Unified Patents LLC v. Voice Tech Corp

1. Case Identification

• Case #: IPR2020-01018
• Patent #: 10,491,679
• Filed: June 5, 2020
• Petitioner(s): Unified Patents, LLC
• Patent Owner(s): Voice Tech Corp
• Challenged Claims: 1-8

2. Patent Overview

• Title: Accessing and Controlling a Computer from a Mobile Device
• Brief Description: The ’679 patent relates to a system for controlling a computer using voice commands received from a remote mobile device. The system's audio command interface decodes the audio, selects an appropriate operating system or application to execute the command, and transmits output data back to the mobile device.

3. Grounds for Unpatentability

Ground 1: Claims 1-8 are obvious over Wong in view of Beauregard.

• Prior Art Relied Upon: Wong (Application # 2006/0235700) and Beauregard (Patent 6,438,545).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Wong disclosed most claim elements, including a system for remotely controlling a computer (a home PC) from a mobile device (a smartphone) using voice commands. Wong's speech engine was said to receive and decode audio, execute a command within a specific application (a photo server app), and transmit resulting data back to the mobile device. Petitioner contended Wong was limited to a single application and that Beauregard supplied the missing limitation of an audio command interface that selects between at least one operating system and at least one application to execute a command. Beauregard's system was designed to control a computer from any context, allowing commands to be executed by the OS or a plurality of different applications.
  • Motivation to Combine: A POSITA would combine Beauregard’s advanced command interpretation and selection logic with Wong's remote access system to improve its functionality. Petitioner noted that Wong expressly contemplated use with "any other type of electronic file," motivating a skilled artisan to expand its capabilities beyond a single photo application. Beauregard's system, designed to improve user productivity by allowing control over multiple applications and the OS from a single interface, provided a known solution to achieve this expansion.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success because both references rely on similar underlying techniques of converting voice to text and matching commands to a database. Petitioner asserted that Beauregard taught the source of the audio input is "irrelevant," indicating that integrating audio from a remote device as taught in Wong would be a straightforward software modification with predictable results.

Ground 2: Claims 1-8 are obvious over Ben-Efraim in view of Balakrishnan.

• Prior Art Relied Upon: Ben-Efraim (Patent 7,203,721) and Balakrishnan (Patent 6,233,559).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Ben-Efraim disclosed a system for accessing a remote computer (a content aggregation server) from a mobile device using voice commands. Ben-Efraim's voice interaction system (VIS) decodes voice input and can execute commands in at least two different applications (e.g., a browsing program and a location-keeping application). Petitioner argued that while Ben-Efraim taught selecting from multiple applications, it lacked detail on how the system arbitrates between them. Balakrishnan was argued to supply this detail by teaching an "arbitrator" within the operating system that determines the appropriate destination for a voice command, deciding whether the OS or one of multiple applications should act upon the speech input.
  • Motivation to Combine: A POSITA seeking to implement Ben-Efraim's system would have been motivated to consult a reference like Balakrishnan for a more detailed disclosure on how to efficiently manage and direct voice commands. Balakrishnan directly addressed the problem of arbitrating commands that could be intended for the OS or various applications, providing a clear method to resolve the ambiguity and avoid wasting system resources—a problem not detailed in Ben-Efraim.
  • Expectation of Success: The combination would have yielded predictable results, as both systems addressed voice command execution in a multi-application environment. Petitioner contended that integrating Balakrishnan's arbitration logic into Ben-Efraim's VIS would have been a minor software modification to enhance its existing functionality, furthering the goal of efficiently processing voice commands from a remote user.

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §325(d) would be improper. It was asserted that the primary references relied upon in the petition—Beauregard, Ben-Efraim, and Balakrishnan—were never considered during the prosecution of the ’679 patent. Furthermore, the specific combination of Wong and Beauregard was never presented to or considered by the Examiner.

5. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-8 of the ’679 patent as unpatentable.