PTAB

IPR2020-01739

Mycroft Ai Inc v. Voice Tech Corp

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1. Case Identification

2. Patent Overview

  • Title: Using Voice Commands from a Mobile Device to Remotely Access and Control a Computer
  • Brief Description: The ’348 patent discloses a system for remotely controlling a computer using voice commands sent from a mobile device. The invention centers on an "audio command interface" on the computer that receives and decodes the audio data, and then intelligently selects an appropriate application or operating system function to execute in response to the command.

3. Grounds for Unpatentability

Ground 1: Claims 3, 7, 13-14, 19, 25-26, and 31 are anticipated by, or in the alternative obvious over, McConnell.

  • Prior Art Relied Upon: McConnell (International Publication No. WO 2005/074634).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that McConnell, which describes a system for controlling a computer via audio commands from a remote device (e.g., a cellular phone), discloses every limitation of this group of claims. McConnell’s "interface program 300," along with its voice recognition and natural language processing modules, was alleged to constitute the claimed "audio command interface." This interface was described as selecting from a plurality of applications (e.g., email, spreadsheets, Microsoft Excel) and operating system functions based on a user's voice command. Petitioner contended that the key limitation requiring the interface to "remember at least one process" was met by McConnell's use of context-based grammars, which limit available commands based on the currently active application, thus "remembering" the context of the prior process.
    • Motivation to Combine (for §103 alternative): For the alternative obviousness ground, Petitioner asserted that a Person of Ordinary Skill in the Art (POSITA) would have found it obvious to apply McConnell's disclosed features to achieve the claimed invention.

Ground 2: Claims 2, 6, 11-12, 18, 23-24, and 30 are obvious over McConnell in view of Roese.

  • Prior Art Relied Upon: McConnell (WO 2005/074634) and Roese (International Publication No. WO 03/075125).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that McConnell teaches all limitations of this claim group except for the use of "location data" in selecting an application or operating system. To supply this missing element, Petitioner cited Roese, which teaches a location-aware system that grants or denies access to applications and data based on the determined physical location of a user's device.
    • Motivation to Combine: A POSITA would combine Roese’s location-based security with McConnell’s remote voice control system to improve security. McConnell already disclosed concerns with securing access to sensitive user data, and Roese taught a known, predictable method for enhancing security by using device location as an authentication factor. Petitioner argued this was an obvious improvement to prevent unauthorized access to sensitive information.
    • Expectation of Success: The combination would predictably yield an audio command interface that restricts access to applications or data based on the user's location, which was described as a straightforward application of a known security technique to an existing remote access system.

Ground 3: Claims 3, 7, 13-14, 19, 25-26, and 31 are obvious over Balakrishnan in view of Wong.

  • Prior Art Relied Upon: Balakrishnan (Patent 6,233,559) and Wong (Application # 2006/0235700).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Balakrishnan discloses an "arbitrator" that functions as an audio command interface, receiving voice input and intelligently deciding whether to direct the command to the operating system or to one of several applications (e.g., Netscape, WisdomPen). However, Balakrishnan's system receives input from a microphone local to the computer. Wong was cited to teach remote control of a computer, including accessing files and issuing voice commands, from a mobile smart phone over a network and transmitting output data back to the mobile device.
    • Motivation to Combine: A POSITA would be motivated to modify Balakrishnan’s system to incorporate Wong’s remote access capabilities. This modification would allow the benefits of Balakrishnan's advanced command arbitration to be used remotely, a well-understood goal in the art. Petitioner framed this as a simple and predictable substitution of Balakrishnan's local microphone with the remote mobile device input taught by Wong.
    • Expectation of Success: Combining the teachings was asserted to be a routine endeavor. Configuring Balakrishnan's interface to receive audio from a remote device (per Wong) and send output data back to it would predictably and beneficially allow remote access to the computer’s applications, achieving an expected result without technical hurdles.

4. Key Claim Construction Positions

  • Petitioner argued for a broad construction of the term "audio command interface" based on its usage in the specification.
  • Proposed Construction: "hardware, software, or a suitable combination of hardware and software at a general purpose computer that allows a person to use voice commands from a mobile device to access and control applications or operating system functions at the general purpose computer."
  • Relevance: Petitioner contended that this broad construction is required by the patent's disclosure and that the Patent Owner’s arguments during prosecution—attempting to narrow the term to exclude systems where applications are already configured for direct mobile interaction—are not supported by the actual claim language.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 2-3, 6-7, 11-14, 18-19, 23-26, and 30-31 of Patent 9,794,348 as unpatentable.