PTAB

IPR2019-01146

Samsung Electronics Co Ltd v. SpeakWare Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Sound-Activated Voice Control System for Appliances
  • Brief Description: The ’186 patent discloses a sound-activated, universal remote control system for appliances. The system operates in two modes: a low-power "sound activation mode" to conserve energy and a "speech recognition mode" for processing commands, purportedly enabling "truly hands-free" operation by automatically switching from the low-power mode to the active mode when a received audio signal's amplitude exceeds a preset threshold.

3. Grounds for Unpatentability

Ground 1: Obviousness over Salazar, Miyazawa, and Bossemeyer - Claims 1-4, 7-16, and 19-20 are obvious over Salazar in view of Miyazawa, further in view of 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 the primary reference, Salazar, disclosed a universal remote system that controls appliances using voice commands and includes a microphone, processor, wireless transceivers, and a power-saving "stop mode." However, Salazar did not teach automatically switching from its low-power mode based on sound amplitude. Miyazawa was argued to supply this missing element by teaching a voice-activated system that automatically switches from a low-power "sleep mode" to an active "speech recognition mode" when the amplitude of an input sound signal exceeds a threshold, enabling hands-free activation. Bossemeyer was asserted to further teach detecting the precise start and end of a spoken utterance by comparing signal amplitude to a threshold, refining the mode-switching mechanism.
    • Motivation to Combine: A POSITA would combine Miyazawa's amplitude-triggered, power-saving mode switching with Salazar's universal remote system to achieve greater power efficiency, an express goal of both references. This combination represents a predictable application of known battery-saving techniques to voice control systems. The addition of Bossemeyer's utterance detection was argued to be a logical step to further improve power efficiency by ensuring speech recognition is applied only to actual voice commands, not background noise.
    • Expectation of Success: Petitioner asserted a high expectation of success because both Salazar and Miyazawa utilize conventional components like microphones, mode-switching processors, and speech recognition hardware. Integrating Miyazawa's power management logic into Salazar's existing architecture would have been straightforward for a POSITA.

Ground 2: Obviousness over Salazar, Miyazawa, and Oppendahl - 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 addressed claim 5, which adds a "user-adjustable sound activation sensitivity control." Petitioner argued the base combination of Salazar and Miyazawa provided the core system that switches modes based on a fixed amplitude threshold. Oppendahl was asserted to teach a voice-operated switch (VOX) transceiver that explicitly included a "user-adjustable VOX threshold" controlled by a "VOX sensitivity control."
    • Motivation to Combine: A POSITA would have been motivated to incorporate Oppendahl's user-adjustable threshold to solve the known problem of false triggers in varying noise environments. Adding this feature to the Salazar-Miyazawa system would predictably allow a user to manually adjust the activation sensitivity to prevent false positives in loud environments or missed activations in quiet ones, a well-known technique for improving the robustness of voice-activated systems.
    • Expectation of Success: The expectation of success was argued to be high, as implementing a user control to adjust a pre-existing threshold value is a routine design modification in the field of electronics.

  • Additional Grounds: Petitioner asserted additional obviousness challenges for other dependent claims, arguing that a POSITA would have found it obvious to incorporate known features into the primary Salazar-Miyazawa combination. These included adding a user-adjustable amplification circuit (as taught by Reichel, Patent 5,459,792) for claim 6; varying processor frequency between modes (as taught by Clark, Patent 6,425,086) for claim 8; and enabling a user-programmable mode to define custom voice commands (as taught by Douma, Patent 5,583,965) for claims 17-18.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial would be inappropriate. First, it contended that the key prior art references—Salazar, Miyazawa, and Bossemeyer—were either not cited or not substantively analyzed by the Patent Office during the original prosecution of the ’186 patent, meaning the petition raised issues not previously considered. Second, Petitioner argued that because this petition was filed with a motion for joinder to a previously instituted inter partes review (IPR) and agreed to a passive role, the General Plastic factors regarding follow-on petitions are effectively neutralized and should not bar institution.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-20 of the ’186 patent as unpatentable.