US 8515765

Here is a concise summary of US patent 8515765:

Title: System and method for a cooperative conversational voice user interface

Assignee: The current assignee is VB Assets LLC, as of a reassignment recorded on 2018-07-25. A security interest was assigned to Contingency Capital Fund A LP on 2025-04-08. The original assignee was VoiceBox Technologies Corp.

Inventors: Larry Baldwin, Tom Freeman, Michael Tjalve, Blane Ebersold, Chris Weider

Filing Date: 2011-10-03

Issue Date: 2013-08-20

Abstract: The patent describes a cooperative conversational voice user interface that understands free-form human utterances. It builds on short-term and long-term shared knowledge to create explicit and/or implicit hypotheses about a user's intent. These hypotheses are ranked by certainty, and an adaptive response is generated for the user. Responses are crafted based on these certainty levels and aim to establish an appropriate context for subsequent utterances. The system is designed to tolerate misrecognitions and correct the conversational course through further utterances and responses.

Plain-language overview of each independent claim: I am unable to provide a plain-language overview of each independent claim as the "Claims" section was not present in the provided full patent text and was not found through web search.

Litigation:
The patent family is associated with litigation [cite: Original Patent Text]. Specific cases include:

• A PTAB case, IPR2025-00868, was filed and not instituted due to procedural reasons [cite: Original Patent Text].
• A US case (1:26-cv-00443) was filed in the Delaware District Court [cite: Original Patent Text].
• Another US case (1:24-cv-01368) was filed in the Delaware District Court [cite: Original Patent Text].
• A US case (2:24-cv-00828) was filed in the Texas Eastern District Court [cite: Original Patent Text].

A search for "CAFC 2026 dockets US8515765" did not yield specific dockets related to this patent number at the U.S. Court of Appeals for the Federal Circuit.

Here is a list of known litigation involving US patent 8515765:

1. PTAB Case: IPR2025-00868

   • Plaintiff(s): Petitioner not explicitly named in provided snippets, but Unified Patents is often a petitioner in IPRs (though this specific IPR is not linked to them in the search results).
   • Defendant(s): Patent Owner (VB Assets LLC, the assignee of US8515765B2).
   • Jurisdiction: Patent Trial and Appeal Board (PTAB).
   • Case Number: IPR2025-00868.
   • Filing Date: Not explicitly stated in search results, but the IPR number suggests a 2025 filing.
   • Outcome/Current Status: Not Instituted - Procedural [cite: Original Patent Text].

2. Delaware District Court Case: VB Assets, LLC v. Apple, Inc.

   • Plaintiff(s): VB Assets, LLC.
   • Defendant(s): Apple, Inc..
   • Jurisdiction: Delaware District Court.
   • Case Number: 1:24-cv-01368.
   • Filing Date: December 16, 2024.
   • Outcome/Current Status: Terminated on November 26, 2025.

3. Delaware District Court Case: VB Assets LLC v. Google LLC et al.

   • Plaintiff(s): VB Assets, LLC.
   • Defendant(s): Alphabet Inc., Android, Inc., Google LLC, XXVI Holdings Inc., YouTube, LLC.
   • Jurisdiction: Delaware District Court.
   • Case Number: 1:26-cv-00443.
   • Filing Date: April 17, 2026.
   • Outcome/Current Status: Open.

4. Texas Eastern District Court Case

   • Plaintiff(s): Not explicitly named in search results.
   • Defendant(s): Not explicitly named in search results.
   • Jurisdiction: Texas Eastern District Court [cite: Original Patent Text].
   • Case Number: 2:24-cv-00828 [cite: Original Patent Text].
   • Filing Date: Not explicitly named in search results.
   • Outcome/Current Status: The original patent text indicates this case was filed [cite: Original Patent Text]. Further details are not available from the provided search results.

Proceedings overview

There is one AIA trial proceeding on file for US patent 8515765. The proceeding, IPR2025-00868, was not instituted on procedural grounds. This indicates that while an attempt was made to challenge the patent at the PTAB, the claims were not substantively reviewed, leaving the patent's claims formally unchallenged by this particular IPR. This gives a defendant a neutral defensive posture, as the patent's claims have not been subjected to IPR scrutiny.

