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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Plaintiff,
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`PARUS HOLDINGS INC.,
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`
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`v.
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`LG ELECTRONICS, INC. and LG
`ELECTRONICS U.S.A., INC.,
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`
`
`
`Defendant.
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`Civil Action No. 6:19-cv-00437-ADA
`
`
`JURY TRIAL DEMANDED
`
`
`
`PARUS HOLDING INC.’S
`FIRST AMENDED COMPLAINT FOR PATENT INFRINGEMENT
`
`Plaintiff Parus Holdings Inc. (“Parus” or “Plaintiff”) for its First Amended Complaint for
`
`Patent infringement (“Complaint”) against LG Electronics, Inc. and LG Electronics U.S.A., Inc.
`
`(collectively “LG” or “Defendants”), hereby alleges as follows:
`
`THE PARTIES
`
`1.
`
`Plaintiff Parus Holdings Inc. is a Delaware corporation having its principal place
`
`of business at 3000 Lakeside Drive, Suite 110S, Bannockburn, IL 60015.
`
`2.
`
`Parus is a privately-held company founded in 1997 that offers for sale and sells a
`
`number of voice-driven technology and speech search solutions to allow customers to spend less
`
`time managing their communication channels by allowing customers to search the Internet with
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`their voice and receive audible search results back. These products include ParusSpeak™
`
`Interactive Voice Response (IVR), ParusOne™ Unified Communications, ParusOffice™ Cloud
`
`PBX, and ParusMobile™ Mobile Applications. See https://www.parus.ai/products/. Parus’s
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`
`
`
`
`
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`brands include Parus, obai, Webley, Webley MD, and Parus Interactive. Parus’s voice-enabled
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`search technology is in competition with LG Products implementing Google Assistant.
`
`3.
`
`Parus is the owner by assignment of U.S. Patent No. 7,076,431 (“the ’431
`
`Patent”) (attached as Exhibit 1) and U.S. Patent No. 9,451,084 (“the ’084 Patent”) (attached as
`
`Exhibit 2).
`
`4.
`
`Defendant LG Electronics, Inc. is a Korean corporation with a principal place of
`
`business at LG Twin Towers, 128 Yeoui-daero, Yeongdungpo-gu, Seoul, 07366, South Korea.
`
`On information and belief, LG Electronics, Inc. is the entity that manufactures the LG-branded
`
`products sold in the United States, including the accused products in this case. On information
`
`and belief, in addition to making the products, LG Electronics, Inc. is responsible for research
`
`and development, product design, and sourcing of components.
`
`5.
`
`Defendant LG Electronics U.S.A., Inc. is the North American subsidiary of LG
`
`Electronics, Inc., organized under the laws of Delaware, with a principal place of business at
`
`1000 Sylvan Ave, Englewood Cliffs, NJ, 07632.
`
`6.
`
`LG Electronics U.S.A, Inc. has regular and established places of business in
`
`Texas at least at 9420 Research Blvd, Austin, Texas 78759; 21251-2155 Eagle Parkway, Fort
`
`Worth, Texas 76177; and 14901 Beach St, Fort Worth, TX 76177.
`
`7.
`
`On information and belief, LG maintains one or more regular and established
`
`places of business in Texas, including offices at 9420 Research Blvd, Austin, Texas 78759.
`
`8.
`
`9.
`
`LG Electronics U.S.A., Inc. is registered to do business in Texas.
`
`LG has placed or contributed to placing infringing products like the LG G8 ThinQ
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`into the stream of commerce via an established distribution channel knowing or understanding
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`that such products would be sold and used in the United States, including in the Western District
`
`2
`
`
`
`
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`of Texas. On information and belief, LG also has derived substantial revenues from infringing
`
`acts in the Western District of Texas, including from the sale and use of infringing products like
`
`the LG G8 ThinQ.
`
`10.
`
`LG had constructive notice of the ’431 Patent based on Parus’s marking at least as
`
`of June 18, 2007.
`
`11.
`
`LG had constructive notice of the ’084 Patent based on Parus’s marking at least as
`
`of February 21, 2018.
