Exhibit A9
`
`WO 01/50453 (“Kovatch”)
`
`WO 01/50453 (“Kovatch”) discloses and/or renders obvious Claims 1, 2, 4, 5, 6, 7, 9, 10, 13, and 14 of U.S. Patent No. 7,076,431
`alone and/or in combination with other references, as set forth in the chart below. Defendants incorporate in this chart all applicable
`qualifications, clarifications, and other statements made in Defendants’ Invalidity Contentions. This invalidity claim chart is based on
`Defendants’ present understanding of Claims 1, 2, 4, 5, 6, 7, 9, 10, 13, and 14 and Parus’s apparent construction of the claims, as set
`forth in Parus’s Infringement Contentions. Defendants are not adopting Parus’s apparent constructions, nor are Defendants admitting
`the accuracy of any particular construction. Where the chart below states that the reference “discloses” a limitation, such disclosure
`may be express, inherent, or implicit. Moreover, to the extent the Court finds that this reference does not disclose certain limitations
`in the asserted claims, such limitations would have been obvious. By mapping claim language to this reference, Defendants do not
`imply or admit that the claim language satisfies 35 U.S.C. § 112. To the extent any cell lacks citations to the charted reference, this
`should not be taken as an admission that the reference does not disclose the corresponding limitation but rather indicates that
`Defendants do not presently intend to rely on the reference as disclosing the limitation based on Defendants’ present understanding of
`the claim limitation.
`
`
`Kovatch
`
`U.S. Patent No.
`7,076,431
`[1.pre] 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
`
`To the extent the preamble is limiting, Kovatch discloses and renders obvious 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, said system comprising.
`
`See, e.g., disclosures below.
`
`
`
`
`1
`
`Parus Exhibit 2002
`Google LLC, et al. v. Parus Holdings, Inc.
`IPR2020-00846
`Page 1 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`enabled device,
`said system
`comprising:
`
`Kovatch Fig. 1
`
`Kovatch
`
`
`
`
`
`
`
`2
`
`Parus Exhibit 2002, Page 2 of 123
`
`

`

`Kovatch Fig. 2
`
`
`Kovatch Fig. 3
`
`
`
`
`
`3
`
`Parus Exhibit 2002, Page 3 of 123
`
`

`

`
`U.S. Patent No.
`Kovatch
`U.S. Patent No.
`Kovatch
`7,076,431
`7,076,43 1
`
`Ins Augclcs
`
`“in. HeyAnita
`Yurk
`
`Infraslructure
`San Francis»:-
`
`.______-_
`
`$2‘ :fl2‘
`
`“-F-T_—_ %
`
`\
`
`' Akita _
`Munitorlng
`Station
`
`\.
`
`\\
`~—F
`
`
`
`
`
`
`
`
`
`
`
`Mnll‘llhili. lmll'a
`
`'I'nltyu‘ .Inlmn
`
`
`
`4
`
`Parus Exhibit 2002, Page 4 of 123
`
`Parus Exhibit 2002, Page 4 of 123
`
`

