PTAB

IPR2026-00148

Amazon.com Services LLC v. Smart Speaker LLC

Key Events
Petition

1. Case Identification

2. Patent Overview

  • Title: AC Powered Appliance with Sensors and Wireless Network
  • Brief Description: The ’590 patent discloses an Alternating-Current (AC) powered appliance for food handling, storage, or preparation. The appliance includes an AC connector, a current sensor, a second generic sensor for a physical phenomenon, and a wireless transceiver, with these components housed within a single enclosure for monitoring and control over a wireless network.

3. Grounds for Unpatentability

Ground 1: Obviousness over Chan - Claims 1-7, 13-16, 19-27, 29, 30, 32, 38, 41, 44-46, 53 are obvious over Chan.

  • Prior Art Relied Upon: Chan (Application # 2010/0238003).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Chan, which discloses a smart "appliance module" for energy monitoring, renders the challenged claims obvious. Chan’s module sits between an appliance and a wall outlet, connecting via a standard AC socket (the "AC connector"). It contains a current transformer (the "current sensor") to measure energy usage and additional sensors like a temperature and humidity sensor (the "first sensor"). The module includes a Zigbee wireless chipset for communication (the "wireless transceiver" and "antenna") and houses all components in a single device enclosure. Petitioner asserted Chan also teaches controlling the connected appliance via wireless signals, such as for on/off switching.
    • Key Aspects: This ground asserted that Chan alone teaches every limitation of the independent claims and numerous dependent claims, establishing a prima facie case of obviousness without needing a combination of references.

Ground 2: Obviousness over Chan in view of Botts - Claims 50-52 are obvious over Chan in view of Botts.

  • Prior Art Relied Upon: Chan (Application # 2010/0238003), Botts (Patent 8,461,861).
  • Core Argument for this Ground:
    • Prior Art Mapping: Claims 50-52 add limitations for a light source within the enclosure that provides illumination or indication based on received data or measured current. Petitioner argued that Botts teaches a household appliance with an internal energy monitor that uses an indicator (e.g., a green or red LED) to visually convey energy usage.
    • Motivation to Combine: A POSITA would combine Botts's conventional LED indicator with Chan’s monitoring module to improve the device's usability by providing a simple, real-time visual cue for energy consumption. This modification would provide immediate feedback to the user, a known benefit.
    • Expectation of Success: The combination was argued to be predictable, as incorporating a simple LED indicator into an electronic monitoring device was a well-understood and common design practice.

Ground 3: Obviousness over Seo in view of Chan - Claims 1, 23-24, 26-27, 38, 41, 53, 59 are obvious over Seo in view of Chan.

  • Prior Art Relied Upon: Seo (Korean Patent Pub. No. 20100083686), Chan (Application # 2010/0238003).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner presented an alternative ground for claim 1, arguing Seo’s smart refrigerator discloses most claim limitations. Seo’s refrigerator includes a control unit with a power consumption detection unit (current sensor), various other sensors like temperature and gas detectors (first sensor), and a wireless communication unit. The components are housed within the refrigerator's main body (single enclosure).
    • Motivation to Combine: While Seo’s refrigerator is already controlled by received wireless data (e.g., displaying messages or switching energy sources), a POSITA would combine it with Chan’s teachings to add more robust remote-control functionalities, such as the basic on/off switching taught by Chan. This would expand the controllable features of Seo's appliance, an obvious improvement.
    • Expectation of Success: Both references enhance appliance performance through energy monitoring and wireless communication. Petitioner argued that integrating Chan's control features into Seo's already wireless-enabled appliance would be a routine integration of known elements with predictable results.
  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges. These included combining Chan with references teaching specific components, such as Scherz (for relay switch types), Middelhoek (for current and power sensor types), Goldsmith (for satellite and 3G network protocols), Rossing (for microphone and speaker details), Benesty (for microphone arrays), Fraden (for various sensor types), Doherty (for network addressing), and Ozturk (for thermoelectric coolers). Further grounds combined Seo and Chan with these secondary references.

4. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-36 and 38-63 of the ’590 patent as unpatentable.