PTAB

IPR2026-00083

Samsung Electronics America Inc v. Zophonos Inc

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: System for Sensing Audio Signals and Controlling Audio Output
  • Brief Description: The ’906 patent discloses a system comprising clusters of computing devices (e.g., wearable devices) that sense ambient audio, identify specific sounds or frequencies, and modify the audio output to a user based on predetermined thresholds, such as removing sounds potentially harmful to hearing.

3. Grounds for Unpatentability

Ground 1: Obviousness over DiCenso641 and Smith - Claims 1, 4-11, and 13-20 are obvious over DiCenso641 in view of Smith.

  • Prior Art Relied Upon: DiCenso641 (Application # 2015/0195641) and Smith (Application # 2014/0254842).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that DiCenso641, which teaches a user-controllable auditory environment using wearable earpieces, disclosed most limitations of the challenged claims. DiCenso641’s system included a mobile device (the "audio control source") communicating with a pair of earpieces (a "cluster" of "computing devices") containing microphones and speakers. Petitioner asserted that Smith, which teaches hearing enhancement and protection, supplied the missing elements, particularly the ability to detect and alter sounds outside the normal audible range (infrasound/ultrasound). Petitioner contended that DiCenso641 taught identifying and isolating sounds based on user preferences, while Smith taught detecting frequencies outside a predetermined threshold (the audible range) and altering them to be audible, thus rendering the combination obvious. For example, DiCenso641’s disclosure of earpieces with microphones, speakers, and wireless capability, controlled by a smartphone app, was argued to meet the core system architecture of claim 1. Smith was used to teach including a power source (battery) in the earpieces and modifying the system to detect and process ultrasonic sounds.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine DiCenso641 and Smith to enhance the capabilities of DiCenso641’s personalized audio system. A POSITA would have recognized the benefit of incorporating Smith’s teachings on processing inaudible sounds to provide enhanced hearing, awareness, and protection within DiCenso641’s framework, which was a known technique to improve a similar system.
    • Expectation of Success: A POSITA would have had a reasonable expectation of success because both references relate to personal audio devices (earpieces) that modify ambient sound. DiCenso641 explicitly contemplated using multiple microphones in its earpieces, making the integration of Smith's specialized infrasound/ultrasound microphones straightforward.

Ground 2: Obviousness over DiCenso641, Goldstein873, and Smith - Claims 1, 4-11, and 13-20 are obvious over DiCenso641 and Smith, further in view of Goldstein873.

  • Prior Art Relied Upon: DiCenso641 (Application # 2015/0195641), Smith (Application # 2014/0254842), and Goldstein873 (Application # 2008/0137873).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground was presented as an alternative to Ground 1, addressing a potential argument that DiCenso641 does not explicitly disclose a wireless transceiver in each earpiece for two-way communication. Petitioner argued that Goldstein873, which discloses an earpiece for monitoring environmental sounds, explicitly taught including a transceiver (e.g., Bluetooth, WiFi) for wireless communication. The core teachings from DiCenso641 (system architecture) and Smith (processing inaudible sounds) remained the same as in Ground 1. Goldstein873 was added to explicitly teach the wireless transceiver and communication mechanism limitations of claim 1.
    • Motivation to Combine: A POSITA would have been motivated to incorporate the transceiver from Goldstein873 into the DiCenso641 system to fully enable the wireless communication features described. Since DiCenso641’s system relied on a wireless link between the earpieces and a mobile device, a POSITA would have looked to known methods for implementing such links in earpieces, as taught by Goldstein873.
    • Expectation of Success: The combination would have been a predictable application of a known technique (including a wireless transceiver in an earpiece) to improve a similar device (DiCenso641’s earpieces) to achieve the predictable result of robust two-way wireless communication.

Ground 3: Obviousness over DiCenso641, Smith, and Holland - Claims 2 and 12 are obvious over DiCenso641 and Smith, further in view of Holland.

  • Prior Art Relied Upon: DiCenso641 (Application # 2015/0195641), Smith (Application # 2014/0254842), and Holland (Application # 2014/0337902).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground targeted dependent claims 2 and 12, which added limitations for a "network adapter" configured for both wired and wireless communication. Petitioner argued that while DiCenso641 disclosed using wired or wireless technology, it lacked implementation details. Holland was introduced because it explicitly taught an electronic device (e.g., a mobile phone) using a network adapter to connect to a network for both wired and wireless communication. This teaching was applied to the mobile device ("audio control source") in the DiCenso641/Smith system.
    • Motivation to Combine: A POSITA seeking to implement the communication functionality in DiCenso641 would have looked to references like Holland for established methods. Holland provided the necessary implementation details for a network adapter supporting both wired and wireless protocols, making it a logical component to incorporate into the DiCenso641 system.
    • Expectation of Success: Success was expected as it amounted to the mere application of a known component (a network adapter as taught by Holland) to a similar device (the mobile device in DiCenso641) to provide a known function (wired and wireless connectivity).

  • Additional Grounds: Petitioner asserted additional obviousness challenges based on combinations including Warren (Application # 2008/0031481) to teach an omnidirectional transducer for claim 3, and applying the Goldstein873 combination to the dependent claims challenged with Holland and Warren.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-20 of Patent 10,656,906 as unpatentable.