`
`JURISDICTION AND VENUE
`
`12.
`
`This is an action for patent infringement arising under the patent laws of the
`
`United States, Title 35 of the United States Code. Accordingly, this Court has subject matter
`
`jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`
`13.
`
`This Court has specific personal jurisdiction over Defendants at least in part
`
`because Defendants conduct business in this Judicial District. Parus’s causes of action arise, at
`
`least in part, from Defendants’ contacts with and activities in the State of Texas and this Judicial
`
`District. Upon information and belief, Defendants have committed acts of infringement within
`
`the State of Texas and this Judicial District by, inter alia, directly and/or indirectly using, selling,
`
`offering to sell, or importing products that infringe one or more claims of the ’431 Patent and/or
`
`the ’084 Patent.
`
`14.
`
`Defendants have committed acts within this District giving rise to this action, and
`
`have established sufficient minimum contacts with the State of Texas such that the exercise of
`
`jurisdiction would not offend traditional notions of fair play and substantial justice.
`
`15.
`
`Venue is proper in this Judicial District pursuant to 28 U.S.C. § 1391(b), (c), and
`
`1400(b). Venue for Defendant LG Electronics, Inc., a foreign corporation, is proper in every
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`judicial district in the U.S., including this one. Venue is proper for LG Electronics U.S.A., Inc.
`
`3
`
`
`
`
`
`because LG Electronics U.S.A., Inc. because LG Electronics USA, Inc.: (1) has a regular and
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`established place of business in this Judicial District, and (2) has committed and continues to
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`commit acts of patent infringement in this Judicial District by, inter alia, directly and/or
`
`indirectly using, selling, offering to sell, or importing products that infringe one or more claims
`
`of the ’431 Patent and/or the ’084 Patent.
`
`COUNT I
`
`LG’S INFRINGEMENT OF U.S. PATENT NO. 7,076,431
`
`Parus restates and incorporates by reference all of the allegations made in the
`
`16.
`
`preceding paragraphs as though fully set forth herein.
`
`17.
`
`Parus is the owner, by assignment, of the ’431 Patent. A true copy of the ’431
`
`Patent granted by the U.S. Patent & Trademark Office is attached as Exhibit 1.
`
`18.
`
`LG has directly infringed, and is continuing to directly infringe, literally or under
`
`the doctrine of equivalents, at least independent claim 1 of Parus’s ’431 Patent by making, using,
`
`selling, and/or offering for sale its smartphone products implementing the Google Android
`
`operating system, including Google Assistant, in the United States, in violation of 35 U.S.C. §
`
`271(a).
`
`19.
`
`LG had constructive notice of the ’431 Patent based on Parus’s marking at least as
`
`of June 18, 2007. LG had actual notice of the ’431 Patent, and that the alleged acts constitute
`
`infringement of the ’431 Patent, at or around August 2, through service of the original
`
`Complaint.
`
`20.
`
`LG’s continued acts of direct infringement of the ’431 Patent, post-filing of this
`
`Complaint, are willful, and have caused and will continue to cause substantial damage and
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`irreparable harm to Parus, and Parus has no adequate remedy at law.
`
`4
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`
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`21.
`
`Various products with Google Assistant made or sold by LG directly infringe at
`
`least independent claim 1 of the ’431 Patent. Those LG products include at least the LG G8
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`ThinQ and other LG products that incorporate the Google Assistant (“LG Accused Products”).
`
`22.
`
`The LG Accused Products in conjunction with Google Assistant is a system for
`
`retrieving information from pre-selected web sites by uttering speech commands into a voice
`
`enabled device and for providing to users retrieved information in an audio form via said voice
`
`enabled device.
`
`23.
`
`The LG G8 ThinQ in conjunction with Google Assistant practices this claim. See
`
`e.g., Andrew Nusca, How voice recognition will change the world (Nov. 4, 2011), available at
`
`https://www.zdnet.com/article/how-voice-recognition-will-change-the-world/, Gene Munster,
`
`Will Thompson, Annual Digital Assistant IQ Test – Siri, Google Assistant, Alexa, Cortana (Jul.
