PTAB

IPR2021-00117

Facebook Inc v. Gabara Thaddeus

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1. Case Identification

2. Patent Overview

  • Title: Method and Apparatus for Obtaining Information from the Web
  • Brief Description: The ’348 patent discloses an "intelligent conversation system" designed to augment a conversation between individuals. The system converts speech to text, determines topics from the text, searches the internet for information related to those topics, and then converts the text-based search results back into speech for the participants.

3. Grounds for Unpatentability

Ground 1: Obviousness over Eggen and Ross - Claims 1-4, 7-10, 12, and 15-19 are obvious over Eggen in view of Ross.

  • Prior Art Relied Upon: Eggen (Application # 2008/0235018) and Ross (Patent 7,496,514).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Eggen discloses nearly all elements of the independent claims. Eggen teaches an intelligent system that monitors a conversation, uses a "speech recognition system" to convert audio to text, employs a "keyword extractor" and "topic finder" to determine topics, and uses a "content finder" to search the internet (e.g., Google) for related content, which is then presented to the participants. The primary element Eggen allegedly lacks is the claimed "finite state machine configured to sequence through the search results to generate recall topics." Petitioner asserted that Ross remedies this deficiency by disclosing a dialog management system for a computer conversation that explicitly uses a "turn manager" that provides a "finite state machine" to control the delivery and audible rendering of a prioritized queue of responses to a user.
    • Motivation to Combine: Petitioner contended that Ross is analogous art, as both references address intelligent conversation systems that provide information to a user. A Person of Ordinary Skill in the Art (POSA) would combine Ross's finite state machine with Eggen's system to provide a known method for managing, prioritizing, and sequencing the presentation of search results. This combination would improve the utility of Eggen's system by ensuring that the most relevant information is presented to users in an orderly and effective manner to augment their conversation.
    • Expectation of Success: A POSA would have a reasonable expectation of success in this combination, as it involved applying the known functionality of a finite state machine for dialog management, as taught by Ross, to the conversational search system of Eggen, representing a predictable integration of existing technologies.

Ground 2: Obviousness over Eggen, Ross, and White - Claims 5, 6, 13, and 14 are obvious over Eggen and Ross in further view of White.

  • Prior Art Relied Upon: Eggen (Application # 2008/0235018), Ross (Patent 7,496,514), and White (Patent 7,072,476).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Eggen and Ross combination to address claims requiring an "earphone configured to transmit the speech of the recall topics." While Eggen and Ross teach audio output via telephones and speakers, White discloses a duplex audio headset with an earphone specifically for use in hands-free communication, including with telephone and voice recognition systems.
    • Motivation to Combine: Petitioner argued a POSA would be motivated to add an earphone, as taught by White, to the base system of Eggen and Ross. This would provide the known benefits of hands-free operation and improved audio clarity in noisy environments, which Eggen's system was designed to accommodate. Using an earphone was a well-known and simple modification for such systems.

Ground 3: Obviousness over Eggen, Ross, and Bodin - Claim 11 is obvious over Eggen and Ross in further view of Bodin.

  • Prior Art Relied Upon: Eggen (Application # 2008/0235018), Ross (Patent 7,496,514), and Bodin (Application # 2007/0276866).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses claim 11, which requires the speech output to conform to an Advanced Audio Codec (AAC) standard. The base combination of Eggen and Ross discloses generating audio output. Bodin explicitly teaches a text-to-speech engine that can create media files using AAC compression.
    • Motivation to Combine: A POSA would combine the teachings of Bodin to make the audio output of the Eggen/Ross system conform to the AAC standard. AAC was a well-known industry standard for audio compression, and using it would ensure compatibility with a wide array of devices and provide an efficient, predictable solution for storing and transmitting audio files.

Ground 4: Obviousness over Eggen, Ross, and Gharachorloo - Claim 17 is obvious over Eggen and Ross in further view of Gharachorloo.

  • Prior Art Relied Upon: Eggen (Application # 2008/0235018), Ross (Patent 7,496,514), and Gharachorloo (Patent 7,467,131).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground addresses method claim 17, which requires a "server located on the world wide web" to perform the search. Eggen teaches using a web search engine like Google, which a POSA would understand operates on servers. Gharachorloo provides an explicit disclosure of an internet search engine system that uses web servers, including cache servers, to perform searches and store results.
    • Motivation to Combine: A POSA would find it obvious to implement the web search function of the Eggen/Ross system using a server architecture as detailed in Gharachorloo. This reflects the standard, necessary infrastructure for any web-based search engine and offers known benefits, such as improved performance through caching, as taught by Gharachorloo.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-19 of the ’348 patent as unpatentable.