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Inter Partes Reviews
`U.S. Patent No. 7,076,431
`and
`U.S. Patent No. 9,451,084
`Oral Argument, June 22, 2021
`
`Apple Inc. v. Parus Holdings, Inc.
`Case Nos. IPR2020-00686 and IPR2020-00687
`
`Petitioner’s Demonstrative Exhibits – Not Evidence
`
`Petitioner’s DX-1
`
`

`

`Grounds for ’431 Patent
`1. Ground 1: Claims 1-3, 8-10, and 14
`} Ladd (Ex. 1004) in view of Kurosawa (Ex. 1005) in further view of
`Goedken (Ex. 1006)
`
`2. Ground 2: Claims 7, 19, and 26-30
`▸ Ladd, Kurosawa, and Goedken in further view of Madnick (Ex. 1007)
`
`3. Ground 3: Claims 5-6
`▸ Ladd, Kurosawa, and Goedken in further view of Houser (Ex. 1008)
`
`4. Ground 4: Claims 9 and 25
`▸ Ladd, Kurosawa, and Goedken in further view of Rutledge (Ex. 1010)
`
`The ’084 Petition presents corresponding Grounds 1-6 relying on the same references
`
`Petition (Paper 1), 10 (identifying challenged claims)
`All citations to the ’431 Patent IPR
`
`Petitioner’s DX-2
`
`

`

`Disputes
`“Speaker-Independent Speech Recognition Device”
`1.
`▸ Ladd teaches this limitation under every construction
`
`2.
`
`Limitation 1(K)
`▸ Ladd in view of Kurosawa and Goedken teaches sequentially
`accessing web sites
`
`3. Motivations to Combine
`▸ Apple provided MTCs the Board found persuasive at Institution
`
`4. Claims 5 and 6
`▸ Ground 3 relies on Houser for Claims 5 and 6
`
`Pet. Reply (Paper 19), 2-3, 15-16, 18, 24
`
`Petitioner’s DX-3
`
`

`

`Automatic Speech Recognition
`
`Mr. Occhiogrosso’s Declaration:
`
`PO Sur-Reply (Paper 21), 11
`
`Ex. 2025, ¶ 49
`
`Petitioner’s DX-4
`
`

`

`Automatic Speech Recognition
`Mr. Occhiogrosso’s Deposition:
`
`Ex. 1039, 40:2-22
`
`Pet. Reply, 5
`
`Petitioner’s DX-5
`
`

`

`’431 Patent, Claim 1
`
`1(C)
`
`1(H)
`
`1(K)
`
`’431 Patent (Ex. 1001), Claim 1
`
`Petitioner’s DX-6
`
`

`

`Claim Construction for “Speaker-Independent
`Speech Recognition Device”
`
`} District Court Construction:
`} “speech recognition device that recognizes
`spoken words without adapting to individual
`speakers or using predefined voice patterns”
`} Parus’s Construction:
`} “speech recognition device that recognizes
`spoken words without using predefined voice
`patterns”
`} Petition Filed: March 18, 2020; Court’s CC
`Order: Sept. 8, 2020
`
`Ex. 2012, 14-15
`
`Ex. 1041, 2
`
`Pet. Reply, 2
`
`Petitioner’s DX-7
`
`

`

`’431 Patent: “Voice Patterns”
`
`’431 Patent’s
`discussion of
`voice patterns
`’431 Patent, 4:38-43
`
`Mr. Occhiogrosso’s
`testimony on voice
`patterns
`Ex. 1039, 25:2-6
`
`Pet. Reply, 2
`
`Petitioner’s DX-8
`
`

`

`Converting Speech into Text
`Mr. Occhiogrosso’s Deposition:
`
`Pet. Reply, 6
`
`Ex. 1039, 33:11-20
`
`Petitioner’s DX-9
`
`

`

`Parus’s “Voice Patterns” Definition
`} Mr. Occhiogrosso’s Deposition:
`
`Ex. 1039, 25:12-17
`
`Pet. Reply, 3-4, 10; Ex. 1040, ¶¶ 23-24
`
`Petitioner’s DX-10
`
`

