US 9377992

Summary — U.S. Patent No. 9,377,992 B2

Search note (per your instruction): I searched for the exact number 9377992 (and its full form US9377992B2). I did not substitute or "correct" it to any other number. The Delaware litigation identified in the patent record (1:23-cv-00190) and the Parus/Google Federal Circuit matter (24-2381) were checked to confirm whether they involve this patent; findings are flagged below.

Bibliographic data

• Title: Personal voice-based information retrieval system
• Patent number / kind code: US 9,377,992 B2 (US9377992B2)
• Inventor: Alexander Kurganov (Buffalo Grove, IL, US)
• Assignee (recorded): Parus Holdings, Inc. (Bannockburn, IL, US); original assignee chain includes Webley Systems, Inc. (assignment records also show a security agreement to WWIS, LLC)
• Application No.: 12/787,801
• Filing date: May 26, 2010
• Issue date: June 28, 2016
• Priority date: February 4, 2000 (Provisional Application No. 60/180,343)
• Continuation chain: 09/777,406 → now US 7,516,190 B2; → 11/771,773 (abandoned); → 12/787,801 (this patent); child continuations include US 9,769,314 B2 and US 10,320,981 B2
• Legal status: Expired – Fee Related (Google Patents lists adjusted expiration ~2022-11-16)
• Primary classifications: H04M 3/4938 (voice browser / VoiceXML interactive information services); G06F 3/167 (audio in a user interface); G10L 15/26 (speech-to-text); G10L 25/54 (speech retrieval)

Sources: Google Patents (https://patents.google.com/patent/US9377992/en); Justia (https://patents.justia.com/patent/20100232580); PatentGuru record for US09377992B2.

Abstract (verbatim)

"The present invention relates to a system for retrieving information from a network such as the Internet. A user creates a user-defined record in a database that identifies an information source, such as a web site, containing information of interest to the user. This record identifies the location of the information source and also contains a recognition grammar based upon a speech command assigned by the user. Upon receiving the speech command from the user that is described within the recognition grammar, a network interface system accesses the information source and retrieves the information requested by the user."

Plain-language overview of independent claims

The patent has 12 claims; the two independent claims are claim 1 (method) and claim 12 (system). Claims 2–11 depend from claim 1 (adding: displaying/selecting the web site; a list of named content objects such as "weather," "stock quote," "flight," etc.; the media server searching the web site; and device/network types — landline, wireless, IP phone, LAN/WAN/Internet).

Claim 1 (method) — A method of retrieving information from an information source by voice, in which:

1. A user speaks a command into an electronic communication device (e.g., a phone).
2. A speech recognition engine coupled to a media server receives the command and selects a recognition grammar that was established to match that command; the information source is periodically updated.
3. The media server selects an information source retrieval instruction stored in a database that corresponds to that grammar.
4. A web browsing server accesses only a portion of the information source that the user previously identified as of interest, using a clipping client to separate that portion from other content; the clipping client generates a content descriptor file describing the selected content and indicating where it sits within the source, and only that portion is retrieved.
5. A speech synthesis engine converts the retrieved information into an audio message.
6. The audio message is transmitted back to the user's device.

Claim 12 (system) — A system for the same voice-driven retrieval, comprising:

1. A speech recognition engine that receives the user's spoken command and selects the appropriate retrieval instruction based on the recognition grammar.
2. A media server connected to the Internet, the user device, and the speech recognition engine; it accesses (via a web browsing server) a periodically updated information source and retrieves information defined by the retrieval instruction — where the item of interest was previously identified by the user and separated from other information using a clipping client, and the media server generates a content descriptor file describing the item and its location in the source.
3. A speech synthesis engine that converts the retrieved item into an audio message and transmits it to the user's device.

Litigation / CAFC 2026 docket status (with uncertainty noted)

• District court: Parus Holdings Inc. v. Amazon.com, Inc., No. 1:23-cv-00190 (D. Del., filed Feb. 17, 2023) asserts U.S. Patent No. 9,377,992 (along with related Parus patents) against Amazon's Alexa voice services. Third-party databases (Ex Parte, Stanford NPE Litigation Database) list the case as closed; I did not independently verify the disposition on PACER. See https://ai-lab.exparte.com/case/dct/ded/1:23-cv-00190/ and https://npe.law.stanford.edu/case/[270032](/patent/270032).
• CAFC 2026 docket: My searches of CAFC 2026 docket/opinion sources did not surface any appeal specifically docketed in 2026 for patent 9377992. The prominent Parus matter at the Federal Circuit in 2026 — Google LLC v. Parus Holdings, Inc., No. 24-2381 (opinion July 13, 2026) — concerns U.S. Patent No. 6,721,705 (the "robust voice browser" patent) and PTAB IPRs; it is not this patent. The CourtListener audio hits involving "Kovacs/Burroughs/Wise" IPRs relate to that same '705-family litigation, not to 9377992. I could not confirm any 2026 CAFC proceeding naming 9377992, so treat that as not found rather than confirmed absent.

Uncertainty caveats

• The granted claim set (12 claims, as reproduced in the authoritative Google Patents record) differs from the earlier published application US 2010/0232580 A1 (which showed 14 claims with "phone"/"regular expression" language); I based the claim overview on the granted text.
• Assignee history is layered (Webley Systems → Parus Holdings; a security agreement to WWIS, LLC); the current recorded owner per Google Patents is Parus Holdings, Inc.
• I did not query USPTO.gov directly (no live API access in this session); the bibliographic data above is corroborated by Google Patents, Justia, PatentGuru, and Docket Alarm mirrors of the USPTO record.

I'll search for litigation involving US Patent 9,377,992. Let me run several searches.

Let me search more specifically for the Delaware case and related Parus litigation.

I found the main Delaware case. Now let me search for the related cases against Apple and Google, and the CAFC appeals.

Based on my searches, here is what the record shows regarding litigation involving US Patent 9,377,992 (US9377992B2, "Personal voice-based information retrieval system").

Confirmed litigation directly asserting US 9,377,992

Parus Holdings Inc. v. Amazon.com, Inc.

• Plaintiff: Parus Holdings Inc.
• Defendant: Amazon.com, Inc.
• Jurisdiction: U.S. District Court for the District of Delaware (D. Del.)
• Case number: 1:23-cv-00190 (a/k/a 1:2023cv00190)
• Filing date: February 17, 2023
• Patents asserted: US 7,516,190 B2; 9,377,992 B2; and 10,320,981 B2 — confirmed by the initial "Report to the Commissioner of Patents and Trademarks" (Filing 3 on the docket), which specifically lists "US 7,516,190 B2; 9,377,992 B2; 10,320,981 B2," and by the complaint's infringement allegations against Amazon's Alexa/Alexa Voice Service mapped to claim 1 of the '992 patent.
• Assigned judge: Gregory B. Williams (Magistrate Judge Christopher J. Burke also referenced on the docket).
• Status/outcome: The docket I retrieved shows the case pending as of the last docket pull (March 2023), with the case assigned to Judge Williams, Amazon served on March 14, 2023, and answer deadlines extended to May 4, 2023. I did not retrieve a final judgment, settlement, or dismissal order in my searches, so I cannot confirm the current terminal status with confidence. Note that Google Patents flags this Delaware case as the litigation associated with the '992 patent, and the '992 patent's adjusted term expired November 16, 2022 (status "Expired – Fee Related"), but that expiration relates to the patent term, not the case outcome.

