PTAB

IPR2026-00073

Google LLC v. SoundClear Technologies LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: Output-Content Control Device, Output-Content Control Method, and Output-Content Control Program
  • Brief Description: The ’675 patent relates to an electronic device, such as a smart speaker, that analyzes a user's voice and generates a tailored response. The device calculates the distance to the user and classifies the user's voice as a "first voice" (far) or "second voice" (near) to modify the content of its spoken output.

3. Grounds for Unpatentability

Ground 1A: Claims 1-7 are obvious over Shin in view of Aoyama.

  • Prior Art Relied Upon: Shin (Application # 2017/0083281) and Aoyama (Application # 2017/0337921).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Shin, an application from Samsung, discloses the core functionalities of the ’675 patent. Shin teaches an electronic device that uses a "distance detection module" or "proximity sensor" to compute the distance to a user. Based on this distance, it classifies the user's voice and adjusts the output content, providing "detailed content" for users within 1 meter and "abbreviated content" for users farther away. This, Petitioner asserted, meets the limitations of claim 1 regarding calculating a distance, classifying a voice into first (far) and second (near) categories based on that distance, and generating different output sentences accordingly (a full sentence for the second voice and an abbreviated one for the first). For the word replacement limitation in claim 1[f], Petitioner contended this was an obvious modification in view of Aoyama. Aoyama, an application from Sony, explicitly teaches tailoring voice output by replacing words—for example, replacing a formal name ("Taro Yamada") with a simpler one ("Mr. Yamada") or a nickname, or replacing complex date formats with simpler terms ("tomorrow").
    • Motivation to Combine: A POSITA looking to implement Shin's distance-based content abbreviation would have been motivated to consult Aoyama to find known methods for simplifying output. Aoyama's word replacement directly addresses Shin's goal of making output easier to grasp for users at a greater distance. Replacing formal names or complex phrases with simpler alternatives is a predictable way to achieve the "abbreviated" or "gist" output described by Shin. Further motivation arose from known privacy concerns, where replacing personal information with neutral alternatives would be a desirable feature.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success in combining the references. The integration was portrayed as trivial, involving configuring Shin's processor to use Aoyama's known word-replacement techniques—a straightforward application of a known technique to a known device to yield predictable results.

Ground 2A: Claims 1-7 are obvious over Shimomura in view of Aoyama.

  • Prior Art Relied Upon: Shimomura (Japanese Application # 2005/202076) and Aoyama (Application # 2017/0337921).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that Shimomura, a 2005 application from Sony, provides an alternative basis for the core limitations of claim 1. Shimomura discloses a speech control device that uses cameras to determine the distance to a user and classifies speech into two categories: a "first voice" for distances greater than 350 cm and a "second voice" for distances less than 350 cm. When a "first voice" is detected, Shimomura's device transforms the output by inserting words (e.g., "ne" in Japanese) after phrases to improve clarity for a distant listener. When a "second voice" is detected, it outputs the original, untransformed content. Petitioner asserted this teaches the claimed concepts of distance-based voice classification and generating distinct first and second output sentences. The combination with Aoyama was argued for the same reasons as in Ground 1A: to provide a specific, known method of word replacement to achieve the content modification for distant users.
    • Motivation to Combine: The motivation to combine Shimomura and Aoyama was presented as being analogous to the Shin/Aoyama combination. Shimomura explicitly aims to make output more clearly understood at a distance. A POSITA would have been motivated to incorporate Aoyama's word replacement feature (e.g., using simpler names) as another, more effective way to enhance comprehension for distant users, directly advancing Shimomura's stated goal.
    • Expectation of Success: Success was expected because it involved applying Aoyama's known technique of word replacement to improve Shimomura's known system of distance-based content adjustment. The integration was described as a predictable combination of known elements to achieve a known goal.

  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Shin with Iwase (11,183,167) and Shimomura with Iwase, where Iwase was presented as an alternative to Aoyama for teaching word replacement to enhance user comprehension. Further grounds argued that claim 5 (classifying a whisper) was obvious over the primary combinations in further view of Schuster (9,680,983), and that all claims were obvious over the primary combinations in further view of Kristjansson (10,147,439) for its teachings on natural language understanding units.

4. Arguments Regarding Discretionary Denial

  • Petitioner argued against discretionary denial under §314(a) by noting that the parallel district court litigation is stayed. Furthermore, Petitioner filed this IPR concurrently with a motion for joinder to an already-instituted IPR on the same patent (IPR2025-00673, filed by Amazon), which weighs against denial.
  • Petitioner also argued against denial under §325(d), asserting that the primary prior art references (Shin, Shimomura, Iwase, and Kristjansson) were never presented to or considered by the Examiner during prosecution. Petitioner contended this constitutes a material error by the USPTO, as the newly presented art and arguments establish a strong, compelling case of unpatentability.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-7 of Patent 11,244,675 as unpatentable under 35 U.S.C. §103.