`

`Ladd’s “Speech Patterns”
`} Ladd’s Description:
`
`Ladd, 9:28-35
`
`Ladd, 8:23-25
`
`Pet. (Paper 1), 22-23; Pet. Reply, 3-4, 9-11
`
`Petitioner’s DX-11
`
`

`

`Ladd’s “Selected Speech Pattern”
`} Apple’s Petitioner Reply:
`
`Pet. Reply, 9-10
`
`Pet. Reply, 9-10
`
`Petitioner’s DX-12
`
`

`

`Parus’s Statement on Ladd’s Teachings
`
`Parus’s Sur-Reply:
`
`i
`
`PO Sur-Reply, 8
`
`PO Sur-Reply, 8
`
`Petitioner’s DX-13
`
`

`

`Exemplary Process from the ’431 Patent
`
`* * * * *
`
`Pet. Reply, 5
`
`’431 Patent, 6:21-56
`
`Petitioner’s DX-14
`
`

`

`}P
`
`arus Raised Two-Phase
`Speech Recognition
`
`…………………………………………………
`
`Mr. Occhiogrosso’s
`Deposition
`Testimony:
`
`Ex. 1039, 52:19-22
`
`Phase (1)
`
`Phase (1I)
`
`Pet. Reply, 7; PO Sur-Reply, 14
`
`Ex. 1039, 49:9-19
`
`Petitioner’s DX-15
`
`

`

`Parus Raised Two-Phase
`Speech Recognition
`
`Parus’s Sur-Reply:
`
`PO Sur Reply, 14
`
`PO Sur-Reply, 14
`
`Petitioner’s DX-16
`
`

`

`“Predefined”
`
`Pet. Reply, 12
`
`Pet. Reply, 12
`
`Petitioner’s DX-17
`
`

`

`Limitation 1(K)
`} Parus Admits to Understanding the Correct Mapping
`
`Patent Owner Response, 24-25
`
`} At Institution (Paper 9, 37-39), the Board found the combination with
`Kurosawa and Goedken teaches limitation 1(k)
`
`Ex. 2025, 95
`
`Pet. Reply, 15-17
`
`Petitioner’s DX-18
`
`

`

`Apple Has Provided
`Motivations to Combine
`} At Institution, the Board found persuasive:
`} Quick and efficient answering
`} Returns information “as soon as possible”
`} Responding within 3-5 seconds (Bennett)
`} Real-time and natural responses
`} Reduces frustration by minimizing wait time
`} The Board agreed Goedken does not teach away
`} “[a] reference may be read for all that it teaches, including uses
`beyond its primary purpose”
`} No Impermissible Hindsight
`} Motivations based on references and expert opinion
`
`Pet., 44-47; Pet. Reply, 18-23; Inst. Decision (Paper 9), 39-42
`
`Petitioner’s DX-19
`
`

`

`Claims 5 and 6
`} Ground 3 of the ’431 Patent relies on Houser for teaching the
`limitations of claims 5 and 6
`
`’431 Patent, Claims 5-6
`
`’431 Patent, Claims 5-6; Pet. Reply, 24-25
`
`Petitioner’s DX-20
`
`

`

`Claims 5 and 6
`} Parus contends:
`
`PO Sur-Reply, 23
`
`PO Sur-Reply, 23
`
`Petitioner’s DX-21
`
`

`

`Parus’s Motion to Exclude
`} Parus seeks to exclude Ex. 1040 (Supp. Dec) as non-responsive
`to POR
`} Ex. 1040 responded to Parus’s new claim construction
`} A Petitioner is allowed to respond to new claim constructions
`} Parus should have sought leave to file a Motion to Strike
`
`PO Motion to Exclude (Paper 29), 2; Pet. Opp. to Motion to Exclude (Paper 30), 1
`
`Petitioner’s DX-22
`
`

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