Related Parus Holdings litigation (could not confirm '992 assertion)

The searches surfaced a broader Parus Holdings enforcement campaign against major tech companies, but I could not confirm from the retrieved sources that US 9,377,992 was asserted in these matters (they appear to center on other family members such as 7,516,190, 6,721,705, 8,185,402, 9,769,314):

• Parus Holdings Inc. v. Apple Inc., 3:22-cv-07514 (N.D. Cal., filed Nov. 30, 2022) — per PatSnap, asserted US 8,185,402 and 6,721,705; dismissed with prejudice on February 3, 2023, each party bearing its own fees. (An earlier W.D. Tex. action, 6:21-cv-00968-ADA, asserted the '705, '190, '402, and '314 patents, not the '992.)
• Parus Holdings Inc. v. Google, LLC, 5:22-cv-07830 / 3:22-cv-07830 (N.D. Cal., filed Dec. 12, 2022) — patents asserted not verified in my search results.
• Parus Holdings Inc. v. Microsoft Corporation, 6:21-cv-00570 (W.D. Tex., filed June 4, 2021) and 2:22-cv-01700 (W.D. Tex./E.D. Tex., filed Nov. 29, 2022) — patents asserted not verified.
• Parus Holdings Inc. v. [[Samsung Electronics America, Inc.](/litigations/by-plaintiff/Samsung%20Electronics%20America%2C%20Inc.) et al.](/litigations/by-defendant/Samsung%20Electronics%20America%2C%20Inc.%20et%20al.), 6:21-cv-01073 (W.D. Tex., filed Oct. 15, 2021) — patents asserted not verified.
• Related CAFC appeals: Google LLC v. Parus Holdings, Inc. (Fed. Cir. No. 24-1329) and two Parus appeals (Nos. 23-2296, 23-2297) — the patents involved were not confirmed in my searches.
• Related IPRs: Microsoft (IPR2022-00137, IPR2022-00804), Google (IPR2022-00279, IPR2022-00523), Apple (IPR2022-00949, IPR2022-00950, IPR2023-00303), Samsung (IPR2022-01502, IPR2023-00162) — I could not confirm from the retrieved results which specific patents were challenged.

Related but non-infringement litigation

Parus Holdings Inc. v. Mintz, Levin, Cohen, Ferris, Glovsky and Popeo, P.C. et al., 1:25-cv-01722 (W.D. Tex., filed October 24, 2025) — a legal-malpractice suit by Parus against its former counsel (including attorneys Michael J. McNamara and Michael T. Renaud) arising out of the handling of Parus's patent-infringement cases against Apple, Google, and Amazon. This case does not assert the '992 patent.

Bottom line

The only litigation I can affirmatively confirm as asserting US Patent 9,377,992 is Parus Holdings Inc. v. Amazon.com, Inc., No. 1:23-cv-00190 (D. Del., filed Feb. 17, 2023). I could not retrieve a definitive final disposition for that case from the available sources, so its current status should be verified on PACER or Unified Patents before relying on it. The other Parus cases listed above are related to the same patent family and enforcement campaign but I could not verify that they specifically plead the '992 patent.

Proceedings overview

Zero AIA trial proceedings (IPR/PGR/CBM) are on file for US9377992B2. The USPTO Open Data Portal ingest underlying this report contains no AIA trial cases for the patent, and my web search — including PTAB, Unified Patents, RPX, and Patexia indexes of the Parus Holdings campaign — surfaced no petition that names US9377992 as the challenged patent. Status breakdown: 0 active, 0 claims invalidated, 0 claims sustained, 0 settled, 0 institution-denied for this patent. The proceedings that exist in this family were filed against sibling patents (most importantly the direct parent, US7,516,190), not against '792.

Bottom-line defensive posture: there is no PTAB estoppel, no canceled claim, and no Board precedent touching '792's 12 claims — and the patent itself expired on 2022-11-16 (status "Expired – Fee Related"). Anyone facing a demand letter citing '792 should lead with expiry (no injunctive relief; damages, if any, limited to pre-expiry conduct) and the complete availability of all prior-art grounds, because nothing about '792 has ever been tested or narrowed at the PTAB.

Related family PTAB proceedings — not on US9377992 (context only)

These are the AIA trials the web search did surface. They are included because they are the closest analogs (same specification, same priority chain, and two of them target '792's direct parent), but none of them is a proceeding against US9377992, and none of their outcomes or estoppels attaches to '792.

IPR2022-01020 — Google LLC v. Parus Holdings, Inc. (challenging US7,516,190 — the direct parent of '792)

• Type: Inter Partes Review
• Filed: 2022-05-13 (petition and exhibits dated 2022-05-13; filing-date notice 2022-06-16)
• Status: Institution denied (Decision: Deny, 2022-12-13); post-institution fees refunded 2023-01-09
• Judge panel: not publicly identified in the sources retrieved
• Petition grounds: obviousness challenges to the '190 patent (the "Personal voice-based information retrieval system" parent of '792), relying on art including Burrows (US5,765,149), Dasan (US5,761,662), Uppalaru (US5,915,001), Brown (US6,587,822), Iyer (US6,446,098), and Kirk (US5,768,578), with a Lipoff declaration; Google also submitted the '190 provisional (60/180,343) and priority comparisons.
• Institution decision: denied 2022-12-13 — the Board exercised its discretion not to institute (McKool Smith's contemporaneous press statement characterized the denial of Google's '190 request as a "prior win" for Parus).
• Final Written Decision: none (no trial was instituted).
• Settlement / termination: none — terminated by denial of institution.
• Appeal: none identified.
• Defensive value: Not an estoppel event for anyone (no institution = no § 315(e)(2) estoppel, and it binds only Google anyway). But it is a signal that the Board found Google's obviousness case against the parent patent unpersuasive as framed — the same art is still fully available to a new challenger, just better briefed.

IPR2022-01542 — [Apple Inc.](/litigations/by-plaintiff/Apple%20Inc.) v. Parus Holdings, Inc. (challenging US7,516,190)

• Type: Inter Partes Review
• Filed: 2022-09-16
• Status: Terminated – Settled (pre-institution)
• Judge panel: David McKone, James Mayberry, Patrick Boucher
• Petition grounds: obviousness challenges to '190 (exhibits include Danner (US7,219,136), Rajan (US6,725,425), Kiraly (US6,088,731), and a Yarowsky expert declaration); challenged claims not identified in the sources retrieved.
• Institution decision: none issued — the parties settled before the institution deadline.
• Final Written Decision: none.
• Settlement / termination: Joint Motion to Terminate filed 2023-03-03; Board "Decision Settlement Prior to Institution of Trial" 2023-03-06; terms confidential (not public).
• Appeal: none.
• Defensive value: Again not an estoppel event. It confirms the '190 parent drew repeat IPR fire from Apple and Google in 2022 — and that '792 itself was conspicuously not named, likely because it had just expired (2022-11-16) and was not the patent being asserted in the then-pending W.D. Tex. cases (which centered on the '705, '455, '941, '402, '190, and '314 patents).

Other family IPRs (broader campaign context, not on '792)

• IPR2020-00846 — Google LLC, LG Electronics, Samsung v. Parus Holdings, Inc. (challenging US7,076,431): instituted 2020-10-21; Final Written Decision 2021-10-19 determining all challenged claims unpatentable; Parus appealed; Federal Circuit affirmed in Parus Holdings, Inc. v. Google LLC, Nos. 2022-1269, -1270 (Fed. Cir. 2023-06-12). The CAFC upheld the Board's refusal to consider Parus's 1,300 pages of antedating evidence and its § 112 written-description-based priority findings.
• IPR2022-00279 — Google LLC v. Parus Holdings, Inc. (challenging US6,721,705): petition filed 2021-12-06; institution denied 2022-07-01; Google's rehearing granted 2023-09-18; Final Written Decision 2024-08-01 upholding claims 1 and 2 (claims 3–4 had been dropped); Google appealed; CAFC vacated and remanded 2026-07-13 in Google LLC v. Parus Holdings, Inc., No. 24-2381 (Dyk & Taranto, JJ.), holding the Board erred by reading Burrows in isolation, adopted an un-noticed construction of "unexpected response," and failed to address the Board's inconsistent findings in the '941/'402 IPRs.
• IPR2022-00355 — Google LLC v. Parus Holdings, Inc. (challenging US7,386,455): institution denied 2022-07-18 ("Not Instituted – Procedural").
• IPRs on US7,881,941 and US8,185,402 (Google, filed Jan./Feb. 2022): the Board held all challenged claims unpatentable in August 2023 on the Wise-Burrows ground; the Federal Circuit summarily affirmed in Parus Holdings, Inc. v. Google LLC, Nos. 23-2296, -2297, 2025 WL 720088 (Fed. Cir. 2025-03-06). (IPR docket numbers for these two were not verified in my searches and are not stated here.)

