Patent Claim Construction Gets a Reset in High-Tech TV Voice Command Dispute

RAI Strategic Holdings, Inc. v. Philip Morris Prods. S.A

Authored by: Jeremy J. Gustrowsky

A recent decision from the United States Court of Appeals has shaken up a long-running patent dispute over voice-controlled television technology. Promptu Systems Corporation accused Comcast Corporation of infringing two of its patents—U.S. Patent No. 7,047,196 and U.S. Patent No. 7,260,538—both relating to how users can control their TVs or access content using voice commands sent over cable networks. The heart of the case wasn’t about whether Comcast copied Promptu’s inventions, but rather how the key terms in Promptu’s patents should be interpreted.

The district court had previously sided with Comcast, adopting narrow definitions for several technical terms. For example, it limited the term “back channel” to only fixed frequency bands or time slots, and required certain components to be physically located together. These narrow interpretations led Promptu to stipulate that, under those definitions, Comcast did not infringe its patents—allowing Promptu to appeal the claim constructions directly.

On appeal, the Federal Circuit found that the district court was too restrictive. The appellate judges emphasized that patent claims should generally be given their ordinary meaning unless the patent clearly says otherwise. They ruled that “back channel” and related terms should not be limited to fixed frequencies or time slots, and that the patents did not require certain components to be physically located together. The court also clarified that a “speech recognition system” could perform other functions besides just speech recognition, and that “coupled to” simply means “connected to,” without any proximity requirement.

This decision sends the case back to the district court for further proceedings, with broader interpretations of the patent claims. The ruling highlights the importance of careful claim construction in patent cases—especially in complex technologies where the meaning of a single word can determine the outcome.