`
`25, 2018), available at https://loupventures.com/annual-digital-assistant-iq-test-siri -google-
`
`assistant-alexa-cortana/, Extending the assistant (Jan. 29, 2019), available at
`
`https://developers.google.com/actions/extending-the-assistant, Voice Browsing (Jan. 29, 2019),
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`available at https://www.w3.org/standards/webofdevices/voice, How Search organizes
`
`information (Jan. 29, 2019), available at https://www.google.com/search/howsearchworks/
`
`crawling-indexing/.
`
`24.
`
`The LG G8 ThinQ in conjunction with Google Assistant is a voice enabled device
`
`because the LG G8 ThinQ includes a microphone and a speaker. See e.g.,
`
`https://www.lg.com/us/support/products/documents/LG_G8_ThinQ_Tech_Specs_TMO_PDF_4-
`
`10-19_LMG820TMB.pdf.
`
`25.
`
`Further, LG incorporates the Android operating system and the Google Assistant
`
`into its products. Google Assistant is built-in to LG Products including the LG G8 ThinQ. See
`
`5
`
`
`
`
`
`e.g., Claire Reilly, LG partners with Google in 10-year patent deal (Jan. 29, 2019), available at
`
`https://www.cnet.com/news/lg-partners-with-google-in-10-year-patent-deal/. LG provides
`
`technical support for Google Assistant by including instructions for setting up and using the
`
`Google Assistant in its LG G8 ThinQ User Manual.
`
`
`
`
`
`See e.g., LG G8 ThinQ User Manual at 26 available at https://www.lg.com/us/support/manuals-
`
`documents?customerModelCode=LMG820TMB&csSalesCode=LMG820TMB.ATMOBK&cate
`
`gory=CT10000027&subcategory=CT10000045. Therefore, the operation of the LG Accused
`
`Products infringe for the same reasons as articulated below as to the Google Android operating
`
`system and the Google Assistant.
`
`26.
`
`Google Assistant retrieves information from pre-selected websites that have
`
`already been crawled by the Googlebot.
`
`6
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`
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`See e.g., https://support.google.com/webmasters/answer/182072.
`
`See e.g., https://www.google.com/search/howsearchworks/crawling-indexing/.
`
`See e.g., https://searchengineland.com/google-assistant-guide-270312.
`
`27.
`
`The retrieved information is in an audio form via said voice enabled device. For
`
`example, Google indicates that one can “hear about weather, your commute, important things to
`
`do, daily fun, and more.”
`
`See e.g., https://assistant.google.com/explore?hl=en_us.
`
`28.
`
`The LG Accused Products in conjunction with Google Assistant include a
`
`computer, said computer operatively connected to the internet.
`
`7
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`
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`29.
`
`For example, the LG G8 ThinQ includes an Octa-Core processor and operatively
`
`connects to the internet in normal usage. See e.g., https://www.lg.com/us/support/products/
`
`documents/LG_G8_ThinQ_Tech_Specs_TMO_PDF_4-10-19_LMG820TMB.pdf.
`
`30.
`
`The LG Accused Products in conjunction with Google Assistant include a voice
`
`enabled device operatively connected to said computer, said voice enabled device configured to
`
`receive speech commands from users.
`
`31.
`
`For example, LG G8 ThinQ in conjunction with Google Assistant is a voice
`
`enabled device because the LG G8 ThinQ includes a microphone and speaker and reacts to
`
`spoken commands through the Google Assistant. See e.g., https://www.lg.com/us/support/
`
`products/documents/LG_G8_ThinQ_Tech_Specs_TMO_PDF_4-10-19_LMG820TMB.pdf.
`
`32.
`
`The LG Accused Products in conjunction with Google Assistant include at least
`
`one speaker-independent speech recognition device, said speaker-independent speech
`
`recognition device operatively connected to said computer and to said voice enabled device.
`
`33.
`
`For example, the LG G8 ThinQ in conjunction with Google Assistant allows a user to
`
`talk to the device and to send commands to the cloud. The microphone operatively connected to
`
`the LG G8 ThinQ in conjunction with Google Assistant is configured to receive speech
`
`8
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`
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`commands from users.
