`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`SDI TECHNOLOGIES, INC.,
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`Petitioner
`
`v.
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`BOSE CORPORATION,
`
`Patent Owner
`
`
`Patent No. 8,401,682
`Filing Date: August 14, 2009
`Issue Date: March 19, 2013
`Title: Interactive Sound Reproducing
`_______________
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`Inter Partes Review No. IPR2014-00343
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`____________________________________________________________
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`AMENDED PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. § 42.100 et seq.
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`Pursuant to Paper No. 5, mailed January 24, 2014, Petitioner SDI
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`Technologies, Inc. submits this Amended Petition, in which (a) the footnotes have
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`been double spaced and (b) all argument has been removed from the claim charts.
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`No substantive changes have been made to the Petition.
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`

`

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`TABLE OF CONTENTS
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`INTRODUCTION ...........................................................................................1  
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`I.  
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`II.  
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`   NOTICE OF LEAD AND BACKUP COUNSEL ..........................................3  
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`III.  
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`   NOTICE OF EACH REAL-PARTY-IN-INTEREST ....................................3  
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`IV.   NOTICE OF RELATED MATTERS .............................................................3  
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`V.  
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`   NOTICE OF SERVICE INFORMATION .....................................................4  
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`VI.   GROUNDS FOR STANDING .......................................................................4  
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`VII.   STATEMENT OF PRECISE RELIEF REQUESTED ...................................5  
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`VIII.   THRESHOLD REQUIREMENT FOR REVIEW ..........................................5  
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`IX.   STATEMENT OF REASONS FOR RELIEF REQUESTED ........................6  
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`A.  
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`B.  
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`C.  
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`D.  
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`E.  
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`F.  
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`G.  
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`Technical Introduction to the ’682 Patent .............................................6  
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`Prior Art: The Sony Music System .......................................................7  
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`Prior Art: Creative Labs Nomad/Samsung Yepp MP3 Player ..............8  
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`Prior Art: WinAmp 1.5, the IRMan, and the
`Altec Lansing ADA310 Remote Controlled Speakers .........................9  
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`   Prior Art: European Patent Application No. 0 929 170 ......................11  
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`   Prosecution History of the ’682 Patent ...............................................12  
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`Construction of the Claims .................................................................13  
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`X.   CLAIM-BY-CLAIM EXPLANATION OF
`GROUNDS FOR INVALIDITY ....................................................................14  
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`A.   Ground I ..............................................................................................14  
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`B.  
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`Ground II .............................................................................................28  
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`XI.   CONCLUSION ...............................................................................................47  
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`ii
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`I.
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`INTRODUCTION
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`On June 12, 2013, SDI Technologies, Inc. (“SDI”) filed a Petition for Inter
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`Partes Review requesting review of claims 1-21, 24, 27, 28, 30-48, 51, 54, 62, 63,
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`67-70, 73, 74, and 76 of the U.S. Patent No. 8,401,682 (“the ’682 patent,” Ex.
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`1001). That proceeding was instituted and is now styled SDI Technologies, Inc. v.
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`Bose Corporation, Case No. IPR2012-00350 (the “350 IPR”).
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`The Board’s Decision on Institution of Inter Partes Review in the 350 IPR
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`granted SDI’s Petition with respect to each of claims 1-21, 24, 27, 28, 30-48, 51,
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`54, 62, 63, 67-70, 73, 74, and 76, citing four grounds.
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`The first two grounds were obviousness over the “SMS” and “Nomad”
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`references, the “Looney” reference being added for certain claims; the second two
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`were obviousness over the “WinAmp,” “IRMan Web Pages,” and “Altec Lansing
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`Manual” references.
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`Patent Owner Bose Corporation (“Bose”) has now accused SDI of infringing
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`additional claims of the ’682 Patent, directed a feature in which the speaker is also
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`“configured to respond to signals received from the computer.” These claims—25,
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`26, 52, 53, 55-61, and 75—can be grouped as follows:
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`Dependent Claims 25 and 26: Claims 25 and 26 depend from independent
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`claim 1 (which is a subject of the 350 IPR), adding that “the sound reproduction
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`device is configured to respond to signals received from the computer” and that
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`1
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`

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`the signals “are transmitted via a signal path of the connector.” Claims 52 and 53,
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`which are essentially identical to claims 25 and 26, depend from independent claim
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`28 (which is a subject of the 350 IPR), adding the same features.
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`Claim 55 and Its Dependents: Independent claim 55 tracks independent
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`claims 1 and 28 (which, again, are subjects of the 350 IPR) but adds that the
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`connector is also configured to “receive signals from the computer.” Dependent
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`claims 56 to 61 and 75 correspond various dependent claims concerning features
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`such as a radio tuner, the connector being in the housing, and the like, that are also
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`already subjects of the 350 IPR.
