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IPA Technologies Inc. v. Amazon.Com, Inc.

United States District Court, D. Delaware

March 31, 2018

IPA TECHNOLOGIES, INC., Plaintiff,
v.
AMAZON.COM, INC. and AMAZON DIGITAL SERVICES, LLC, Defendants. IPA TECHNOLOGIES, INC., Plaintiff,
v.
SONY ELECTRONICS INC. AND SONY MOBILE COMMUNICATIONS USA INC., Defendants. IPA TECHNOLOGIES, INC., Plaintiff,
v.
DISH NETWORK CORP and DISH NETWORK L.L.C., Defendants. IPA TECHNOLOGIES, INC., Plaintiff,
v.
TCL COMMUNICATION TECHNOLOGY HOLDINGS, LTD., TCT MOBILE LIMITED, and TCT MOBILE US, INC., Defendants. IP A TECHNOLOGIES, INC., Plaintiff,
v.
LG ELECTRONICS INC., LG ELECTRONICS U.S.A., INC., and LG ELECTRONICS MOBILECOMM U.S.A., INC., Defendants. IP A TECHNOLOGIES, INC., Plaintiff,
v.
HUA WEI TECHNOLOGIES CO., LTD. and HUA WEI DEVICE USA, INC., Defendants.

          Stephen P. Brauerman, BAYARD, P.A., Wilmington, DE; Marc A. Fenster and Brian Ledahl, RUSS, AUGUST & KABAT, Los Angeles, CA. Attorneys for Plaintiff.

          Andrew C. Mayo, ASHBY & GEDDES, Wilmington, DE; J. David Hadden and Ravi Ranganath, FENWICK & WEST LLP, Mountain View, CA. Attorneys for Defendants Amazon.com and Amazon Digital Services, LLC.

          Rodger D. Smith, MORRIS, NICHOLS, ARSHT & TUNNEL LLP, Wilmington, DE; Michael Hendershot and David Okano, PAUL HASTINGS LLP, Palo Alto, CA. Attorneys for Defendants Sony Electronics Inc. and Sony Mobile Communications (USA) Inc.

          MEMORANDUM OPINION

          ANDREWS, U.S, . DISTRICT JUDGE.

         Presently before the Court is the Amazon Defendants' Motion to Dismiss Pursuant to Federal Rule of Civil Procedure 12(b)(6) (No. 16-1266, D.I. 12). The issues are fully briefed. (D.I. 13, 15, 17). The Court held oral argument on November 16, 2017.[1] (D.I. 25). For the reasons that follow, the Court will grant Defendants' motion to dismiss as to claim 1 of the '021 patent, claim 1 of the '061 patent, and claim 1 of the '718 patent.

         I. BACKGROUND

         Plaintiff filed suit on December 19, 2016, alleging that Defendants infringe U.S. Patent Nos. 6, 742, 021 ("the '021 patent"), 6, 523, 061 ("the '061 patent"), and 6, 757, 718 ("the '718 patent") owned by Plaintiff. (D.I. 1). The asserted patents are generally directed to navigating an electronic data source by means of spoken language. ('021 patent, Abstract). The asserted patents share a common specification. (D.I. 13, p. 4 n.2).

         Claim 1 of the '021 patent reads:

1. A method for speech-based navigation of an electronic data source, the electronic data source being located at one or more network servers located remotely from a user, comprising the steps of:
(a) receiving a spoken request for desired information from the user;
(b) rendering an interpretation of the spoken request;
(c) constructing at least part of a navigation query based upon the interpretation;
(d) soliciting additional input from the user, including user interaction in a non-spoken modality different than the original request without requiring the user to request said non-spoken modality;
(e) refining the navigation query, based upon the additional input;
(f) using the refined navigation query to select a portion of the electronic data source; and
(g) transmitting the selected portion of the electronic data source from the network server to a client device of the user.

('021 patent, claim 1). Claim 1 of the '061 patent reads:

1. A method for utilizing agents for speech-based navigation of an electronic data source, comprising the steps of:
(a) receiving a spoken request for desired information from a user;
(b) rendering an interpretation of the spoken request;
(c) constructing a navigation query based upon the interpretation;
(d) routing the navigation query to at least one agent, wherein the at least one agent utilizes the navigation query to select a portion of the electronic data source; and
(e) invoking a user interface agent for outputting the selected portion of the electronic data source to the user, wherein a facilitator manages data flow among multiple agents and maintains a registration of each of said agents' capabilities.

('061 patent, claim 1). Claim 1 of the '718 patent reads:

1. A method for speech-based navigation of an electronic data source located at one or more network servers located remotely from a user, wherein a data link is established between a mobile information appliance of the user and the one or more network servers, comprising the steps of:
(a) receiving a spoken request for desired information from the user utilizing the mobile information appliance of the user, wherein said mobile information appliance comprises a portable remote control device or a set-top box for a television;
(b) rendering an interpretation of the spoken request;
(c) constructing a navigation query based upon the interpretation;
(d) utilizing the navigation query to select a portion of the electronic data source; and
(e) transmitting the selected portion of the electronic data source from the network server to the mobile information appliance of the user.

('718 patent, claim 1).

         On June 26, 2017, Plaintiff submitted proposed claim constructions for purposes of Defendants' motion ...


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