PTAB

IPR2024-00750

Google LLC v. Dialect LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Mobile Systems and Methods For Responding To Natural Language Speech Utterance
  • Brief Description: The ’845 patent describes a system for processing natural language speech commands within a vehicle environment. The system can determine whether to execute a command on-board the vehicle or off-board via a wireless network.

3. Grounds for Unpatentability

Ground 1: Claims 1-3, 7-8, 10, 12, 15, 17-20, 24-25, 27, 29, 32, 34, and 36 are obvious over Coffman in view of Julia and Cooper.

  • Prior Art Relied Upon: Coffman (International Publication No. WO 00/20962), Julia (Patent 7,036,128), and Cooper (Patent 6,757,362).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Coffman disclosed the core inventive concept: a distributed "conversational computing system" with an in-vehicle "central unit," referred to as a Personal Vehicle Assistant (PVA), that acts as a conversational arbitrator. This PVA receives natural language utterances and determines whether to execute corresponding commands on-board the vehicle or on off-board devices (like a desktop PC). Coffman’s system was designed to parse and interpret speech, determine context and domain, formulate commands, and dispatch them to the appropriate on-board or off-board device. Petitioner contended that Coffman’s PVA inherently performs the central claimed step of "determining whether the command or query is to be executed on-board or off-board the vehicle."
    • While Coffman described this framework and mentioned applications like navigation and email, it did not provide specific examples of natural language commands for them. Petitioner asserted that Julia and Cooper supply these missing, obvious details. Julia explicitly taught an in-vehicle system that receives natural language commands (e.g., "I want to go to SRI...") for an on-board navigation application. Cooper taught a remote-access system that receives natural language commands (e.g., "read my e-mail messages from John Smith") to interact with an off-board email application. Petitioner argued these references merely filled in conventional details for the types of applications Coffman’s system was designed to control.
    • Dependent claims were addressed as reciting routine features. For example, executing a command on a "built into the vehicle" device (claim 2) was taught by Coffman's description of a "conversational car PC." Executing an on-board search query related to an aspect of the vehicle (claim 8) was taught by Coffman and Julia’s navigation examples.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would have been motivated to combine the references to implement the specific applications Coffman’s general framework described. Since Coffman taught a system for controlling both on-board and off-board applications via voice, a POSITA would naturally look to prior art like Julia (for on-board navigation) and Cooper (for off-board email) to provide the specific, well-known command functionalities. All three references are in the analogous field of speech-enabled interfaces for vehicle or mobile environments and address the same problems. Julia and Cooper simply provided beneficial detail for implementing applications Coffman already contemplated.
    • Expectation of Success: A POSITA would have had a high expectation of success in combining the teachings. The combination involved applying known voice-command techniques (from Julia and Cooper) to a system expressly designed to accommodate them (Coffman), which would have yielded predictable results without undue experimentation.

4. Arguments Regarding Discretionary Denial

  • §314(a) (Fintiv): Petitioner argued that discretionary denial would be inappropriate because the co-pending district court litigation is in its early stages. Petitioner stated that no discovery or claim construction had occurred, no trial date was set, and the case was recently transferred. If the inter partes review (IPR) is instituted, Petitioner intends to file a motion to stay the litigation.
  • §325(d): Petitioner contended that the Examiner materially erred during the original prosecution by failing to reject the claims over Coffman. Although a U.S. counterpart to Coffman was before the Examiner, Petitioner argued the Examiner did not fully appreciate its teachings regarding a central, in-vehicle unit determining where to execute commands. Petitioner asserted that the Examiner mistakenly agreed with the applicant that Coffman did not teach performing the "determining" step at a vehicle, a misreading of Coffman’s disclosure of an in-vehicle PVA acting as the system’s central arbitrator for both on-board and off-board devices.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 1-3, 7-8, 10, 12, 15, 17-20, 24-25, 27, 29, 32, 34, and 36 of the ’845 patent as unpatentable.