APPLE INC. v. ZENTIAN LTD.

APPLE INC. v. ZENTIAN LTD. The Federal Circuit held that the Board legally erred by requiring the prior art to accommodate a large-vocabulary acoustic model when the claims required only an acoustic model and covered smaller abbreviated models. The Board also erred by requiring proof that a skilled artisan could personally fabricate a new integrated circuit, where fabrication was not a claimed step. The decision is a useful reminder that the Board cannot import unclaimed implementation requirements into an obviousness analysis, including size requirements or manufacturing steps not present in the claims. Vacated and remanded. The claims required an acoustic model memory and calculating apparatus on a single integrated circuit; the Board treated the acoustic model as requiring a large-vocabulary model. The Federal Circuit held that was legal error because the claim language covered abbreviated models, such as a digits-recognizer model, that define a plurality of acoustic states. The court found Apple had raised the abbreviated-model point in reply, contrary to the Board's timeliness ruling, but left factual questions about memory capacity for remand. For the Smyth/Mozer combination, the Board must address whether Mozer's 4,000-byte on-chip memory could store an abbreviated model and whether the combination would have yielded the claimed integrated-circuit arrangement. The court also rejected the Board's requirement that Apple prove a POSA could personally fabricate the combined circuit, because the claims did not require fabrication as a method step. § 103 claim construction waiver / forfeiture remand non-precedential § 103 claim construction waiver / forfeiture remand non-precedential § 103 claim construction remand non-precedential