PTAB

IPR2025-01429

Apple Inc. v. MessageLoud, Inc.

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1. Case Identification

2. Patent Overview

  • Title: System for Hands-Free Message Delivery
  • Brief Description: The ’775 patent relates to systems and methods that automatically, without user input, receive various types of messages (e.g., text, email, messenger), place them in a queue, analyze their content, and read them aloud to a user engaged in an activity such as driving.

3. Grounds for Unpatentability

Ground 1: 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 discloses all limitations of the challenged claims. Boelter taught an in-vehicle system for managing notifications to reduce driver distraction. This system automatically determines when different message types (e.g., emails, text messages) are received, analyzes their content without user input to identify sender and time, and places them into a chronological queue for later display on a touchscreen. Petitioner asserted this met the limitations of determining message receipt, analyzing content, and placing messages in a queue in order of receipt time, as required by independent claims 1, 23, and 24.
    • Gruber taught a virtual assistant that could read various message types aloud to a user, specifically to reduce the need for visual or manual interaction while driving. Gruber disclosed reading lists of messages in "sequential order," sorting by time, and providing spoken notifications. Petitioner argued it would have been obvious to modify Boelter’s visual notification queue to be read aloud as taught by Gruber. Further, Gruber’s disclosure of a pause between announcing a sender’s identity and reading the message body—explicitly for "user interruption"—was argued to meet the limitation of allowing a user time to take an affirmative action to stop the read-aloud. If no action is taken, Gruber’s system proceeds to read the body, meeting the limitation of reading the body based on not receiving an input.
    • Motivation to Combine: Petitioner argued a person of ordinary skill in the art (POSITA) would combine Gruber’s text-to-speech functionality with Boelter’s message queuing system to advance Boelter's stated goal of limiting driver distractions. Making Boelter’s visually-displayed queue audible would be a predictable improvement, reducing the amount of time a driver’s eyes are off the road. This combination would simplify message review for the user by presenting a unified, audible stream of notifications, thereby preventing the user from needing to toggle between different messaging applications.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in this combination because text-to-speech was a well-known and commercially available technology already implemented in vehicles. Petitioner contended that because Boelter’s system already included the necessary hardware (processor, memory, touchscreen), the combination would only require routine software modification, well within the skill of an ordinary artisan at the time.

Ground 2: Obviousness over Boelter, Gruber, and Polak - Claims 1-24 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: This ground asserted that to the extent the combination of Boelter and Gruber was insufficient, the addition of Polak rendered the claims obvious. Polak taught a mobile application that automatically announces incoming messages, including sounding the sender's details, "without touching the phone." Petitioner argued that Polak’s teachings provided additional support for the claim limitation of "informing the user without any input by the user...by reading aloud at least an identity of the sender." Polak's system automatically reads sender details upon message arrival, reinforcing the concept of a fully automated audible notification.
    • Motivation to Combine: Petitioner argued a POSITA would be motivated to incorporate Polak’s automatic read-aloud feature into the Boelter/Gruber system to further enhance safety and streamline the user experience. Automatically announcing the sender without requiring the user to first select a message from a list would remove a decision-making step, fully automating the notification process and furthering the primary goal of minimizing driver distraction.
    • Expectation of Success: The expectation of success for adding Polak’s teachings was based on the same reasoning as for combining Boelter and Gruber. The proposed modification involved simple, routine programming changes to implement a well-understood feature, not the exploration of new technology.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-24 of Patent 10,516,775 as unpatentable.