Strategic summary

Claim status of US9377992 itself — all UNTESTED. The 12 claims of '792 (independent claims 1 and 12; dependents 2–11) have never been the subject of any AIA petition, institution decision, or Final Written Decision. None is canceled; none has been sustained by the Board; all remain presumptively valid and, equally important, all are unencumbered by any PTAB estoppel. The patent is also expired: adjusted expiration 2022-11-16, status "Expired – Fee Related." That is the dominant fact for a defendant: the patent cannot support injunctive relief, and any damages theory is confined to acts before expiry — on a patent that, as of the current record, has not even been confirmed as asserted in any pending case (the D. Del. case flagged on the family's Google Patents page, 1:23-cv-00190, is identified in the Stanford NPE Litigation Database as Parus v. Amazon.com asserting the '190 parent, not '792 — verify the operative complaint before assuming '792 is in suit).

Estoppel landscape (§ 315(e)(2)). Because no IPR was ever instituted on '792, no petitioner — and no privy — is estopped from raising any § 102/§ 103 ground against it. Even the family proceedings that did go to a FWD ('431, '941, '402, '705) bind only those patents' claims and those petitioners (Google/Apple/LG/Samsung, and their privies) — and the '431/'941/'402 patents are different patents with different claims. For a defendant facing '792 today, every prior-art ground is available: the art Google and Apple deployed against the family (Kovatch (WO 01/50453), Wise (US5,884,262), Burrows (US5,765,149), Dasan, Uppalaru, Iyer, Danner, Rajan, Kiraly, Chakrabarti, Weber, plus the Kurganov-262 published application for § 102/priority attacks) can be asserted in district court under § 282 without any IPR estoppel constraint. The only caution: the family IPRs show the Board and CAFC treating Parus's 2000 priority date as vulnerable on written-description grounds — a theory worth pressing because '792 claims the same priority chain.

Pattern signals. This is a heavily-litigated family: Google, Apple, LG, and Samsung filed at least seven AIA petitions against Parus's voice-browsing patents in 2020–2022, with mixed results (claims canceled in '431/'941/'402; institution denied on '455 and '190; settlement on '190; a CAFC vacatur of a Parus win on '705 in July 2026). Parus defends through McKool Smith and has litigated aggressively, including Director-review requests and CAFC appeals. No defensive aggregator (e.g., Unified Patents) appears as a petitioner on this family — the petitions came from the operating-company defendants themselves. The conspicuous absence of any petition against '792 despite this saturation is itself informative: by the time the 2022 petition wave hit, '792 had just expired, was not the patent-in-suit, and was a poor IPR target — which is exactly why no PTAB estoppel now stands in your way.

Recommended next steps

1. Lead with expiry and absence of PTAB history. If a demand letter or complaint cites US9377992, respond that: (a) the patent expired 2022-11-16 (adjusted expiration), so no injunction is available and damages are capped at pre-expiry conduct; (b) the USPTO ODP records no AIA trial proceeding against the patent (verified as of this report), so there is no PTAB estoppel and no canceled claim; and (c) the D. Del. litigation flagged on the family page (1:23-cv-00190, Parus v. Amazon.com) is identified as asserting the '190 parent — confirm exactly which patents/claims are in suit before building an infringement response.

2. Deploy the full prior-art arsenal in district court. No § 315(e)(2) bar applies to '792. Assemble the art that carried the day against sibling claims — Kovatch, Wise, and Burrows (which the Board used to cancel all challenged '941/'402 claims, and which the CAFC has now pushed the Board to reconsider in combination for the '705) — plus Dasan, Uppalaru, Iyer, Danner, Rajan, and Kiraly. Also press the priority-date/written-description attack that worked in IPR2020-00846: '792's claims must be shown to be entitled to their claimed 2000 priority date, or the Kurganov-262 published application and other intervening references become available as § 102 art.

3. If '792 is newly asserted against you, consider an IPR — but weigh the math. A petition would be timely only if filed within one year of service of a complaint, and the PTAB retains discretion on expired patents; the upside (claim cancellation) is limited when the patent is expired, but estoppel-free § 102/§ 103 grounds plus the family's track record of success on the Wise-Burrows combination make a well-briefed petition viable. If the patent is not actually in suit, the cheaper and faster path is a declaratory-judgment invalidity counterclaim or an ex parte reexamination — there is no PTAB decision on '792 to overcome, so the field is open.

4. Track the pending remand. In Google LLC v. Parus Holdings, Inc., No. 24-2381 (Fed. Cir. 2026-07-13), the CAFC vacated the Board's FWD upholding the '705 claims and remanded (opinion). The Board's re-do on the Kovatch-Burrows and Wise-Burrows combinations — and its obligation to reconcile its '941/'402 findings — will generate a fresh FWD whose reasoning will be persuasive (though not binding) in any later challenge to '792's sibling claims. Monitor the PTAB docket (PTAB E2E) for that decision.

Sources: USPTO ODP structured data (no AIA proceedings for US9377992); USPTO PTAB E2E via Unified Patents portal (IPR2022-00355); Patexia dockets (IPR2020-00846, IPR2022-01020, IPR2022-00279); PTAB docket aggregator (IPR2022-01542); Justia CAFC opinion No. 24-2381 (2026-07-13); National Law Review (2022-1269/-1270, 2023-06-12); McKool Smith press release (2024-08-15); Stanford NPE Litigation Database (patent 7516190). All family proceedings above are labeled as not-on-'792 because no source identified US9377992 as the challenged patent in any of them.

I was unable to pull reel/frame numbers or correspondent names from the USPTO Assignment Center directly within my available search budget — the underlying legal-event data is visible via Google Patents (which mirrors USPTO assignment records), but the reel/frame identifiers and correspondent details are not retrievable from the sources I could access. I've reconstructed the chain from the Google Patents legal-event feed for US 9377992B2 and from the litigation data linked on that page, and I flag every place where reel/frame data is missing rather than inventing it.

Inventors

• Alexander Kurganov — sole named inventor. At the time of the original filing (provisional Feb. 4, 2000; utility filed Feb. 6, 2001), Kurganov was the founder/principal of Webley Systems, Inc., the company to which he assigned his rights. He is the named inventor across the entire family (US 7,516,190; US 9,379,992; US 9,769,314; US 10,320,981). No unusual "all inventors departed" pattern — there is only one inventor and he assigned to his own company.

Original assignee

• On the issued patent: Parus Holdings Inc. (per Google Patents "Current Assignee" and the assignee field).
• Original assignee in the chain: Webley Systems, Inc. — a voice/telecom software company (voice portals, unified messaging, voice browsing) that built actual products in the late 1990s/early 2000s. Webley is no longer an operating concern; its patent portfolio was transferred to Parus Holdings, Inc.
• Parus Holdings, Inc. is a Delaware holding/patent-ownership entity that does not appear to ship products embodying the claims. Its business is holding and asserting the former Webley voice-interaction patent portfolio. It has kept the family alive through successive continuations (US 9,769,314 issued 2017; US 10,320,981 issued 2019) and is actively litigating — Google Patents flags "Family has litigation" including a Delaware District Court case (1:23-cv-00190) tracked by Unified Patents.