`
`
`
`See e.g., User Manual at 27, available at https://www.lg.com/us/support/manuals-
`
`documents?customerModelCode=LMG820TMB&csSalesCode=LMG820TMB.ATMOBK&cate
`
`gory=CT10000027&subcategory=CT10000045.
`
`34.
`
`The LG Accused Products in conjunction with Google Assistant include at least
`
`one speech synthesis device, said speech synthesis device operatively connected to said
`
`computer and to said voice enabled device.
`
`9
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`35.
`
`For example, the LG G8 ThinQ in conjunction with Google Assistant can handle
`
`voice commands on the device itself or with help from the cloud.
`
`See e.g., https://ai.googleblog.com/2018/05/duplex-ai-system-for-natural-conversation.html.
`
`
`
`
`
`See id.
`
`10
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`36.
`
`The LG Accused Products in conjunction with Google Assistant include at least
`
`one instruction set for identifying said information to be retrieved, said instruction set being
`
`associated with said computer.
`
`37.
`
`For example, because the LG G8 ThinQ in conjunction with Google Assistant can
`
`handle voice commands on the device itself or with help from the cloud, there is an instruction
`
`set for identifying said information to be retrieved, said instruction set being associated with said
`
`computer. The LG G8 ThinQ with Google Assistant can handle voice commands on the device
`
`it is running on or with help from the cloud, there is an instruction set for identifying said
`
`information to be retrieved, said instruction set being associated with said computer. See e.g.,
`
`https://blog.google/products/pixel/pixel-3-and-device-ai-putting-superpowers-your-pocket/; see
`
`also https://ai.googleblog.com/2018/05/duplex-ai-system-for-natural-conversation.html.
`
`38.
`
`The LG Accused Products in conjunction with Google Assistant include an
`
`instruction set comprising a plurality of pre-selected web site addresses, each said web site
`
`address identifying a web site containing said information to be retrieved.
`
`39.
`
`The LG G8 ThinQ in conjunction with Google Assistant retrieves information
`
`from pre-selected websites that have already been crawled by the Googlebot. For example,
`
`Google indicates that Google Assistant retrieves information from pre-selected websites that
`
`have already been crawled by the Googlebot.
`
`See e.g., https://support.google.com/webmasters/answer/182072.
`
`11
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`
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`See e.g., https://www.google.com/search/howsearchworks/crawling-indexing/.
`
`See id.
`
`See e.g., https://searchengineland.com/google-assistant-guide-270312.
`
`40.
`
`The LG Accused Products in conjunction with Google Assistant include at least
`
`one recognition grammar associated with said computer, each said recognition grammar
`
`corresponding to each said instruction set and corresponding to a speech command.
`
`41.
`
`For example, because the LG G8 ThinQ in conjunction with Google Assistant can
`
`handle voice commands on the device itself or with help from the cloud, there is a recognition
`
`grammar corresponding to each said instruction set and corresponding speech command. Google
`
`Assistant is described as handling voice commands on the device itself or with help from the
`
`cloud, there is a recognition grammar corresponding to each said instruction set and
`
`corresponding speech command. See e.g., https://blog.google/products/pixel/pixel-3-and-device-
`
`ai-putting-superpowers-your-pocket/; see also https://ai.googleblog.com/2018/05/duplex-ai-
`
`system-for-natural-conversation.html.
`
`12
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`42.
`
`The LG Accused Products in conjunction with Google Assistant includes said
`
`speech command comprising an information request selectable by the user.
`
`43.
`
`The LG G8 ThinQ in conjunction with Google Assistant is a system for retrieving
`
`information from pre-selected web sites by uttering speech commands into a voice enabled
`
`device. For example, Google indicates that the LG G8 ThinQ in conjunction with Google
`
`Assistant will make tasks easier. Google describes the Google Assistant on its web pages. See
`
`e.g., https://store.google.com/us/category/phones?hl=en-US.
`
`44.
`
`Google indicates that the Google Assistant will “help you find answers and
`
`control your phone and compatible smart home devices – all with a simple squeeze or by using
`
`your voice.”
