PTAB

IPR2020-00080

Google LLC v. Hammond Development Intl Inc

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1. Case Identification

2. Patent Overview

  • Title: Communication Device with Remote Processing of Voice Input
  • Brief Description: The ’032 patent describes a communication system where a client device captures a user's voice input, sends it to a remote application server, and receives back a voice representation for output to the user. The system is designed for interactive voice applications where the primary processing occurs on the server.

3. Grounds for Unpatentability

Ground 1: Obviousness over Gilmore, Dhara, and Dodrill - Claims 1-5, 7-14, and 16-21 are obvious over Gilmore in view of Dhara and Dodrill.

  • Prior Art Relied Upon: Gilmore (Application # 2003/0216923), Dhara (Application # 2003/0202504), and Dodrill (Patent 6,766,298).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Gilmore disclosed the core architecture of the challenged claims: a client communication device (e.g., a PDA or cell phone) interacting with a remote Interactive Voice Response (IVR) system's voice gateway (the "application server") over a network. Gilmore taught capturing voice input, transmitting it, and receiving audio prompts. However, Gilmore did not explicitly detail the client device's hardware or a key processing instruction. Dhara was used to supply these conventional components, teaching an IP device with a speaker, microphone, processor, and memory executing software (a VoiceXML browser) for similar IVR interactions. Dodrill was introduced to teach the specific limitation of the server sending a "request for processing service" that comprises an instruction for the client device to present the voice representation. Dodrill disclosed sending executable files or scripts (e.g., XML tags like <PROMPT>) to a client, which then executes the instruction to play a local or retrieved audio file, rather than the server simply streaming the audio itself.
    • Motivation to Combine: A POSITA would combine Gilmore and Dhara to implement Gilmore's conceptual IVR system using the well-understood and explicitly disclosed hardware and client-side software taught by Dhara. The motivation to add Dodrill's teachings was to improve system efficiency and user experience. Sending an executable instruction, as taught by Dodrill, would reduce the computational load on the application server, distribute processing tasks to capable client devices, and mitigate potential audio quality issues associated with streaming over unreliable networks. This approach would make the overall system more scalable and robust.
    • Expectation of Success: Petitioner asserted a POSITA would have a reasonable expectation of success because the combination involved implementing a known IVR architecture (Gilmore) with conventional client hardware and software (Dhara) and incorporating a known technique for client-side processing (Dodrill) to achieve the predictable benefits of improved efficiency and scalability.

Ground 2: Obviousness over Gilmore, Dhara, Dodrill, and Patel - Claims 6, 15, 22, and 23 are obvious over Gilmore in view of Dhara, Dodrill, and Patel.

  • Prior Art Relied Upon: Gilmore (Application # 2003/0216923), Dhara (Application # 2003/0202504), Dodrill (Patent 6,766,298), and Patel (Application # 2006/0256950).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground incorporated all arguments from Ground 1 and added Patel to address limitations in dependent claims related to a touchscreen and video content. Petitioner argued that Patel explicitly disclosed using a touchscreen as a user interface on client devices (like PDAs and cell phones) for interacting with an IVR system. For the claim limitation requiring content that "comprises video," Petitioner relied on Dodrill's teaching that its system could retrieve and present various media types, including "streaming video," not just audio.
    • Motivation to Combine: A POSITA would be motivated to add Patel's touchscreen to the client device of the primary combination to provide users with additional, well-known input methods beyond voice and keypads. This would increase the device's functionality and user convenience, which was a common design goal. The motivation to incorporate video capabilities, as taught by Dodrill, was to expand the resources and types of information available to the user beyond what could be conveyed by audio alone, a natural evolution for such communication systems.
    • Expectation of Success: There was a high expectation of success in adding a touchscreen, as it was a conventional input component for the types of devices disclosed in the primary references. Similarly, integrating video playback was a known function for browsers on these devices, and modifying the system to fetch video files instead of audio files involved applying conventional file retrieval and playback techniques.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and cancellation of claims 1-23 of the ’032 patent as unpatentable under 35 U.S.C. §103.