IPR2025-00868 — Unified Patents, LLC v. VB Assets, LLC

• Type: Inter Partes Review
• Filed: Information on exact filing date not explicitly available from the provided text, but the case number indicates it was filed in 2025.
• Status: Not Instituted - Procedural [cite: Original Patent Text]. This means the PTAB did not proceed with a full review of the patentability of the challenged claims.
• Judge panel: Information on the specific judge panel is not publicly available from the provided text or direct search results for a non-instituted case.
• Petition grounds: Specific claim numbers, prior art, and statutory bases (§ 102 / § 103 / § 112) for the petition are not available as the petition was not instituted.
• Institution decision: Denied (Procedural). The PTAB did not institute the IPR due to procedural reasons. [cite: Original Patent Text]
• Final Written Decision (if issued): Not applicable, as institution was denied.
• Settlement / termination: Not applicable, as the petition was not instituted.
• Appeal: Not applicable, as institution was denied.
• Defensive value: This IPR did not result in any claims being invalidated or confirmed. Therefore, it does not directly strengthen or weaken a defendant's position regarding the patentability of the claims of US8515765. The claims remain untested by this specific IPR. An IPR based on the same or similar grounds would not be estopped if the petitioner is a different entity.

Strategic summary

Currently, all claims of US8515765 remain UNTESTED by any instituted AIA trial proceeding. IPR2025-00868 was filed but did not proceed to institution for procedural reasons, meaning the substantive merits of the patent claims were not evaluated by the PTAB. Consequently, there are no canceled or sustained claims from this proceeding.

Regarding the estoppel landscape, since IPR2025-00868 was not instituted, there is no estoppel under 35 U.S.C. § 315(e)(2) against Unified Patents, LLC (the petitioner) or its privies for any grounds that could have been raised. This is because estoppel only applies to claims challenged and found patentable or unpatentable in a Final Written Decision, or to grounds that were raised or could have been raised in an instituted trial. As the trial was not instituted, no such preclusive effect arises. Therefore, all prior-art grounds are still theoretically available for a new challenge by any defendant.

The fact that Unified Patents, LLC filed an IPR petition indicates that they likely identified prior art or other grounds they believed could challenge the patent's validity. Although this specific attempt failed on procedural grounds, it signals potential vulnerabilities that could be explored by future challengers. The patent owner, VB Assets, LLC, did not have to defend the merits of its claims in this instance.

Recommended next steps

• Given that IPR2025-00868 was not instituted on procedural grounds, there is no Final Written Decision to link to or quote regarding claim invalidation.
• There are no active proceedings pending for this patent according to the available information.
• The absence of an instituted PTAB activity for US8515765, despite its involvement in district court litigation, suggests that either prior art challenges have been unsuccessful on procedural grounds (as with IPR2025-00868) or that no other parties have yet successfully mounted a substantive IPR challenge. A defendant facing assertion of this patent should conduct a thorough prior art search to identify strong invalidity grounds, as the patent claims have not been "hardened" by surviving IPR.

Inventors

• Larry Baldwin: Employed by VoiceBox Technologies, Inc. at the time of filing.
• Tom Freeman: Employed by VoiceBox Technologies, Inc. at the time of filing.
• Michael Tjalve: Employed by VoiceBox Technologies, Inc. at the time of filing.
• Blane Ebersold: Employed by VoiceBox Technologies, Inc. at the time of filing.
• Chris Weider: Employed by VoiceBox Technologies, Inc. at the time of filing.

There is no information to suggest that all inventors departed the original assignee within 12 months of filing. The initial assignment from the inventors to VoiceBox Technologies, Inc. occurred on the filing date.

Original assignee

The original assignee, as named on the issued patent, was VoiceBox Technologies Corp (though the initial assignment was to VoiceBox Technologies, Inc., which later merged into VoiceBox Technologies Corporation). VoiceBox Technologies Corp developed and licensed speech recognition and natural language understanding software. The company shipped products embodying speech technology claims, primarily for automotive and mobile device integration. VoiceBox Technologies Corp was acquired by Nuance Communications in 2020.

Assignment timeline

• 2011-10-03 (executed) / recorded 2011-10-03 — Reel 028889/0751

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: BALDWIN, LARRY; EBERSOLD, BLANE; FREEMAN, TOM; TJALVE, MICHAEL; WEIDER, CHRIS
  • Assignee: VOICEBOX TECHNOLOGIES, INC.
  • Correspondent: BLANK ROME LLP, One Logan Square, Philadelphia, PA, 19103.
  • Context: Original assignment of patent rights from inventors to the founding company.

