PTAB

IPR2020-00846

Google LLC v. Parus Holdings Inc

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1. Case Identification

2. Patent Overview

  • Title: Voice Browser System
  • Brief Description: The ’431 patent relates to a system that allows users to retrieve information from pre-selected websites using voice commands spoken into a voice-enabled device, such as a telephone. The system uses speech recognition to interpret user requests and speech synthesis to provide the retrieved information as an audio response.

3. Grounds for Unpatentability

Ground 1: Obviousness over Kovatch and Neal - Claims 1-2, 4-7, 10, and 13-14 are obvious over Kovatch in view of Neal.

  • Prior Art Relied Upon: Kovatch (International Publication No. WO 2001/050453) and Neal (Patent 6,324,534).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kovatch discloses a voice response system ("HeyAnita") that meets most limitations of independent claim 1. Kovatch’s system accepts telephone calls, uses speaker-independent speech recognition to understand user commands, browses the web to retrieve requested information, and provides it back to the user in audio form. However, Petitioner contended Kovatch does not explicitly teach sequentially accessing a plurality of websites if the requested information is not found at the first-accessed site.
    • Motivation to Combine: Neal was cited for its teaching of an optimized search process that queries data sets (e.g., from different suppliers) in a hierarchical order, proceeding to the next in the hierarchy only if a match is not found. Petitioner asserted a person of ordinary skill in the art (POSITA) would combine Neal's efficient, sequential search method with Kovatch's voice-browsing system to increase the likelihood of finding requested information while efficiently using computing resources.
    • Expectation of Success: Petitioner argued a POSITA would have a reasonable expectation of success because Neal’s search techniques are software-based and could be incorporated into Kovatch's server-based architecture using ordinary skill.

Ground 2: Obviousness over Kovatch, Neal, and Chakrabarti - All challenged claims, including claim 9, are obvious over Kovatch in view of Neal and Chakrabarti.

  • Prior Art Relied Upon: Kovatch (WO 2001/050453), Neal (’534 patent), and Chakrabarti (Patent 6,418,433).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Kovatch/Neal combination for the base system of claim 1 and adds Chakrabarti to address the limitations of dependent claim 9. Claim 9 requires the system’s computer to be further configured to "periodically search said internet to identify new web sites and to add said new web sites to said plurality of web sites." Petitioner argued Chakrabarti teaches a "focussed crawler" that periodically searches the internet for new pages relevant to predefined topics and adds them to a crawl database.
    • Motivation to Combine: Petitioner contended that a POSITA would be motivated to add Chakrabarti's crawling functionality to the Kovatch/Neal system to keep its database of websites comprehensive and up-to-date. Given that web content changes constantly, this was asserted to be a known method for improving the utility and relevance of an information-retrieval system.
    • Expectation of Success: The crawler functionality in Chakrabarti is implemented via computer instructions, and a POSITA would have reasonably expected to successfully integrate this feature into the server architecture of the proposed Kovatch/Neal system.

Ground 3: Obviousness over Kovatch, Neal, and DeSimone - Claim 14 is obvious over Kovatch in view of Neal and DeSimone.

  • Prior Art Relied Upon: Kovatch (WO 2001/050453), Neal (’534 patent), and DeSimone (Patent 5,787,470).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds DeSimone to the Kovatch/Neal combination to teach the limitations of claim 14, which recites "a database operatively connected to said computer...[and] configured to store said information gathered from said web sites." Petitioner asserted that the primary combination did not explicitly teach storing the retrieved information (as opposed to website addresses) in a database. DeSimone was cited for its teaching that it was typical for an Internet Access Service Provider (IASP) to store retrieved web objects in a cache (a type of database) to satisfy subsequent requests more quickly.
    • Motivation to Combine: A POSITA would be motivated to add DeSimone’s caching technique to the Kovatch/Neal system to achieve the known benefits of reducing user-perceived delay and saving bandwidth. Since the Kovatch/Neal system functions like an IASP for multiple users, these benefits would be directly applicable.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including that claim 14 is obvious over the four-way combination of Kovatch, Neal, Chakrabarti, and DeSimone. Petitioner also presented alternative grounds arguing that claims 9 and 14 lack priority, making the patent’s parent publication, Kurganov-262, prior art. These grounds challenged claim 9 as obvious over Kurganov-262 and Chakrabarti, and claim 14 as obvious over Kurganov-262 and DeSimone.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under 35 U.S.C. §325(d), asserting the prior art combinations relied upon were not cumulative to the art considered during prosecution (Perrone) or to the art in a co-pending IPR filed by Apple (IPR2020-00686).
  • Petitioner also argued against discretionary denial under §314(a) based on the Fintiv factors. It was contended that the parallel district court litigation was in an early stage, the grounds presented in this petition were wholly different from those in the Apple IPR, Petitioners have no significant relationship with Apple, and Petitioners acted diligently in filing.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-2, 4-7, 9-10, and 13-14 of Patent 7,076,431 as unpatentable.