Google LLC v. Sonos Inc

1. Case Identification

• Case #: IPR2025-01213
• Patent #: 10,541,883
• Filed: July 8, 2025
• Petitioner(s): Google LLC
• Patent Owner(s): Sonos, Inc.
• Challenged Claims: 1-20

2. Patent Overview

• Title: Automatically Configuring a Playback Device
• Brief Description: The ’883 patent discloses a method for simplifying the process of connecting a new device to a network with minimal user intervention. The method involves establishing an initial, temporary communication path to transfer necessary network parameters to the new device, which then uses those parameters to connect to the main network.

3. Grounds for Unpatentability

Ground 1: Obviousness over Cheshire - Claims 1-3, 7-8, 10, 12, 14-15, and 20 are obvious over Cheshire in view of the knowledge of a POSITA.

• Prior Art Relied Upon: Cheshire (Patent 7,532,862).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Cheshire, which teaches a "reverse advertising" method for configuring a new wireless device to join an existing network, discloses or renders obvious all limitations of the challenged claims. Cheshire’s “new wireless device,” which can be an “audio output device,” corresponds to the claimed playback device. The process in Cheshire involves the new device powering on (a triggering event), advertising a temporary "new wireless network" (an initial communication path), being discovered by an "existing wireless device" (a computing device), and receiving a packet with configuration information (e.g., network name and encryption key) over that temporary network to join the main "existing wireless network." Petitioner asserted this process maps directly to the claimed steps of entering a setup mode, receiving a response, and receiving network parameters over a communication path that does not traverse the main network's access point.
  • Motivation to Combine (for §103 grounds): The ground relied on the knowledge of a Person of Ordinary Skill in the Art (POSITA) to understand that Cheshire’s teachings inherently met the claim limitations. For instance, a POSITA would have known that a wireless device configured to execute a process, as described in Cheshire, would necessarily include standard components like a processor, network interface, and non-transitory memory, even if not explicitly named with the exact claim language.
  • Expectation of Success: A POSITA would have had a high expectation of success in applying general knowledge to Cheshire's system, as it involved implementing basic, well-understood components for their intended and conventional functions in a networking context.

Ground 2: Obviousness over Cheshire and Meenan - Claims 1-10, 12, 14-18, and 20 are obvious over Cheshire and Meenan.

• Prior Art Relied Upon: Cheshire (Patent 7,532,862) and Meenan (Patent 7,313,384).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground used Cheshire as the primary reference and supplemented its teachings with Meenan. Meenan, which also relates to configuring devices on a home network, was argued to explicitly teach limitations that were otherwise implicit or not detailed in Cheshire. Specifically, Meenan taught sending an "acknowledgment" that configuration settings were successfully modified, which Petitioner mapped to the limitation in claims 4 and 16 of "providing an indication that the playback device has successfully received the network configuration parameters." Further, Meenan was cited for disclosing the assignment of a "user-assigned name" to a device, which rendered obvious the limitation in claim 9 of receiving a command to assign a name.
  • Motivation to Combine: Petitioner argued a POSITA would combine Cheshire and Meenan because both address the same problem of simplifying wireless device configuration and are analogous art. A POSITA would have been motivated to incorporate Meenan’s acknowledgment step into Cheshire's process to improve its reliability. Providing confirmation that configuration data was received would be a logical and predictable improvement, preventing the controlling device from needlessly resending packets.
  • Expectation of Success: The combination would have yielded predictable results. Adding an acknowledgment step is a routine and well-known technique in network communication protocols and would not alter the fundamental operation of Cheshire's configuration process.

Ground 3: Obviousness over Cheshire, Spurgat, and optionally Meenan - Claims 1-19 are obvious over Cheshire and Spurgat (Ground 3A) or Cheshire, Meenan, and Spurgat (Ground 3B).

• Prior Art Relied Upon: Cheshire (Patent 7,532,862), Spurgat (Application # 2002/0174243), and Meenan (Patent 7,313,384).
• Core Argument for this Ground:
  • Prior Art Mapping: This ground contended that Spurgat, which discloses a networked digital audio system, provides additional teachings specific to audio playback devices that render further claim limitations obvious. Spurgat was argued to teach a post-connection "discovery" process where an audio gateway finds players on the network. Petitioner mapped this discovery to the limitation in claim 6 of providing an "indication that the playback device has successfully connected to the secure WLAN," as discovery is only possible after a successful connection. Spurgat also taught synchronizing content and grouping players, which Petitioner argued rendered obvious the limitations of retrieving audio content from a source (claim 11) and forming a synchronized group of players (claim 13).
  • Motivation to Combine: Petitioner asserted a POSITA would have been motivated to implement the specific audio features from Spurgat (e.g., device discovery, content synchronization) into the general network setup process of Cheshire. This would create a more feature-rich and functional networked audio system, which was a well-known goal in the art. The combination amounted to using a known network configuration method (Cheshire) with known audio device features (Spurgat).
  • Expectation of Success: A POSITA would have reasonably expected success, as the combination involved integrating known and compatible technologies for their intended purposes. Implementing a discovery process after establishing a network connection was a common and routine step in networked systems.

4. Relief Requested

• Petitioner requests institution of IPR and cancellation of claims 1-20 of the ’883 patent as unpatentable.