Google LLC v. Sonos, Inc. – Do It For The Caselaw

Holding: The Federal Circuit reversed the Patent Trial and Appeal Board's determination that the challenged patent claims were unpatentable as anticipated or obvious and remanded the case for further proceedings.
Vote: Panel Decision
Practical effect: The decision clarifies the evidentiary burden for anticipation in inter partes review proceedings involving low power modes in smart devices. It requires the Board to strictly adhere to the specific limitations of the prior art reference when finding anticipation.

The United States Court of Appeals for the Federal Circuit reversed and remanded a Patent Trial and Appeal Board decision finding Google patents unpatentable. The court held that the prior art reference failed to disclose exchanging messages while a device remained in a low power mode.

Background

Google owns patents directed to improvements in hotword detection in sound-enabled devices, specifically addressing how intended devices react to a hotword while suppressing reactions on other devices. Sonos filed petitions for inter partes review challenging claims of these patents as anticipated or obvious over prior art references. The Patent Trial and Appeal Board held the challenged claims unpatentable, finding the prior art disclosed the claimed limitations.

The court’s reasoning

The court reviewed the Board’s factual findings for substantial evidence. It agreed with Google that the prior art reference, Rosenberger, did not disclose exchanging weighted signals while the computing device remained in a low power listening mode. The court found that Rosenberger’s disclosure of a device changing a status light or waking up did not support the Board’s finding that the device remained in the low power mode during signal exchange. The court also declined to make new fact findings regarding an alternative low power mode theory raised by Sonos, as the Board had not made findings on that theory.

Rosenberger’s column 8 disclosure therefore cannot anticipate because it fails to disclose the limitations directed to exchanging messages while in a low power mode.

Google LLC v. Sonos, Inc., 2024-2119, 2024-2120 (Fed. Cir. June 9, 2026)

What it means going forward

The decision clarifies the evidentiary burden for anticipation in inter partes review proceedings involving low power modes in smart devices. It requires the Board to strictly adhere to the specific limitations of the prior art reference when finding anticipation.