APPLE INC. v. ZENTIAN LTD.
Patent Trial and Appeal Board
Holding
The Federal Circuit held that the Board legally erred by requiring the prior art to accommodate a large-vocabulary acoustic model when the claims required only an acoustic model and covered smaller abbreviated models. The Board also erred by requiring proof that a skilled artisan could personally fabricate a new integrated circuit, where fabrication was not a claimed step.
Why It Matters
The decision is a useful reminder that the Board cannot import unclaimed implementation requirements into an obviousness analysis, including size requirements or manufacturing steps not present in the claims.
Full Summary
Key Points
- The claims required an acoustic model memory and calculating apparatus on a single integrated circuit; the Board treated the acoustic model as requiring a large-vocabulary model.
- The Federal Circuit held that was legal error because the claim language covered abbreviated models, such as a digits-recognizer model, that define a plurality of acoustic states.
- The court found Apple had raised the abbreviated-model point in reply, contrary to the Board's timeliness ruling, but left factual questions about memory capacity for remand.
- For the Smyth/Mozer combination, the Board must address whether Mozer's 4,000-byte on-chip memory could store an abbreviated model and whether the combination would have yielded the claimed integrated-circuit arrangement.
- The court also rejected the Board's requirement that Apple prove a POSA could personally fabricate the combined circuit, because the claims did not require fabrication as a method step.
How this summary was made: Drafted with AI from the court's opinion or order. Read the document itself before relying on the summary. Editorial policy
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