PTAB

IPR2025-00869

Samsung Electronics Co Ltd v. VB Assets LLC

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Selecting and Presenting Promotional Content
  • Brief Description: The ’536 patent discloses a system for selecting and presenting advertisements based on the natural language processing of voice-based input. The system uses multiple domain agents to competitively generate context-based interpretations of a user's spoken utterance to perform tasks and provide relevant promotional content.

3. Grounds for Unpatentability

Ground 1: Claims 1-12, 16-23, 30, 32, and 50-55 are obvious over O'Neill in view of Jones.

  • Prior Art Relied Upon: O’Neill (Application # 2005/0278180) and Jones (Application # 2007/0174258).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that O’Neill discloses an automatic, interactive dialogue system that uses multiple domain-specific "agents" to process user requests within defined transactional areas (e.g., booking a hotel). Jones was argued to teach a system for providing targeted advertising to mobile devices using voice recognition. It discloses identifying keywords, looking up corresponding advertisements, using context to interpret requests, and tracking user engagement. The combination of O'Neill's dialogue management and agent-based interpretation with Jones's targeted advertising framework was asserted to teach the limitations of the independent claims, including receiving utterances, providing responses, and presenting promotional content based on an interpretation of the user's speech.
    • Motivation to Combine: A POSITA would combine these references to monetize O’Neill’s interactive dialogue system using the known technique of targeted advertising taught by Jones. Petitioner asserted that both references operate in the same field of voice-controlled information systems, are designed to assist users with requests via ASR, and explicitly suggest their systems are compatible with other speech processing technologies. Adding Jones’s advertising capabilities to O’Neill’s system, which already included payment processing, was presented as a logical and predictable improvement.
    • Expectation of Success: Petitioner contended a POSITA would have a reasonable expectation of success, as the combination involves integrating a known advertising component (Jones) into a known dialogue system (O’Neill) that operates in the same manner.

Ground 2: Claims 13-15, 24, and 33-38 are obvious over O'Neill and Jones in view of Franco.

  • Prior Art Relied Upon: O’Neill (’180 application), Jones (’258 application), and Franco (Application # 2010/0125458).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the O'Neill and Jones combination by adding Franco, which teaches methods for correcting errors in speech recognition. Franco describes combining acoustic evidence from an initial, misrecognized utterance with a subsequent, repeated utterance to generate a more accurate "reinterpretation." Petitioner argued this combination teaches claim limitations requiring the reinterpretation of a second natural language utterance based on a third utterance, a feature not explicitly provided by O'Neill and Jones alone.
    • Motivation to Combine: A POSITA would combine Franco with the O'Neill/Jones system to improve its accuracy, a common goal in the field of speech recognition. Petitioner noted that Franco itself states a "need in the art" for better error correction, suggesting its teachings are broadly applicable. Further, O'Neill is open to "modifications and variation," which would motivate a POSITA to incorporate an improvement like Franco's error correction technique.
    • Expectation of Success: The combination was argued to be predictable because Franco’s error correction module is disclosed as a subsystem that can be coupled to a processor via a communication channel, such as the telephone system in which the O'Neill and Jones systems operate.

Ground 3: Claims 25-26, 31, and 39-43 are obvious over O'Neill and Jones in view of Wang.

  • Prior Art Relied Upon: O’Neill (’180 application), Jones (’258 application), and Wang (Patent 7,609,829).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground adds Wang to the primary combination to address claims involving multiple distinct requests within a single utterance. Wang discloses a voice application system with "multi-slot capability," allowing it to process multiple requests in parallel from one user utterance (e.g., "send me one of each CD, and tell me the return policy"). Petitioner asserted that Wang teaches processing a first request associated with a first application (e.g., a commerce application) and a second request associated with a different, second application (e.g., a database application) from a single dialogue turn.
    • Motivation to Combine: A POSITA would be motivated to incorporate Wang's multi-request functionality to enhance the efficiency of the O'Neill/Jones system, reducing the number of user-system interactions required to complete tasks. Wang expressly touts this efficiency as a key benefit over prior art systems, providing a clear reason for its adoption.
    • Expectation of Success: Petitioner argued for a high expectation of success because Wang’s features are designed for voice applications served over a communication network, making them directly compatible with the phone-based systems of O'Neill and Jones.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 4) for claims 27-29 and 44-49 based on O’Neill, Jones, and Howard (Patent 6,513,006). Howard was used to teach a natural language system that processes requests across multiple, independent devices on a network (e.g., a refrigerator and a printer), thereby addressing claims requiring requests to be processed by different devices.

4. Key Claim Construction Positions

  • Petitioner stated that while the Board need not expressly construe any term, the challenged claims are unpatentable under the constructions from a related district court litigation (VB Assets, LLC v. Amazon.com Servs. LLC). Key constructions relied upon include:
  • "domain agent": "software with domain-specific behavior and information."
  • "speech recognition": "software or hardware that recognizes the words or phrases in the natural language utterance."

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-55 of the ’536 patent as unpatentable.