PTAB

IPR2020-01067

Amazon.com Inc v. Hammond Development Intl Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Processing a Request for a Service
  • Brief Description: The ’816 patent discloses a client-server system where a client device (e.g., cell phone) communicates with an application server over a first communication link. The application server retrieves applications, such as VoiceXML applications, from a repository over a second communication link to provide voice-interactive services to the client.

3. Grounds for Unpatentability

Ground 1: Obviousness over Maes and Maes 2 - Claims 1-30 are obvious over Maes in view of Maes 2.

  • Prior Art Relied Upon: Maes (Patent 6,934,756) and Maes 2 (International Publication No. WO 99/23008). Petitioner asserted that Maes incorporates Maes 2 by reference, allowing them to be treated as a single disclosure.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Maes discloses all limitations of the challenged claims. Maes teaches a client-server system for speech-enabled clients (e.g., smartphones) to interact with powerful information servers. The claimed "application server" was mapped to Maes' combined browser server and engine server, which process applications (SpeechML pages). The system uses a "first communication link" (a network) to connect the client to the server and a "second communication link" to connect the server to a repository (Maes' "presentation server") to retrieve applications. In response to a spoken user request (e.g., for banking information), the server establishes a "communication session" and uses its "conversational engines" (the claimed voice processing software) to generate and transmit a voice representation back to the client.
    • Motivation to Combine: The motivation was explicit, as Maes directly incorporates Maes 2 for its "detailed discussion of the architecture and operation of the speech browser."
    • Expectation of Success: A person of ordinary skill in the art (POSITA) would have a reasonable expectation of success in combining the teachings because both references describe conventional, interoperable client-server architectures for voice applications and share a common inventor.

Ground 2: Obviousness over Bharedwaj and Salomon - Claims 1-3, 5-30 are obvious over Bharedwaj in view of Salomon.

  • Prior Art Relied Upon: Bharedwaj (International Publication No. WO 01/17274) and Salomon (Application # 2003/0041125).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Bharedwaj discloses a "thin client" system that meets most claim limitations. Bharedwaj’s server acts as the "application server," connected to a client over a first communication link and to the internet (a second communication link) to download applications. The server establishes a "session" with the client in response to a request and uses a "speech protocol subsystem" for voice processing. The primary alleged deficiency in Bharedwaj was its disclosure of a repository, which Petitioner argued was met by combining it with Salomon.
    • Motivation to Combine: A POSITA, starting with Bharedwaj's system that downloads applications from the internet, would have been motivated to look to references like Salomon to understand how such applications are efficiently stored and retrieved. Salomon teaches using a central repository with databases to increase the efficiency of distributing applications, ensure proper security, and free up application server resources by only storing active applications locally. Implementing Salomon's repository structure in Bharedwaj's system was argued to be a combination of known elements for a predictable result.
    • Expectation of Success: A POSITA would expect success because both references describe similar client-server systems, and using a centralized repository to serve applications was a well-known and conventional practice.

Ground 3: Obviousness over Bharedwaj, Salomon, and Thelen - Claims 10, 19, and 25 are obvious over Bharedwaj and Salomon in further view of Thelen.

  • Prior Art Relied Upon: Bharedwaj (WO 01/17274), Salomon (’125 application), and Thelen (Patent 6,487,534).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground built upon the combination of Bharedwaj and Salomon to address claims 10, 19, and 25, which further require the client device to comprise a voice recognition application. Petitioner argued that while Bharedwaj's server performs speech recognition, Thelen provides the teaching of performing some recognition tasks on the client device itself.
    • Motivation to Combine: A POSITA would be motivated to add Thelen's client-side voice recognition to the Bharedwaj system for known benefits. Thelen explicitly teaches improving prior art systems by handling simple speech recognition tasks locally on the client to conserve server resources and reduce network traffic. Bharedwaj itself identifies reducing data sent to the server as a key benefit of its invention, providing a clear reason to incorporate Thelen's efficiency-improving technique.
    • Expectation of Success: The combination represented applying a known technique (local voice recognition) to a known device type (a PDA or smartphone, as in Bharedwaj) to achieve the predictable result of improved system performance.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 1c) against claims 3 and 14-30 based on the Maes/Maes 2 combination in further view of Salomon to ensure the clear disclosure of a repository having a database.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under Fintiv, stating that the IPR and a co-pending district court litigation are not co-extensive, as twelve of the challenged claims are not asserted in the litigation and will not be addressed by the court.
  • Petitioner further argued that the court had not yet substantively addressed the obviousness arguments, whereas the Board had already invested considerable resources in evaluating related patents.
  • Finally, Petitioner contended that denying institution due to the litigation schedule would supplant Congressional intent for the one-year statutory bar, particularly since the Patent Owner delayed serving infringement contentions and providing claim constructions in the district court case.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-30 of the ’816 patent as unpatentable.