"U.S. Patent No. 9,491,542 is titled "Automatic Sound Pass-Through Method and System for Earphones" and was challenged by Samsung via inter partes review (IPR) after ST1 sued Samsung for infringement. Samsung argued that claims 1-10 and 13- 20 of the patent were invalid due to obviousness based on three prior art references: Rosenberg, Ichimura and Visser. The PTAB ultimately found all of the challenged claims obvious over combinations of the prior art, but also found unchallenged claims 11 and 12 unpatentable without explanation."
"On appeal, the CAFC agreed with the Board's construction of the claim term "detecting a cessation of the voice activity," known as the "cessation limitation." ST1 argued the cessation limitation should be construed to mean detecting an end of speech," which excludes "momentary pauses within speech," while Samsung argued it should be construed broadly enough "to also encompass detecting the end of a word within a sentence or conversation." The CAFC found both the claim language and specification supported the Board's construction."
CAFC affirmed in part PTAB's determination that several claims of U.S. Patent No. 9,491,542 are obvious, and vacated the Board's decision regarding claims 11 and 12 because those claims were not challenged in Samsung's petition. Samsung pursued inter partes review challenging claims 1–10 and 13–20 as obvious over Rosenberg, Ichimura and Visser. PTAB found the challenged claims obvious and also declared claims 11 and 12 unpatentable without explanation. CAFC agreed with PTAB's construction of the 'detecting a cessation of the voice activity' limitation, rejected ST1's narrower construction, and found another claim limitation protected the invention's purpose.
Read at IPWatchdog.com | Patents & Intellectual Property Law
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