PTAB

IPR2024-01300

HARMAN INTERNATIONAL INDUSTRIES, INC. v. ST CasesTech, LLC

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1. Case Identification

2. Patent Overview

  • Title: System of Acoustic Devices with Distributed Control
  • Brief Description: The ’329 patent is directed to a system of networked acoustic devices where one device can assume the role of a controller. This controller selects a subset of the devices, gathers acoustic sensor data from them, and analyzes the combined data to detect the presence of speech.

3. Grounds for Unpatentability

Ground 1: Obviousness over Denny - Claims 1, 5, and 7-9 are 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 all elements of the challenged claims. Denny teaches an incident reporting system with multiple "remote sensing units" (RSUs) that function as the claimed "acoustic devices." In Denny, upon detecting an incident like a car accident, one RSU acts as a controller, identifies other nearby RSUs, collects their sensor data (including audio data from an "audio recorder"), and performs a "second analysis" on the aggregated data to confirm the incident. Petitioner contended that Denny's disclosure of analyzing for "fearful screaming" is a form of speech detection, thus meeting the limitation of analyzing data "to identify if speech is present."
    • Motivation to Combine (for §103 grounds): Although presented as anticipation and obviousness, the argument for obviousness relied on a person of ordinary skill in the art (POSITA) understanding that "fearful screaming" inherently includes "speech" (e.g., a scream of "help me"). A POSITA would have recognized the benefit of analyzing the content of the scream to improve the reliability of incident detection, as a generic scream could be unrelated to an actual accident.
    • Expectation of Success: A POSITA would have had a high expectation of success in configuring Denny's system to specifically identify speech within audio data, as this was a known and routine signal processing task.

Ground 2: Obviousness over Denny in view of Hirata - Claims 1-9 are 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: This ground built upon the Denny reference by adding Hirata to more explicitly teach the speech analysis limitation. Petitioner argued that Denny discloses the core system of a controller device gathering data from a subset of acoustic devices. Hirata was cited for its teaching of a portable device that uses speech recognition on uttered words (e.g., "help me") to determine if an emergency notification is necessary. The combination, therefore, taught analyzing the acoustic data gathered by the Denny system using the specific keyword recognition technique from Hirata. This combination was argued to render claims 1-9, which relate to keyword analysis and triggering events, obvious.
    • Motivation to Combine: A POSITA would combine Denny and Hirata to improve the accuracy of Denny's incident reporting system. While Denny detected generic "fearful screaming," applying Hirata's specific keyword detection would allow the system to more accurately distinguish between an actual emergency requiring a response (e.g., a person yelling "help me") and other non-emergency sounds, thereby improving system reliability.
    • Expectation of Success: Success was predictable because it involved applying a known speech recognition technique (from Hirata) to a known incident reporting system (from Denny) to achieve the predictable benefit of improved accuracy.

Ground 3: Obviousness over Denny in view of Byers - Claims 1-11 are 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: Similar to the previous ground, this combination used Byers to supply the explicit teaching of keyword-based speech recognition. Critically, Byers also disclosed determining which of a set of microphones is the closest to a user by analyzing the arrival time of a sound pressure wave. Petitioner argued this teaching, when combined with Denny's system, rendered obvious dependent claims 10 and 11, which require determining the closest acoustic device to a user who uttered a keyword and sending a voice command to it.
    • Motivation to Combine: A POSITA would combine these references to enhance Denny's system not only with keyword detection but also with precise user localization. This would improve the dispatch of emergency services by pinpointing the closest RSU to the user needing help, ensuring a more accurate response. For example, the controller could instruct the closest RSU to call 911, rather than a more distant one.
    • Expectation of Success: Petitioner asserted a high expectation of success, as it involved integrating known functionalities (Denny's network, Byers' keyword recognition and user localization) to achieve the predictable result of a more accurate and responsive emergency system.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including adding Green (Application # 2007/0038395) to the primary combinations to teach determining a direction of measurement for claim 4, and adding Murata (Japanese Publication No. 2004/212544) to teach analyzing for animal sounds for claim 8.

4. Arguments Regarding Discretionary Denial

  • §325(d) (Same or Substantially Same Art/Arguments): Petitioner argued against discretionary denial under §325(d), stating that the primary references (Denny, Hirata, Byers, Green, Murata) were never considered during the original prosecution of the ’329 patent. Because the prosecution record contains no substantive rejections and only a first-action allowance with unclear reasoning, the newly presented art and arguments were argued to be neither the same nor cumulative.
  • §314(a) (Fintiv Factors): Petitioner contended that discretionary denial under the Fintiv factors would be inappropriate. It was noted that the co-pending district court case in Delaware, filed in July 2023, had no trial date or substantive schedule set. Given the median 33-month time to trial in that venue, a trial would likely occur after the statutory deadline for a Final Written Decision (FWD) in this IPR, making the IPR a more efficient forum for resolving the patentability issues.

5. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-11 of Patent 11,589,329 as unpatentable under 35 U.S.C. §§102/103.