`
`
`
`See e.g., https://www.blog.google/products/pixel/google-pixel-3/.
`
`45.
`
`The LG Accused Products in conjunction with Google Assistant include said
`
`speaker-independent speech recognition device configured to receive from users via said voice
`
`enabled device said speech command and to select the corresponding recognition grammar upon
`
`receiving said speech command.
`
`46.
`
`For example, because the LG G8 ThinQ in conjunction with Google Assistant can
`
`handle voice commands on the device itself or with help from the cloud, there is a recognition
`
`grammar corresponding to each said instruction set and corresponding speech command. For
`
`example, because the Google Assistant can handle voice commands on the device itself or with
`
`13
`
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`
`
`help from the cloud, there is a recognition grammar corresponding to each said instruction set
`
`and corresponding speech command.
`
`See e.g., https://blog.google/products/pixel/pixel-3-and-device-ai-putting-superpowers-your-
`
`pocket/.
`
`See e.g., https://ai.googleblog.com/2018/05/duplex-ai-system-for-natural-conversation.html.
`
`47.
`
`The LG Accused Products in conjunction with Google Assistant include said
`
`computer configured to retrieve said instruction set corresponding to said recognition grammar
`
`selected by said speaker-independent speech recognition device.
`
`14
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`48.
`
`For example, because the LG G8 ThinQ in conjunction with Google Assistant can
`
`handle voice commands on the device itself or with help from the cloud, there is a recognition
`
`grammar corresponding to each said instruction set and corresponding speech command. For
`
`example, the Google Assistant can handle voice commands on the device itself or with help from
`
`the cloud, there is a recognition grammar corresponding to each said instruction set and
`
`corresponding speech command. See e.g., https://blog.google/products/pixel/pixel-3-and-device-
`
`ai-putting-superpowers-your-pocket/; see also, https://ai.googleblog.com/2018/05/duplex-ai-
`
`system-for-natural-conversation.html.
`
`49.
`
`The LG Accused Products in conjunction with Google Assistant includes said
`
`computer further configured to access at least one of said plurality of web sites identified by said
`
`instruction set to obtain said information to be retrieved, aid computer configured to first access
`
`said first web site of said plurality of web sites and, if said information to be retrieved is not
`
`found at said first web site, said computer configured to sequentially access said plurality of web
`
`sites until said information to be retrieved is found or until said plurality of web sites has been
`
`accessed.
`
`50.
`
`The LG G8 ThinQ in conjunction with Google Assistant is a system for retrieving
`
`information from pre-selected web sites by uttering speech commands into a voice enabled
`
`device. For example, Google indicates that the LG G8 ThinQ in conjunction with Google
`
`Assistant will make tasks easier. The LG G8 ThinQ in conjunction with Google Assistant is a
`
`system for retrieving information from pre-selected web sites by uttering speech commands into
`
`a voice enabled device. For example, Google touts the Google Assistant on its web pages. See
`
`e.g., https://store.google.com/us/category/phones?hl=en-US.
`
`15
`
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`
`
`
`51.
`
`Google indicates that a phone in conjunction with Google Assistant will “help you
`
`find answers and control your phone and compatible smart home devices – all with a simple
`
`squeeze or by using your voice.” See e.g., https://www.blog.google/products/pixel/google-pixel-
`
`3/.
`
`52.
`
`Google Assistant retrieves information from pre-selected websites that have
`
`already been crawled by the Googlebot.
`
`See e.g., https://support.google.com/webmasters/answer/182072.
`
`See e.g., https://www.google.com/search/howsearchworks/crawling-indexing/.
`
`See id.
`
`See e.g., https://searchengineland.com/google-assistant-guide-270312.
`
`53.