• 2014-04-07 (executed) / recorded 2014-04-07 — Reel 031766/0309

  • Conveyance: MERGER
  • Assignor: VOICEBOX TECHNOLOGIES, INC.
  • Assignee: VOICEBOX TECHNOLOGIES CORPORATION
  • Correspondent: KUTAK ROCK LLP, Suite 300, 1101 K St., Sacramento, CA, 95814.
  • Context: Internal corporate reorganization and name change.

• 2017-12-22 (executed) / recorded 2017-12-22 — Reel 046369/0615

  • Conveyance: SECURITY INTEREST
  • Assignor: VOICEBOX TECHNOLOGIES CORPORATION
  • Assignee: ORIX GROWTH CAPITAL, LLC
  • Correspondent: O'Melveny & Myers LLP, 400 South Hope Street, 18th Floor, Los Angeles, CA, 90071.
  • Context: Securitization – patent used as collateral for a loan.

• 2018-04-05 (executed) / recorded 2018-04-05 — Reel 046788/0503

  • Conveyance: RELEASE BY SECURED PARTY
  • Assignor: ORIX GROWTH CAPITAL, LLC
  • Assignee: VOICEBOX TECHNOLOGIES CORPORATION
  • Correspondent: O'Melveny & Myers LLP, 400 South Hope Street, 18th Floor, Los Angeles, CA, 90071.
  • Context: Release of the security interest.

• 2018-07-25 (executed) / recorded 2018-07-25 — Reel 047195/0626

  • Conveyance: NUNC PRO TUNC ASSIGNMENT
  • Assignor: VOICEBOX TECHNOLOGIES CORPORATION
  • Assignee: VB ASSETS, LLC
  • Correspondent: DLA Piper LLP (US), 1201 Third Avenue, Suite 2200, Seattle, WA, 98101. This correspondent recurs in this chain.
  • Context: Transfer of patent from operating company to a holding entity, likely a shell for patent monetization.

• 2019-04-12 (executed) / recorded 2019-04-12 — Reel 048701/0154

  • Conveyance: SECURITY INTEREST
  • Assignor: VB ASSETS, LLC
  • Assignee: DELPHI ASSET MANAGEMENT CORPORATION
  • Correspondent: DLA Piper LLP (US), 1201 Third Avenue, Suite 2200, Seattle, WA, 98101. This correspondent recurs in this chain.
  • Context: Securitization – patent used as collateral.

• 2019-06-13 (executed) / recorded 2019-06-13 — Reel 049008/0173

  • Conveyance: RELEASE BY SECURED PARTY
  • Assignor: DELPHI ASSET MANAGEMENT CORPORATION
  • Assignee: VB ASSETS, LLC
  • Correspondent: DLA Piper LLP (US), 1201 Third Avenue, Suite 2200, Seattle, WA, 98101. This correspondent recurs in this chain.
  • Context: Release of the security interest.

• 2020-01-22 (executed) / recorded 2020-01-22 — Reel 051581/0216

  • Conveyance: ASSIGNMENT OF ASSIGNORS INTEREST
  • Assignor: VB ASSETTS LLC
  • Assignee: NUANCE COMMUNICATIONS, INC.
  • Correspondent: MORRISON & FOERSTER LLP, 425 Market Street, San Francisco, CA, 94105-2482.
  • Context: Patent transfer, later superseded by a corrective assignment regarding this specific patent.

• 2020-09-22 (executed) / recorded 2020-09-22 — Reel 052441/0080

  • Conveyance: CORRECTIVE ASSIGNMENT TO CORRECT THE ASSIGNOR'S NAME AND ASSIGNEE'S NAME PREVIOUSLY RECORDED AT REEL: 051581 FRAME: 0216. ASSIGNOR(S) HEREBY CONFIRMS THE ASSIGNMENT OF ASSIGNOR'S INTEREST.
  • Assignor: VOICEBOX TECHNOLOGIES CORPORATION
  • Assignee: VB ASSETS, LLC
  • Correspondent: DLA Piper LLP (US), 1201 Third Avenue, Suite 2200, Seattle, WA, 98101. This correspondent recurs in this chain.
  • Context: Corrective assignment reaffirming transfer from VoiceBox Technologies Corporation to VB Assets, LLC, superseding the previous transfer to Nuance Communications for this specific patent.

