District Court Dismissed Claim Directed to Natural Speech Processing in a Vehicle-Mounted System as Patent Ineligible

November 21, 2023

Reading Time : 4 min

The Eastern District of Virginia recently dismissed a patent infringement claim, holding that the asserted claim directed to natural speech processing is patent ineligible under 35 U.S.C. § 101, because it fails the Alice framework. Under step one, the court found the claim is directed to an abstract idea, because it is “plainly result-oriented” and “directed to any arrangement of programs and processors.” Under step two, the court found the claim lacks an inventive concept, because it does not explain how its “conclusory, result-oriented requirements” overcome the defects in prior art.

Dialect, LLC v. Amazon.com, No. 1:23-cv-581 (E.D. Va.).

Dialect sued Amazon for infringing seven patents. Amazon moved to dismiss six of the patents for patent ineligibility under § 101. The court only considered the asserted claim of one patent, deferring a ruling on the others until further proceedings. The claim at issue is from U.S. Patent No. 9,031,845, which is directed to a vehicle-mounted system of physical processors programmed to process natural speech. The court summarized the claim as a set of prior art physical processors that: (1) perform speech recognition; (2) use the parsed and interpreted message to choose a piece of software to address the message; (3) translate the message into a form the selected sub-processor can understand; (4) determine whether the formulated command or query is to be executed on or off-board the vehicle; and (5) either execute the command at the vehicle or send it to the off-board destination using a wireless wide area network.

The court analyzed eligibility using the Supreme Court’s two-step Alice framework. In step one, a court determines whether the claims, in their entirety, are “directed to a patent-ineligible concept,” such as an abstract idea. Alice Corp. v. CLS Bank Int’l, 573 U.S. 208, 217 (2014). If they are, the court proceeds to step two—the search for an “inventive concept”—and considers “the elements of each claim both individually and ‘as an ordered combination’ to determine whether the additional elements ‘transform the nature of the claim’ into a patent-eligible application.” Id. (citing Mayo Collaborative Servs. v. Prometheus Lab’ys, Inc., 566 U.S. 66, 78-79 (2012)).

1. Alice Step One

Addressing Alice step one, the court concluded that the claim is directed to the abstract idea of using context to execute a spoken request. The court considered examples of abstract claims from the Federal Circuit, such as claims directed to a process for which computers are invoked merely as a tool, claims reciting mental processes (e.g., collecting and analyzing data), and claims that recite result-based functional language. The court found that the asserted claim is “plainly result-oriented” because it is directed to “any arrangement of programs and processors that accomplishes Claim 1’s stated goal.” The court also found that the asserted claim recites functionality, “regardless of the method of deployment” and “using exclusively generic, prior-art components.” In addition, the court decided that the claimed process—essentially, “understanding language using context, determining whether an on- or off-board processor is to handle that language, and then using that processor to execute the language”—is no less abstract than the collection of information, comprehension of its meaning, and the indication of the results, which is an idea the Federal Circuit has repeatedly found to fail Alice step one.

The patent owner argued that the claim is directed to a “specific improvement to vehicle-based systems” and not an abstract idea, because it “recites a system that formulates a command or query based on a domain and context … [and] recites determining whether that command or query is to be executed on-board or off-board the vehicle.” The court rejected this argument because “it inappropriately considers Claim 1’s elements in isolation from one another.” The court explained that Alice step one requires that a claim be assessed “in [its] entirety” to determine its “focus.”

2. Alice Step Two

Addressing Alice step two, the court concluded the claim lacked any inventive concept. The court first filtered out from the claim the use of the ineligible abstract idea itself and found that the only aspect that remains is “determining whether [the] command or query is to be executed on-board or off-board the vehicle” and then executing it. The court found there was nothing inventive about this portion and that the patent owner did not plead any facts that would demonstrate this “conclusory step” is not “well-understood, routine, and conventional to a skilled artisan in the relevant field.”