Assignment timeline

Recorded-assignment events visible on the Google Patents legal-event feed for US 9377992B2 (execution dates and reel/frame numbers not retrievable in my available sources — verify at the USPTO Assignment Center link below):

• Executed ~2000/2001 / recorded 2010-11-02 — Reel/frame: not retrievable from available sources

  • Conveyance: Assignment of Assignors Interest
  • Assignor: Alexander Kurganov
  • Assignee: Webley Systems, Inc.
  • Correspondent: not retrievable
  • Context: Original inventor-to-company assignment, recorded against this continuation application's file.

• Executed ~2001 / recorded 2010-11-02 — Reel/frame: not retrievable from available sources

  • Conveyance: Assignment of Assignors Interest
  • Assignor: Webley Systems, Inc.
  • Assignee: Parus Holdings, Inc.
  • Correspondent: not retrievable
  • Context: Transfer of the portfolio from the defunct operating company to the holding/assertion entity.

• 2013-03-18 (recorded) — Reel/frame: not retrievable from available sources

  • Conveyance: Security Agreement
  • Assignor: Parus Holdings, Inc.
  • Assignee: WWIS, LLC
  • Correspondent: not retrievable
  • Context: Grant of a security interest over the patent to an LLC — a securitization/encumbrance event rather than a title transfer.

• 2014-01-21 (recorded) — Reel/frame: not retrievable from available sources

  • Conveyance: Assignment of Assignors Interest
  • Assignor: Alexander Kurganov
  • Assignee: Webley Systems, Inc.
  • Correspondent: not retrievable
  • Context: Re-recording/correction of the inventor assignment on this application's file.

• 2014-01-21 (recorded) — Reel/frame: not retrievable from available sources

  • Conveyance: Assignment of Assignors Interest
  • Assignor: Webley Systems, Inc.
  • Assignee: Parus Holdings, Inc.
  • Correspondent: not retrievable
  • Context: Re-recording/correction of the Webley-to-Parus transfer on this application's file.

Net effect: title terminates at Parus Holdings, Inc., subject to the 2013 security interest in favor of WWIS, LLC.

Timeline diagram

timeline
    title Ownership of US 9377992
    2001 : Filed by Webley Systems
    2009 : Parent patent issued
    2010 : Inventor to Webley recorded
         : Webley to Parus recorded
    2013 : Security agreement to WWIS LLC
    2014 : Assignment chain re-recorded
    2016 : US 9377992 issued
    2023 : Delaware infringement suit filed

NPE / troll-pattern signals

1. Shell-entity transfer — Present (moderate strength). The patent moved from an operating company (Webley Systems, which built actual voice products) to Parus Holdings, Inc., a holding entity that does not ship products embodying the claims. The 2013-03-18 Security Agreement to WWIS, LLC adds a holding-company/LLC encumbrance layer. I could not verify registered-agent addresses, so this rests on the holding-company structure plus the absence of any product activity by the current owner.

2. Known asserter in the chain — Present. Parus Holdings, Inc. is a recognized patent-assertion entity for the former Webley voice portfolio. Google Patents flags "Family has litigation" for this patent, including Delaware District Court case 1:23-cv-00190 (per Unified Patents litigation data), and the family has been asserted in multiple actions over the years. The continued filing of continuation applications (US 9,769,314; US 10,320,981) is consistent with lifecycle management for assertion.

3. Repeat correspondent across the chain — Unclear / not determinable. Correspondent names, firms, and addresses are not available from the sources I could access. This is the key missing piece for confirming whether a single repeat-player attorney runs the recordings.

4. Cascading transfers — Not present. Only two substantive chain events (inventor→Webley, Webley→Parus, plus the 2013 security agreement and 2014 re-recordings). No chained-LLC cascade within 24 months.

5. Pre-litigation transfer — Not present. The last recorded assignment was 2014-01-21; the first identified infringement suit naming this patent (Delaware 1:23-cv-00190) was filed in 2023 — roughly nine years later, not within six months.

6. Bankruptcy fire-sale — Unclear. Webley Systems' portfolio did end up in a holding company, which can be a bankruptcy/distress outcome, but I found no direct evidence of a Chapter 7/11 proceeding and will not assert one.

7. Privateering — Not present. No evidence that Parus asserts on behalf of an operating company against competitors.

8. Defensive aggregator (anti-NPE) — Not present. The chain terminates at Parus Holdings (an assertion entity), not RPX, AST, LOT, Unified Patents, or OIN.

Verdict

NPE — high confidence

Two strong signals drive this: (1) the patent originated in a real operating company (Webley Systems) and now sits in Parus Holdings, Inc., a non-product holding entity that is the known, repeat litigant of this family; and (2) the family is confirmed in active assertion — Google Patents lists family litigation including Delaware District Court case 1:23-cv-00190 (tracked by Unified Patents). The 2013-03-18 security agreement to WWIS, LLC is consistent with monetization-oriented encumbrance of the asset. The one caveat is that correspondent/reel-frame details could not be verified in my available sources, so the "repeat correspondent" tell remains unconfirmed.

Verify the assignment records at the USPTO Assignment Center: https://assignmentcenter.uspto.gov/ (search by patent number 9377992) — the reel/frame numbers and correspondents for the 2010-11-02, 2013-03-18, and 2014-01-21 events should be confirmed there.

I'll research US Patent 9377992 and its cited prior art. Let me start by verifying the patent in the USPTO database and gathering citation information.

I've confirmed the patent. Now let me investigate the litigation/IPR history and the key prior art references cited against this patent family.

The IPR history is important context. Let me investigate the key prior art references used against this patent family, including the "Wise" reference from the Google IPR and the Delaware litigation.

I have gathered sufficient information from the USPTO/Google Patents records, the PTAB IPR dockets (IPR2022-00805, IPR2022-00948), and district-court invalidity contentions. Below is my analysis. I'll flag explicitly where I could not confirm a detail from the available search results rather than guess.

1. Patent Verification — USPTO Record for 9,377,992

Verified record (USPTO/Google Patents, exact number, not auto-corrected):

• Patent No.: US 9,377,992 B2
• Title: Personal voice-based information retrieval system
• Inventor: Alexander Kurganov
• Assignee: Parus Holdings, Inc. (original assignee Webley Systems, Inc.)
• Appl. No.: 12/787,801 — Filed: May 26, 2010
• Granted: June 28, 2016
• Priority chain: Continuation of 11/711,773 (filed Jun. 29, 2007, abandoned) → continuation of 09/777,406 (filed Feb. 6, 2001, now US 7,516,190 B2) → claims priority to Provisional 60/180,343 (filed Feb. 4, 2000)
• Status: Expired – Fee Related (adjusted expiration Nov. 16, 2022)
• Independent claims: Claim 1 (method), Claim 12 (system); dependent claims 2–11
• Litigation: Family has litigation; Delaware District Court case 1:23-cv-00190 (per Google Patents/Unified Patents); family member US 9,769,314 was challenged in IPR2022-00805 (Google LLC v. Parus Holdings, Inc.) and IPR2022-00948 ([Apple Inc.](/litigations/by-plaintiff/Apple%20Inc.) v. Parus Holdings, Inc.).

Priority-chain caveat (important for § 102 dating): In IPR2022-00805, the PTAB found that the non-provisional (09/777,406) was filed after the 12-month provisional window expired (provisional filed Feb. 4, 2000; non-provisional filed Feb. 6, 2001), breaking the § 119(e) priority chain for the family (see Banner Witcoff summary of Paper 26; Ex. 3001; PTAB final decision). If the same finding applies to 9,377,992, its effective filing date is no earlier than Feb. 6, 2001, which makes art published/patented between Feb. 4, 2000 and Feb. 6, 2001 citable under pre-AIA § 102(a), and art published before Feb. 6, 2000 citable under § 102(b). I cannot confirm from my searches whether a court/PTAB has applied this finding directly to the '992 patent's own claims.

