PTAB

IPR2019-01147

Samsung Electronics Co., LTD v. SpeakWare, Inc.

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1. Case Identification

2. Patent Overview

  • Title: Audio Signal Activated Control System and Method
  • Brief Description: The ’186 patent discloses a sound-activated universal remote system for controlling appliances using voice. The system operates in two primary modes: a low-power "sound activation mode" and a "speech recognition mode." The device remains in the low-power mode until it detects a voice signal exceeding a predetermined amplitude threshold, at which point it automatically switches to the active speech recognition mode to process commands.

3. Grounds for Unpatentability

Ground 1: Claims 21, 23-26, 28-36, 39-41, 43-52, and 55 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 combination of these references taught all elements of the challenged claims. Salazar disclosed the foundational universal remote control system with a voice-activated mode and a power-saving "stop mode." However, Salazar did not teach automatically switching from the low-power mode based on voice amplitude. Miyazawa supplied this missing element, teaching a voice-activated system that switches from a low-power "sleep mode" to an active speech recognition mode when the amplitude of an input sound signal exceeds a threshold, without requiring a physical switch. Bossemeyer was argued to further teach or clarify the concept of using a threshold-based system to detect the precise start and end of a voice utterance, improving upon Miyazawa's trigger mechanism.
    • Motivation to Combine: A POSITA would combine Salazar and Miyazawa to improve the power efficiency of Salazar’s universal remote, a goal explicitly stated in both references. The combination involved applying Miyazawa's known power-saving, voice-triggered switching to Salazar's known voice-controlled remote system to achieve the predictable result of a more power-efficient, hands-free device. A POSITA would have been further motivated to incorporate Bossemeyer’s utterance detection to improve the trigger's accuracy and avoid processing background noise, thereby increasing efficiency.
    • Expectation of Success: Petitioner asserted a POSITA would have had a high expectation of success, as the combination merely integrated known elements for their intended purposes to achieve a predictable improvement in power management and usability.

Ground 2: Claims 22 and 42 are obvious over the combination of Salazar, Miyazawa, and Bossemeyer, further in view of Oppendahl.

  • Prior Art Relied Upon: Salazar, Miyazawa, Bossemeyer, and Oppendahl (Patent 5,008,954).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the primary combination from Ground 1 to address the limitations of claims 22 and 42, which require that the predetermined threshold of the sound activation circuit be "user-adjustable." Oppendahl was cited for its disclosure of a voice-operated switch (VOX) system that included a "VOX sensitivity control," allowing a user to manually adjust the voice detection threshold.
    • Motivation to Combine: A POSITA would be motivated to add Oppendahl's user-adjustable threshold to the primary combination to give the user manual control over the system's sensitivity. This would predictably allow a user to fine-tune the device to prevent false positives (if the threshold is too low) or false negatives (if too high) in various noise environments, complementing the automatic thresholding taught by Miyazawa and fulfilling a shared goal of reducing false triggers and conserving power.

Ground 3: Claim 27 is obvious over the combination of Salazar, Miyazawa, and Bossemeyer, further in view of Reichel.

  • Prior Art Relied Upon: Salazar, Miyazawa, Bossemeyer, and Reichel (Patent 5,459,792).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground addressed claim 27, which requires a "user-adjustable amplification level control" to vary the amplitude of the electrical signals for controlling sensitivity. Reichel was cited for teaching an audio input circuit with a user-adjustable gain control (a potentiometer) to control the amplification level of a microphone signal before it is sent to a voice recognition system.
    • Motivation to Combine: A POSITA would have recognized that adjusting the input signal's gain is a well-known, alternative way to control a voice recognition system's sensitivity. It would have been an obvious design choice to incorporate Reichel's adjustable amplification into the primary combination to provide another method for fine-tuning performance, which would have been a predictable application of a known technique.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claims 37, 38, 53, and 54 are obvious over the primary combination of Salazar, Miyazawa, and Bossemeyer in view of Douma (Patent 5,583,965). Douma was cited for its teaching of a trainable voice recognition system, which a POSITA would have been motivated to add to provide for user-defined commands and increase customization.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under the General Plastic factors would be inappropriate. The petition was filed with a motion for joinder to a previously instituted inter partes review (IPR) filed by another party.
  • Petitioner asserted that the primary references (Salazar, Bossemeyer) and the specific combination rationales were not considered by the USPTO during the original prosecution of the ’186 patent, and that these new grounds and arguments weighed strongly in favor of institution.

5. Relief Requested

  • Petitioner requested institution of IPR and cancellation of claims 21-55 of the ’186 patent as unpatentable under 35 U.S.C. §103.