PTAB

IPR2025-01427

Apple Inc v. MessageLoud Inc

Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Delivering Messages to a User Engaged in an Activity
  • Brief Description: The ’725 patent describes systems and methods that automatically detect incoming messages of different types (e.g., text, email, messenger), place them into a single chronological queue, and read them aloud to a user without requiring user input. The technology is primarily aimed at reducing distraction for users engaged in activities such as driving.

3. Grounds for Unpatentability

Ground 1A: Obviousness over Boelter and Gruber - Claims 1-24 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 disclosed all limitations of the challenged claims. Boelter taught a system for managing in-vehicle notifications that receives different message types (e.g., emails, text messages) and queues them for display on a touchscreen in chronological order without user input, particularly after a critical driving situation has passed. While Boelter focused on visual display, Gruber taught a virtual assistant capable of reading lists of various message types (including texts and emails) aloud to a user, especially in hands-free contexts like driving. Petitioner asserted that implementing Gruber’s read-aloud functionality into Boelter’s message queuing system rendered the claimed invention obvious. For example, Boelter’s chronological "summarized notification page" was argued to be the claimed "single queue," and Gruber’s teaching of reading such lists aloud satisfied the read-aloud limitations.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Boelter and Gruber to improve user safety and convenience. The primary motivation was to further Boelter's stated goal of reducing driver distraction. A POSITA would have recognized that replacing Boelter’s visual notification queue with Gruber’s established audio-based output was a logical and predictable improvement, as it would reduce the need for a driver to look at a screen. Reading a mixed-message queue aloud would simplify message review and was a known technique for improving safety in vehicles.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because implementing text-to-speech technology was a routine programming task by the patent's priority date. Boelter’s system was described as comprising standard computing components (processor, memory) also found in the systems of Gruber, which would only require software modification, not a fundamental redesign, to integrate audio playback of the existing notification queue.

Ground 1B: Obviousness over Boelter, Gruber, and Polak - Claims 1-24 are obvious over Boelter, Gruber, and 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: This ground was presented as an alternative to Ground 1A, adding Polak to further support the obviousness of notifying the user without their input. Petitioner argued that to the extent the combination of Boelter and Gruber was found insufficient, Polak provided additional teachings that rendered the claims obvious. Specifically, Polak disclosed a system that automatically "sounds" the sender's details (e.g., name or phone number) to a driver upon a message's arrival, explicitly occurring without any user interaction with the application. This was argued to reinforce the obviousness of the limitation in claim 1[d] requiring "informing the user without any input by the user...by reading aloud at least an identity of the sender."
    • Motivation to Combine: A POSITA would have been motivated to incorporate Polak's teachings into the Boelter/Gruber framework to further enhance driver safety. By automatically announcing the sender's identity upon message arrival (after a critical driving period, as taught by Boelter), the system would remove another decision point for the user, thereby reducing cognitive load. This directly aligned with the shared goal of all three references: enabling safer, less distracting message interaction while driving.
    • Expectation of Success: The expectation of success remained high, as incorporating Polak's automatic audio announcement was a simple and routine programming change. The functionality was well-known and would not require complex or unpredictable modifications to the system proposed under the Boelter and Gruber combination.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-24 of Patent 10,110,725 as unpatentable under 35 U.S.C. §103.