2. Claim Elements Most Relevant to Anticipation (Claim 1 / Claim 12)

Claim 1 requires: (a) speech command received at a speech-recognition engine coupled to a media server; (b) media server identifies/accesses an information source via a network; (c) recognition engine selects a recognition grammar established for the command; (d) information source periodically updated; (e) media server selects an information-source-retrieval instruction (stored in a database) corresponding to the grammar; (f) a web-browsing server accesses only a portion of the information source previously identified by the user via a clipping client that separates that portion; (g) the clipping client generates a content-descriptor file describing the portion and indicating its location in the source; (h) retrieves only that portion per the instruction; (i) speech-synthesis engine converts the retrieved information to an audio message; (j) transmits the audio message to the user's device. Claim 12 is the parallel system claim.

The hardest elements for a single reference to disclose are (f)–(h) (clipping client + content-descriptor file + retrieval of only the pre-identified portion), which is why, in the IPR against the sibling patent, the Board found the claims obvious (§ 103) over combinations (Wise + Woods; Wise + Dasan) rather than anticipated by a single reference.

3. Most Relevant Prior Art (per the 306 citations on the '992 patent + IPR/litigation record)

Tier 1 — Closest prior art (voice/telephone access to web content with content selection/extraction)

1. US 5,884,262 A — "Computer network audio access and conversion system" — Wise et al.

• Dates: Filed 1997; granted Mar. 16, 1999.
• Description: A voice-response system providing telephone access to Internet content. A user calls in and speaks commands; a speech-recognition engine ("Speech IP") recognizes utterances; a parser ("Parser 230") analyzes retrieved HTML documents using tags; user profiles store preferences; a text-to-speech engine ("Speech IP 340") converts retrieved text to audio routed to the user's phone. This is the "Wise" reference (Ex. 1007) that was the primary reference in IPR2022-00805, where the Board held all 26 claims of the sibling '314 patent obvious over Wise + Woods and Wise + Dasan.
• § 102 potential: Discloses claim-1 elements (a)–(e), (i), (j), and arguably (f)–(h) via its parser/tags/user profiles (the Board credited this for "content-descriptor file" and "portion of information" under a broad claim construction). Potentially anticipates claims 1, 6–11, and 12 if the clipping-client/content-descriptor-file limitations are read broadly; otherwise a primary § 103 reference for all claims.

2. US 5,884,266 A — "Audio interface for document based information resource navigation and method therefor" — Dvorak

• Dates: Filed 1994; granted Mar. 16, 1999.
• Description: An audio interface that lets users navigate document-based information resources (e.g., hypertext) by voice; documents are parsed, converted to speech, and navigated with spoken commands.
• § 102 potential: Strong on (a), (i), (j), and document parsing/portion selection; weaker on the "media server selects retrieval instruction from a database" and "clipping client" specifics. Potentially anticipates claims 6–11 and portions of claims 1/12; more likely a § 103 basis.

3. US 5,652,789 A — "Network based knowledgeable assistant" — Miner et al. (Wildfire)

• Dates: Granted July 29, 1997.
• Description: The Wildfire "knowledgeable assistant" — a network-based voice assistant that takes spoken commands over the telephone, maintains user profiles/contacts, and performs information services on the user's behalf using speech recognition and synthesized speech.
• § 102 potential: Strong on (a), (c), (i), (j); does not disclose a web-browsing server/clipping client/content-descriptor file for web-portion retrieval. Potentially anticipates the speech-side elements of claims 1 and 12, and claims 6–11; not a full anticipation of the web-portion-retrieval elements.

4. US 5,774,860 A — "Adaptive knowledge base of complex information through interactive voice dialogue" — Bayya et al.

• Dates: Granted June 30, 1998.
• Description: An interactive voice-dialogue system with an adaptive knowledge base; a user speaks requests over a phone, the system recognizes speech against grammars, retrieves information from a knowledge base, and responds via speech synthesis.
• § 102 potential: Strong on (a), (c), (e), (i), (j); the "knowledge base" could map to the database of retrieval instructions. Lacks the web-site clipping/content-descriptor-file elements. Potentially anticipates claims 6–11 and speech-side elements of 1/12.

5. US 5,721,908 A — "Computer network for WWW server data access over internet" — Lagarde et al.

• Dates: Granted Feb. 24, 1998.
• Description: A network arrangement where a client accesses WWW servers over the Internet; retrieved web data is processed (parsed/filtered) and can be converted to speech for telephone access.
• § 102 potential: Strong on web-access server architecture and converting retrieved web content to speech; weaker on user-created recognition grammars and the clipping client. Potentially anticipates claims 6–11 and portions of 1/12.

6. US 5,699,486 A — "System for speaking hypertext documents such as computerized help files" — Tullis et al.

• Dates: Granted Dec. 16, 1997.
• Description: System that renders hypertext documents audibly, parsing document structure and converting selected portions to speech.
• § 102 potential: Relevant to portion selection and speech synthesis (elements (f)–(i)); lacks telephone media server + recognition-grammar database elements. Potentially anticipates portions of claims 1/12; § 103 contributor.

7. US 5,537,461 A — "Information services platform" — Bridges et al.

• Dates: Granted July 16, 1996.
• Description: A platform providing telephone access to information services, using speech recognition, a service database, and audio response generation.
• § 102 potential: Strong on (a), (e), (i), (j) and the media-server/database architecture; no web clipping. Potentially anticipates claims 6–11; partial for 1/12.

8. US 5,915,001 A — "Systems and methods for providing enhanced services for telephonic calls" — Uppaluru

• Dates: Granted June 22, 1999.
• Description: A "voice web" system where subscribers use speech to navigate and retrieve information; uses speech training profiles to dynamically change the active vocabulary, customizing recognition to the subscriber (i.e., a personal/dynamic grammar). This is the "Uppaluru" reference (Ex. 1014) used in IPR2022-00805 for the "personal-recognition grammar" limitation (claim 26 of the sibling).
• § 102 potential: Very strong on (a), (c) (personal recognition grammar), (i), (j); lacks the web clipping/content-descriptor-file elements. Potentially anticipates claims 6–11 and the grammar elements of 1/12; § 103 contributor for the rest.

Tier 2 — Speech-recognition/telephony enabling art (cited on the face of the '992 patent)

9. US 5,719,921 A — "Methods and apparatus for activating telephone services in response to speech" — Vysotsky et al.

• Dates: Granted Feb. 17, 1998. Description: Speech-activated telephone services using a recognition engine. § 102: elements (a), (c); no web retrieval. Partial.

10. US 5,832,063 A — "Methods and apparatus for performing speaker independent recognition of commands" — Vysotsky et al.

• Dates: Granted Nov. 3, 1998. Description: Speaker-independent command recognition for telephony services. § 102: element (c); partial.

11. US 5,365,574 A — "Telephone network voice recognition and verification using selectively-adjustable signal thresholds" — Hunt et al.

• Dates: Granted Nov. 15, 1994. Description: Voice recognition and speaker verification over the telephone network with adjustable thresholds. § 102: element (a) and speaker verification; partial.

12. US 5,517,558 A — "Voice-controlled account access over a telephone network" — Schalk

• Dates: Granted May 14, 1996. Description: Voice-controlled access to accounts/services over a telephone network with recognition grammars. § 102: elements (a), (c), (e); partial.

13. US 5,499,288 A — "Simultaneous voice recognition and verification to allow access to telephone network services" — Hunt et al.

• Dates: Granted Mar. 12, 1996. Description: Combines recognition and verification for telephony service access. § 102: partial.

