PTAB

IPR2022-01594

Sonos Inc v. Google LLC

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1. Case Identification

2. Patent Overview

  • Title: Voice-Activated Device Arbitration
  • Brief Description: The ’128 patent discloses methods and systems for coordinating among multiple voice interface devices in a single environment. The technology aims to select a single "leader" device to respond to a user's voice input to reduce user confusion when multiple devices detect the same command.

3. Grounds for Unpatentability

Ground 1: Anticipation by Rosenberger - Claims 1-3, 5-8, 10-13, and 15 are anticipated by Rosenberger.

  • Prior Art Relied Upon: Rosenberger (Patent 8,340,975).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Rosenberger discloses a system for resolving the "duplicate response" problem where multiple speech recognition devices in a home automation system detect the same voice command. Rosenberger’s "control devices" are equivalent to the ’128 patent’s "electronic devices," each equipped with microphones, speakers, and processors. Upon detecting a voice input, each Rosenberger device calculates a numeric "weighted signal" (WS) based on factors like signal strength and recognition confidence; this WS is the claimed "quality score." The devices then broadcast their WS to other devices on a local network and receive the WS values from others. The device that determines its own WS is the highest proceeds to interact with the user, while the other devices that received a higher WS forgo responding. This maps directly to all limitations of independent claims 1, 6, and 11. Petitioner asserted that Rosenberger also discloses the dependent claim limitations, such as using a local wireless network and basing the quality score on a confidence level.

Ground 2: Obviousness over Rosenberger and Kim - Claims 5, 10, and 15 are obvious over Rosenberger in view of Kim.

  • Prior Art Relied Upon: Rosenberger (Patent 8,340,975) and Kim (Application # 2013/0238326).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Rosenberger teaches all limitations of the independent claims. The challenged dependent claims add a limitation requiring the system to respond to a detected command based on a determination that the type of command is related to the specific electronic device. While Rosenberger suggests this by disclosing devices with different vocabularies (e.g., a light switch dimmer), Kim was argued to explicitly teach this concept. Kim addresses the same multi-device voice control problem and discloses a system where a device identifies an attribute of a voice command and determines if that attribute corresponds to its own functional capabilities. For example, Kim teaches that devices capable of supporting a "volume setting attribute" (like a TV or laptop) will recognize and respond to a volume command, while a device without that capability (like a refrigerator) will not.
    • Motivation to Combine: A POSITA would combine Kim's command-type analysis with Rosenberger's arbitration system to improve the selection of the single best device to respond to a user. Both references are in the same field of endeavor and address the same problem. Incorporating Kim’s teachings would make Rosenberger’s system more intelligent and efficient by allowing a device to respond immediately if a command is uniquely suited to its capabilities (e.g., "play a video" to a smart TV), potentially bypassing Rosenberger's WS comparison process entirely. This would provide a more accurate determination of user intent and reduce unnecessary network traffic and processing.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the systems, as it involved applying Kim's known software-based command attribute analysis to Rosenberger's known voice-enabled hardware.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued that discretionary denial under 35 U.S.C. §314(a) based on Fintiv factors would be inappropriate. The petition was filed expeditiously (less than two months after service of the district court complaint), a mandatory stay of the parallel litigation was expected, and minimal investment had been made in the court case, meaning the Board would likely issue a Final Written Decision (FWD) before a district court trial.
  • Petitioner also argued that denial under 35 U.S.C. §325(d) would be inappropriate because the USPTO committed material error during the prosecution of the ’128 patent. Specifically, the Examiner failed to apply Rosenberger—the primary reference in this petition—despite the same Examiner repeatedly asserting that Rosenberger disclosed the broad subject matter during prosecution of other applications in the same patent family. Petitioner contended the Examiner allowed the claims based on an erroneous assumption that they contained a "low power state" limitation, which is not recited in the claims.

5. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-3, 5-8, 10-13, and 15 of the ’128 patent as unpatentable.