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Potter Voice Technologies, LLC v. Apple Inc.

Representative Claim

Claim 1:

A method for controlling a digital computer using oral input, comprising:

(a) providing receiving means and a digital computer;

(b) receiving oral input comprising a plurality of words;

(c) generating input information corresponding to said oral input;

(d) associatively searching a tabular data structure comprising labels using at least a first part of said input information to locate at least a first label in such tabular data structure relating to said input information; and

(e) determining content information relating to said oral input.


Claim 22:

An apparatus for using oral input to control a digital computer, comprising:

(a) receiving means for receiving oral input;

(b) word recognition means, operatively associated with said receiving means, for generating input information;

(c) a digital computer, operatively associated with said word recognition means;

(d) storage means located within said digital computer, for storing data in a tabular data structure;

(e) search means, located within said digital computer, for associatively searching said tabular data structure, comprising means for identifying labels within said tabular data structure which relate to at least a first part of such input information;

(f) content determination means, located within said digital computer, for determining content information relating to input information; and

(g) processing means, located within said digital computer, for processing data.


Rule 12(C) – Motion Summary Judgment under 35 U.S.C. § 101.

Abstract Idea: Yes

The present patent is like that in Ultramercial in that it is directed to an abstraction; its disclosure of the use of a human voice to control a computer has no tangible or concrete form. Like Ultramercial, the claims contain some limitations, such as the use of a microphone and word recognition software, but these are not novel inventions.

Something More: Yes/No

Claims 1, 4, 6, and 7

The patent does not introduce any novel hardware. PVT does not claim that a digital computer, storage means, processing means or audio speakers are inventive. The independent claims disclose a way to use oral input to control a digital computer, comprising several components. . . . These disclosures fail to provide an inventive concept. With the exception below, the claims simply recite the abstract idea of finding and processing data implemented on a generic computer which is controlled by a generic word recognition device.

Claims 22-24

Claim 22 contains a means-plus-function content determination term. . . . Although the claim term does not disclose any inventive concepts, the specification further describes using content determination in conjunction with natural language and associative search. See ’659 patent at 11:7–27. PVT argues that the ’659 patent advanced existing voice controls for computers by using syntactic and semantic content information to enable associative searching. . . .. PVT contends that these teachings allow the computer to identify or access something “merely by describing it using natural language words” instead of requiring “the user to determine and input an address, or point at a visual representation, in order to identify or access a data element or object, or to specify an action.” ’659 patent at 3:7–14.  In light of Alice’s instruction to “tread carefully in construing [its] exclusionary principle lest it swallow all of patent law,” the Court finds that claim 22 and its dependent claims, claims 23 and 24, may involve an inventive concept of content determination when described and limited by the relevant language in the specification.1 134 S.Ct. at 2354.