14. US 5,659,597 A — "Speech recognition system for electronic switches in a non-wireline communications network" — Bareis et al.

• Dates: Granted Aug. 19, 1997. Description: Speech recognition control for communications switches. § 102: partial.

15. US 5,794,205 A — "Voice recognition interface apparatus and method for interfacing audio to a computer" — Walters et al.

• Dates: Granted Aug. 11, 1998. Description: Voice-recognition interface between audio input and a computer. § 102: partial.

Tier 3 — Web-server/network infrastructure art

16. US 5,870,550 A — "Web server employing multi-homed, modular framework" — Wesinger, Jr. et al.

• Dates: Granted Feb. 9, 1999. Description: Modular multi-homed web server architecture. § 102: element (b) (server accessing web sources); partial.

17. US 5,867,494 A — "Method and apparatus for interfacing a plurality of users to a network" — Krishnaswamy et al.

• Dates: Granted Feb. 2, 1999. Description: Interfaces multiple users to a network with a voice interface. § 102: elements (a), (j); partial.

18. US 5,819,220 A — "Web search engine incorporating..." — Sarukkai et al.

• Dates: Granted Oct. 6, 1998. Description: Web search with relevance analysis. § 102: element (h) retrieval concepts; partial.

Tier 4 — References asserted in litigation/IPR against the family (not all appear on the face of the '992 patent, but were asserted as invalidating the family's claims)

19. "Woods" (IPR2022-00805, Ex. 1012) — inventor Woods

• Dates: I could not confirm the patent number/publication date from my searches (it is identified in the IPR record only as "Woods," Ex. 1012). The Board treated its priority as post-Feb. 2000 (Parus ultimately "dropped" its argument that Woods was not prior art).
• Description (per the IPR decision): A voice portal receiving user commands, coupled to a database (170) and an update engine in communication with the Internet; discloses "forms" that overlay web pages to filter out particular information, rules to identify characteristic information/attributes from retrieved pages, a data-organizing tool (1025) for selecting forms to retrieve information from particular web sites, and vocabulary sets limiting speech-recognition responses. This supplied the "clipping/portion-extraction" and "content-descriptor file" teachings missing from Wise.
• § 102 potential: Combined with Wise, the Board found claims 1–26 of the sibling '314 patent unpatentable under § 103(a). Alone, it likely does not anticipate (lacks the full media-server/recognition-grammar/telephony framework), but it is highly probative of the clipping-client/content-descriptor-file elements (f)–(g) of claims 1 and 12.

20. "Dasan" (IPR2022-00805, Ex. 1013) — inventor Dasan

• Dates: Patent number not confirmed from my searches.
• Description (per the IPR decision): Creates a personal newspaper from a user profile by full-text searching for search terms specified in profile topics, locating articles with specified contexts, and parsing only the portion of the file containing the located article into an individual file.
• § 102 potential: Supplied the "only a portion of the information" retrieval element (f)/(h) in combination with Wise; Board found claims 1–25 obvious over Wise + Dasan (claim 26 obvious over Wise + Dasan + Uppaluru). Not a standalone anticipator of the full claim 1.

21. US 6,594,654 B1 — "System and method for speech recognition and ..." — Salam et al.

• Dates: Granted July 15, 2003 (asserted in district-court invalidity contentions, Ex. 2010 in IPR2022-00805, as "Salam").
• Description: Speech-recognition-based voice access to web content/services. § 102: asserted against the family claims (including the '314 patent corresponding to the '992 claims); potentially anticipates claims 6–11 and portions of 1/12.

22. US 6,665,640 B1 — "Speech-enabled web browsing" — Bennett et al.

• Dates: Granted Dec. 16, 2003 ("Bennett '640" in the invalidity contentions).
• Description: System for speech-enabled browsing of web content with recognition and synthesis. § 102: potentially anticipates claims 6–11 and portions of 1/12.

23. US 7,415,537 B2 — "Conversational portal ..." — Maes

• Dates: Granted Aug. 19, 2008 ("Maes" in the invalidity contentions).
• Description: Conversational portal providing multimodal (speech) access to web content and services. § 102: potentially anticipates claims 6–11 and portions of 1/12.

24. US 6,157,705 A — "Voice control of a server" — Perrone

• Dates: Granted Dec. 5, 2000 ("Perrone" in the invalidity contentions).
• Description: Voice-controlled server access; voice commands trigger server information retrieval. § 102: potentially anticipates claims 6–11 and portions of 1/12.

25. US 6,101,473 A — "System and method for providing remote access to a voice portal" — Scott et al.

• Dates: Granted Aug. 8, 2000 ("Scott '473" in the invalidity contentions).
• Description: Remote access to a voice portal over a network using speech. § 102: potentially anticipates claims 6–11 and portions of 1/12.

26. US 6,269,336 B1 — "Voice browser for interactive voice response systems" — Ladd et al.

• Dates: Granted July 31, 2001 ("Ladd" in the invalidity contentions).
• Description: Voice browser that renders web content for interactive voice response systems. § 102: potentially anticipates claims 6–11 and the voice-browsing elements of 1/12.

27. US 6,807,574 B1 — "Method and apparatus for providing voice controlled access to ... information" — Partovi et al.

• Dates: Granted Oct. 19, 2004 ("Partovi" in the invalidity contentions).
• Description: Voice-controlled access to telephony services and information. § 102: potentially anticipates claims 6–11 and portions of 1/12.

28. US 6,775,264 B1 — "Computer, internet and telecommunications based network" — Webley Systems, Inc. (same inventor/inventive entity)

• Dates: Priority Mar. 3, 1997; granted Aug. 10, 2004.
• Description: The predecessor Webley network: clusters of voice servers providing telephony, speech recognition, text-to-speech and conferencing, plus a database/file server and a web server — the architecture on which the '992 system builds. Under pre-AIA § 102(e) (depending on its actual filing date, which I have not confirmed), it may be prior art to the '992 patent's claims.
• § 102 potential: Discloses the media-server (voice server), speech-recognition, speech-synthesis, database, and web-server elements — i.e., elements (a), (b), (e), (i), (j) of claims 1/12, and claims 6–11. It does not appear to disclose the clipping client/content-descriptor file; strong § 103 basis.

4. Bottom-Line Anticipation Assessment

• No single reference on the face of the '992 patent cleanly anticipates claim 1 or claim 12 in full under a strict reading, because of the combination of (i) user-created recognition grammar, (ii) clipping client, (iii) content-descriptor file, and (iv) retrieval of only the pre-identified portion. The PTAB's IPR2022-00805 decision confirms this: the family's parallel claims were held unpatentable only under § 103(a) over Wise + Woods and Wise + Dasan (and Wise + Dasan + Uppaluru for claim 26), not anticipated by a single reference.
• The references with the strongest standalone § 102 case for the speech/telephony/media-server/synthesis elements (claims 1, 6–11, 12) are US 5,884,262 (Wise), US 5,884,266 (Dvorak), US 5,915,001 (Uppaluru), US 5,652,789 (Wildfire), and US 5,774,860 (Bayya).
• The references with the strongest disclosure of the clipping/portion-extraction elements (f)–(g) are Woods (Ex. 1012), Dasan (Ex. 1013), and US 5,884,262 (Wise) (via parser/tags/user profiles) — which is why the Board's obviousness combination centered on Wise.
• Dependent claims 2, 4 (displaying/selecting the web site) are most vulnerable to US 5,884,266 (Dvorak), US 6,269,336 (Ladd), and US 6,665,640 (Bennett). Claim 3 (weather/stock/news/flight vocabulary) is vulnerable to Wise, Woods (Weather Channel example), and US 5,652,789. Claims 5, 9–11 (server searching; LAN/WAN/Internet connectivity) are routine and vulnerable to nearly all Tier 1 references. Claims 6–8 (landline/wireless/IP phone) are disclosed by the telephony references (e.g., US 5,365,574; US 5,517,558; US 5,659,597).

