Google LLC v. Sonos, Inc.

Background

Sonos, Inc. asserted that Google LLC infringed several patents involving wireless multi-room audio systems. This order addressed claim 1 of United States Patent No. 10,848,885, which concerns a “zone player,” such as a speaker, that can be placed into multiple predefined groups, called “zone scenes.” The claim requires the player to operate individually until a selected scene is invoked and then coordinate with other players for synchronized media playback.

Sonos moved for summary judgment of infringement. Google cross-moved for summary judgment of noninfringement and raised two invalidity theories concerning claim 1: that the claim covered patent-ineligible subject matter under 35 U.S.C. § 101 and that the patent lacked adequate written-description support. Google’s separate motion concerning claim 13 of United States Patent No. 9,967,615 was not decided in this order.

Infringement

The court explained that literal infringement requires every properly construed claim element to be present in the accused products. Sonos presented evidence that Google’s accused products, including Cast-enabled applications such as Google Home, Google Play Music, and YouTube Music, met each element. Google did not dispute Sonos’s evidence concerning the remaining elements, but made three arguments focused on limitation 1.5.

First, Google argued that its products did not allow users to form a “zone scene.” The court assumed, for purposes of analysis, Google’s proposed definition of a zone scene as a previously saved grouping of zone players according to a common theme. The court nevertheless concluded that Google’s products met that limitation because users could save speaker groups and give them thematic names. The court rejected Google’s argument that a zone scene must also include additional attributes, such as volume settings or selected music. It also explained that the accused products need only be reasonably capable of satisfying the claimed function, even if they can also operate in noninfringing ways.

Second, Google argued that its products did not receive an indication that a zone player “has been added to” a zone scene. Sonos identified a “join_group” message sent to an accused player after a user added it to a group through the Google Home application. The court agreed with Sonos that the claim did not require a later message memorializing an earlier addition. Because the message was sent after an action adding the player to the group, it satisfied the limitation.

Third, Google argued that the indication had to identify the other players included in the group. The court rejected that reading, concluding that the claim’s reference to a group of players modified “zone scene,” not “indication.” The court held that Google’s noninfringement arguments did not present a triable factual dispute and that Sonos had shown infringement of claim 1.

Validity

The court rejected Google’s argument that claim 1 was directed to the abstract idea of grouping and controlling speakers. Applying the first step of the framework used to distinguish patent-ineligible concepts from patent-eligible applications, the court concluded that the claim described a specific technological improvement: saving customized and overlapping speaker groups and controlling their synchronized playback on demand. Because the claim was not directed to an abstract idea, the court found it unnecessary to address the framework’s second step.

The court also rejected Google’s written-description challenge. Written description requires the patent’s specification to reasonably show that the inventor possessed the claimed subject matter when filing. Google argued that the specification did not disclose adding a zone player to two scenes at the same time or the claimed sequence in which the player operates alone before transitioning to group operation. The court found adequate support in the patent’s figures and text, including disclosures that already-grouped zones could be included in a scene, that multiple scenes could be saved, and that players could operate individually before a scene was invoked.

Disposition

The court granted Sonos’s motion for summary judgment and denied Google’s corresponding motion for summary judgment. The ruling concerned claim 1 of the ’885 patent. The opinion states that a separate order would address Google’s motion concerning claim 13 of the ’615 patent.