Obviousness

Obviousness Analysis under 35 U.S.C. § 103 for US Patent 9,979,826

A person having ordinary skill in the art (PHOSITA) in May 2013, when the earliest priority application for US Patent 9,979,826 was filed, would have found the claimed invention obvious in light of combinations of the identified prior art references and general knowledge in the field of mobile computing and communication.

The patent US9979826 describes a system and method where a handheld computerized device (e.g., a smartphone) uses its connection to a Bluetooth peripheral to select and send automated responses to incoming messages. Key aspects include associating specific replies with peripheral identification codes, retrieving these replies upon connection, and using them to automatically respond to messages, often in contexts like preventing distracted driving.

Combination of Prior Art References

The following prior art references, all predating the May 18, 2013 priority date of US9979826, are highly relevant:

1. US20130097269A1 (Yagi Corp.) - "Context-Sensitive Auto-Responder" (Publication Date: April 18, 2013)

   • Disclosure: This patent application teaches systems and methods for context-sensitive auto-response to incoming communications. It describes defining one or more contexts, each including context parameters. Rules are defined with triggers (e.g., detection of an incoming communication and satisfaction of context parameters) and actions (e.g., sending an auto-response).

2. US20130157629A1 (Realnetworks, Inc.) - "Customizable media auto-reply systems and methods" (Priority Date: December 14, 2011; Publication Date: June 20, 2013)

   • Disclosure: This patent application describes systems and methods that allow for customizable auto-reply messages.

Obviousness of Independent Claims 1 and 6

Independent claims 1 (method) and 6 (device) form the core of the invention. Their obviousness can be established by combining Yagi '269, Realnetworks '629, and the general knowledge of a PHOSITA regarding smartphone capabilities and Bluetooth technology by May 2013.

Analysis of Claim Elements:

• Handheld computerized device (smartphone) with processor, Bluetooth transceiver, GUI, memory, cellular network transceiver, and reply software: Yagi '269 describes a "system" for context-sensitive auto-response that would inherently run on a computerized device. By 2013, smartphones were ubiquitous, possessing all these hardware and software components. The "reply software" in US9979826 is embodied by Yagi's auto-response system.
• At least one Bluetooth peripheral device with an individually identifiable Bluetooth peripheral device identification code: Bluetooth technology, including devices with unique identification codes (e.g., MAC addresses or device names), was well-established and widely used in conjunction with smartphones by 2013. A PHOSITA would be fully aware of how to identify connected Bluetooth devices.
• Using reply software, GUI, processor to assign Bluetooth peripheral device linked automatic replies to Bluetooth peripheral device identification code, and storing in memory: Yagi '269 teaches that triggers can include the "satisfaction of one or more context parameters." A PHOSITA would readily recognize that the connection status or identification code of a Bluetooth peripheral device is a direct and easily detectable "context parameter" on a smartphone. Realnetworks '629 teaches that auto-reply messages should be "customizable." Therefore, it would be an obvious design choice for a PHOSITA to allow users to assign specific, customized auto-reply messages (as taught by Realnetworks '629) to these Bluetooth peripheral connection contexts (as context parameters in Yagi '269) and store these associations in the device's memory.
• When Bluetooth connecting to peripheral, reply software determines ID code, uses ID code to select and retrieve linked automatic reply: If a Bluetooth connection is established as a "context parameter" within Yagi's system, then the detection of this connection and the determination of its unique ID (an inherent part of Bluetooth pairing/connection) would naturally trigger the selection and retrieval of the associated custom reply from memory.
• In response to an incoming message from cellular network transceiver, using selected/retrieved reply to automatically respond: Yagi '269 explicitly teaches "sending an auto-response to the incoming communication." On a smartphone, "incoming communication" would typically be received via the wireless cellular network transceiver.

Motivation to Combine:
A PHOSITA in 2013, faced with the desire to create a more intelligent and flexible auto-responder for smartphones, would be motivated to combine the teachings of Yagi '269 and Realnetworks '629. Yagi '269 provided the foundational framework for context-sensitive auto-responses. Realnetworks '629 highlighted the importance of message customizability. It would be an obvious step to integrate these concepts by using readily available contextual information from smartphones, such as connections to Bluetooth peripherals. Bluetooth connections are a natural indicator of a user's current environment or activity (e.g., driving with a car's hands-free system, exercising with a headset). Leveraging the unique identification codes of these peripherals to trigger specific, customizable auto-replies would provide the desired flexibility and responsiveness in a technically straightforward manner.

