PTAB

IPR2026-00084

Samsung Electronics America Inc v. Zophonos Inc

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Managing Sensed Noise
  • Brief Description: The ’736 patent describes a system for managing a user's auditory environment using "clusters" of computing devices, such as wearable in-ear devices. The system senses ambient audio signals, identifies and isolates specific sounds or frequencies, determines if they are outside a predetermined threshold (e.g., hazardous to hearing), and modifies or controls audio output accordingly.

3. Grounds for Unpatentability

Ground 1: Obviousness over DiCenso641 and Smith - Claims 1, 4-11, 13-20, 25-28 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 DiCenso641 discloses the core system of the independent claims: a user-controllable auditory environment using wearable in-ear devices (a "cluster") that contain microphones ("sound sensing mechanism"), speakers, and a digital signal processor (DSP). DiCenso641’s system communicates wirelessly with a mobile device (a "data source") to process ambient sounds based on user preferences, including identifying and isolating sounds. Petitioner asserted that Smith, which teaches a hearing enhancement system, remedies DiCenso641’s lack of disclosure regarding sounds outside the normal human hearing range. Smith explicitly teaches using microphones sensitive to infrasound (<20 Hz) and ultrasound (>20 kHz) and processing these signals, which meets the limitation of determining if a sound includes a frequency outside a predetermined threshold.
    • Motivation to Combine: A POSITA would combine Smith's teachings with DiCenso641’s system to enhance its functionality. Both references are directed to altering a user's auditory environment. Incorporating Smith’s ability to detect and process otherwise inaudible sounds would improve user awareness and provide a more comprehensive and enhanced auditory experience, which is consistent with DiCenso641’s objective.
    • Expectation of Success: A POSITA would have a reasonable expectation of success because DiCenso641 already contemplates using "one or more microphones or transducers" in its earpieces. Modifying this system to include the specialized infrasonic or ultrasonic microphones taught by Smith would be a straightforward application of a known technique to an existing system to achieve a predictable improvement.

Ground 2: Obviousness over DiCenso641, Smith, and Holland - Claims 2 and 12 are obvious over DiCenso641 and Smith 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 builds upon the combination of DiCenso641 and Smith. It adds Holland to address the limitations of claim 2, which requires an "interfacing mechanism" including a "network adapter, configured to transmit and receive the data through both wired and wireless communication." While DiCenso641 discloses wireless communication, it does not provide implementation details for supporting both wired and wireless connections. Holland explicitly teaches a mobile device that includes a network adapter for coupling to a network, allowing for both wired and wireless communication.
    • Motivation to Combine: A POSITA implementing the system of DiCenso641 would be motivated to look for references providing specific implementation details for robust communication. Holland provides these details, teaching the use of a network adapter in a mobile device to achieve the exact dual-mode (wired and wireless) communication functionality recited in the claims. The combination would be a mere application of a known technique to improve a similar device.

Ground 3: Obviousness over DiCenso641, Smith, and DiCenso645 - Claims 21-24 are obvious over DiCenso641 and Smith in view of DiCenso645.

  • Prior Art Relied Upon: DiCenso641 (Application # 2015/0195641), Smith (Application # 2014/0254842), and DiCenso645 (Application # 2015/0170645).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground adds DiCenso645 to the base combination to teach the limitations of claim 21, which requires an output device that includes a display. DiCenso645 is directed to audio enhancement in listening devices (e.g., headphones) and explicitly discloses including a display, such as an OLED display, to provide visual indicators to others (e.g., displaying "Do Not Disturb!").
    • Motivation to Combine: A POSITA would be motivated to add a display as taught by DiCenso645 to the earpieces of the DiCenso641 system. DiCenso641 teaches a "focus mode" where ambient noises are blocked. Adding a visual display from DiCenso645 would advance this goal by providing a visual cue to others that the user does not wish to be disturbed, thereby improving the system's overall utility.
  • Additional Grounds: Petitioner asserted numerous other obviousness challenges, including combinations adding Warren (Application # 2008/0031481) to teach an omni-directional microphone for claim 3, and Goldstein873 (Application # 2008/0137873) to teach transmitting an alert to another computing device for claim 32. Petitioner also presented an alternative set of grounds using Goldstein873 as a primary reference to teach a wireless transceiver and memory in an earpiece.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-28 and 32 of the ’736 patent as unpatentable under 35 U.S.C. §103.