PTAB

IPR2026-00145

Amazon.com Services LLC v. Smart Speaker LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: System and method for server-based control
  • Brief Description: The ’710 patent relates to a method for operating multiple actuators using a client device, a controlled device, and an external, Internet-connected server. The method requires capturing a first human voice command to operate an actuator within the client device itself, and capturing a second human voice command to operate an actuator in a separate, wirelessly connected controlled device, such as a home appliance.

3. Grounds for Unpatentability

Ground 1: Obviousness over Williams - Claims 1, 5-6, 16, 23, and 29 are obvious over Williams.

  • Prior Art Relied Upon: Williams (Application # 2012/0198339).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Williams discloses all elements of the challenged claims. Williams describes a home automation system with an "interface device" (client device) and controllable "on-premises devices" like media players and home automation equipment (controlled devices), all communicating wirelessly. Petitioner asserted that Williams teaches the complete two-command flow of claim 1. First, the interface device captures a user's spoken question, sends it to a remote server for processing, and the server sends back an "audio answer" (first message) to be played on the interface device’s speaker (first actuator). Second, Williams explicitly teaches the system can "accept spoken commands" to "control various on-premises devices," which inherently contain second actuators (e.g., displays on televisions, motors in home automation devices). This control command constitutes the second message operating the second actuator in response to a second voice input.
    • Key Aspects: Petitioner contended that Williams alone discloses the core inventive concept alleged in the ’710 patent: a two-step voice command process where one command prompts a local response on the client device and another prompts an action on a separate controlled device.

Ground 2: Obviousness over Williams and Wittenberg - Claim 2 is obvious over Williams in view of Wittenberg.

  • Prior Art Relied Upon: Williams (Application # 2012/0198339), Wittenberg (Patent 7,529,677).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued Williams provides the base system as described in Ground 1. Claim 2 adds the limitation that the server’s processing comprises "performing a voice recognition algorithm for identifying the voice of a specific person." Wittenberg discloses exactly this feature, teaching a system that performs remote voice recognition processing to "determine whether the audio signal has been supplied by an authorized user."
    • Motivation to Combine: A POSITA would combine Wittenberg's user-specific voice recognition with Williams’ system to provide enhanced, personalized security, which is a highly desirable feature for a system that controls devices within a private home. Petitioner noted that Williams already discloses employing "authorization and authentication safeguards," making the inclusion of Wittenberg's specific, well-known voice biometric technique a predictable and logical improvement. Wittenberg itself touts that its method provides an "additional degree of security."
    • Expectation of Success: A POSITA would have a reasonable expectation of success because the underlying algorithms for performing voice recognition were well-known at the time, as stated by Wittenberg.

Ground 3: Obviousness over Howard and Doherty - Claims 1, 5-6, 10-11, 13, 16-21, 23, and 29 are obvious over Howard in view of Doherty.

  • Prior Art Relied Upon: Howard (Patent 7,062,339), Doherty ("Wireless Home Networking Simplified," a 2007 textbook).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Howard discloses the complete method of claim 1. Howard describes a portable device (client device) with a microphone and speaker that captures distinct voice commands and sends them to a server for processing. For example, a first voice command ("TV") causes the server to send back a first message (the audio reply "What can I do for you?") to the portable device’s speaker (first actuator). A subsequent, second voice command ("A little small") causes the server to generate and send a second message (control signals) to a separate controlled device (a VTR) to adjust its volume, thereby operating a second actuator.
    • Motivation to Combine: Petitioner argued that while Howard teaches the core functionality, Doherty provides the conventional network architecture to implement it in a modern home. Doherty is a textbook that teaches a POSITA how to set up a standard wireless home network where multiple devices communicate via a central wireless router connected to the Internet. A POSITA would combine Howard’s system with Doherty’s teachings to ensure reliable wireless connectivity for all devices (the portable client, TVs, etc.) and to implement Howard’s server as a remote cloud server. This is motivated by the known benefits, acknowledged in Howard, of offloading complex processing to a server to reduce the cost, size, and power consumption of the local client device.
    • Expectation of Success: The combination would yield the predictable result of a more robust and efficient system by applying Doherty’s standard, off-the-shelf networking solutions to Howard's functional client-server architecture.
  • Additional Grounds: Petitioner asserted numerous additional obviousness grounds. These included challenges based on Williams in view of Gruber, Benesty, Goldsmith, Chatterjee, Rosenberger, and Rossing to add features such as sensor integration, microphone arrays, specific wireless protocols, and control of various home appliances. Petitioner also asserted analogous grounds using the Howard and Doherty combination in view of these same secondary references.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-29 of Patent 11,128,710 as unpatentable.