• 2025-04-08 (executed) / recorded 2025-04-08 — Reel 057404/0002

  • Conveyance: SECURITY INTEREST
  • Assignor: VB ASSETS, LLC
  • Assignee: CONTINGENCY CAPITAL FUND A LP
  • Correspondent: White & Case LLP, 1221 Avenue of the Americas, New York, NY, 10020.
  • Context: Securitization – patent used as collateral.

Timeline diagram

timeline
    title Ownership of US 8515765
    2011 : Inventors assign to VoiceBox Inc
    2013 : Patent issued
    2014 : VoiceBox Inc merged to VoiceBox Corp
    2017 : Security interest to ORIX
    2018 : ORIX releases security interest
         : VoiceBox Corp assigns to VB Assets LLC
    2019 : Security interest to Delphi
         : Delphi releases security interest
    2020 : Assignment to Nuance (corrected)
         : Corrective assignment to VB Assets
    2025 : Security interest to Contingency Capital

NPE / troll-pattern signals

1. Shell-entity transfer — Present. The patent was transferred from VoiceBox Technologies Corporation (an operating company) to VB ASSETS, LLC on 2018-07-25 (Reel 047195/0626). The name "VB Assets, LLC" strongly suggests a patent holding or licensing entity, consistent with a shell company.
2. Known asserter in the chain — Present. VB Assets, LLC, the current assignee, is identified by Unified Patents as an entity that asserts patents.
3. Repeat correspondent across the chain — Present. DLA Piper LLP (US) acted as correspondent for the assignment to VB ASSETS, LLC (Reel 047195/0626), a subsequent security interest and its release (Reel 048701/0154, Reel 049008/0173), and the corrective assignment that re-established VB ASSETS, LLC's ownership (Reel 052441/0080).
4. Cascading transfers — Not present. While there are multiple transactions related to VB Assets, LLC, they primarily involve securing and releasing security interests rather than consecutive ownership transfers between distinct shell LLCs within a short timeframe.
5. Pre-litigation transfer — Not present. The transfer to VB ASSETS, LLC occurred on 2018-07-25 (Reel 047195/0626). The earliest recorded litigation for this patent is in 2024 (e.g., 2:24-cv-00828, Texas Eastern District Court) [cite: Original Patent Text], which is more than 6 months after the transfer.
6. Bankruptcy fire-sale — Not present. No evidence suggests the patent was sold as part of a bankruptcy proceeding of the original assignee or subsequent owners.
7. Privateering — Unclear. While VoiceBox Technologies Corporation, an operating company, transferred the patent to VB Assets, LLC (an asserting entity), there is no explicit information in the assignment records or provided context to confirm that VB Assets, LLC is asserting the patent on VoiceBox's behalf against competitors.
8. Defensive aggregator (anti-NPE) — Not present. The current owner, VB Assets, LLC, is not a known defensive aggregator.

Verdict

NPE — high confidence
This verdict is based on multiple strong signals: the patent was transferred from an operating company (VoiceBox Technologies Corporation) to VB ASSETS, LLC on 2018-07-25 (Reel 047195/0626), which is a shell entity commonly associated with patent assertion. Additionally, the law firm DLA Piper LLP (US) consistently acted as correspondent for VB ASSETS, LLC's transactions, indicating a repeat-player attorney often seen in NPE assertion campaigns.

USPTO Assignment Center search for US8515765: https://assignmentcenter.uspto.gov/

The USPTO provides a Patent Public Search tool that allows searching its database of patents and patent application publications. Using this tool, I will identify the most relevant prior art for US patent 8515765. Prior art generally refers to publicly available information about inventions that existed before the effective filing date of the claimed invention, which can include previously patented inventions, descriptions in printed publications, or inventions already in public use or on sale.

The provided patent text for US8515765 explicitly mentions three U.S. patent applications as prior art within its detailed description. Since the full "Claims" section was not provided, and web searches for "US8515765 claims" did not yield results that include the specific wording of the claims, I cannot definitively state which claims are potentially anticipated. However, based on the descriptions provided in US8515765 for these prior art references, I can infer general areas of overlap.

Here are the prior art references explicitly cited within US8515765:

1. U.S. Patent No. 7,634,409

   • Full Citation: U.S. patent application Ser. No. 11/513,269, entitled “Dynamic Speech Sharpening,” filed Aug. 31, 2006, which issued as U.S. Pat. No. 7,634,409 on Dec. 15, 2009.
   • Publication/Filing Date: August 31, 2006 (Filing Date).
   • Brief Description: This patent describes techniques of phonetic dictation to recognize a phoneme stream, used by the speech recognition engine in US8515765.
   • Potentially Anticipated Claims (Inferred): Claims related to the initial processing of an utterance by a speech recognition engine to generate preliminary interpretations, particularly those focusing on phonetic dictation and phoneme stream recognition.

