PTAB

IPR2020-01380

Amazon.com Inc v. VB Assets LLC

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Petition
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1. Case Identification

2. Patent Overview

  • Title: VOICE COMMERCE
  • Brief Description: The ’703 patent discloses a method for voice-based e-commerce where a computer system receives a user’s natural language utterance, determines a product or service to be purchased, and automatically completes the transaction by obtaining payment and shipping information from a stored user profile without requiring further user input.

3. Grounds for Unpatentability

Ground 1: Claims 1, 7-15, 21-24, and 30-33 are obvious over Cohen in combination with Hao and Kennewick-II.

  • Prior Art Relied Upon: Cohen (Patent 6,859,776), Hao (Patent 8,078,502), and Kennewick-II (Application # 20040193420).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Cohen, Hao, and Kennewick-II disclosed all limitations of the challenged claims.
      • Cohen taught a voice-activated browser that allowed users to perform e-commerce transactions, such as booking flights and rental cars, using spoken commands. It disclosed a speech recognition engine, a natural language interpreter to determine context, and the use of a stored user profile containing information like credit card details to streamline transactions. Petitioner asserted Cohen’s system met the core limitations of independent claim 1, including receiving a voice utterance, determining a product, and obtaining payment and shipping information from a user profile to complete a purchase without further input.
      • Hao was presented as teaching a more advanced voice e-commerce system where a user could populate a shopping cart with multiple items, specify payment, and provide shipping instructions within a single, continuous natural language utterance (e.g., “I need 5 gallons of milk... Charged to my credit card and sent to my home”). Hao’s system would then automatically parse this input, identify products, and retrieve specific payment (VISA) and shipping (a quantified street address) details from a "shopper profile" to complete the purchase.
      • Kennewick-II was cited for its disclosure of an advanced speech interface that uses a "scoring system" to determine the most likely context or domain for a user’s utterance. This system weighs factors like user profile data, previous context, and domain-specific knowledge to interpret ambiguous commands, enhancing the basic context determination taught by Cohen.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine these references because they are all in the same field of voice-based e-commerce and share the common goal of simplifying user transactions. A POSITA would have been motivated to enhance the foundational voice-browser system of Cohen by incorporating the more sophisticated single-utterance transaction processing from Hao to allow for more natural and efficient shopping. Furthermore, a POSITA would integrate the scoring-based context determination from Kennewick-II to improve the accuracy and reliability of interpreting user commands in the combined Cohen/Hao system.
    • Expectation of Success: Petitioner contended that a POSITA would have a reasonable expectation of success because the combination involved applying known speech processing and e-commerce techniques to improve an existing system architecture. The integration of Hao's and Kennewick-II's features into Cohen's system was a predictable implementation of established technologies to achieve the known benefits of faster and more accurate voice-based purchasing.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that the Board should not exercise its discretion to deny institution under 35 U.S.C. §314(a) or §325(d). It was contended that while a parallel district court case existed, the complaint in that litigation only alleged infringement of claim 30, whereas the IPR petition challenged a much broader set of claims.
  • Regarding Kennewick-II, which was cited during prosecution, Petitioner argued denial under §325(d) was inappropriate because the reference was part of an Information Disclosure Statement (IDS) containing over 700 references and was never substantively considered or applied by the examiner.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 7-15, 21-24, and 30-33 of the ’703 patent as unpatentable.