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`This Petition challenges these additional claims of the ’682 patent, all of
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`which add to subject matter already being treated in the 350 IPR that the speaker
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`receives signals from the computer. As discussed in more detail below, this feature
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`is explicitly described in the Altec Lansing Manual, rendering the additional claims
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`invalid based on the second combination cited in the 350 Decision (WinAmp/
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`IRMan/Altec Lansing). These claims are also invalid in light of the first
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`combination (SMS/Nomad/Looney), as it would have been obvious to one of skill
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`in the art at the time of the invention to have the speaker respond to signals from
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`the computer such as, for example, in determining whether the computer was on
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`prior to attempting to communicate with it, a common feature of electronic
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`2
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`communication protocols, in order to, for example, avoid futile communicates with
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`a device that is not present or not turned on.
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`II. NOTICE OF LEAD AND BACKUP COUNSEL
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`Lead Counsel:
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`
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`Matthew B. Lowrie (Reg. No. 38,228)
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`Tel: 617-342-4006; Fax: 617-342-4001
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`Backup Counsel:
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`Aaron W. Moore (Reg. No. 52,043)
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`Address:
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`Tel: 617-342-4007; Fax: 617-342-4001
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`James C. De Vellis (Reg. No. 52,814)
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`Tel: 617-342-4037; Fax: 617-342-4001
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`Foley & Lardner LLP
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`111 Huntington Avenue, Boston, MA 02199
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`
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`
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`III. NOTICE OF EACH REAL-PARTY-IN-INTEREST
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`The real-party-in-interest is SDI Technologies, Inc.
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`IV. NOTICE OF RELATED MATTERS
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`As noted above, claims 1-21, 24, 27, 28, 30-48, 51, 54, 62, 63, 67-70, 73, 74,
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`and 76 of the ’682 Patent are the subject of instituted IPR2013-00350. SDI is
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`today filing a motion to join this proceeding with the 350 IPR.
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`The ’682 patent has been asserted in the following action: Bose Corporation
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`v. SDI Technologies, Inc. (D. Mass. Case No. 13-cv-10277-WGY), filed on
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`February 13, 2013, and still pending.
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`A parent of the ’682 patent, U.S. Patent No. 7,277,765 (the “’765 patent”),
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`was asserted in Bose Corporation v. SDI Technologies, Inc., et al. (D. Mass. Case
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`3
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`No. 09-cv-11439), which resulted in a grant of summary judgment of non-
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`infringement, which is pending on appeal.
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`The ’765 patent is also the subject of Inter Partes Reexamination No.
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`95/001,260, in which all claims stand rejected. The Board affirmed the Examiner’s
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`rejections and also added a new ground of rejection. The patent owner reopened
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`prosecution, the Examiner entered the new ground of rejection in addition to the
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`others, and the appeal is again before the Board. In addition, the parent ’765 patent
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`was the subject of Inter Partes Reexamination Request No. 95/001,332. That
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`request was denied, however, because the art presented was found to be cumulative
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`of art that had already resulted in the rejection of all of the claims of the patent.
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`The immediate parent of the ’682 patent, U.S. Patent No. 8,364,295 (the
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`“’295 patent”), is the subject of instituted IPR2013-00465.
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`V. NOTICE OF SERVICE INFORMATION
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`Please address all correspondence to the lead counsel at the address shown
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`above. Petitioner also consents to electronic service by email at
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`mlowrie-PTAB@foley.com and amoore-PTAB@foley.com.
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`VI. GROUNDS FOR STANDING
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`Petitioner hereby certifies that the patent for which review is sought is
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`available for inter partes review and that the petitioner is not barred or estopped
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`4
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`from requesting an inter partes review challenging the patent claims on the
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`grounds identified in the petition.
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`VII. STATEMENT OF PRECISE RELIEF REQUESTED
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`The Petitioner respectfully requests that claims 25, 26, 52, 53, 55-61, and 75
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`of U.S. Patent No. 8,401,682 (Ex. 1001) be canceled based on the following
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`grounds of invalidity, explained in detail (including relevant claim constructions)
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`in the following sections.
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`VIII. THRESHOLD REQUIREMENT FOR REVIEW
`A petition for Inter Partes Review must demonstrate “a reasonable
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`likelihood that the petitioner would prevail with respect to at least 1 of the claims
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`challenged in the petition.” 35 U.S.C. § 314(a). This Petition meets the threshold.
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`Each of the elements of the subject claims of the ’682 patent are taught as
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`explained below in the proposed rejections, with an appropriate motivation to
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`combine where the proposed rejection is under 35 U.S.C. § 103(a).