`

`Kovatch Fig. 4
`
`
`Kovatch Fig. 5
`
`
`
`
`
`5
`
`Parus Exhibit 2002, Page 5 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`Kovatch
`
`
`
`Kovatch at 4-6:
`The present invention is directed to an interactive voice response system that permits users to access information
`that is not originally formatted for audio interfacing to an information exchange network, such as a computer
`network. Users spoken utterance is analyzed and matched with an index of destinations. A list of valid
`destinations is produced and the user is the guided along the path with pre-recorded voice prompts. The user
`accessing the system can control the navigation via more speech and/or telephone keypad entry. The intent of the
`system is to be able to come up with a single choice destination amongst the many offered within the system.
`
`The decision to choose a valid destination is driven by a variety of factors
`
`User preferences
`
`User profile derived from usage pattern history
`
`User responses
`
`Advertiser rules
`
`Utterance match weightage
`
`Active context
`
`
`
`6
`
`Parus Exhibit 2002, Page 6 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`Kovatch
`
`Call origin
`Call date/time
`Call length
`
`
`
`
`
`The destination that is derived earlier is then accessed via spoken utterance and/or telephone keypad entry. User
`specific information about the destination is derived from the user profile and the current call context and is used
`to offer access to the facilities offered by the destination. The facilities offered are specific to the application
`provided by the destination node.
`
`User responses and queries are appropriately translated to the destination format and vice versa. All of the
`interaction is via concatenated pre-recorded or synthesized voice segments or fragments.
`
`The inventive voice response system includes a number of novel functional and logical components, including
`without limitations query engine, ad generator, web parser, profiler and replication engine, managed by a
`manager. These components may physical reside in the same or different servers.
`
`The present invention will be described in reference to "HeyAnita", and in the alternate "Anita", which references
`relates to the commercial system launched by HeyAnita, Inc. (www.heyanita.com).
`
`HeyAnita Inc.'s proposed solution is to enable the world's population to access, by voice, the wealth of
`information and applications available on the Internet, using any type of phone - rotary, touchtone or wireless.
`The rationale behind this vision is threefold:
`
`1. Everyone knows how to use a telephone. 2. Most cities in the world already have reliable land-line phones as
`well as wireless infrastructure.
`
`3. The easiest user interface is the speaker's natural language, both spoken and heard.
`
`As competition within Internet and cellular usage intensifies, high traffic Internet portals, other e-commerce
`providers and traditional companies will continue to seek ways to expand and enrich their consumer offerings
`with unique and compelling content and products. This will create significant opportunities for HeyAnita to
`
`
`
`7
`
`Parus Exhibit 2002, Page 7 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`Kovatch
`
`connect eyeballs to eardrums, thereby enabling these companies to target and reach a significantly expanded
`audience.
`
`Kovatch at 7:
`HeyAnita enables individuals to surf the Internet from any phone, anywhere, anytime simply by using their voice.
`By utilizing its revolutionary HeyAnita operating system ("HeyAnita OS") technology and easy to use interface,
`HeyAnita establishes a comprehensive Voice Internet Portal ("VIP"), providing a voice interface to the Internet
`and allowing Internet and telephone users to access volumes of information, headline news, stock quotes,
`horoscopes, auctions, food delivery services, weather forecasts, sports scores, travel, shipping status, free
`integrated voice mail, and much more. In addition, HeyAnita enables e-commerce providers to add voice
`application (v-application) services to their existing platform and enables traditional corporations to efficiently
`compete in the digital arena. HeyAnita' s unique solution increases traffic and commerce by providing access to
`individuals who do not use traditional Web-based browsers and also allows traditional Internet users access from
`locations lacking connectivity.
`
`Kotatch at 9-10:
`HeyAnita Speech Objects (110):
`These are a set of COM+ components that encapsulate hardware devices and speech recognition engines. Once
`the applications are written using these interfaces, they can be ported easily from one hardware device to another
`or from one recognition engine to another by simply replacing the corresponding HeyAnita Speech Object.
`Speech Recognition Manager (SR) - This object encapsulates the speech recognition engine and the text to speech
`engines and provides a consistent interface to these engines in a vendor independent fashion. Audio Source (Al) -
`This object encapsulates the audio input device and provides a consistent interface in a device independent
`fashion.
`Audio Destination (AO) - This object encapsulates the audio output device and provides a consistent interface in
`a device independent fashion.
`Grammar Object (GO) - This object provides a consistent interface to provide grammar files for speech
`recognition. The grammar files can reside anywhere on the Internet. The grammar object refers to the grammars
`files by URL
`Prompt Object (PO) - This object provides a consistent interface to provide prompts in speech applications. The
`prompts can reside anywhere on the Internet. The prompt object refers to the prompt files by URL
`
`
`
`8
`
`Parus Exhibit 2002, Page 8 of 123
`
`