Obviousness of Dependent Claims

The additional features described in the dependent claims would also have been obvious to a PHOSITA when building upon the combined teachings of Yagi '269 and Realnetworks '629, along with general knowledge:

• Claim 2 (Dataset/Contact specific, reply priority): Yagi '269's framework of "rules" and "context parameters" readily extends to including the sender's identity (a "contact" from a "dataset") as a context parameter. Assigning specific messages to contacts was a known feature in various communication management systems. Implementing a prioritization scheme between different types of rules (e.g., peripheral-specific vs. contact-specific) is a routine engineering task to manage conflicting conditions in a rule-based system.

  • Motivation: To provide a more granular and personalized auto-response experience, a PHOSITA would be motivated to allow message customization based on the sender and to implement logical rules for resolving conflicts, thereby enhancing user control and system utility.

• Claim 3 (Reply differs by dataset item and last connected peripheral): The "reply differs according to an item in a dataset" is covered by the reasoning for Claim 2. The concept of using the "peripheral connection ID of a Bluetooth peripheral device last connected" as a prioritization scheme when multiple peripherals are connected is a simple and intuitive heuristic. It's a common design choice to infer the user's current primary context from the most recent interaction. The patent itself notes this as a common default priority.

  • Motivation: To effectively manage scenarios where multiple contextual triggers (peripherals) might be simultaneously active, a PHOSITA would implement a straightforward prioritization logic like "last connected" to ensure a predictable and user-friendly behavior.

• Claim 4 (Prevent distracted driving/operation, equipment associated BT peripheral, customized for originator): The problem of distracted driving was a significant societal concern well before 2013, and the use of hands-free Bluetooth devices in vehicles was common. Applying the context-sensitive auto-responder (from Yagi '269 and Realnetworks '629) to automatically respond when a handheld device is connected to an "equipment associated Bluetooth peripheral device" (e.g., a car's hands-free system) for the explicit purpose of preventing distracted driving would be an obvious application driven by the known problem. Customizing responses for the originator is covered by Claim 2.

  • Motivation: Given the well-publicized dangers of distracted driving, a PHOSITA would be strongly motivated to apply existing context-sensitive auto-response technologies to this specific, high-impact use case, using readily available car-related Bluetooth connections as the contextual trigger.

• Claim 5 (Handheld device is any of a smartphone or tablet device): This is a statement of capability for common devices existing prior to 2013 and is inherently obvious.

• Claim 7 (Device claim for distracted driving): This is the device counterpart to method claim 4 and is obvious for the same reasons.

• Claim 8 (Incoming message types): Yagi '269's "incoming communications" is broad enough to encompass various message types. Extending auto-reply functionality from basic text messages (SMS) to multimedia messages (MMS), video content, and other communication types (e.g., social media interactions) is a routine enhancement for a PHOSITA to make a comprehensive auto-responder system, as different communication protocols and formats were well-known by 2013.

  • Motivation: To maximize the utility and applicability of the auto-response system across all prevalent forms of digital communication on a smartphone.

• Claim 9 (Plurality of peripheral device linked automatic replies): This is a direct consequence of combining the context-specificity of Yagi '269 with the customizability of Realnetworks '629. If one can assign a message to a peripheral, one can assign a plurality of distinct messages to a plurality of peripherals, fulfilling a recognized need for flexibility in prior art systems.

  • Motivation: To overcome the limitations of prior art systems that lacked sufficient flexibility for a variety of different automatic response messages, a PHOSITA would logically allow for the assignment of multiple, distinct messages to different peripheral contexts.

• Claim 10 (Reply selected based on the peripheral device identification code of the last connected peripheral device): As discussed for Claim 3, this is a specific, logical, and intuitive prioritization scheme for managing multiple connected peripherals, and its implementation would be a routine design choice. The patent itself identifies this as a potential default.

  • Motivation: To establish a clear and easily understandable default behavior for the auto-response system when multiple peripheral contexts are detected simultaneously.

Conclusion

Based on the combination of US20130097269A1 (Yagi Corp.) and US20130157629A1 (Realnetworks, Inc.), coupled with general knowledge of smartphone capabilities and Bluetooth technology, a PHOSITA would have found the independent claims 1 and 6, and by extension the dependent claims 2-5 and 7-10, of US Patent 9,979,826 obvious by the priority date of May 18, 2013. The motivation would stem from a desire to create a more flexible, context-aware, and user-configurable auto-response system for smartphones, applying known technologies to common user scenarios, including addressing public safety concerns like distracted driving.