`
`Google uses technology to discover and index web sites that have information that
`
`is subsequently used to respond to search requests. Upon receiving a specific search request,
`
`16
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`
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`Google’s search algorithms are configured to access the plurality of web sites in some
`
`“sequential” order (as by the ranking order of the websites, the ranking order specifies a
`
`sequence) until information pertinent to the request is found or until the web sites (in the ranking
`
`order defined) are accessed to find specific information to respond to the specific search request;
`
`Google’s operations meet the claimed recitation “said computer further configured to access at
`
`least one of said plurality of web sites identified by said instruction set to obtain said information
`
`to be retrieved” and “said computer configured to first access said first web site of said plurality
`
`of web sites” and if the information is not found at the first web site, Google’s search algorithms
`
`sequentially access the websites until the information is retrieved or until all the sources are
`
`considered.
`
`54.
`
`The LG Accused Products in conjunction with Google Assistant include said
`
`speech synthesis device configured to produce an audio message containing any retrieved
`
`information from said pre-selected web sites, and said speech synthesis device further configured
`
`to transmit said audio message to said users via said voice enabled device.
`
`55.
`
`For example, the retrieved information is in an audio form via said voice enabled
`
`device as Google indicates that one can “hear about weather, your commute, important things to
`
`do, daily fun, and more.”
`
`See e.g., https://assistant.google.com/explore?hl=en_us.
`
`56.
`
`In addition to directly infringing the ’431 Patent, since around the service of the
`
`original Complaint, LG has indirectly infringed the ’431 Patent pursuant to 35 U.S.C. § 271(b).
`
`LG has had knowledge of the ’431 Patent and of the alleged acts that constitute infringement of
`
`
`
`17
`
`
`
`
`
`the ’431 Patent since at least service of the original Complaint. By the time of trial, LG will
`
`have known and intended (since receiving such notice) that their continued actions would
`
`actively induce the infringement of the claims of the ’431 Patent.
`
`57.
`
` LG indirectly infringes the ’431 Patent by instructing, directing and/or requiring
`
`others, including customers, purchasers, users and developers, to perform one or more of the
`
`steps of the method claims, either literally or under the doctrine of equivalents, of the ’431
`
`Patent, where all the steps of the method claims are performed by either the LG, its customers,
`
`purchasers, users, and developers, or some combination thereof. LG knew or should have known
`
`that it was inducing others, including customers, purchasers, users, and developers, to infringe by
`
`practicing one or more method claims of the ’431 Patent.
`
`58.
`
`Upon information and belief, LG knowingly and actively aided and abetted the
`
`direct infringement of the ’431 Patent by instructing and encouraging its customers, purchasers,
`
`users, and developers to use the ’431 Patent methods and technology. These instructions of
`
`encouragement include, but are not limited to, using the accused products as described in the
`
`claims of the ’431 Patent, in advertising and promoting the use of the ’431 Patent’s claimed
`
`technology, and as further described above.
`
`COUNT II
`
`LG’S INFRINGEMENT OF U.S. PATENT NO. 9,451,084
`
`Parus restates and incorporates by reference all of the allegations made in the
`
`59.
`
`preceding paragraphs as though fully set forth herein.
`
`60.
`
`Parus is the owner, by assignment, of the ’084 Patent. A true copy of the ’084
`
`Patent granted by the U.S. Patent & Trademark Office is attached as Exhibit 2.
`
`18
`
`
`
`
`
`61.
`
`LG has directly infringed, and is continuing to directly infringe, literally or under
`
`the doctrine of equivalents, at least independent claim 1 of Parus’s ’084 Patent by making, using,
`
`selling, and/or offering for sale its smartphone products implementing the Google Android
`
`operating system, including Google Assistant, in the United States, in violation of 35 U.S.C. §
`
`271(a).
`
`62.
`
`LG had constructive notice of the ’084 Patent based on Parus’s marking at least as
`
`of February 21, 2018. LG had actual knowledge of the ’084 Patent, and of the alleged acts that
`
`constitute infringement of the ’084 Patent, at or around August 2, 2019, through service of the
`
`original Complaint.
`
`63.
`
`LG’s continued acts of direct infringement of the ’084 Patent, post-filing of this
`
`Complaint, are willful, and have caused and will continue to cause substantial damage and
`
`irreparable harm to Parus, and Parus has no adequate remedy at law.
`
`64.