`

`Kovatch
`
` A
`
` typical voice application will create a SR object for speech recognition, an Al object as an audio input object,
`an AO object as an audio output, a GO object for recognizing speech and several PO objects for the various
`prompts it may require. The application can then play the prompts using the audio out object, accept input using
`the audio in object and recognize the input using the speech recognition- object while the grammar object gives
`context to the speech recognition object.
`
`Kovatch at 17-18:
`ANITA SERVER - PROCESS
`1. When a user calls, Anita Telephone Interface 1 receives the call and hands it over to Anita Speech Recognition
`Engine 2.
`2. Anita Speech Recognition engine 2 converts spoken utterance into text and sends it to Anita Natural Language
`Engine 3 for further processing.
`3. Anita Natural Language Engine 3 interprets Natural Language text and sends structured commands to Anita
`Query Engine 4.
`4. Anita Query Engine 4 takes into consideration all of the governing factors such as user preferences, user
`context, usage patterns and history to determine an end destination node for the user's request.
`5. Anita Query Engine 4 generates web queries needed to fulfill user's request and sends them to the Anita State
`Machine and Web Parser 8.
`6. Anita State Machine and Web Parser 8 browses the Internet/web 11 to retrieve information requested by the
`user. It parses each received page to convert unstructured text into structured datasets.
`7. While Anita State Machine and Web Parser 8 is busy retrieving the requested information, Anita Query Engine
`4 asks Anita Prompt Generator 6 to generate context-sensitive voice prompts. It also sends a request to Anita
`Profiler to add generated queries to the user's profile.
`8. Anita Prompt Generator 6 asks Anita Ad Generator 9 to create a set of entertaining commercials based on
`user's preferences and context.
`9. Anita Ad Generator 9 asks Anita Profiler 10 for the user preference and usage history data and uses it to select
`appropriate commercials.
`10. Anita Prompt Generator 6 creates an audio stream based on commercials and web information returned by
`Anita State Machine and Web Parser 8 and sends it to Anita Telephone Interface 12.
`
`
`U.S. Patent No.
`7,076,431
`
`
`
`9
`
`Parus Exhibit 2002, Page 9 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`Kovatch
`
`Kovatch at 20:
`Example 1: Weather
`Assistant: How can I help you?
`User: What is the weather forecast?
`Assistant: Weather in your home city of Los Angeles is sunny and seventy degrees with a high expected to be
`seventy-six and a low expected to be sixty. Would you like the extended forecast for Los Angeles?
`User: What's the weather like in New York?
`Assistant: It's sunny and seventy degrees with a high expected to be seventy-six and a low expected to be sixty.
`Would you like the extended forecast for New York?
`
`Kovatch claim 1:
`
`1. An interactive audio response system that permits users to access information that is not originally formatted
`for voice interfacing to an information exchange network, comprising:
`
` a
`
` voice interface for user to input request for information; a speech recognition engine that converts user's spoken
`utterance from the voice interface into text;
`a natural language engine that interprets the meaning and context embodied in the converted text and output
`structured commands;
`
` a
`
` query engine that, in response to the structured commands, determines an end destination node for the user's
`request and generates corresponding web queries;
`
` a
`
` web parser that, in response to the web queries, browses the web to retrieve information requested by user, and
`parses each received page from the web to convert unstructured text into structured datasets; and
`
` a
`
` prompt generator that generates context-sensitive voice prompts to the voice interface in the event that an end
`destination node cannot be determined by the query engine.
`
`To the extent that Parus contends Kovatch does not disclose or render obvious this claim element, this claim
`element is obvious in light of a combination of Kovatch with the knowledge of ordinary skill in the art or one or
`
`
`
`10
`
`Parus Exhibit 2002, Page 10 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`[1.a] a computer,
`said computer
`operatively
`connected to the
`internet;
`
`Kovatch
`
`more other references. See e.g., Exs. A1-A25, B1-B18, limitation 1.pre; Ex. C, limitation 1.pre; and Section VI
`of Defendants’ Invalidity Contentions.
`
`Kovatch discloses and renders obvious a computer, said computer operatively connected to the internet.
`
`See, e.g., disclosures below.
`
`Kovatch at Fig. 1
`
`
`
`
`
`11
`
`Parus Exhibit 2002, Page 11 of 123
`
`

