PTAB

IPR2026-00146

Amazon.com Services LLC v. Smart Speaker LLC

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Petition

1. Case Identification

2. Patent Overview

  • Title: Client Device for Smart Home Control
  • Brief Description: The ’706 patent describes a client device for use in a building with a Wireless Local Area Network (WLAN). The device uses a microphone to capture human voice data, sends this data over the Internet to an external server for processing, and in response, receives messages to operate an actuator on the client device and to send control messages to a separate controlled device (e.g., a home appliance).

3. Grounds for Unpatentability

Ground 1: Obviousness over Lim - Claims 1, 5-6, 10, 12, 16, 20-21, 23, and 29 are obvious over Lim.

  • Prior Art Relied Upon: Lim (Application # 2013/0132094).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Lim discloses all elements of the challenged claims. Lim teaches a “controlling device,” such as a smartphone, with a microphone for capturing voice input. This device connects via WiFi to a remote server over the Internet for speech recognition. Based on the server's processing, Lim’s device receives responsive messages that trigger local actuators (e.g., an illuminated LED, speaker output) and sends control commands to other home appliances (e.g., televisions, HVAC systems). Lim also expressly discloses the client device is addressable using an IP address.
    • Motivation to Combine (for §103 grounds): As a single-reference ground, the argument is that Lim’s disclosure is so comprehensive that modifying it to arrive at the claimed invention would have been an obvious design choice for a person of ordinary skill in the art (POSITA).
    • Expectation of Success (for §103 grounds): The straightforward application of Lim’s teachings would predictably result in the claimed system.

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

  • Prior Art Relied Upon: Lim (Application # 2013/0132094), Wittenberg (Patent 7,529,677).
  • Core Argument for this Ground:
    • Prior Art Mapping: Claim 2 adds the limitation that the server processes voice data using a voice recognition algorithm to identify a specific person. While Lim teaches remote voice processing, Wittenberg explicitly discloses a technique for remotely processing an audio command to determine if the person issuing the command is an authorized user by comparing speech patterns to stored voice information.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Wittenberg’s user-authorization feature with Lim’s smart home control system to achieve greater security. Adding a security layer to prevent unauthorized users from controlling home appliances was a known and desirable improvement.
    • Expectation of Success (for §103 grounds): Integrating Wittenberg’s server-side voice-matching logic into Lim’s existing server-side processing architecture was a predictable combination of analogous technologies.

Ground 9: Obviousness over Williams and Lim - Claims 1, 5-6, 10, 12, 16, 20-21, 23, and 29 are obvious over Williams in view of Lim.

  • Prior Art Relied Upon: Williams (Application # 2012/0198339), Lim (Application # 2013/0132094).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Williams discloses a similar smart home system with an "interface device" (client device) that captures voice commands in a home and communicates with a cloud server over a WLAN. The Williams server processes the commands to control on-premises devices like media players and home automation systems. However, Williams suggests the server may communicate directly with the various controlled devices. Lim provides the missing architectural element: a centralized model where the server sends control information back to the primary client device, which then acts as a local hub to relay commands to the other controlled appliances.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Lim’s centralized hub-and-spoke communication architecture with the Williams system to yield predictable benefits. This combination would simplify network management, improve reliability and security, and make the system easier to scale by having the server manage a connection to a single client hub rather than numerous individual appliances.
    • Expectation of Success (for §1O3 grounds): Applying Lim's well-understood network topology to Williams's analogous smart home system was a predictable design choice with a high expectation of success, as it represented one of a finite number of known solutions for managing networked devices.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges against various claims by combining either Lim or the Williams-Lim system with other secondary references. These included Gruber (for adding sensor data context), Benesty (for using microphone arrays), Goldsmith (for specific WLAN and cellular protocols), Chatterjee (for controlling specific household appliances), Rosenberger (for using multi-color LED status lights), and Rossing (for details of microphone and speaker construction). The motivation for these combinations was generally to add known, desirable features to the base smart home system.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-29 of Patent 12,316,706 as unpatentable.