PTAB

IPR2025-01429

Apple Inc v. MessageLoud Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Systems for Audibly Delivering Messages
  • Brief Description: The ’775 patent relates to a system for managing incoming messages (e.g., text messages, emails, messenger notifications) for a user engaged in an activity such as driving. The technology automatically determines message receipt, analyzes content, places messages in a queue, and reads them aloud to the user to minimize distraction.

3. Grounds for Unpatentability

Ground 1: 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 Boelter discloses the core framework of the claimed invention, while Gruber provides the essential "read aloud" functionality. Specifically, Boelter teaches a system for managing in-vehicle notifications that, without user input, receives various message types like emails and texts (meeting claim 1[a]), analyzes their content to identify sender and time (meeting claim 1[b]), and places them in a chronological "summarized notification page" or queue for later display, especially after a critical driving situation has passed (meeting claim 1[c]). Petitioner contended that while Boelter’s system notifies the user visually, Gruber makes it obvious to provide these notifications audibly. Gruber discloses a virtual assistant that reads lists of messages to a user, including audibly announcing the sender's identity to inform the user of a new message (meeting claim 1[d]), pausing to allow the user an opportunity to provide an affirmative action to stop playback (meeting claim 1[e]), and then proceeding to read the message body if no interruption occurs (meeting claim 1[f]). The combination of Boelter's automated queuing of diverse message types with Gruber's established text-to-speech process allegedly rendered the independent claims obvious. The dependent claims were argued to add further conventional features also taught by the combination, such as parsing messages into sender/body parts or running an application in the background.
    • Motivation to Combine: A POSITA would combine Gruber’s audio playback with Boelter’s notification system to directly further Boelter's stated goal of reducing driver distraction. Petitioner argued that replacing or supplementing Boelter’s visual, text-based queue with an audible one was a predictable and logical improvement. This combination would reduce the need for a driver to look at and interact with a screen, simplify the process of reviewing multiple messages, and improve overall safety, all of which were known goals in the art.
    • Expectation of Success: Petitioner asserted a POSITA would have a high and reasonable expectation of success in making this combination. The integration of text-to-speech technology into vehicle systems was well-known and commercially available at the time. The combination would require only software modifications to Boelter's system, which already disclosed the necessary hardware components (processor, memory, display). Therefore, implementing the audio features taught by Gruber was presented as a matter of routine programming, not requiring undue experimentation.

Ground 2: Claims 1-24 are obvious over Boelter in view of 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, arguing that if any doubt remained from Ground 1, the addition of Polak would render the claims obvious. Polak was cited to strengthen the teaching of automatically reading sender information aloud without requiring any user input. Polak discloses a mobile application that, immediately upon a message's arrival, “sounds” the sender’s name or phone number to the user first. Petitioner argued this explicit disclosure reinforces the motivation to modify Boelter's system to audibly announce sender identity (claim 1[d]) automatically. This addresses any potential argument that Gruber's system might require some initial user interaction to begin reading messages. Polak’s teaching of an immediate, automatic audio announcement upon receipt provides a clear and obvious path to the fully automated system recited in the claims.
    • Motivation to Combine: A POSITA would have been motivated to incorporate Polak's teaching of an automatic, unsolicited sender announcement into the Boelter/Gruber combination to further enhance driver safety and convenience. This modification would remove a potential decision point for the user (i.e., whether to initiate the read-aloud sequence), thereby streamlining the notification process and better aligning with the overarching goal of minimizing all forms of driver interaction with the system. Announcing the sender automatically allows the driver to triage messages hands-free and eyes-free from the very start of the notification.
    • Expectation of Success: Similar to Ground 1, the expectation of success was argued to be high. The addition of Polak's specific teaching of automatic sender announcement was framed as another straightforward programming task. It represents a minor variation on the text-to-speech functionality already taught by Gruber and would not require any physical changes to the underlying hardware disclosed in Boelter, making it a routine implementation for a skilled artisan.

4. Relief Requested

  • Petitioner requests institution of IPR and cancellation of claims 1-24 of Patent 10,516,775 as unpatentable.