`

`Kovatch Fig. 3
`
`
`
`Kovatch at 4-6:
`The present invention is directed to an interactive voice response system that permits users to access information
`that is not originally formatted for audio interfacing to an information exchange network, such as a computer
`network. Users spoken utterance is analyzed and matched with an index of destinations. A list of valid
`destinations is produced and the user is the guided along the path with pre-recorded voice prompts. The user
`accessing the system can control the navigation via more speech and/or telephone keypad entry. The intent of the
`system is to be able to come up with a single choice destination amongst the many offered within the system.
`
`The decision to choose a valid destination is driven by a variety of factors
`
`User preferences
`
`User profile derived from usage pattern history
`
`User responses
`
`Advertiser rules
`
`Utterance match weightage
`
`
`
`12
`
`Parus Exhibit 2002, Page 12 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`Kovatch
`
`Active context
`Call origin
`Call date/time
`Call length
`
`
`
`
`
`
`The destination that is derived earlier is then accessed via spoken utterance and/or telephone keypad entry. User
`specific information about the destination is derived from the user profile and the current call context and is used
`to offer access to the facilities offered by the destination. The facilities offered are specific to the application
`provided by the destination node.
`
`User responses and queries are appropriately translated to the destination format and vice versa. All of the
`interaction is via concatenated pre-recorded or synthesized voice segments or fragments.
`
`The inventive voice response system includes a number of novel functional and logical components, including
`without limitations query engine, ad generator, web parser, profiler and replication engine, managed by a
`manager. These components may physical reside in the same or different servers.
`
`The present invention will be described in reference to "HeyAnita", and in the alternate "Anita", which references
`relates to the commercial system launched by HeyAnita, Inc. (www.heyanita.com).
`
`HeyAnita Inc.'s proposed solution is to enable the world's population to access, by voice, the wealth of
`information and applications available on the Internet, using any type of phone - rotary, touchtone or wireless.
`The rationale behind this vision is threefold:
`
`1. Everyone knows how to use a telephone. 2. Most cities in the world already have reliable land-line phones as
`well as wireless infrastructure.
`
`3. The easiest user interface is the speaker's natural language, both spoken and heard.
`
`As competition within Internet and cellular usage intensifies, high traffic Internet portals, other e-commerce
`providers and traditional companies will continue to seek ways to expand and enrich their consumer offerings
`
`
`
`13
`
`Parus Exhibit 2002, Page 13 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`Kovatch
`
`with unique and compelling content and products. This will create significant opportunities for HeyAnita to
`connect eyeballs to eardrums, thereby enabling these companies to target and reach a significantly expanded
`audience.
`
`Kovatch at 7:
`HeyAnita enables individuals to surf the Internet from any phone, anywhere, anytime simply by using their voice.
`By utilizing its revolutionary HeyAnita operating system ("HeyAnita OS") technology and easy to use interface,
`HeyAnita establishes a comprehensive Voice Internet Portal ("VIP"), providing a voice interface to the Internet
`and allowing Internet and telephone users to access volumes of information, headline news, stock quotes,
`horoscopes, auctions, food delivery services, weather forecasts, sports scores, travel, shipping status, free
`integrated voice mail, and much more. In addition, HeyAnita enables e-commerce providers to add voice
`application (v-application) services to their existing platform and enables traditional corporations to efficiently
`compete in the digital arena. HeyAnita' s unique solution increases traffic and commerce by providing access to
`individuals who do not use traditional Web-based browsers and also allows traditional Internet users access from
`locations lacking connectivity.
`
`Kovatch at 17-18:
`ANITA SERVER - PROCESS
`1. When a user calls, Anita Telephone Interface 1 receives the call and hands it over to Anita Speech Recognition
`Engine 2.
`2. Anita Speech Recognition engine 2 converts spoken utterance into text and sends it to Anita Natural Language
`Engine 3 for further processing.
`3. Anita Natural Language Engine 3 interprets Natural Language text and sends structured commands to Anita
`Query Engine 4.
`4. Anita Query Engine 4 takes into consideration all of the governing factors such as user preferences, user
`context, usage patterns and history to determine an end destination node for the user's request.
`5. Anita Query Engine 4 generates web queries needed to fulfill user's request and sends them to the Anita State
`Machine and Web Parser 8.
`6. Anita State Machine and Web Parser 8 browses the Internet/web 11 to retrieve information requested by the
`user. It parses each received page to convert unstructured text into structured datasets.
`
`
`
`14
`
`Parus Exhibit 2002, Page 14 of 123
`
`

