PTAB

IPR2025-01426

Apple Inc v. MessageLoud Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems for Listening to Messages While Engaged in an Activity
  • Brief Description: The ’117 patent discloses systems and methods that allow a user to listen to various message types (e.g., emails, text messages) while engaged in an activity like driving. The technology centers on automatically detecting, analyzing, and placing incoming messages from different sources into a single queue to be read aloud to the user sequentially and without user input.

3. Grounds for Unpatentability

Ground 1: Claims 1-25 are obvious over Boelter in view of Gruber.

  • Prior Art Relied Upon: Boelter (Application # 2014/0303842) and Gruber (Application # 2013/0275138).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that the combination of Boelter and Gruber taught every limitation of the challenged claims. Boelter disclosed a foundational system for managing in-vehicle notifications by receiving various message types (texts, emails), analyzing them, and placing them in a single chronological queue for display on a touchscreen when driving conditions are safe. Boelter also taught using "intuitive finger gesture[s]" for interaction without needing to look at the screen. However, Boelter’s system was primarily visual. Petitioner contended that Gruber, which disclosed a virtual assistant for hands-free operation, supplied the missing "read aloud" functionality. Gruber taught reading lists of messages sequentially, including announcing the sender and then the message body, and pausing between them to allow for user interruption via touch or voice commands. The combination of Boelter’s single queue of mixed message types with Gruber’s sequential read-aloud capability rendered the core invention of the ’117 patent obvious.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine these references to further the shared goal of reducing distracted driving. Modifying Boelter’s visual notification queue to incorporate Gruber’s audio-based reading would reduce a driver's need to look at and interact with a screen, thereby improving safety. Reading the consolidated queue from Boelter aloud would also simplify message review, as the user would not need to toggle between different applications. This combination represented a predictable solution to a known problem.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because implementing text-to-speech functionality into a notification management system was a well-known and routine programming task by the patent’s priority date. Boelter’s system already described the necessary hardware (processor, memory, touchscreen), so the combination would only require software modifications, not a physical redesign.

Ground 2: Claims 1-25 are obvious over Boelter and Gruber in view of Polak.

  • Prior Art Relied Upon: Boelter (Application # 2014/0303842), Gruber (Application # 2013/0275138), and Polak (Application # 2015/0350400).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted this ground as an alternative, arguing that to the extent any teachings were found lacking in the Boelter and Gruber combination, Polak provided the remainder. Polak disclosed a system that enables drivers to hear text messages vocally "without touching the phone." Polak reinforced and supplemented the teachings of the primary combination. For example, Polak explicitly taught automatically "sounding" the sender's details to the user upon a message's arrival without any user input, strengthening the argument for claim limitation 1[d]. Furthermore, Polak’s exemplary user interface did not display any portion of the message text, providing additional motivation for the limitation in claim 1[g] to avoid displaying messages while driving to keep the user's eyes on the road.
    • Motivation to Combine: The motivation to add Polak’s teachings was consistent with the primary ground: to enhance driver safety and reduce distractions. A POSITA looking to improve upon the system of Boelter and Gruber would have looked to analogous art like Polak. Implementing Polak's feature of automatic sender announcement would remove a decision point for the user (i.e., selecting which message to hear), further streamlining the hands-free experience. Polak's minimal visual interface offered another known technique to limit on-screen distractions, a goal shared by all the asserted references.
    • Expectation of Success: Success was predictable, as Polak's features were software-based and addressed the same technical problem. Integrating Polak's method of automatic audio notification into the combined Boelter/Gruber system would involve routine programming and was a well-understood design choice for minimizing user interaction.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-25 of Patent 9,591,117 as unpatentable.