PTAB

IPR2025-00868

Samsung Electronics Co Ltd v. VB Assets LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Method and System for Providing a Voice Interface
  • Brief Description: The ’765 patent discloses a voice interface system using a "cooperative conversational model." The system determines a "conversation type" (Query, Didactic, or Exploratory) based on the user's role (leader or supporter) in the dialogue and generates responses adapted to that conversation type.

3. Grounds for Unpatentability

Ground 1: Obviousness over Smith & Hipp and Guinn - Claims 1-14 are obvious over Smith & Hipp in view of Guinn.

  • Prior Art Relied Upon: Smith & Hipp (R.W. Smith, et al., “An Architecture for Voice Dialog Systems Based on Prolog-Style Theorem Proving” (1995)) and Guinn (Curry I. Guinn, “Mechanisms for Mixed-Initiative Human-Computer Collaborative Discourse” (1996)).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Smith & Hipp taught a sophisticated voice dialog system that operated using four distinct "initiative modes" which directly correspond to the ’765 patent's claimed "conversation types." Specifically, Smith & Hipp’s "passive" mode (user-led) maps to the claimed "query" conversation; its "directive" mode (computer-led) maps to the "didactic" conversation; and its "suggestive" and "declarative" modes (mixed-initiative) map to the "exploratory" conversation. Smith & Hipp’s system determined the appropriate mode based on which participant, the user or the computer, had control of the dialogue, thereby teaching the core limitation of determining conversation type based on the user's "leader" or "supporter" role. However, Smith & Hipp expressly identified that its system lacked an automatic mechanism for switching between these modes during a conversation, calling it an "important unsolved problem." Petitioner contended that Guinn solved this exact problem by disclosing algorithms for "automatic dialogue initiative setting." Guinn’s method assigned initiative to the "more knowledgeable agent," thereby providing the mechanism to automatically determine and shift between the dialogue modes taught by Smith & Hipp based on the relative knowledge of the user and the system.
    • Motivation to Combine: Petitioner asserted that a Person of Ordinary Skill in the Art (POSITA) would combine these references for two primary reasons. First, Smith & Hipp explicitly motivated the combination by identifying the need for an "automatic mechanism ... for setting the appropriate level of initiative as an interaction proceeds." A POSITA would have looked to the field for a solution and found Guinn. Second, Guinn directly recognized this need in Smith & Hipp's work, stating that "Smith presents no algorithm for the computer to change initiative during a dialogue." Guinn’s work was thus presented as a direct solution to the problem identified in Smith & Hipp.
    • Expectation of Success: Petitioner argued a POSITA would have had a reasonable expectation of success because Guinn’s research was expressly intended to improve systems like the one described in Smith & Hipp. The combination involved applying Guinn’s known initiative-switching algorithm to Smith & Hipp’s established dialog system to achieve the predictable result of automated, dynamic dialogue control.

4. Arguments Regarding Discretionary Denial

  • To simplify the Fintiv analysis for potential discretionary denial under §314(a), Petitioner stipulated that if the IPR is instituted, it will not pursue in the related district court proceeding any invalidity ground that was raised or reasonably could have been raised in the IPR. Petitioner noted this stipulation follows the Board’s precedential decision in Sotera Wireless, Inc. v. Masimo Corp.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of the ’765 patent as unpatentable.