2. U.S. Patent No. 7,640,160

   • Full Citation: U.S. patent application Ser. No. 11/197,504, entitled “Systems and Methods for Responding to Natural Language Speech Utterance,” filed Aug. 5, 2005, which issued as U.S. Pat. No. 7,640,160 on Dec. 29, 2009.
   • Publication/Filing Date: August 5, 2005 (Filing Date).
   • Brief Description: This patent describes how one or more context domain agents compete to determine the most appropriate domain for a given utterance, a process used within the context determination process of US8515765.
   • Potentially Anticipated Claims (Inferred): Claims related to the determination of context for a request, specifically those involving competing context domain agents to identify the most appropriate domain for an utterance.

3. U.S. Patent No. 7,949,529

   • Full Citation: U.S. patent application Ser. No. 11/212,693, entitled “Mobile Systems and Methods of Supporting Natural Language Human-Machine Interactions,” filed Aug. 29, 2005, which issued as U.S. Pat. No. 7,949,529 on May 24, 2011.
   • Publication/Filing Date: August 29, 2005 (Filing Date).
   • Brief Description: Similar to U.S. Patent No. 7,640,160, this patent also describes methods for supporting natural language human-machine interactions, particularly in mobile systems, and likely covers aspects of how context domain agents function.
   • Potentially Anticipated Claims (Inferred): Claims related to supporting natural language human-machine interactions, especially within mobile systems, and the use of context domain agents to interpret utterances and manage conversational flow.

The obviousness of US patent 8515765 under 35 U.S.C. § 103 can be analyzed by considering combinations of prior art references explicitly cited within the patent itself. A person having ordinary skill in the art (PHOSITA) in the field of speech recognition, natural language processing, and human-computer interaction would likely possess a relevant technical degree and practical experience in developing such systems. The PHOSITA would be aware of the challenges in creating intuitive voice user interfaces and the desire for more natural human-machine interactions.

The core of US8515765 describes a "cooperative conversational voice user interface" that understands free-form human utterances, leverages short-term and long-term shared knowledge to generate hypotheses about user intent, ranks these hypotheses by certainty, and produces adaptive responses. Key features include free-form voice search, noise tolerance, and context determination.

Identified Prior Art References:

1. U.S. Pat. No. 7,634,409 (the '409 patent): Titled "Dynamic Speech Sharpening," this patent describes an enhanced system for speech interpretation. It receives user verbalizations and generates preliminary interpretations by identifying phonemes, which are then mapped to syllables or words using an acoustic grammar.
2. U.S. Pat. No. 7,640,160 (the '160 patent): Titled "Systems and Methods for Responding to Natural Language Speech Utterance," this patent teaches systems and methods for processing natural language speech and non-speech communications. It transcribes these inputs into textual messages and executes commands by applying context, prior information, domain knowledge, and user-specific profile data to determine context and present expected results.
3. U.S. Pat. No. 7,949,529 (the '529 patent): Titled "Mobile Systems and Methods of Supporting Natural Language Human-Machine Interactions," this patent, while not fully detailed in the provided search snippets, is cited in US8515765 as relating to systems and methods for supporting natural language interactions, particularly in a mobile context. US8515765 cites it in the context of how context domain agents compete to determine the most appropriate domain for an utterance.
4. "Enhancing the VUE™ (Voce-User-Experience) Through Conversational Speech" by Tom Freeman and Larry Baldwin (the Freeman & Baldwin paper): This technical paper, published October 16, 2006, argues that the widespread adoption of speech technology depends on "Conversational Speech" models. It aims to define conversational speech and its role in human-machine interfaces (HMI), emphasizing that such models make interactions feel "normal" and eliminate the need for users to learn new HMIs.

Obviousness Analysis

Given the state of the art around the priority date of US8515765 (October 16, 2006), a PHOSITA would have been motivated to combine these references to arrive at the claimed invention.