`

`Kovatch
`
`7. While Anita State Machine and Web Parser 8 is busy retrieving the requested information, Anita Query Engine
`4 asks Anita Prompt Generator 6 to generate context-sensitive voice prompts. It also sends a request to Anita
`Profiler to add generated queries to the user's profile.
`8. Anita Prompt Generator 6 asks Anita Ad Generator 9 to create a set of entertaining commercials based on
`user's preferences and context.
`9. Anita Ad Generator 9 asks Anita Profiler 10 for the user preference and usage history data and uses it to select
`appropriate commercials.
`10. Anita Prompt Generator 6 creates an audio stream based on commercials and web information returned by
`Anita State Machine and Web Parser 8 and sends it to Anita Telephone Interface 12.
`
`Kovatch at 20:
`Example 1: Weather
`Assistant: How can I help you?
`User: What is the weather forecast?
`Assistant: Weather in your home city of Los Angeles is sunny and seventy degrees with a high expected to be
`seventy-six and a low expected to be sixty. Would you like the extended forecast for Los Angeles?
`User: What's the weather like in New York?
`Assistant: It's sunny and seventy degrees with a high expected to be seventy-six and a low expected to be sixty.
`Would you like the extended forecast for New York?
`
`Kovatch claim 1:
`
`1. An interactive audio response system that permits users to access information that is not originally formatted
`for voice interfacing to an information exchange network, comprising:
`
` voice interface for user to input request for information; a speech recognition engine that converts user's spoken
`utterance from the voice interface into text;
`a natural language engine that interprets the meaning and context embodied in the converted text and output
`structured commands;
`
`
` a
`
`U.S. Patent No.
`7,076,431
`
`
`
`15
`
`Parus Exhibit 2002, Page 15 of 123
`
`

`

`a query engine that, in response to the structured commands, determines an end destination node for the user's
`request and generates corresponding web queries;
`
`Kovatch
`
` a
`
` web parser that, in response to the web queries, browses the web to retrieve information requested by user, and
`parses each received page from the web to convert unstructured text into structured datasets; and
`
` a
`
` prompt generator that generates context-sensitive voice prompts to the voice interface in the event that an end
`destination node cannot be determined by the query engine.
`
`To the extent that Parus contends Kovatch does not disclose or render obvious this claim element, this claim
`element is obvious in light of a combination of Kovatch with the knowledge of ordinary skill in the art or one or
`more other references. See e.g., Exs. A1-A25, B1-B18, limitation 1.a; Ex. C, limitation 1.a; and Section VI of
`Defendants’ Invalidity Contentions.
`
`Kovatch discloses and renders obvious a voice enabled device operatively connected to said computer, said voice
`enabled device configured to receive speech commands from users.
`
`See, e.g., disclosures below.
`
`
`U.S. Patent No.
`7,076,431
`
`[1.b] a voice
`enabled device
`operatively
`connected to said
`computer, said
`voice enabled
`device
`configured to
`receive speech
`commands from
`users;
`
`
`
`16
`
`Parus Exhibit 2002, Page 16 of 123
`
`

