PTAB

IPR2025-01080

Amazon.com Inc v. SoundClear Technologies LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Volume Control in Audio Devices
  • Brief Description: The ’819 patent discloses systems and methods for controlling audio output by locking the volume. The purported novelty is preventing a device from unlocking while its volume control is set to an undesirably high level, thereby avoiding sudden loud audio output.

3. Grounds for Unpatentability

Ground 1A: Claims 1-2, 4-5, and 7-8 are obvious over Kajiyama

  • Prior Art Relied Upon: Kajiyama (Japanese Patent App. Publ. No. JP2012182639A).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Kajiyama, which discloses an audio output device with volume locking functionality, teaches nearly every limitation of the challenged claims. Kajiyama’s device has a locked state where volume is fixed and an unlocked state where it can be varied. To unlock, a user must press buttons and adjust the volume knob to "match" the previously locked volume level. Petitioner contended this "matching" requirement meets the claim limitation of the operating value falling "within a predetermined range based on the lock value," as an exact match is simply a range with identical upper and lower bounds.
    • Motivation to Combine (for §103 grounds): As a single-reference ground, the motivation focused on modifying Kajiyama’s "matching" feature. Petitioner asserted a person of ordinary skill in the art (POSITA) would have found it obvious to implement Kajiyama's matching by comparing the volume knob’s value to a range of values around the lock value, rather than requiring a precise match. This was presented as one of a few, predictable design choices. The motivation was to improve user experience by allowing for minor tolerance, making the device easier to unlock, and to account for hardware imprecision, all while achieving the same goal of preventing unintentional volume changes.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because modifying the control logic to check if a value is within a numerical range instead of an exact match was a trivial software or hardware modification.

Ground 1C: Claim 3 is obvious over Ground 1A or 1B and Shure

  • Prior Art Relied Upon: Kajiyama, Nelson (Patent 8,843,222), and Shure (SHURE ULX WIRELESS SYSTEM USER GUIDE).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the combination of Kajiyama and optionally Nelson to address dependent claim 3, which adds the limitation of displaying information indicating the locked state. While Kajiyama’s system remains locked until the volume is matched, it does not explicitly disclose a visual indicator for this status. Shure’s audio receiver user guide explicitly teaches a "volume lock indicator" that appears when the volume is locked and a "Volume Level warning indicator" that flashes if the volume knob is set higher than the locked level.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Shure's teachings with Kajiyama’s device to provide beneficial user feedback. Petitioner argued that since Kajiyama’s device could remain locked even after an unlock operation was initiated, a user would need to know the device's status. Adding a simple, conventional status indicator like the one in Shure was a predictable design choice to improve the device's usability.
    • Expectation of Success: Success was expected because adding status indicators like LEDs or icons to a user interface was a routine and well-understood practice in electronic device design.

Ground 2A: Claims 1-5 and 7-8 are obvious over Shure and Nelson

  • Prior Art Relied Upon: Shure (SHURE ULX WIRELESS SYSTEM USER GUIDE) and Nelson (Patent 8,843,222).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Shure discloses a wireless audio receiver with all the core features of claim 1, including locking the output level to prevent accidental changes. To unlock Shure, a user must perform a complex button-and-knob sequence and rotate the volume knob down until a warning indicator stops flashing. Petitioner argued this implies an unlocking condition based on the volume level being at or below the locked level, which a POSITA would obviously implement as a "predetermined range." Nelson was introduced to supply a simpler "predetermined operating part" (a sliding switch) for locking and unlocking, which was more user-friendly than Shure’s complex sequence.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the references to improve the usability of Shure’s device. Shure's lock/unlock process was complex, and a POSITA would have looked to known, simpler mechanisms like the sliding switch disclosed in Nelson to create a more intuitive user experience. This represents the simple substitution of one known locking mechanism for another to achieve a predictable improvement.
    • Expectation of Success: A POSITA would have expected success because implementing a simple mechanical switch for a locking function, as taught by Nelson, was a well-understood and common practice in electronic devices.

  • Additional Grounds: Petitioner asserted Ground 1B (Kajiyama in view of Nelson), arguing Nelson’s simple sliding switch was an obvious replacement for Kajiyama’s button-press lock mechanism. Petitioner also asserted Ground 2B (Shure, Nelson, and Kajiyama), arguing Kajiyama’s specific method of unlocking (matching the current volume to the locked volume) was an obvious way to implement Shure’s more general disclosure of requiring the volume to be turned down to unlock.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-5 and 7-8 of Patent 9,804,819 as unpatentable.