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`5
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`IX. STATEMENT OF REASONS FOR RELIEF REQUESTED
`A. Technical Introduction to the ’682 Patent
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`The ’682 patent is directed to “an audio system attachable to a computer”
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`that includes a powered speaker. One embodiment of the system of the ’682 patent
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`is illustrated schematically in Figure 1, with the computer being the large box (20)
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`on the right, and the sound reproduction device (the speaker) being the large box
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`(10) on the left:
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`
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`The independent claims of the ’682 patent are generally directed to the
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`capability of the remote (item 17) to control both the speaker (item 10) directly and
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`the computer (item 20) indirectly though an IR receiver that is located in the
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`speaker, as illustrated schematically below.
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`6
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`B.
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`Prior Art: The Sony Music System
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`The prior art Sony Music System Manual (Ex. 1002), which bears a 1998
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`Copyright date, describes a portable music player that included a remote control.
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`The manual is prior art under 35 U.S.C. § 102(b). The system could be connected
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`to a Sony MiniDisc player, in which case the remote control supplied with the
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`boom box would control the Music System directly (e.g., the volume) and would
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`also control the MiniDisc player through the Music System, as in the system of the
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`’682 patent. (See Exhibit 1002, at 41-44.) The Music System (below, left) is
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`shown on page 4 of the manual, and the connection to the MiniDisc player (below,
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`right) is illustrated on page 41:
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`
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`
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`A schematic illustration of the Sony Music System, which is virtually
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`identical to that for the patented system, is provided below.
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`7
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`C.
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`Prior Art: Creative Labs Nomad/Samsung
`Yepp MP3 Player
`The Creative Labs Nomad MP3 Player Manual (Ex. 10051), which bears a
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`June 1999 date, describes a portable MP3 player, in a form factor that resembled
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`the Sony MiniDisc player, that played music from any one of a number of sources,
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`including internal memory, removable memory cards, music downloaded to the
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`memory or the memory cards from the internet, and a built in FM radio. The
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`manual is prior art under 35 U.S.C. § 102(b). The device is also described in an
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`August 19, 1999 PCWorld article (Exhibit 1006).
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`
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`The Creative Nomad device was also released in 1999 as the Samsung Yepp
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`                                                                                                                
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`YP-D40, as shown in the April 1999 issue of Popular Science magazine (Exhibit
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`1 In light of the Motion for Joinder, and in order to avoid confusion, Petitioner has
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`omitted exhibit numbers 1003, 1004, 1013, 1014, and 1015, so that the rest of the
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`exhibits common to the 350 IPR retain the same numbering as in the 350 IPR.
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`8
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`1007) and an April 29, 1999 Samsung Press Release (Exhibit 1008), which
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`describes it as a “digital audio device that allows the user to download music files
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`from the Internet or other on-line services” that included an FM tuner. The
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`magazine and press release are prior art under 35 U.S.C. § 102(b).
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`D.
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`Prior Art: WinAmp 1.5, the IRMan, and the Altec Lansing
`ADA310 Remote Controlled Speakers
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`WinAmp 1.5, described on pages 65-93 of Guy Hart-Davis and Rhonda
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`Holmes, MP3! (Sybex Inc. 1999) (excerpted as Ex. 1009), was a widely used
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`computer software package for playing MP3s. According to the records of the
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`U.S. Copyright Office, the MP3! book was published on September 10, 1999 (see
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`Exhibit 1009), making it prior art under 35 U.S.C. § 102(b). MP3! describes how
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`WinAmp would play locally stored music files, as well as music streamed from
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`internet radio stations.
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`The IRMan, described in the web pages of its manufacturer, Evation,
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`captured by archive.org on June 8, 1999 (Ex. 1010), was a system that included a
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`remote control unit and an IR receiver that connected to a computer. The purpose
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`of the system was to allow the remote control to control software running on the
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`9
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`computer, including MP3 software and, in particular, WinAmp. The web pages
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`are prior art under 35 U.S.C. § 102(b).2
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`
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`The Altec Lansing ADA310 speaker system, described in a 1998 Manual
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`(Exhibit 1011) and an October 17, 1997 Business Wire article (Exhibit 1012) was a
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`set of powered computer speakers that included a remote control for controlling the
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`operation of the speakers. The speakers were configured to accept audio in either
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`digital or analog format. The manual and article are prior art under 35 U.S.C. §
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`102(b).
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`The combination of WinAmp, the IRMan, and the Altec Lansing speakers
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`would have provided the same functionality as the system of the ’682 patent,
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`except that there would be two remotes (one for the speaker and one for the
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`IRMan), and the IRMan signal would not pass though the speaker.
