Google LLC v. Sonos Inc

1. Case Identification

• Case #: IPR2026-00131
• Patent #: 10,966,025
• Filed: November 24, 2025
• Petitioner(s): Google LLC
• Patent Owner(s): Sonos, Inc.
• Challenged Claims: 1-4, 7-10, 12-23

2. Patent Overview

• Title: Pairing Playback Devices
• Brief Description: The ’025 patent discloses systems for pairing individual network-enabled playback devices to create or enhance a multi-channel listening environment. The devices can switch between an unpaired state, where they play audio independently (e.g., stereo), and a paired state, where they play different assigned channels (e.g., left/right) of the same audio source as part of a synchronized group.

3. Grounds for Unpatentability

Ground 1: Obviousness over Litbak and Seydoux - Claims 1, 3-4, 7-10, 12-14, 16, 18, and 21 are obvious over Litbak in view of Seydoux.

• Prior Art Relied Upon: Litbak (Application # 2007/0055399) and Seydoux (Application # 2007/0160225).
• Core Argument for this Ground:
  • Prior Art Mapping: Petitioner argued that Litbak disclosed the core inventive concept: an "audio switching arrangement" that, upon receiving an "actuation signal," switches between two states. In the unpaired "straight-through state," it outputs two-channel stereo audio locally. In the paired "diverted state," it outputs one audio channel locally while transmitting the other channel to a remote "puppet" device for playback. Petitioner contended that Litbak described a conceptual framework but omitted necessary, conventional implementation details. Seydoux allegedly supplied these details, teaching a wireless network of loudspeakers using standard technologies like Bluetooth, a remote controller to send commands, and a processor with memory executing software modules for audio processing and establishing connections. The combination of Litbak’s switching concept with Seydoux’s well-known wireless implementation details allegedly rendered the independent claims obvious.
  • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Seydoux's off-the-shelf wireless and processing components with Litbak's system to make it a functional, marketable product. Litbak expressly noted its components were "standard items" from "common wireless household communication systems," which would have directed a POSITA to known solutions like the Bluetooth systems described in Seydoux.
  • Expectation of Success: A POSITA would have a high expectation of success, as the combination involved implementing well-known technologies (e.g., Bluetooth modules, processors, software) for their intended and predictable functions to enable Litbak's audio switching concept.

Ground 2: Obviousness over Litbak, Seydoux, and Palmer - Claims 2, 17, 19-20, and 22-23 are obvious over Litbak and Seydoux in view of Palmer.

• Prior Art Relied Upon: Litbak (Application # 2007/0055399), Seydoux (Application # 2007/0160225), and Palmer (Patent 5,581,626).

• Core Argument for this Ground:

  • Prior Art Mapping: This ground built upon the base combination of Litbak and Seydoux. Petitioner asserted that certain dependent claims require changing the audio processing (e.g., pass-filter parameters or frequency response) based on the device's pairing status. Palmer allegedly taught this exact concept, disclosing a speaker system that automatically switches its equalization when a subwoofer is added. When operating alone (unpaired), the system used "full range filters." When a subwoofer was connected (paired), the system switched to "high pass filters," directing only mid- and high-range frequencies to the main speakers. This teaching of using different filter parameters for different frequency ranges based on pairing status directly maps to the limitations of the challenged dependent claims.
  • Motivation to Combine: A POSITA, having already created a surround sound system by expanding upon the Litbak/Seydoux combination, would be motivated to incorporate Palmer's filter-switching technique. This would optimize audio performance by allowing the main speakers to handle mid/high frequencies while a paired subwoofer handles low frequencies, a common and advantageous configuration in multi-channel audio systems.
  • Expectation of Success: Success would be reasonably expected because implementing filter switching via software, as suggested by Seydoux's architecture, was a routine and conventional practice in digital audio processing.

• Additional Grounds: Petitioner asserted additional obviousness challenges against claim 12 based on Litbak and Seydoux in view of Holm, and against claim 15 based on Litbak and Seydoux in view of Lee, but relied on similar design modification theories to incorporate further conventional features.

4. Key Claim Construction Positions

• Petitioner stated that no terms required construction but noted that the parties in related litigation had agreed to certain constructions, which the prior art meets.
• The construction for "pair"/"pairing"/"paired" was defined as a "configuration involving two or more playback devices that have different playback roles." This construction was central to Petitioner's argument that Litbak’s "diverted state"—where the "arrangement" plays one channel and the "puppet" plays another—meets the claim limitations for pairing.

5. Key Technical Contentions (Beyond Claim Construction)

• Priority Date Entitlement: Petitioner contended that the ’025 patent was not entitled to a priority date earlier than January 25, 2011. It was argued that key limitations recited in the independent claims—such as receiving a pairing instruction and performing different processing based on pairing status—were not disclosed in the earlier priority applications. As all cited prior art predates January 25, 2011, Petitioner argued the references were valid prior art regardless of whether the Board resolved the priority date dispute.

6. Arguments Regarding Discretionary Denial

• Petitioner argued against discretionary denial under 35 U.S.C. §325(d). It was asserted that while Seydoux and Holm were previously cited by the USPTO during prosecution, they were never relied upon or considered in the specific combinations presented in the petition. Because the same or substantially the same art and arguments were not previously presented to the Office, Petitioner contended that the Examiner materially erred and that the petition should be considered on its merits.

7. Relief Requested

• Petitioner requests institution of an inter partes review and cancellation of claims 1-4, 7-10, and 12-23 of the ’025 patent as unpatentable.