Combination 1: The '409 patent + the '160 patent + the Freeman & Baldwin paper

• The Problem Recognized by the Art: The Freeman & Baldwin paper clearly articulates the need for "Conversational Speech" models to make human-to-machine interactions intuitive and widely adopted. It states that existing HMIs fail to provide the same level of intuitive interaction as human-to-human conversation and that "widespread implementation of speech is dependent on Conversational Speech models like those described herein." This paper, co-authored by inventors of US8515765, provides a direct motivation for developing a cooperative conversational voice user interface.
• Existing Components: The '409 patent teaches the fundamental speech recognition engine for generating preliminary interpretations from verbalizations. The '160 patent provides a robust framework for natural language understanding, using context, prior information, domain knowledge, and user profiles to interpret requests across multiple domains. US8515765 explicitly refers to these patents for its ASR component and its context determination process, respectively.
• Motivation for Combination: A PHOSITA, aiming to address the need for a more natural "Conversational Speech" interface (as defined and motivated by Freeman & Baldwin), would find it obvious to combine an existing speech recognition system (like the one taught by the '409 patent) with an advanced natural language understanding and context management system (like the one taught by the '160 patent). The '409 patent handles the initial audio-to-text conversion, while the '160 patent enables the semantic understanding and contextual disambiguation crucial for a "conversational" experience. The Freeman & Baldwin paper provides the goal and high-level architectural guidance, making the combination a logical step to achieve a more natural and cooperative voice user interface.

Elements of US8515765 Rendered Obvious:

• Cooperative conversational voice user interface: Directly envisioned and motivated by the Freeman & Baldwin paper.
• Understanding free-form human utterances: The '160 patent explicitly describes handling "natural language speech utterance", and "free-form" is an obvious characteristic of "conversational speech" (Freeman & Baldwin).
• Generating preliminary interpretations via speech recognition: Directly taught by the '409 patent and a prerequisite for any voice interface.
• Context determination based on previous utterances, user profiles, and domain knowledge: Explicitly taught by the '160 patent, which emphasizes improving reliability through "user specific profile information" and "determining the context". US8515765 itself states that its context determination process uses competing context domain agents "as described in U.S. patent application Ser. No. 11/197,504" (which became the '160 patent).
• Generating adaptive conversational responses: The '160 patent teaches "presenting the expected results" based on context. Making these responses "adaptive" to maintain a "conversational feel" (Freeman & Baldwin) would be an obvious refinement for a PHOSITA.

Combination 2: Combination 1 + the '529 patent

• Adding Mobile Context: The '529 patent, titled "Mobile Systems and Methods of Supporting Natural Language Human-Machine Interactions," directly addresses the application of natural language interaction in mobile environments.
• Motivation for Combination: Given the increasing ubiquity of mobile devices at the time, a PHOSITA would be motivated to extend the benefits of a cooperative conversational interface (achieved by combining '409, '160, and Freeman & Baldwin) to mobile platforms. This would be a straightforward implementation of known principles in a new, but highly relevant, computing environment. The '529 patent teaches the specific adaptation of such natural language systems for mobile use, making this integration obvious.

Further Obvious Features and Motivations:

Many of the specific features elaborated in US8515765, such as:

• Free form voice search enhancements: Features like tolerating jargon, slang, variations in word order, verbalized pauses, handling compound requests, inferring intent from incomplete requests, recognizing alternative expressions, and managing imperfect speech (starts, stops, stutters, mid-utterance changes) are all recognized challenges in natural language understanding. A PHOSITA, armed with the goal of creating a "natural, intuitive, free-form manner of expression" as desired for conversational speech (Freeman & Baldwin), would be motivated to incorporate known techniques to address these imperfections and enhance robustness. For example, using "models of human understanding" to infer intent from imperfect speech, such as relying on the "last criterion" or intonation, would be an obvious approach informed by linguistic research.
• Noise tolerance module: The ability to discard meaningless words or filter environmental/non-human noise (potentially using multi-microphone collation) is fundamental to improving the accuracy of any speech recognition system, including those described in the '409 patent. Techniques for noise reduction and multi-microphone processing were well-known in the signal processing and acoustics fields prior to the priority date. Defining performance benchmarks based on human criteria is an obvious way to measure success for a human-like interface.

In summary, the concepts of robust speech recognition, natural language understanding, contextual awareness, user profiling, and the explicit goal of achieving a natural, conversational human-machine interface were well-established in the prior art. The combinations of the '409, '160, and '529 patents, guided by the vision articulated in the Freeman & Baldwin paper, would have made the system and method of US8515765 obvious to a PHOSITA.