PTAB

IPR2026-00147

Amazon.com Services LLC v. Smart Speaker LLC

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Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: System for Operating Actuators Using Voice Data
  • Brief Description: The ’174 patent describes a system for operating multiple actuators in response to captured human voice data. The system architecture generally involves a local client device that captures voice, an external internet-connected server that processes the voice data, and one or more controlled devices that perform actions based on commands derived from the voice data.

3. Grounds for Unpatentability

Ground 1: 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, which relates to controlling appliances using a voice-enabled device, discloses all elements of the challenged claims. Lim’s "controlling device" (e.g., a smartphone) was identified as the claimed client device, which includes a microphone, speaker, and display (actuators). Lim’s "controllable appliances" (e.g., televisions, HVAC systems) were mapped to the controlled device with a second actuator. Lim’s "remote server" performs speech recognition and was mapped to the claimed Internet-connected server device. Petitioner asserted that Lim shows the client device capturing voice, sending it to the server over a wireless network, receiving messages back from the server, and operating both its own actuators (e.g., providing a synthesized spoken prompt) and the actuators of the controlled devices in response.
    • Motivation to Combine (for §103 grounds): As a single-reference ground, the argument was that Lim itself renders the claims obvious without combination.

Ground 2: 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) and Lim (Application # 2013/0132094).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Williams discloses a voice-controlled smart-home system with an interface device (client), a server, and on-premises devices (controlled devices) that collectively meet the limitations of claim 1. Williams’s system accepts spoken commands, processes them on a remote server, and operates actuators in both the interface and controlled devices.
    • Motivation to Combine (for §103 grounds): A POSITA would combine the teachings of Williams and Lim to create a more reliable and scalable system. Petitioner argued Williams’s architecture, where the server may communicate with numerous individual controlled devices, is less efficient than Lim’s. A POSITA would have been motivated to modify Williams by incorporating Lim’s approach, where the server communicates with a central client device, which then acts as a local hub to distribute commands to the various controlled devices. This modification simplifies network management and improves security.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in this combination, as it would predictably enhance system reliability and scalability by implementing a well-understood centralized hub-and-spoke communication model.

Ground 3: Claim 2 is obvious over Lim in view of Wittenberg.

  • Prior Art Relied Upon: Lim (Application # 2013/0132094) and Wittenberg (Patent 7,529,677).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner contended that Lim provides the base system of claim 1, and Wittenberg supplies the additional limitation of claim 2: "performing a voice recognition algorithm for identifying the voice of a specific person." Wittenberg was cited for its explicit disclosure of a remote voice recognition processor that analyzes audio signals to determine if the speaker is an "authorized user" by comparing speech characteristics against stored voice information.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Wittenberg’s user-authentication feature with Lim’s general voice-control system to enhance security. Wittenberg was argued to expressly teach this benefit, stating that its voice recognition processing "provides an additional degree of security" by preventing unauthorized individuals from manipulating a local device.
    • Expectation of Success: Success would be expected because both references operate in the analogous field of remote voice processing for device control, and adding a known security feature like user-specific voice identification would be a predictable improvement to Lim’s system.

  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges based on combinations of Lim or Williams-Lim with other references to teach specific dependent claim features. These included: Gruber (Application # 2012/0265528) for using device sensors to provide contextual information; Benesty (a 2008 textbook) for using microphone arrays to improve audio pickup; Goldsmith (a 2005 textbook) for disclosing specific wireless communication standards (WLAN, 3G); Chatterjee (Application # 2013/0052946) for controlling specific types of household appliances; Rosenberger (Patent 8,340,975) for using an illuminated LED to indicate device status; and Rossing (a 2007 textbook) for conventional microphone and speaker designs.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-29 of the ’174 patent as unpatentable.