Potter Voice Technologies LLC, v. Apple, Inc., et al, 4-13-cv-01710 (CAND June 11, 2015, Order) (Wilken, J.)
Wednesday, June 17, 2015
Computer Voice Control Patent Claims Invalid Under 35 U.S.C. § 101
The court granted defendant's motion for judgment on the pleadings that four claims of plaintiff's patent for voice control of a computer were invalid for lack of patentable subject matter and found the claims were directed to an abstract idea. "The [patent-in-suit] describes a method and apparatus that 'uses oral input, natural language based rules, associative search and tabular data structures to provide an easily learned means for controlling a digital computer.' . . . [Plaintiff] also emphasizes that the patent is directed to using the human voice to control a computer using natural language. . . . The present patent is like that in [Ultramercial, Inc. v. Hulu, LLC, 772 F.3d 709, 714 (Fed. Cir. 2014)] 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. . . . The [patent-in-suit] does not simply perform a pre-existing business practice on the internet, but neither does it solve a business problem created by internet commerce."