PTAB

IPR2025-01335

Meta Platforms Inc v. Dialect LLC

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petition

1. Case Identification

2. Patent Overview

  • Title: Method for Processing Natural Language Speech Utterances with Context-Specific Domain Agents
  • Brief Description: The ’006 patent discloses methods for processing natural language speech requests. The system receives a spoken utterance, determines its meaning and context, and formulates a request that can be processed by a context-specific "domain agent" (e.g., an external application) to generate and present a response.

3. Grounds for Unpatentability

Ground 1: Obviousness over Ross, Ittycheriah, and Ross018 - Claim 5 is obvious over Ross in view of Ittycheriah and Ross018

  • Prior Art Relied Upon: Ross (Patent 7,085,723), Ittycheriah (Patent 5,937,383), and Ross018 (Patent 7,249,018).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Ross taught the core method of the ’006 patent, disclosing a "speech center" that receives a spoken utterance, determines the appropriate context and target application ("domain agent"), and translates the utterance into a command for that application. Petitioner asserted that Ittycheriah, an IBM-developed speech recognition system like Ross, provided the specific engine for recognizing words and phrases using a cache database and a larger vocabulary, satisfying the "recognizing" limitation of claim 5. Further, Petitioner contended that Ross018, described as an "expansion" of Ross's conversation manager, taught the detailed steps of "formulating" the request. Ross018 disclosed a parser with a "semantics analysis module" that processes an utterance using a grammar specific to a domain to create a semantic representation, extract criteria and parameters (values), infer missing information using a reasoning facility, and transform this into a script call (token) formatted for the target application.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to improve upon a known system. Ross explicitly contemplated using off-the-shelf speech engines, and Ittycheriah, also from IBM, represented a known, efficient option. Because Ross018 shared a provisional application with Ross and was presented as a functional expansion of Ross's parsing capabilities, a POSITA would have been motivated to integrate Ross018's more sophisticated parsing and semantic analysis to provide more natural and robust user interaction.
    • Expectation of Success: Petitioner argued a POSITA would have had a high expectation of success because the combination involved integrating known, compatible technologies to achieve a predictable result. The shared origin (IBM) of Ross and Ittycheriah, and the complementary design of Ross and Ross018, ensured technical compatibility.

Ground 2: Obviousness over Ross and Aridor - Claim 6 is obvious over Ross in view of Aridor

  • Prior Art Relied Upon: Ross (Patent 7,085,723) and Aridor (Patent 6,636,848).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground again used Ross as the primary system for receiving and processing a spoken request containing at least one question and command. Petitioner argued that Aridor supplied the specific teachings for processing such a request by querying network information sources, as required by claim 6. Aridor taught using domain-specific "knowledge agents" to perform internet metasearches by submitting asynchronous queries to multiple search engines (e.g., Google, AltaVista). Aridor further disclosed asynchronously receiving the results, scoring their relevance using textual and topological criteria based on a dynamic knowledge base ("prior probabilities or fuzzy possibilities"), applying "scraping criteria" to extract values, and ranking the results to determine the best responses. This mapping covered the claim 6 limitations of directing a command, querying a network, submitting multiple queries, asynchronously receiving results, and scoring/evaluating them to select the best values.
    • Motivation to Combine: A POSITA would have been motivated to combine Ross with Aridor to expand the information retrieval capabilities of Ross's speech-command system to the internet, a rich and conventional source of information. While Ross taught invoking local applications, Aridor (also an IBM system) provided a well-understood method for network-based searches. Combining them would allow a user to use voice commands to query the internet and receive ranked results, a desirable and logical improvement.
    • Expectation of Success: Petitioner asserted success would be expected, as the combination involved applying a known internet search methodology (Aridor) to a known voice-command framework (Ross). The integration was a predictable application of existing technologies to enhance system functionality.

  • Additional Grounds: Petitioner asserted additional obviousness challenges against claim 5 over Hartono (WO 00/11571) in view of Baker (Patent 5,680,511) and against claim 6 over Hartono in view of Aridor. These grounds relied on Hartono as an alternative base system for processing natural language commands via different "task agents."

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 5 and 6 of the ’006 patent as unpatentable.