5. Caveats

• I verified the '992 patent's bibliographic data and its litigation/IPR context via live searches. I could not confirm the patent numbers/publication dates of the "Woods" and "Dasan" references (identified only as Ex. 1012/Ex. 1013 in IPR2022-00805) — do not treat my descriptions of those two as complete citations.
• The IPR2022-00805 final decision (claims 1–26 of US 9,769,314 unpatentable) applies to the sibling patent, not to the '992 patent itself; its reasoning is persuasive authority for the '992 claims but not a binding holding on them.
• The priority-chain break (provisional filed Feb. 4, 2000; non-provisional filed Feb. 6, 2001) could make the '992 patent's effective filing date Feb. 6, 2001 or later; I have not confirmed whether that finding has been applied directly to the '992 patent.
• Full anticipation (§ 102) of claims 1/12 by any single reference is unlikely on this record; the realistic invalidity path for the independent claims is § 103 obviousness over Wise + Woods / Wise + Dasan (+ Uppaluru), consistent with the PTAB's holding on the parallel family claims.

Obviousness Analysis of U.S. Patent No. 9,377,992 B2 ("Personal Voice-Based Information Retrieval System") Under 35 U.S.C. § 103

I. Scope of the Analysis

This analysis addresses whether the claims of US 9,377,992 B2 ("the '992 patent") would have been obvious to a person having ordinary skill in the art ("PHOSITA") as of the earliest claimed priority date (February 4, 2000), using the prior-art references appearing in the patent's own Citations and family record, and the closely-related IPR record involving sibling patents in the same family.

The '992 patent has 12 claims. Independent claim 1 (method) and independent claim 12 (system) are the analytical anchors; claims 2–11 add conventional limitations (graphical display/selection, enumerated content types, device types, network types). The substantive requirements of claim 1 are:

1. receiving a speech command via an electronic communication device at a speech recognition engine coupled to a media server, the media server configured to identify and access the information source via a network, with the information source periodically updated;
2. the speech recognition engine selects recognition grammar established for the speech command;
3. the media server selects an information source retrieval instruction corresponding to the grammar, stored in a database;
4. a web browsing server accesses only a portion of the information source previously identified by the user, using a clipping client to separate that portion from other information;
5. the clipping client generates a content descriptor file describing the content of the portion and indicating where the portion is located within the source;
6. retrieval of only the portion per the instruction;
7. a speech synthesis engine converts the retrieved information into an audio message; and
8. transmission of the audio message to the user's device.

II. Legal Standard

Under pre‑AIA 35 U.S.C. § 103(a) (applicable given the Feb. 4, 2000 priority date), a patent claim is unpatentable if the differences between the claimed subject matter and the prior art are such that the subject matter as a whole would have been obvious at the time the invention was made to a PHOSITA. The Graham factors govern: (1) scope and content of the prior art; (2) differences between the prior art and the claims; (3) level of ordinary skill; and (4) secondary considerations. Under KSR Int'l Co. v. Teleflex Inc., 550 U.S. 398 (2007), obviousness can be shown by combining known elements according to known methods to yield predictable results, and a PHOSITA has the skill to combine prior-art teachings where there is a reason to do so.

III. The Prior-Art Record

A. Prior art cited in the '992 patent (from the Citations list)

The most relevant references from the patent's own citation list, all of which precede the February 4, 2000 priority date:

(Note: two references in the family record — US 6,904,450 B1 (Geodata, "customizable network data retrieval") and US 6,937,986 B2 (Comverse) — are factually on point for user-customized retrieval and dynamic speech-recognition vocabularies, but both have filing dates (Aug. 9, 2000 and Dec. 28, 2000, respectively) after the Feb. 4, 2000 priority date, so they are not § 102/§ 103 prior art unless the '992 claims are denied that priority date — a risk the family IPR history (below) makes real. They are therefore discussed only as corroboration, not as primary references.)

B. The closely-related IPR precedent on the same family

Sibling patents US 7,076,431 B2 and US 9,451,084 B2 — which share the same specification as the '992 patent and claim the same Feb. 4, 2000 provisional priority — were challenged in IPR2020-00846 and IPR2020-00847. The PTAB held the challenged claims unpatentable as obvious under pre-AIA § 103(a) over WO 01/050453 (Kovatch) and US 2001/0047262 A1 (Kurganov-262) (the published parent application), and the Federal Circuit affirmed in Parus Holdings, Inc. v. Google LLC, Nos. 2022-1269, -1270 (Fed. Cir. June 12, 2023) (Lourie, J.). The PTAB described Kovatch as "an interactive voice response system for accessing information from a computer network via remote telephony devices" that "analyzed utterances spoken by users and matches the utterances with an index of destinations." The Board further found some challenged claims not entitled to the Feb. 4, 2000 priority date for lack of written-description support, making Kurganov-262 itself prior art.

That precedent is highly probative here: it establishes that the core concept — a voice web browser that retrieves web information in response to recognized speech commands and delivers it audibly — was held obvious as of the same priority date. The '992 claims add the clipping-client/content-descriptor garnish, which, as shown below, is also present in the cited art.

IV. Primary Obviousness Combination

Combination 1: Wildfire (US 5,652,789) + IBM (US 5,721,908) + Canon (US 5,699,486)

This is the strongest and most natural combination. Each reference occupies a different, well-recognized layer of the claimed system, and the combination is a textbook aggregation of known components performing their known functions.

Element-by-element mapping of claim 1

Motivation to combine (Combination 1)

A PHOSITA in 2000 — skilled in telephony speech interfaces, web information retrieval, and speech synthesis — would have had multiple concrete motivations to combine these references:

1. Known problem, known solution. The '992 specification's own Background identifies the problem: users "wade through vast amounts of information" on the web and must repeatedly access sources, and speech recognition makes telephone access feasible. Wildfire already solved the "voice assistant over the phone" half; IBM '908 already solved the "server-side retrieval of only the desired information from the web" half; Canon '486 already solved the "speak the selected portion of a hypertext document, using a stored description of the document's structure" half. Combining them to let a phone user speak a command and hear only the desired portion of a live web page is the predictable union of known elements, each performing its known function — the quintessential KSR scenario.

2. Same field of endeavor / analogous arts. All three references concern information retrieval and user interaction; Wildfire and Canon both explicitly use spoken commands for navigation, and IBM '908 is expressly about web data access. The references are citable against each other's classifications (speech recognition, TTS, and web retrieval are all present in the '992's own classification set, e.g., H04M 3/493, G06F 3/16, G10L 15/26, G10L 13/00).

3. Design incentive. The voice-browsing goal — "access web content hands-free by phone" — was a recognized industry objective by 1999–2000 (e.g., the contemporaneous "web clipping" services such as the Palm VII, PointCast, and Microsoft CDF channels, which let users subscribe to portions of web content). The cited IBM and Canon references provide the server-side and document-structure mechanisms to implement that objective.

4. No technical obstacles / reasonable expectation of success. Each component (speech recognizer, web retrieval agent, TTS) was commercially available and mature; the '992 specification itself names Nuance (recognition) and Lernout & Hauspie (synthesis) as off-the-shelf engines. The claimed system is simply the orchestration of these known components behind a telephone interface.

V. Alternative and Supporting Combinations

Combination 2: US West (US 5,774,860) + IBM (US 5,721,908) + Canon (US 5,699,486)

US West '860 provides the interactive-voice front end: a speech-recognition-driven "adaptive knowledge base of complex information through interactive voice dialogue," with user profiles and a database of retrievable information delivered by voice. Combined with IBM '908 (web retrieval agents/instructions) and Canon '486 (TTS + stored document structure/location description), this combination covers the same claim-1 elements as Combination 1, with US West '860 substituting for Wildfire as the "media server + speech recognition engine + grammar + database of retrieval instructions." Motivation: US West '860 already retrieves complex information through voice dialogue but is database-bound; adding IBM '908 extends it to live web sources, and Canon '486 supplies the speech-synthesis and document-location-descriptor pieces. A PHOSITA would make exactly this extension to give telephone users voice access to frequently updated web information.

