Amazon.com Services LLC v. VB Assets LLC

1. Case Identification

• Case #: IPR2025-01167
• Patent #: 11,087,385
• Filed: June 16, 2025
• Petitioner(s): Amazon.com, Services LLC
• Patent Owner(s): VB Assets, LLC
• Challenged Claims: 1-40

2. Patent Overview

• Title: Voice Commerce Method and System
• Brief Description: The ’385 patent describes technology for facilitating voice commerce. The system processes a user's natural language utterance to identify a product or service, selects an item for purchase, and completes the transaction upon receiving a voice confirmation from the user.

3. Grounds for Unpatentability

Ground 1: Obviousness over Li - Claims 1, 3-8, 10-16, 18-23, 25-38

• Prior Art Relied Upon: Li (Application # 2012/0284105).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Li discloses all limitations of the challenged claims. Li describes a “Data Processing System” that provides voice commerce by receiving a “single first user input” in the form of a “speech utterance” (e.g., “Buy XYZ”). This utterance is provided to a “Speech Recognition Module” that functions as the claimed speech recognition engine to recognize words or phrases. Based on these phrases, Li’s system searches databases for an “Object of Interest,” selects a retailer offering the object, and presents this information to the user—all without further user input. Li then receives a “second user input” when the user confirms the purchase (e.g., by saying or clicking “Buy”), which completes the transaction “without further user input after the receipt of the second user input.” Li also expressly teaches obtaining stored payment and shipping information to complete the purchase without user confirmation of that specific information, satisfying various dependent claims.

Ground 2: Obviousness over Chen in view of Barnes - Claims 1, 3-11, 14-16, 18-26, 29-38

• Prior Art Relied Upon: Chen (Patent 9,922,364), Barnes (Application # 2012/0096358).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner asserted that Chen’s “hybrid response system” (HRS) provides the basic framework for the invention. Chen’s HRS receives a voice request (e.g., “Buy Brand X basketball shoes for me”), uses a transcription module to convert speech to text, identifies a target product, prompts the user for confirmation (“Speak ‘buy’ to purchase”), and completes the order using stored user account information. To the extent Chen does not explicitly disclose searching multiple databases of different vendors, Petitioner contended Barnes supplies this teaching. Barnes discloses a “Multi-Vender Search” system that processes voice input to identify a product and then searches data from multiple vendors in local memory, a remote computer, or a service registry to find available sellers and compare prices.
  • Motivation to Combine: A person of ordinary skill in the art (POSITA) would combine Chen and Barnes to improve the functionality of Chen’s voice commerce system. Incorporating Barnes’s multi-vendor search capability would allow Chen’s HRS to query multiple retailers, compare offerings and prices, and present the user with more comprehensive and relevant results, which was a well-known goal in e-commerce.
  • Expectation of Success: A POSITA would have had a reasonable expectation of success, as the combination involves applying a known technique (Barnes’s multi-vendor search) to an existing system (Chen’s voice purchasing system) to achieve the predictable result of an improved, more flexible commerce experience.

Ground 3: Obviousness over Li in view of Kennewick - Claims 2, 17

• Prior Art Relied Upon: Li (Application # 2012/0284105), Kennewick (Application # 2004/0193420).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground targets claims 2 and 17, which add the limitation of selecting a product based on a determined “context.” Petitioner argued that Li inherently discloses determining a context by classifying a user request (e.g., as an “immediate single purchase” versus a “contingent single purchase”) and performing different actions accordingly. To the extent Li’s disclosure was insufficient, Kennewick was introduced for its explicit teaching of determining an utterance’s “context or domain.” Kennewick’s speech interface analyzes recognized words by applying “prior probabilities or fuzzy possibilities” and considering user profile data and dialog history to determine the context.
  • Motivation to Combine: A POSITA would be motivated to incorporate Kennewick’s more advanced context determination methods into Li’s system. Doing so would improve the accuracy and robustness of Li's request classification, making the system less prone to failure and better able to handle a wider variety of user utterances and product domains (e.g., fast food vs. travel services, as taught by Kennewick).
  • Expectation of Success: Success would be expected because this combination involves substituting a known, more sophisticated technique (Kennewick's probabilistic context determination) for a simpler one (Li’s rule-based classification) to achieve the predictable benefit of a more robust and accurate speech recognition system.

• Additional Grounds: Petitioner asserted additional obviousness challenges based on other combinations, including Li with Chen or Lee; Chen and Barnes with Kennewick, Li, or Lee. These grounds relied on similar theories of combining known elements from speech-based interfaces and e-commerce systems to add features like user-preferred seller lists, enhanced context determination, and more detailed confirmation prompts.

4. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-40 of Patent 11,087,385 as unpatentable.