The patent owner argued that the asserted claim discloses “specific improvements” because prior art systems “relied solely on keywords to determine whether processing should be performed on-board or off-board the vehicle” rather than using context as in claim 1. The court rejected this argument because it “rests on novelty, not inventiveness.” The court reasoned that a claim element that adds “nothing of significance to the underlying abstract idea is, no matter how novel, insufficient to salvage an invalid claim at Alice Step Two.” The patent owner also argued inventiveness because claim 1 discloses “a novel configuration of software structures.” The court rejected this argument as conclusory because the patent owner did not explain how. The patent owner pointed to an embodiment in the specification, but the court noted that “features that are not claimed are irrelevant” to the Alice analysis.

Practice Tip: Patent owners should avoid claiming a result and instead claim the means to achieving that result. Patent owners should claim with specificity rather than using general language that direct claims to any arrangement of system components. Patent owners should avoid equating the novelty analysis with the inventive analysis, as the two are separate inquiries. Patent owners should also state limitations in the claim when asserting inventiveness, as limitations in the specification are not enough.

Share This Insight

Previous Entries

IP Newsflash

December 2, 2024

The Patent Trial and Appeal Board determined that a reference could be used as prior art because patent owner failed to provide sufficient evidence that the prior art’s disclosure was invented by all four named inventors, and thus the same “inventive entity,” as the challenged claims.

...

Read More

IP Newsflash

December 2, 2024

The Patent Trial and Appeal Board rejected a patent owner’s assertion that petitioner should have named a third party, which was a defendant in a related district court patent infringement litigation and a party to a joint defense agreement (JDA) with petitioner, as a real party-in-interest (RPI). Had the board ruled otherwise and found the third party to be an RPI, the petition would have been time-barred under 35 U.S.C. § 315(b).

...

Read More

IP Newsflash

November 27, 2024

A district court recently refused to exclude testimony regarding consumer surveys conducted by a design patent expert, holding instead that the consumer surveys may be probative of how an ordinary observer would view the designs at issue, and thus could assist the factfinder in determining design patent infringement under the ordinary observer test.

...

Read More

IP Newsflash

November 5, 2024

The Federal Circuit vacated a district court’s fee award because the district court considered certain information that was not relevant to the question of whether plaintiff’s case was exceptional. Specifically, the Federal Circuit held that only those “red flags” that related to the successful Section 101 defense, which served as the basis for the district court’s grant of summary judgment, could be used to show the case was fatally flawed.   

...

Read More

IP Newsflash

November 1, 2024

The Federal Circuit’s decision in Kyocera Senco Industrial Tools Inc. v. International Trade Commission articulated a bright-line test for patent expert admissibility: to testify from the perspective of a “person of ordinary skill in the art” (POSITA), the expert must at least meet the definition of a POSITA for the patents-in-suit. Absent that level of skill, Kyocera holds that the witness’s testimony is not sufficiently reliable or relevant enough to be relied on by a fact-finder.

...

Read More

IP Newsflash

October 29, 2024

The PTAB denied a petitioner’s motion to compel routine discovery that sought information from a parallel ITC investigation for alleged inconsistent positions taken by patent owner in the IPR. The board found that patent owner had not taken inconsistent positions but warned patent owner that it had an ongoing duty to produce any information inconsistent with arguments made during the present IPR, even if that information related to arguments patent owner had dropped at the ITC.

...

Read More

IP Newsflash

October 11, 2024

The Central District of California ruled that the heightened pleading standard of Federal Rule of Civil Procedure 9(b) applies to all three prongs of a false patent marking claim, including the third prong, competitive injury. In doing so, took a clear stand on an issue with a nationwide split among district courts.

...

Read More

IP Newsflash

October 10, 2024

In a patent case containing a variety of federal and state law claims, the District of Massachusetts retained supplemental jurisdiction over the state law claims even after all the federal law claims were dismissed.

...

Read More

© 2024 Akin Gump Strauss Hauer & Feld LLP. All rights reserved. Attorney advertising. This document is distributed for informational use only; it does not constitute legal advice and should not be used as such. Prior results do not guarantee a similar outcome. Akin is the practicing name of Akin Gump LLP, a New York limited liability partnership authorized and regulated by the Solicitors Regulation Authority under number 267321. A list of the partners is available for inspection at Eighth Floor, Ten Bishops Square, London E1 6EG. For more information about Akin Gump LLP, Akin Gump Strauss Hauer & Feld LLP and other associated entities under which the Akin Gump network operates worldwide, please see our Legal Notices page.