`

`Kovatch Fig. 2
`
`
`
`Kovatch at 4-6:
`The present invention is directed to an interactive voice response system that permits users to access information
`that is not originally formatted for audio interfacing to an information exchange network, such as a computer
`network. Users spoken utterance is analyzed and matched with an index of destinations. A list of valid
`destinations is produced and the user is the guided along the path with pre-recorded voice prompts. The user
`accessing the system can control the navigation via more speech and/or telephone keypad entry. The intent of the
`system is to be able to come up with a single choice destination amongst the many offered within the system.
`
`The decision to choose a valid destination is driven by a variety of factors
`
`User preferences
`
`User profile derived from usage pattern history
`
`User responses
`
`Advertiser rules
`
`Utterance match weightage
`
`
`
`17
`
`Parus Exhibit 2002, Page 17 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`Kovatch
`
`Active context
`Call origin
`Call date/time
`Call length
`
`
`
`
`
`
`The destination that is derived earlier is then accessed via spoken utterance and/or telephone keypad entry. User
`specific information about the destination is derived from the user profile and the current call context and is used
`to offer access to the facilities offered by the destination. The facilities offered are specific to the application
`provided by the destination node.
`
`User responses and queries are appropriately translated to the destination format and vice versa. All of the
`interaction is via concatenated pre-recorded or synthesized voice segments or fragments.
`
`The inventive voice response system includes a number of novel functional and logical components, including
`without limitations query engine, ad generator, web parser, profiler and replication engine, managed by a
`manager. These components may physical reside in the same or different servers.
`
`The present invention will be described in reference to "HeyAnita", and in the alternate "Anita", which references
`relates to the commercial system launched by HeyAnita, Inc. (www.heyanita.com).
`
`HeyAnita Inc.'s proposed solution is to enable the world's population to access, by voice, the wealth of
`information and applications available on the Internet, using any type of phone - rotary, touchtone or wireless.
`The rationale behind this vision is threefold:
`
`1. Everyone knows how to use a telephone. 2. Most cities in the world already have reliable land-line phones as
`well as wireless infrastructure.
`
`3. The easiest user interface is the speaker's natural language, both spoken and heard.
`
`As competition within Internet and cellular usage intensifies, high traffic Internet portals, other e-commerce
`providers and traditional companies will continue to seek ways to expand and enrich their consumer offerings
`
`
`
`18
`
`Parus Exhibit 2002, Page 18 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`Kovatch
`
`with unique and compelling content and products. This will create significant opportunities for HeyAnita to
`connect eyeballs to eardrums, thereby enabling these companies to target and reach a significantly expanded
`audience.
`
`Kovatch at 20:
`Example 1: Weather
`Assistant: How can I help you?
`User: What is the weather forecast?
`Assistant: Weather in your home city of Los Angeles is sunny and seventy degrees with a high expected to be
`seventy-six and a low expected to be sixty. Would you like the extended forecast for Los Angeles?
`User: What's the weather like in New York?
`Assistant: It's sunny and seventy degrees with a high expected to be seventy-six and a low expected to be sixty.
`Would you like the extended forecast for New York?
`
`Kovatch claim 1:
`
`1. An interactive audio response system that permits users to access information that is not originally formatted
`for voice interfacing to an information exchange network, comprising:
`
` a
`
` voice interface for user to input request for information; a speech recognition engine that converts user's spoken
`utterance from the voice interface into text;
`a natural language engine that interprets the meaning and context embodied in the converted text and output
`structured commands;
`
` a
`
` query engine that, in response to the structured commands, determines an end destination node for the user's
`request and generates corresponding web queries;
`
` a
`
` web parser that, in response to the web queries, browses the web to retrieve information requested by user, and
`parses each received page from the web to convert unstructured text into structured datasets; and
`
`
`
`
`19
`
`Parus Exhibit 2002, Page 19 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`[1.c] 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;
`
`
`
`Kovatch
`
`a prompt generator that generates context-sensitive voice prompts to the voice interface in the event that an end
`destination node cannot be determined by the query engine.
`
`To the extent that Parus contends Kovatch does not disclose or render obvious this claim element, this claim
`element is obvious in light of a combination of Kovatch with the knowledge of ordinary skill in the art or one or
`more other references. See e.g., Exs. A1-A25, B1-B18, limitation 1.b; Ex. C, limitation 1.b; and Section VI of
`Defendants’ Invalidity Contentions.
`
`Kovatch discloses and renders obvious 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.
`
`See, e.g., disclosures below.
`
`Kovatch at Fig. 1
`
`
`
`20
`
`Parus Exhibit 2002, Page 20 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`
`Kovatch Fig. 2
`
`Kovatch
`
`Kovatch Fig. 5
`
`
`
`
`
`21
`
`Parus Exhibit 2002, Page 21 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`Kovatch
`
`
`
`
`Kotatch at 9-10:
`HeyAnita Speech Objects (110):
`These are a set of COM+ components that encapsulate hardware devices and speech recognition engines. Once
`the applications are written using these interfaces, they can be ported easily from one hardware device to another
`or from one recognition engine to another by simply replacing the corresponding HeyAnita Speech Object.
`Speech Recognition Manager (SR) - This object encapsulates the speech recognition engine and the text to speech
`engines and provides a consistent interface to these engines in a vendor independent fashion. Audio Source (Al) -
`This object encapsulates the audio input device and provides a consistent interface in a device independent
`fashion.
`Audio Destination (AO) - This object encapsulates the audio output device and provides a consistent interface in
`a device independent fashion.
`Grammar Object (GO) - This object provides a consistent interface to provide grammar files for speech
`recognition. The grammar files can reside anywhere on the Internet. The grammar object refers to the grammars
`files by URL
`
`
`
`22
`
`Parus Exhibit 2002, Page 22 of 123
`
`

