PTAB

IPR2019-01352

Apple Inc v. Advanced Voice Recognition Systems Inc

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1. Case Identification

2. Patent Overview

  • Title: Speech Recognition and Transcription Across Incompatible Protocols
  • Brief Description: The ’730 patent describes systems and methods for facilitating speech recognition and transcription among users employing otherwise incompatible communication protocols. The purported invention utilizes a central "System Transaction Manager" operating with a "uniform system protocol" to route speech information requests to a "Speech Recognition and Transcription Engine" for processing and transcription.

3. Grounds for Unpatentability

Ground 1: Obviousness over Skladman and Obilisetty - Claims 15 and 17 are obvious over Skladman in view of Obilisetty.

  • Prior Art Relied Upon: Skladman (Patent 6,487,278) and Obilisetty (Patent 7,558,735).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Skladman taught a unified messaging system that serves as the claimed "system transaction manager." Skladman’s system integrates legacy messaging systems (like voicemail) using different protocols by routing messages through a central "unified message server" that converts them into a predetermined, uniform format. Skladman also disclosed "user application service adapters" in the form of its middleware server and user-facing interfaces. However, while Skladman taught text-to-speech conversion, it did not explicitly teach speech-to-text transcription. Petitioner contended that Obilisetty, which described a system for capturing and transcribing dictated voice files, supplied this missing "speech recognition and transcription engine" limitation.
    • Motivation to Combine: A POSITA would combine Obilisetty’s transcription functionality with Skladman’s messaging framework to provide the highly desirable feature of receiving voicemail transcriptions as text (e.g., via email). Petitioner asserted this was a natural extension of Skladman’s system, which already handled both voice and text messages and performed the inverse text-to-speech conversion for delivering emails as audio.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because Skladman already provided the framework for integrating disparate message types and protocol conversions. Obilisetty’s system was designed to interface with legacy systems over the internet, making its integration into Skladman’s architecture a predictable and straightforward modification.

Ground 2: Obviousness over Skladman, Obilisetty, and Schrage - Claims 15 and 17 are obvious over Skladman in view of Obilisetty and in further view of Schrage.

  • Prior Art Relied Upon: Skladman (Patent 6,487,278), Obilisetty (Patent 7,558,735), and Schrage (Patent 6,850,609).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1. Petitioner argued that if Obilisetty were found not to disclose a fully automated, computer-based transcription engine, Schrage would supply this feature. Schrage explicitly taught a centralized transcription server that performs an "automated speech recognition operation on the recorded speech" using a process running on a computer, thereby meeting all requirements of the claimed "speech recognition and transcription engine."
    • Motivation to Combine: A POSITA would be motivated to use Schrage’s automated transcription system to improve the Skladman/Obilisetty combination for reasons of cost, speed, and efficiency over potentially human-based transcription services. Petitioner noted that the ’730 patent itself acknowledged that computerized transcription systems were well-known and commercially available, making the substitution of an automated engine a simple and obvious design choice.
    • Expectation of Success: Integrating a known automated transcription module (Schrage) into a unified messaging system was a predictable implementation with a high expectation of success, as it involved combining known technologies for their intended purposes.

Ground 3: Obviousness over Cohn and Obilisetty - Claims 15 and 17 are obvious over Cohn in view of Obilisetty.

  • Prior Art Relied Upon: Cohn (Patent 6,064,723) and Obilisetty (Patent 7,558,735).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Cohn disclosed a network communications system with distributed "network hubs" that could translate messages between disparate protocols, including performing speech-to-text translation. In Cohn's distributed architecture, these hubs collectively performed the functions of the system transaction manager and transcription engine. Obilisetty, in contrast, taught a centralized server for voice transcription.
    • Motivation to Combine: A POSITA would be motivated to modify Cohn's distributed system by centralizing its transcription functionality into a single location (such as Cohn's "network center 37"), as taught by Obilisetty's centralized model. The motivation was to create a simpler, more efficient, and less expensive system by eliminating redundant hardware (e.g., a "media translator" in each hub) and streamlining management. Petitioner noted that Cohn itself expressly suggested that network hub functions could be "implemented as a task on a central server."
    • Expectation of Success: A POSITA would expect success in this combination because centralizing distributed server functions was a well-known and common design choice in network architecture. Both Cohn and Obilisetty described systems using standard network protocols, facilitating the integration.

4. Key Claim Construction Positions

  • Petitioner argued for applying claim constructions adopted in a co-pending district court litigation, many of which were based on explicit definitions in the ’730 patent’s specification. These constructions were central to mapping the prior art onto the claims.
  • "system transaction manager": Construed as "a server application that provides a central interconnect point (hub) and a communications interface among system components and Users having disparate or heterogeneous protocols..." This supported mapping the central servers of Skladman and Cohn to this limitation.
  • "uniform system protocol": Construed as "a protocol that processes information expressed in a normalized data format." This was key to arguing that the internal, standardized protocols used in Skladman and Cohn met the claim limitation.
  • "user application service adapter": Construed as "a specific Application Service Adapter that handles formatting and Routing of Speech Information Requests and Responses..." This allowed Petitioner to map the various interface components in the prior art (e.g., Skladman’s middleware, Cohn’s network hubs) to this element.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 15 and 17 of Patent 7,558,730 as unpatentable.