`
`The LG Accused Products in conjunction with Google Assistant form a system
`
`for acquiring information from one or more sources maintaining a listing of web sites by
`
`receiving speech commands uttered by users into a voice-enabled device and for providing
`
`information retrieved from the web sites to the users in an audio form via the voice-enabled
`
`device.
`
`65.
`
`The LG G8 ThinQ in conjunction with Google Assistant practices this claim. See
`
`e.g., Andrew Nusca, How voice recognition will change the world (Nov. 4, 2011), available at
`
`https://www.zdnet.com/article/how-voice-recognition-will-change-the-world/, Gene Munster,
`
`Will Thompson, Annual Digital Assistant IQ Test – Siri, Google Assistant, Alexa, Cortana (Jul.
`
`25, 2018), available at https://loupventures.com/annual-digital-assistant-iq-test-siri -google-
`
`assistant-alexa-cortana/, Extending the assistant (Jan. 29, 2019), available at
`
`19
`
`
`
`
`
`https://developers.google.com/actions/extending-the-assistant, Voice Browsing (Jan. 29, 2019),
`
`available at https://www.w3.org/standards/webofdevices/voice, How Search organizes
`
`information (Jan. 29, 2019), available at https://www.google.com/search/howsearchworks/
`
`crawling-indexing/.
`
`66.
`
`The LG G8 ThinQ in conjunction with Google Assistant is a voice enabled device
`
`because the LG G8 ThinQ includes a microphone and a speaker. See e.g.,
`
`https://www.lg.com/us/support/products/documents/LG_G8_ThinQ_Tech_Specs_TMO_PDF_4-
`
`10-19_LMG820TMB.pdf.
`
`67.
`
`Google Assistant is built-in to LG Products including the LG G8 ThinQ. LG
`
`incorporates the Android operating system and the Google Assistant into its products. See e.g.,
`
`Claire Reilly, LG partners with Google in 10-year patent deal (Jan. 29, 2019), available at
`
`https://www.cnet.com/news/lg-partners-with-google-in-10-year-patent-deal/. LG provides
`
`technical support for Google Assistant by including instructions for setting up and using the
`
`Google Assistant in its LG G8 ThinQ User Manual.
`
`
`
`
`
`20
`
`
`
`
`
`
`
`See e.g., LG G8 ThinQ User Manual at 26 available at https://www.lg.com/us/support/manuals-
`
`documents?customerModelCode=LMG820TMB&csSalesCode=LMG820TMB.ATMOBK&cate
`
`gory=CT10000027&subcategory=CT10000045.
`
`68.
`
`Google Assistant retrieves information from pre-selected websites that have
`
`already been crawled by the Googlebot.
`
`
`
`
`
`
`
`See e.g., https://support.google.com/webmasters/answer/182072.
`
`See e.g., https://www.google.com/search/howsearchworks/crawling-indexing/.
`
`See e.g., https://searchengineland.com/google-assistant-guide-270312.
`
`69.
`
`The retrieved information is in an audio form via said voice enabled device. For
`
`example, Google indicates that one can “hear about weather, your commute, important things to
`
`do, daily fun, and more.”
`
`21
`
`
`
`
`
`
`
`See e.g., https://assistant.google.com/explore?hl=en_us.
`
`70.
`
`The LG Accused Products in conjunction with Google Assistant include at least
`
`one computing device, the computing device operatively coupled to one or more networks.
`
`71.
`
`For example, the LG G8 ThinQ includes an Octa-Core processor and is connected
`
`to at least one network in normal operation. See e.g., https://www.lg.com/us/support/
`
`products/documents/LG_G8_ThinQ_Tech_Specs_TMO_PDF_4-10-19_LMG820TMB.pdf.
`
`72.
`
`The LG Accused Products in conjunction with Google Assistant include at least
`
`one speaker-independent speech-recognition device, the speaker-independent speech-recognition
`
`device operatively connected to the computing device and configured to receive the speech
`
`commands.
`
`73.
