetsuo, Bissonnette, and Stanley (Patent 5,684,924).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Tetsuo and Bissonnette combination by adding Stanley to address claims requiring user-adjustable parameters. Stanley taught a speech recognition system with a user-adjustable "sensitivity" threshold to distinguish speech from background noise (claim 5) and a user-adjustable gain amplification circuit (claim 6).
    • Motivation to Combine: A POSITA would incorporate Stanley’s user-adjustable features into the Tetsuo/Bissonnette system to enhance its functionality. This would allow a user to customize the system for different ambient noise levels and for users with different voice volumes, thereby improving performance and preventing unintended activations or failures to activate.
    • Expectation of Success: The combination was predictable, as adjustable sensitivity and gain were well-known features in audio systems to improve signal processing, and their implementation in the base system would be straightforward.

Ground 3: Obviousness over Tetsuo, Bissonnette, and Geilhufe - Claims 9-13 and 44-48 are obvious over Tetsuo and Bissonnette in further view of Geilhufe.

  • Prior Art Relied Upon: Tetsuo, Bissonnette, and Geilhufe (Patent 6,584,439).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground added Geilhufe to the base combination to teach automatic termination of the speech recognition mode. Geilhufe disclosed a voice-controlled system that automatically returns to a low-power "idle state" after a predetermined period of silence (claim 10) or upon detecting an out-of-vocabulary word error (claims 12-13).
    • Motivation to Combine: A POSITA would combine Geilhufe’s automatic timeout feature to further improve the power efficiency and user-friendliness of the Tetsuo/Bissonnette system. This modification would ensure the device returned to its power-saving mode without requiring manual user intervention, which aligned with the power-saving goals already present in Tetsuo.
    • Expectation of Success: Success was expected because implementing a software-based timeout or error-handling routine to revert to a standby state was a conventional and well-documented technique in the field of voice control systems.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under §314(a) would be improper. The petition asserted that its primary prior art reference, Tetsuo, had not been cited in any of the several prior-filed IPRs against the ’186 patent by other petitioners (including Google and Microsoft). Therefore, the grounds presented were substantially different and stronger than those in earlier petitions. Petitioner also contended that it had acted diligently, had not engaged in tactical serial filings, and that since the Board had not yet instituted review on any prior petitions, there was no risk of duplicative effort or inefficient use of Board resources.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-20 and 41-55 of Patent 6,397,186 as unpatentable under 35 U.S.C. §103.