Microsoft Corp v. Dialect LLC

1. Case Identification

• Case #: IPR2025-01193
• Patent #: 7,917,367
• Filed: July 21, 2025
• Petitioner(s): Microsoft Corporation
• Patent Owner(s): Dialect, LLC
• Challenged Claims: 11-12, 15, 17-18

2. Patent Overview

• Title: Systems and Methods for Responding to Natural Language Speech Utterance
• Brief Description: The ’367 patent discloses a system for synchronizing "context" across multiple mobile devices. The system uses a central "context manager" with which devices register and subscribe to context events, allowing a context change on one device to be communicated to all other registered devices.

3. Grounds for Unpatentability

Ground 1: Claims 11-12 and 15 are obvious over Belfiore.

• Prior Art Relied Upon: Belfiore (Application # 2002/0059425).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Belfiore taught every element of claims 11, 12, and 15. Belfiore’s distributed computing "platform" was asserted to be the claimed "context manager" because it manages user context (e.g., session status) across devices. The process of authenticating devices in Belfiore was argued to meet the "registering" limitation. Belfiore’s system used an "event component" to which devices subscribe to receive notifications, which Petitioner mapped to the claimed steps of subscribing to, receiving, and being informed of "context change events" to synchronize context across devices. For claim 15, Petitioner argued that removing a device from registration was obvious, as Belfiore described terminating relationships between entities and its directory, and state-of-the-art systems commonly deregistered devices upon logout or via timed leases.
  • Motivation to Combine (for §103 grounds): This ground relied on a single reference. Petitioner argued that a person of ordinary skill in the art (POSITA) would have found it obvious to implement Belfiore’s authentication process as a formal "registration" process, as device registration was a well-known, state-of-the-art technique for managing networked mobile devices. This would have been a predictable solution to facilitate the secure synchronization of user data that Belfiore explicitly taught.
  • Expectation of Success: A POSITA would have a high expectation of success in implementing registration in Belfiore's system because it was a conventional technique, and Belfiore already disclosed the necessary directory and security components for managing device information.

Ground 2: Claims 11-12, 15, 17, and 18 are obvious over Kennewick in view of Belfiore.

• Prior Art Relied Upon: Kennewick (Application # 2004/0044516) and Belfiore (Application # 2002/0059425).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner contended that Kennewick disclosed a natural language processing system that synchronized user "history and profile information" across multiple devices, but lacked specific implementation details. Belfiore supplied these details, teaching an event-based subscription model for synchronizing context. For the system claims (11-12, 15), the combined teachings were argued to meet the limitations for the same reasons as in Ground 1. For method claims 17-18, Petitioner asserted that Kennewick’s "parser" performed the functions of the claimed "knowledge-enhanced speech recognition engine." Kennewick’s parser determined the "context" of an utterance by using dialog history, user profiles, and a "context stack" to identify matching contexts, score them, and select the most likely one, mapping directly to the limitations of claim 17.
  • Motivation to Combine: A POSITA seeking to implement the general device synchronization taught by Kennewick would combine its teachings with Belfiore. Belfiore provided a specific and advantageous mechanism—device authentication and event-based subscriptions—to achieve the synchronization Kennewick described. This combination would predictably result in a robust system that allowed users to switch devices mid-session while maintaining consistent state and context, a benefit taught by Belfiore.
  • Expectation of Success: Success was expected because both references described distributed natural language processing systems, and incorporating Belfiore's event-based synchronization into Kennewick's architecture would involve conventional software modifications.

Ground 3: Claims 17 and 18 are obvious over Kennewick, Belfiore, and Ross.

• Prior Art Relied Upon: Kennewick (Application # 2004/0044516), Belfiore (Application # 2002/0059425), and Ross (Application # 2002/0133354).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground was presented to preempt any argument that Kennewick did not teach verbatim matching of text combinations against grammar entries, as recited in claim 17. Petitioner argued that Ross explicitly taught this concept. Ross described a context manager that compared a transcribed utterance against grammars associated with different application contexts. Ross provided examples of verbatim matching, such as matching the utterance "print it" against grammar rules in both an email and a calendar application to determine the correct context.
  • Motivation to Combine: A POSITA implementing the Kennewick-Belfiore system would combine its teachings with Ross to incorporate a more detailed and explicit method for grammar-based context matching. Because Kennewick taught a similar matching concept generally, a POSITA would naturally turn to a reference like Ross, which described a highly similar technique in greater detail, to implement that functionality.
  • Expectation of Success: A POSITA would expect success because Ross merely provided a more detailed implementation of a "comparing" technique already disclosed in Kennewick. The teachings were highly compatible and would involve the straightforward application of conventional technologies.

4. Key Claim Construction Positions

• Petitioner argued that no terms required means-plus-function analysis. However, should the Patent Owner assert that "registration module" or "context manager" are means-plus-function terms, Petitioner contended the prior art disclosed the corresponding structure (a computer programmed to perform the recited functions) and rendered the claims obvious under that construction.
• For terms in claims 17 and 18, Petitioner noted that similar terms in a related patent (Patent 9,263,039) were construed in a district court litigation. Without conceding the correctness of those constructions, Petitioner argued that the prior art satisfied the claims even under those constructions.

5. Relief Requested

• Petitioner requested institution of an inter partes review and cancellation of claims 11-12, 15, and 17-18 of Patent 7,917,367 as unpatentable.