Harman Intl Industries Inc v. St CasesTech LLC

1. Case Identification

• Case #: IPR2024-01300
• Patent #: 11,589,329
• Filed: August 30, 2024
• Petitioner(s): Harman International Industries, Inc.
• Patent Owner(s): ST CasesTech, LLC
• Challenged Claims: 1-11

2. Patent Overview

• Title: System of Communicating Acoustic Devices
• Brief Description: The ’329 patent relates to a system of acoustic devices that communicate information with one another. One device assumes a controller role to select a subset of devices, receive acoustic data from them, and perform speech detection on the collected data.

3. Grounds for Unpatentability

Ground 1: Obviousness over Denny - Claims 1, 5, and 7-9 are asserted to be obvious over Denny.

• Prior Art Relied Upon: Denny (Patent 7,570,158).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Denny discloses an incident reporting system comprising multiple "remote sensing units" (RSUs), which are analogous to the claimed "acoustic devices." Each RSU can broadcast its location, allowing a designated controller RSU (e.g., RSU 316) to identify and select a subset of other RSUs in the vicinity of a detected incident. The controller then collects sensor data, including audio data, from this subset. Petitioner contended that Denny’s step of performing a "second analysis" on this aggregated data to confirm the incident, which can include detecting "fearful screaming," directly teaches the claimed analysis of acoustic data to identify if speech is present. The system also selects devices based on proximity to the incident (claim 5) and generates an alert by notifying emergency services (claim 7).
  • Motivation to Combine (for §103 grounds): Not applicable, as Petitioner asserted Denny alone teaches all limitations.
  • Expectation of Success (for §103 grounds): Not applicable.

Ground 2: Obviousness over Denny and Hirata - Claims 1-9 are asserted to be obvious over Denny in view of Hirata.

• Prior Art Relied Upon: Denny (Patent 7,570,158) and Hirata (Application # 2008/0132199).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Denny teaches the core system architecture, and to the extent additional disclosure for identifying speech is required, Hirata explicitly provides it. Hirata discloses portable radio devices that use a "sound processing section" to perform speech recognition on captured audio. This process analyzes uttered words like "help me" to judge whether an emergency notification is necessary. The combination thus clearly teaches analyzing acoustic data to identify if speech is present (claim 1) and analyzing for a specific keyword (claim 2).
  • Motivation to Combine (for §103 grounds): A POSITA would combine Hirata's known keyword detection technique with Denny's incident reporting system to improve incident detection accuracy. This modification would enable the system to differentiate between general sounds and specific spoken words associated with an emergency, leading to fewer false positives and a more reliable response.
  • Expectation of Success (for §103 grounds): Success would be highly predictable. Both references are in the field of acoustic incident reporting, and implementing Hirata’s software-based speech recognition on Denny’s processor-based system was a straightforward and well-understood application of known technologies.

Ground 3: Obviousness over Denny and Byers - Claims 1-11 are asserted to be obvious over Denny in view of Byers.

• Prior Art Relied Upon: Denny (Patent 7,570,158) and Byers (Patent 6,219,645).

• Core Argument for this Ground:

  • Prior Art Mapping: As an alternative to Hirata, Petitioner argued that Byers teaches the speech recognition limitations. Byers discloses a system where multiple microphones relay voice commands to an automatic speech recognition (ASR) controller for analysis against a vocabulary table. Critically for claims 10 and 11, Byers also teaches determining which device is closest to a user by detecting the first arrival of a sound pressure wave and using triangulation. After identifying the closest device and a valid command, a control command can be sent to that device.
  • Motivation to Combine (for §103 grounds): A POSITA would combine Byers’ teachings with Denny’s system to enhance it, particularly for dispatching emergency services with greater precision. By using Byers' method to pinpoint the closest RSU to a user uttering a keyword, the system could direct emergency responders to a more accurate location or instruct the closest device to execute a voice command (e.g., "call 911"), improving response effectiveness.
  • Expectation of Success (for §103 grounds): The combination involved applying known techniques for their intended purposes and would have yielded predictable results. Integrating Byers' location and command-and-control logic into Denny's distributed network was a routine design choice for a POSITA seeking to improve such a system.

• Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations further in view of Green (Application # 2007/0038395) for teaching the determination of a sound's direction of measurement (claim 4), and Murata (Japanese Application # 2004/212544) for explicitly teaching the analysis of animal sounds (claim 8).

4. Arguments Regarding Discretionary Denial

• Petitioner argued that discretionary denial under 35 U.S.C. §325(d) is unwarranted because the primary prior art references (Denny, Hirata, Byers, Green, Murata) are not the same as, and are not substantially similar to, the art considered by the Examiner during the patent's prosecution, which resulted in a first-action allowance with no rejections.
• Petitioner further argued that discretionary denial under §314(a) based on Fintiv factors would be inappropriate. The co-pending district court litigation in Delaware was filed in July 2023, has no trial date or substantive schedule set, and the median time to trial of 33 months in that venue places the likely trial date well after the statutory deadline for a Final Written Decision in this inter partes review (IPR).

5. Relief Requested

• Petitioner requests institution of an IPR and cancellation of claims 1-11 of the ’329 patent as unpatentable.