Prior art

Prior Art Analysis for U.S. Patent 9,269,097

As a technical patent analyst, a thorough review of the prior art cited in U.S. Patent 9,269,097 is crucial to understanding the landscape of the invention and potential challenges to its validity. Under 35 U.S.C. § 102, a patent claim is anticipated if each and every element of the claim is found in a single prior art reference. The following analysis details the most relevant prior art cited against patent 9,269,097 and assesses which claims each reference could potentially anticipate.

The analysis focuses on the independent claims of the '097 patent, which are the broadest claims and therefore most susceptible to an anticipation challenge. Independent claim 1 describes a method for interpreting a natural language utterance based on a presented advertisement, specifically by determining if a pronoun in the utterance refers to the advertised product, service, or provider. Independent claim 23 covers a system comprising one or more processors programmed to perform this method.

Key Prior Art References and Potential Anticipation

Based on the citations listed in the patent file wrapper for U.S. Patent 9,269,097, the following references are considered most relevant for a potential anticipation analysis:

1. U.S. Patent 7,590,224 (filed Sep. 15, 1995)

• Full Citation: US Patent 7,590,224, "Automated task classification," issued to AT&T Intellectual Property, II, L.P. on September 15, 2009.
• Brief Description: The '224 patent discloses a system for automatically classifying tasks based on a user's spoken request. It describes receiving a spoken utterance, identifying the task requested, and routing it to an appropriate automated system for fulfillment. The system can handle a variety of tasks such as making a telephone call or retrieving information.
• Potential Anticipation of Claims: This reference could be argued to anticipate elements of claims 1 and 23. While it may not explicitly mention advertisements, its disclosure of receiving a natural language utterance and classifying the intended action forms a foundational element of the '097 patent's claims. An argument for anticipation would hinge on whether the '224 patent's system for task classification inherently performs the step of resolving ambiguous references (like pronouns) in the context of the available information, which could be construed to include the "advertisement" of the '097 patent.

2. U.S. Patent Application Publication 2008/0228494 (filed Mar. 20, 2007)

• Full Citation: US Patent Application Publication 2008/0228494, "Method and apparatus for providing a voice user interface to a search engine," assigned to Google Inc., published on September 18, 2008.
• Brief Description: This patent application describes a voice-enabled search interface where a user can speak a query, which is then converted to text and submitted to a search engine. The results can be presented back to the user in an audible format. It focuses on improving the accuracy of speech recognition and query interpretation for search applications.
• Potential Anticipation of Claims: The '494 application could potentially anticipate elements of claims 1 and 23. It discloses a system that receives a natural language utterance and interprets it to perform an action (a search). The core of a potential anticipation argument would be whether the context of the search, including previous queries or displayed results (which could be analogized to an advertisement), is used to resolve pronouns or other ambiguities in subsequent spoken queries. If the application discloses or inherently suggests resolving a spoken "search for it" by referring to a previously displayed search result, it would be highly relevant.

3. U.S. Patent 7,949,529 (filed Aug. 29, 2005)

• Full Citation: US Patent 7,949,529, "Mobile systems and methods of supporting natural language human-machine interactions," issued to VoiceBox Technologies Corp. on May 24, 2011.
• Brief Description: The '529 patent, from the original assignee of the '097 patent, describes a system for a more conversational human-machine interface on mobile devices. It details how the system can understand and respond to natural language queries by considering the context of the conversation and the user's environment.
• Potential Anticipation of Claims: This reference is highly relevant to claims 1 and 23 and presents a significant potential for anticipation, particularly as it originates from the same inventors and assignee. The '529 patent's focus on using conversational context to understand user intent is a core component of the '097 patent. If this patent describes resolving pronouns based on the immediate context of what is being displayed or discussed on the device, it could be argued that this context is analogous to the "advertisement" in the '097 patent's claims. The key would be whether the '529 patent discloses interpreting a pronoun in a follow-up command in relation to a specific product or service that was the subject of the initial interaction.

4. U.S. Patent Application Publication 2007/0156494 (filed Dec. 29, 2005)

• Full Citation: US Patent Application Publication 2007/0156494, "Voice-based access to location-based services," assigned to Vlingo, Inc., published on July 5, 2007.
• Brief Description: This application describes a system for accessing location-based services using voice commands. For example, a user could say "find the nearest Starbucks," and the system would understand the command and provide relevant location information. It discusses the challenges of interpreting natural language queries in the context of location-based services.
• Potential Anticipation of Claims: The '494 application may anticipate elements of claims 1 and 23. The system it describes must resolve ambiguities in spoken commands. If a user receives a list of restaurants and then says, "call them," the system would need to determine that "them" refers to one of the listed restaurants. This scenario is functionally very similar to the core inventive concept of the '097 patent, where the list of restaurants could be considered the "advertisement" and the pronoun "them" is resolved in that context.

Conclusion

A comprehensive analysis of the prior art cited in the prosecution history of U.S. Patent 9,269,097 reveals several references that could potentially anticipate the patent's independent claims. The references from VoiceBox Technologies itself ('529 patent) and those from competitors in the voice recognition and search space (Google's '494 application and Vlingo's '494 application) appear to be the most significant. A successful anticipation argument under 35 U.S.C. § 102 would require demonstrating that a single one of these references discloses every element of the claims. Given the ongoing litigation involving this patent, the interpretation of these prior art references will likely be a central issue in determining the patent's validity.