PTAB

IPR2025-01343

Amazon.com Services LLC v. VB Assets LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Natural Language Content Dedication Service
  • Brief Description: The ’025 patent describes a service for dedicating digital content, such as a song, to a recipient using natural language voice commands. The system employs an automatic speech recognizer and a conversational language processor to interpret a user's spoken utterances, identify the desired content, and associate a second dedication utterance with it for delivery to the recipient.

3. Grounds for Unpatentability

Ground 1: Obviousness over Weider and Gold - Claims 1, 3, 6-8, 10, 13-14, and 19 are obvious over Weider in view of Gold.

  • Prior Art Relied Upon: Weider (Application # 2007/0050191) and Gold (Application # 2002/0032752).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Weider disclosed a natural language speech interface system capable of recognizing user commands to play specific songs. Gold disclosed a "song dedication system" that allows a user to select a song, record a voice message, and send the combined dedication to a recipient via a notification link. Petitioner contended that combining Weider's speech front-end with Gold's back-end dedication functionality met the limitations of independent claims 1 and 8. This combination allegedly taught receiving a first utterance (a command), interpreting it, identifying content, receiving a second utterance (a dedication message), and sending access information to a recipient.
    • Motivation to Combine: A POSITA would combine the references to enhance Weider's speech-controlled music system with the popular and desirable feature of dedicating songs, as taught by Gold. Petitioner argued this combination would create a more complete and emotionally resonant user experience, which was a known market goal.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because Weider was designed with a flexible, agent-based architecture for incorporating new services ("domains"), and Gold's song dedication service represented a straightforward domain to integrate.

Ground 2: Obviousness over Weider, Gold, and Martinez - Claims 2, 9, 17, and 18 are obvious over Weider in view of Gold and Martinez.

  • Prior Art Relied Upon: Weider (Application # 2007/0050191), Gold (Application # 2002/0032752), and Martinez (Application # 2007/0083762).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground built upon the Weider/Gold combination by adding Martinez, which disclosed a tool for creating composite media items with associated metadata. Specifically, Martinez taught storing graphical images (like album art) or electronic links as "tags" within the metadata. Petitioner argued that adding Martinez's teachings to the base Weider/Gold system satisfied the limitations of claims 2 and 9 (providing an image tag), claim 17 (providing an electronic link tag), and claim 18 (providing a voice tag).
    • Motivation to Combine: A POSITA would be motivated to add Martinez's metadata tagging functionality to the Weider/Gold system to enhance the dedication with useful information. For example, including album art as a metadata tag would allow the recipient to more easily identify the song and artist, improving the user experience and providing an efficient way to package and convey related data with the primary content.
    • Expectation of Success: The combination was presented as a predictable application of a known data management technique (Martinez's metadata tagging) to an existing system (Weider/Gold's content dedication).

Ground 3: Obviousness over Weider, Gold, Ginter, and Wang - Claims 5 and 12 are obvious over Weider in view of Gold, Ginter, and Wang.

  • Prior Art Relied Upon: Weider (Application # 2007/0050191), Gold (Application # 2002/0032752), Ginter (Patent 5,892,900), and Wang (Application # 2004/0199387).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground added Ginter and Wang to the base combination to address claims related to purchasing content. Petitioner asserted Ginter disclosed a virtual distribution environment for commercial content, teaching the concept of a distributor purchasing content from a creator to build a library. Wang disclosed a service that allowed users to identify a song and purchase it using various options, such as a "buy-to-own" download or a subscription, and then billed the user accordingly. This four-way combination allegedly met the limitations of claims 5 and 12 regarding identifying purchase options and billing the user.
    • Motivation to Combine: A POSITA would incorporate the teachings of Ginter and Wang to monetize the Weider/Gold dedication service, a predictable business goal. Ginter provided the framework for legally acquiring content for the service's database, and Wang provided well-known e-commerce models to charge users for sending dedications.
    • Expectation of Success: Success would be highly predictable, as combining a content delivery service with standard e-commerce purchasing and billing models was a conventional and well-understood practice in the art.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges. Grounds 6-10 substituted Kennewick (Application # 2004/0193420), a natural language speech system similar to Weider, as the primary reference in combination with the same secondary references used in Grounds 1-5. Other grounds relied on similar design modification theories to challenge the same claims.

4. Relief Requested

  • Petitioner requested the institution of an inter partes review and the cancellation of claims 1-19 of the ’025 patent as unpatentable.