Google LLC v. Sonos, Inc.

Google LLC v. Sonos, Inc. The Federal Circuit held that substantial evidence did not support the Board's finding that Rosenberger disclosed exchanging coordination messages while a device remained in a low-power mode. The court reversed and remanded, declining to affirm on Sonos's alternative low-power-mode theory because the Board had made no findings on that theory. The decision reinforces that the Federal Circuit will not supply missing PTAB fact findings to sustain IPR unpatentability grounds, even where an alternative record theory might exist. Reversed and remanded; costs awarded to Google. The claims addressed avoiding multiple voice-enabled devices responding to the same hotword by exchanging hotword-processing outputs while remaining in low-power mode. The Board relied on Rosenberger's column 8 disclosure to find anticipation, but the Federal Circuit held that passage did not disclose exchanging weighted signals while in the low-power listening mode. The court rejected Sonos's reliance on Rosenberger's status-light and wake-up disclosures, finding they did not show the claimed low-power-mode message exchange. Sonos's alternative theory—that coordination occurred in some other power-conserving mode under the agreed construction—was not addressed by the Board, so the court left it for remand. The opinion is nonprecedential and turns on substantial-evidence review of the Board's anticipation findings. § 102 § 103 remand non-precedential § 102 § 103 remand non-precedential § 102 § 103 remand