PTAB

IPR2026-00085

Samsung Electronics America Inc v. Zophonos Inc

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System for Autonomously Adjusting In-Ear Monitor Output
  • Brief Description: The ’016 patent describes a system of wirelessly connected devices, such as in-ear monitors, that sense ambient audio levels. The system is designed to autonomously adjust its own audio output to protect users from hearing loss caused by exposure to loud sounds.

3. Grounds for Unpatentability

Ground 1A: Claims 39-43 are obvious over Goldstein873 in view of Newham

  • Prior Art Relied Upon: Goldstein873 (Application # 2008/0137873) and Newham (Application # 2013/0316642).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Goldstein873 discloses a single earpiece designed for hearing protection that includes a sound sensing mechanism (microphones), a processor, and a speaker (ear canal receiver) to monitor sound pressure levels (SPL) and adjust audio output to safe levels. Goldstein873 suggests its earpiece can be used in a pair in a master-slave arrangement but does not detail the implementation. Newham teaches a system of two wireless earpieces that operate in a master-slave configuration, specifically addressing how to manage the connection and balance battery load by dynamically swapping roles. The combination of Goldstein873’s audio protection features with Newham’s dual-earpiece master-slave architecture allegedly renders the claimed system of a "cluster" of devices obvious.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA), seeking to implement the pair of earpieces mentioned in Goldstein873, would have been motivated to consult Newham. Newham provides a known solution for implementing a master-slave arrangement between wireless earpieces, a technique that would predictably improve the functionality and battery life of the system contemplated by Goldstein873.
    • Expectation of Success: Petitioner contended that a POSITA would have a reasonable expectation of success because both references describe earpiece systems using standard wireless protocols like Bluetooth. Combining Newham’s master-slave communication protocol with Goldstein873’s audio processing logic would be a straightforward integration of known technologies to achieve a predictable result.

Ground 1B: Claim 44 is obvious over Goldstein873, Newham, and Brulle

  • Prior Art Relied Upon: Goldstein873 (Application # 2008/0137873), Newham (Application # 2013/0316642), and Brulle (Application # 2007/0127734).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground builds on the Goldstein873/Newham combination for the core earpiece system. Petitioner introduced Brulle to teach the specific limitation of claim 44, wherein the output device comprises an "infotainment system of a vehicle." Brulle discloses an information distribution system for vehicles that flexibly routes audio from sources like mobile phones, navigation systems, and radio to various outputs, including wireless headsets.
    • Motivation to Combine: A POSITA would have been motivated to adapt the hearing protection earpiece system of Goldstein873/Newham for use in a vehicle, a common environment for audio consumption. Brulle provides a known method for integrating wireless audio devices with a vehicle’s audio system. The combination would enhance the utility of the earpieces by allowing them to function within a vehicle's infotainment system.
    • Expectation of Success: The integration would be predictable, as Brulle’s system is designed to work with standard wireless devices, such as the Bluetooth-enabled earpieces disclosed in Goldstein873.

Ground 2A: Claims 32, 33, and 36-38 are obvious over Goldstein873, Newham, and Chaudhri

  • Prior Art Relied Upon: Goldstein873 (Application # 2008/0137873), Newham (Application # 2013/0316642), and Chaudhri (Application # 2009/0061837).

  • Core Argument for this Ground:

    • Prior Art Mapping: This ground uses the Goldstein873/Newham combination as a base and adds Chaudhri. Petitioner argued that Goldstein873 teaches monitoring sound parameters (SPL) and aggregating them over time through its "SPL Dose" calculation, which quantifies cumulative sound exposure. However, Goldstein873 does not focus on manual user volume control. Chaudhri discloses a mobile media player (specifically an iPod, a device also mentioned in Goldstein873) with a graphical user interface that includes a volume slide control for manual adjustment of audio output.
    • Motivation to Combine: A POSITA implementing the audio system of Goldstein873/Newham would recognize the need for a conventional manual volume control. Since Goldstein873 does not detail this feature but acknowledges its system can interface with media players like an iPod, a POSITA would be motivated to look to a reference like Chaudhri, which teaches a standard implementation of volume control on such a device.
    • Expectation of Success: Combining a hearing protection system with a standard user volume control is a simple application of known techniques to a known device. The result—a system that both automatically protects hearing and allows for manual volume adjustment—would be entirely predictable.

  • Additional Grounds: Petitioner asserted an additional obviousness challenge (Ground 2B) against claims 34 and 35 based on the combination of Goldstein873, Newham, Chaudhri, and Smith (Application # 2014/0254842). This ground relied on Smith’s disclosure of using microphones sensitive to infrasound and ultrasound to add the capability of detecting sounds outside the normal human hearing range.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 32-44 of the ’016 patent as unpatentable.