`
`For example, the LG G8 ThinQ in conjunction with Google Assistant allows a
`
`user to talk through the device to send commands to the cloud. For example, a phone in
`
`conjunction with Google Assistant can handle voice commands on the device itself or with help
`
`from the cloud. See e.g., https://blog.google/products/pixel/pixel-3-and-device-ai-putting-
`
`superpowers-your-pocket/.
`
`22
`
`
`
`
`
`See e.g., https://ai.googleblog.com/2018/05/duplex-ai-system-for-natural-conversation.html.
`
`See id.
`
`74.
`
`The LG Accused Products in conjunction with Google Assistant include at least
`
`one speech-synthesis device, the speech-synthesis device operatively connected to the computing
`
`device.
`
`23
`
`
`
`
`
`
`
`
`
`75.
`
`For example, the LG G8 ThinQ in conjunction with Google Assistant can handle
`
`voice commands on the device itself or with help from the cloud. For example, a phone in
`
`conjunction with Google Assistant can handle voice commands on the device itself or with help
`
`from the cloud and produce an audio response.
`
`
`
`See e.g., https://blog.google/products/pixel/pixel-3-and-device-ai-putting-superpowers-your-
`
`pocket/.
`
`76.
`
`The LG Accused Products in conjunction with Google Assistant include a
`
`memory operatively associated with the computing device with at least one instruction set for
`
`identifying the information to be retrieved, the instruction set being associated with the
`
`computing device.
`
`77.
`
`The LG G8 ThinQ includes a memory that is associated with the computing
`
`device and includes at least one instruction set for the Google Assistant in order to allow the
`
`Google Assistant to run. See e.g., https://www.lg.com/us/support/products/documents/
`
`LG_G8_ThinQ_Tech_Specs_TMO_PDF_4-10-19_LMG820TMB.pdf /.
`
`78.
`
`The LG Accused Products in conjunction with Google Assistant include at least
`
`one instruction set for identifying the information to be retrieved comprising a plurality of web
`
`site addresses for the listing of web sites, each web site address identifying a web site containing
`
`the information to be retrieved.
`
`24
`
`
`
`
`
`79.
`
`The LG G8 ThinQ in conjunction with Google Assistant retrieves information
`
`from websites that have already been crawled by the Googlebot. For example, Google indicates
`
`that a phone such as the LG G8 ThinQ in conjunction with Google Assistant retrieves
`
`information from pre-selected websites that have already been crawled by the Googlebot.
`
`
`
`
`
`
`
`
`
`See e.g., https://support.google.com/webmasters/answer/182072.
`
`See e.g., https://www.google.com/search/howsearchworks/crawling-indexing/.
`
`See id.
`
`See e.g., https://searchengineland.com/google-assistant-guide-270312.
`
`80.
`
`Google uses technology to crawl the web to index web sites with information to
`
`respond to a search request. The indexed websites are identified by web site addresses. These
`
`25
`
`
`
`
`
`indexed websites are “a plurality of pre-selected web site addresses,” and each such website
`
`“indentif[ies] a web site containing said information to be retrieved.
`
`81.
`
`The LG Accused Products in conjunction with Google Assistant include at least
`
`one recognition grammar associated with the computing device, each recognition grammar
`
`corresponding to each instruction set and corresponding to a speech command, the speech
`
`command comprising an information request provided by the user, the speaker-independent
`
`speech-recognition device configured to receive the speech command from the users via the
`
`voice-enabled device and to select the corresponding recognition grammar upon receiving the
`
`speech command.
`
`82.
`
`For example, because the LG G8 ThinQ in conjunction with Google Assistant can
`
`handle voice commands on the device itself or with help from the cloud, there is a recognition
`
`grammar corresponding to each said instruction set and corresponding speech command. For
`
`example, because Google Assistant can handle voice commands on the device itself or with help
`
`from the cloud, there is a recognition grammar corresponding to each said instruction set and
`
`corresponding speech command on the device. See e.g., https://blog.google/products/pixel/pixel-
`
`3-and-device-ai-putting-superpowers-your-pocket/; see also
`
`https://ai.googleblog.com/2018/05/duplex-ai-system-for-natural-conversation.html.
`
`83.
`
`The LG Accused Products in conjunction with Google Assistant include the
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