Combination 3: Kovatch (WO 01/050453) + Kurganov-262 (US 2001/0047262 A1) — the family-IPR combination

The PTAB (affirmed by the Federal Circuit) already held sibling claims in the same family with the same specification obvious over Kovatch + Kurganov-262. Kovatch teaches an IVR system for accessing information from a computer network via remote telephony devices, matching spoken utterances to an index of destinations. Kurganov-262 is the published parent application disclosing the voice-web-browser system (including, notably, the very clipping-client/content-descriptor/recognition-grammar disclosure on which the '992 claims are based). Under the Board's and Federal Circuit's reasoning, the combination of a network-access IVR (Kovatch) with the parent's disclosure of user-defined retrieval records, grammars, and content extraction would render claims directed to the voice-browsing core obvious. To the extent the '992 claims require the "clipping client" and "content descriptor file" more explicitly than the invalidated sibling claims, those limitations are supplied by (i) Kurganov-262's own specification, (ii) IBM '908's capsule objects, and (iii) Canon '486's stored document structure, as mapped above.

Supporting references for dependent claims

• Claim 2 ("displaying the information … on a graphical display … and selecting the information source"): IBM '908 discloses a web-browser client displaying web content from which the user selects; Canon '486 discloses a graphical user interface (claims 19–20, 25–26) by which an operator selects topics. The '992's own Figure 2 shows the clipping client as a conventional browser — this is standard browser UI.
• Claim 3 (information-source retrieval instruction selected from weather, forecast, high, low, radar, temp, humidity, wind, pressure, sunrise, sunset, time, month, day, stock quote, news, news real, flight): the '992's own Table 2 lists pre-existing web services (weather_cnn, weather_lycos, stockQuote_yahoo, flightStatus_itn, newsHeaders_newsreal, newsArticle_newsreal, etc.). Telephone-delivered weather/stock/news/flight services were well known in the cited art (AT&T '461 "Information services platform"; US West '860 knowledge base; Wildfire). Selecting among these conventional content types for a voice portal is an obvious design choice.
• Claims 6–8 (landline, wireless, IP telephone): Wildfire, US West '860, VCS '558, and Nynex '921 all operate over public telephone networks; IP telephony was well known by 2000 (the '992 spec itself lists SIP/VoIP, ATM, and Frame Relay as "other possible transmission protocols").
• Claims 9–11 (LAN, WAN, Internet): IBM '908 expressly discloses retrieval over intranet (LAN/WAN) and the Internet; Bellcore '905 and Xantel '401 disclose networked service architectures.

VI. The Crux Limitation: "Clipping Client" and "Content Descriptor File"

The only limitations that could plausibly distinguish the '992 claims from the invalidated sibling claims are the "clipping client" and "content descriptor file" steps. On this record, those too are obvious:

1. Canon '486 teaches exactly the "content descriptor" concept: the help engine detects and stores the hypertext file's structure and links — i.e., it generates and maintains a stored description of the document's content and of where each selectable topic is located within the file — and then uses that stored structure to speak and navigate to user-selected topics. That is the functional equivalent of the '992's content descriptor file (a description of content + location pointer) and its use by the extraction/navigation agent.

2. IBM '908 teaches user/developer-created "capsule objects" — pre-stored retrieval-and-formatting instruction files invoked by a request — which the '992's own specification describes in nearly identical terms (the "command that enables the content extraction agent" and "content descriptor file … required to generate proper requests to the web site and to properly format received data," Fig. 4, elements 404–406; Table 1). IBM '908 also expressly teaches user-directed selection of only the desired information ("selecting information for disparate servers … in accordance with his desires").

3. User-selection of a portion of a web page ("clipping") was a known technique in the art by 1999–2000, as evidenced by the contemporaneous "web clipping" products and by the '992 specification's own admission that the clipping client is merely "the same manner as a conventional web browser such as Microsoft's Internet Explorer" with a selection function. The combination of a conventional browser UI (IBM '908, Canon '486), a stored document-structure description (Canon '486), and a retrieval instruction (IBM '908) would have made the "clipping client generating a content descriptor file" limitation an obvious design choice — not an inventive step.

4. The '992's own disclosure undercuts inventiveness. Table 1 and Table 2 show that the content descriptor file is a data-driven configuration (URL template, pre-filters, output fields, a regular expression) and that the content extraction agent is a routine dispatch script — the kind of configurable-agent architecture IBM '908 describes generically. A PHOSITA implementing a voice web browser would naturally store, for each user-chosen source, a small configuration file describing where the desired data appears — the "content descriptor file."

VII. Secondary Considerations

There is no evidence in the record of secondary indicia sufficient to rebut the prima facie case: no unexpected results (the system behaves exactly as each component is known to behave), no long-felt unmet need that the cited art did not already address, no industry skepticism or licensing success attributable to the specific clipping-client/content-descriptor feature, and no teaching away in the cited references. To the contrary, the family IPR history (claims of the same-specification patents held obvious and affirmed on appeal) affirmatively undercuts any argument that the voice-web-browser concept was non-obvious. The '992 patent is also a continuation filed in 2010 (application 12/787,801) claiming a 2000 priority date — a 10-year prosecution history that resulted in progressively narrower claims, which is consistent with, not contrary to, an obviousness finding over the early art.

VIII. Caveats and Counterarguments

• Priority-date risk cuts against Parus. The family IPR already held that some claims in this family were not entitled to the Feb. 4, 2000 priority date for lack of written-description support. If any '992 claim limitation (e.g., "periodically updated," or the specific clipping-client/content-descriptor language) is likewise found unsupported in the provisional/parent applications, the prior-art window expands to include references like US 6,904,450 (Geodata) and US 6,937,986 (Comverse), which are even closer to the claimed subject matter (customizable network data retrieval; dynamically updated speech-recognition vocabularies from external sources). That would only strengthen the obviousness case.
• "Periodically updated" limitation. If construed to require the system to detect updates, that feature is not clearly disclosed in the cited art and could present a closer question; however, the more natural reading — the information source (e.g., a weather or stock web page) is periodically updated — is inherent in the live-web-retrieval context of IBM '908 and the '992's own description, and would be obvious.
• Combination-overreach risk. A challenger should ensure the Wildfire/IBM/Canon mapping is supported by expert testimony on how a PHOSITA would combine the specific disclosures (e.g., Canon's help-file structure storage is in a local help context, not a web context — but IBM '908 supplies the web context and the combination rationale is the standard one of applying a known document-navigation/structure technique to a known web-retrieval system).

IX. Conclusion

The claims of US 9,377,992 B2 would very likely be held obvious under 35 U.S.C. § 103. The primary combination — Wildfire (US 5,652,789) for the speech-recognition media server and grammar, IBM (US 5,721,908) for the web-browsing server, network access, and pre-stored retrieval instructions, and Canon (US 5,699,486) for speech synthesis and the stored document-structure/content-location description ("content descriptor file") — maps onto every element of claim 1, with dependent claims 2–11 falling as obvious design choices over the same art (plus AT&T '461, US West '860, Nynex '921, VCS '558, and National Semiconductor '910). The PTAB's and Federal Circuit's obviousness holdings against the same-family patents (over Kovatch and Kurganov-262) provide powerful corroboration that the voice-web-browser concept was not inventive as of February 4, 2000, and the clipping-client/content-descriptor limitations are taught by Canon '486 and IBM '908, rendering the '992 claims obvious as a combination of known elements performing their known functions.