PTAB

IPR2025-00673

Amazon.com Inc v. SoundClear Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Output-Content Control Device
  • Brief Description: The ’675 patent describes an electronic device, such as a smart speaker, that analyzes a user's voice input. The device uses a proximity sensor to calculate the distance to the user, classifies the voice based on this distance, and generates a tailored voice response, which may involve replacing words in the output sentence.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Shin and Aoyama - Claims 1-7 are obvious over Shin in view of Aoyama.

  • Prior Art Relied Upon: Shin (Application # 2017/0083281) and Aoyama (Application # 2017/0337921).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Shin, an application from Samsung, discloses the core limitations of claim 1, including a device that computes the distance to a user and tailors the output content based on that distance. For example, Shin taught providing "detailed content" for users within one meter and "abbreviated content" for users farther away, thereby teaching the classification of voice into a "first voice" (far) and "second voice" (near) to generate different outputs. However, Shin's method of abbreviation was not explicitly word replacement. Petitioner asserted that Aoyama, an application from Sony, remedied this by teaching a system that customizes voice output by replacing words based on the user or situation, such as replacing a formal name ("Taro Yamada") with an honorific ("Mr. Yamada") or replacing complex date formats with simpler terms ("tomorrow"). Aoyama's teachings on replacing words based on context and user data were argued to supply the word replacement limitation of claim 1[f].
    • Motivation to Combine: A POSITA would combine Shin and Aoyama to improve Shin's distance-based content tailoring system. Aoyama's word replacement feature directly served Shin's goal of simplifying output for users at greater distances, making information easier to grasp. A POSITA would have seen it as a predictable and logical step to incorporate Aoyama's known word-replacement techniques into Shin's system to provide more nuanced, user-friendly, and private (by replacing personal information) abbreviated content for distant users.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because the combination involved applying a known technique (Aoyama's word replacement) to a similar device (Shin's voice assistant) to achieve a predictable result (simplified output for distant users).

Ground 2A: Obviousness over Shimomura and Aoyama - Claims 1-7 are obvious over Shimomura in view of Aoyama.

  • Prior Art Relied Upon: Shimomura (Japanese Application Publication # 2005/202076) and Aoyama (Application # 2017/0337921).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Shimomura, like Shin, taught the core concept of tailoring voice output based on user distance. Shimomura disclosed a robot that detected the distance to a "conversation partner" and classified speech into two categories (e.g., greater or less than 350 cm). For users farther away (the "first voice"), the device transformed the output by inserting words like the Japanese conversational particle "ne" after phrases to improve clarity and comprehension. For closer users (the "second voice"), it provided the original, untransformed content. Petitioner contended this taught the distance calculation, voice classification, and generation of different first and second output sentences. The argument for combining with Aoyama was identical to Ground 1A: Aoyama's teachings on replacing names and other words would be used to supply the specific word replacement limitation required by the claims.
    • Motivation to Combine: The motivation was similar to that in Ground 1A. A POSITA would combine Shimomura's distance-based output adjustment with Aoyama's word replacement feature to further Shimomura's stated goal of enhancing clarity for distant users. Replacing formal, harder-to-understand names with simpler, informal ones, as taught by Aoyama, was presented as a direct and obvious way to improve upon Shimomura's method of adding conversational particles.
    • Expectation of Success: Success was expected because it involved the simple addition of a known element (Aoyama's word replacement) to another known system (Shimomura's distance-based content adjustment) to achieve the predictable result of easier-to-understand output for users at greater distances.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Shin and Iwase (Patent 11,183,167) and Shimomura and Iwase, where Iwase was used as an alternative to Aoyama for teaching word replacement to enhance comprehension. Further grounds added Schuster (Patent 9,680,983) for whisper detection (claim 5) and Kristjansson (Patent 10,147,439) for natural language understanding components.

4. Arguments Regarding Discretionary Denial

  • §314(a) (Fintiv Factors): Petitioner argued against discretionary denial by providing a Sotera stipulation, promising not to pursue the same grounds or any that could have been reasonably raised in the IPR in the parallel district court litigation. Petitioner also argued that the petition presents compelling evidence of unpatentability and that the district court case is in its early stages with no trial date set.
  • §325(d) (Advanced Bionics Factors): Petitioner argued that denial under §325(d) would be inappropriate because the primary prior art references asserted in the petition (including Shin, Shimomura, Iwase, and Kristjansson) were never before the Examiner during prosecution. Therefore, the Examiner did not consider the core arguments and combinations presented in the petition.

5. Relief Requested

  • Petitioner requests institution of inter partes review and cancellation of claims 1-7 of Patent 11,244,675 as unpatentable under 35 U.S.C. §103.