`

`U.S. Patent No.
`7,076,431
`
`Kovatch
`
`Prompt Object (PO) - This object provides a consistent interface to provide prompts in speech applications. The
`prompts can reside anywhere on the Internet. The prompt object refers to the prompt files by URL
`
` A
`
` typical voice application will create a SR object for speech recognition, an Al object as an audio input object,
`an AO object as an audio output, a GO object for recognizing speech and several PO objects for the various
`prompts it may require. The application can then play the prompts using the audio out object, accept input using
`the audio in object and recognize the input using the speech recognition- object while the grammar object gives
`context to the speech recognition object.
`
`Kovatch claim 1:
`
`1. An interactive audio response system that permits users to access information that is not originally formatted
`for voice interfacing to an information exchange network, comprising:
`
` a
`
` voice interface for user to input request for information; a speech recognition engine that converts user's spoken
`utterance from the voice interface into text;
`a natural language engine that interprets the meaning and context embodied in the converted text and output
`structured commands;
`
` a
`
` query engine that, in response to the structured commands, determines an end destination node for the user's
`request and generates corresponding web queries;
`
` a
`
` web parser that, in response to the web queries, browses the web to retrieve information requested by user, and
`parses each received page from the web to convert unstructured text into structured datasets; and
`
` a
`
` prompt generator that generates context-sensitive voice prompts to the voice interface in the event that an end
`destination node cannot be determined by the query engine.
`
`To the extent that Parus contends Kovatch does not disclose or render obvious this claim element, this claim
`element is obvious in light of a combination of Kovatch with the knowledge of ordinary skill in the art or one or
`
`
`
`23
`
`Parus Exhibit 2002, Page 23 of 123
`
`

`

`Kovatch
`
`more other references. See e.g., Exs. A1-A25, B1-B18, limitation 1.c; Ex. C, limitation 1.c; and Section VI of
`Defendants’ Invalidity Contentions.
`
`Kovatch discloses and renders obvious at least one speech synthesis device, said speech synthesis device
`operatively connected to said computer and to said voice enabled device.
`
`See, e.g., disclosures below.
`
`Kotatch at 9-10:
`HeyAnita Speech Objects (110):
`These are a set of COM+ components that encapsulate hardware devices and speech recognition engines. Once
`the applications are written using these interfaces, they can be ported easily from one hardware device to another
`or from one recognition engine to another by simply replacing the corresponding HeyAnita Speech Object.
`Speech Recognition Manager (SR) - This object encapsulates the speech recognition engine and the text to speech
`engines and provides a consistent interface to these engines in a vendor independent fashion. Audio Source (Al) -
`This object encapsulates the audio input device and provides a consistent interface in a device independent
`fashion.
`Audio Destination (AO) - This object encapsulates the audio output device and provides a consistent interface in
`a device independent fashion.
`Grammar Object (GO) - This object provides a consistent interface to provide grammar files for speech
`recognition. The grammar files can reside anywhere on the Internet. The grammar object refers to the grammars
`files by URL
`Prompt Object (PO) - This object provides a consistent interface to provide prompts in speech applicat