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`                                                                                                                
`2  The IRMan web pages are available in the Internet Archive at web.archive.org/
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`web/19990508121919/http://www.evation.com/irman/index.html, where the
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`number sequence “19990508” in the URL establishes a prior art date no later than
`May 8, 1999, 1998. See MPEP § 2128; e.g., Ex Parte Molander, Appeal 2008-
`2589, Application 09/845,537, pp. 9-12 (B.P.A.I. March 17, 2009); Ex Parte
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`Shaouy, Appeal 2007-0987, Application 09/810,992 (B.P.A.I. May 24, 1997).  
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`10
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`Thus, the primary difference between this combination and the claimed
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`invention is that the invention combines the remotes of the IRMan and ADA310
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`speaker and places the IRMan receiver in the speaker. The functionality is the
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`
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`same.
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`Of particular relevance to this Petition, the 1998 Manual explains that
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`“[c]omputers that are USB (universal serial bus) equipped can control all speaker
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`functions from the desktop.” (Ex. 1011, at 3.) This is done with software that runs
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`on the computer and includes a graphic user interface. (Id.) In addition, the
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`speaker does not have a power switch but, instead, “[w]hen audio is received . . .
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`the speaker turns on automatically.” (Ex. 11011, at 4.) Thus, the speaker was
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`configured to respond to signals received from the computer.
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`E.
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`Prior Art: European Patent Application No. 0 929 170
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`European Patent Application No. 0 929 170 (the “EP ’170 Application,”
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`Exhibit 1018), titled “Methods, systems and apparatus for providing device status
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`information within a communication network,” was published on July 14, 1999,
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`making it prior art under 35 U.S.C. 102(b). The application describes a home
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`audio/visual network in which TVs, PCs, and other devices can be coupled
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`11
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`together. Paragraph 42 of the application explains that “[w]ithin a communications
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`network where devices can communicate and control other devices, it is important
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`that devices and associated software objects be aware of the current status of
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`devices in the network to provide effective communication, control and reporting
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`functions.”
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`F.
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`Prosecution History of the ’682 Patent
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`
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`The ’682 patent was filed August 14, 2009 with original claims 1-51 and
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`assigned serial number 12/541,742. A First Preliminary amendment was filed
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`November 22, 2011, canceling claims 1-51 and adding new claims 52-125. A
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`Second Preliminary amendment was filed February 29, 2012, canceling claims
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`110, 111, 121 and 122, amending many dependent claims, and adding new claims
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`126-131. The Second Preliminary amendment amends independent claims 52, 79,
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`106 and 115 “to clarify that the remote control is configured such that a user can
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`use it to issue commands for controlling user functions of the sound reproduction
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`system (‘first type of command from the user’) or the computer (‘second type of
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`command from the user’). (Second Preliminary Amendment, page 19.)
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`A Notice of Allowance was mailed December 26, 2012. The Examiner
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`provided an Examiner’s Statement of Reasons for Allowance, stating: “The reason
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`for allowance to claims 52-109, 112-120, 123-125 is the same reasoning as set
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`forth in the reason for allowance in the parent cases 11608034 [the ’295 patent]
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`12
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`and 09689337 [the ’765 patent].” (Notice of Allowance, page 2.) This means
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`that the Examiner allowed the claims of the ’682 patent for reasons that the
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`Board has now rejected in the reexamination of the ’765 patent.
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`The issue fee was paid December 27, 2012 and the ’682 patent issued on
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`March 19, 2013.
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`G. Construction of the Claims
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`The claim terms are presumed to take on their ordinary and customary
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`meaning, except as described below.
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`In the decision instituting the 350 IPR, the Board construed the following
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`terms that are relevant to this Petition, and SDI believes those terms should be
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`afforded the same construction in this proceeding.
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`Term
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`“computer”
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`Construction
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`“any machine capable of receiving input,
`processing, storing, and outputting data”
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`13
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`“computer that is configured to
`provide audio information from
`any one of a plurality of sources,
`including digital music files
`stored on the computer and a
`network accessible by the
`computer”
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`Additionally, the Board construed “network” and “audio information from
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`Only requires a computer configured to
`provide audio information from either one or
`more of digital music files stored on a
`computer, or one or more of different
`networks accessible by a computer, but, it
`does not preclude providing the information
`from both types of sources.
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`the network via the computer,” but neither is material to the grounds upon which
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`the Board instituted the 350 IPR, or the grounds presented here.
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`X. CLAIM-BY-CLAIM EXPLANATION OF GROUNDS
`FOR INVALIDITY
`A. Ground I
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`Claims 25, 26, 52, 53, 55-61, and 75 are invalid under 35 U.S.C. § 103 in
`
`view of the combination of MP3! book, describing WinAmp (Ex. 1009), the
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`IRMan Web Pages (Ex. 1010), and the Altec Lansing Manual (Ex. 1011) (or the
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`Altec Lansing Press Release (Ex. 1012), describing the same device). It would
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`have been obvious to make this combination because IRMan device was intended
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`to control the WinAmp MP3 player software running on a computer, and the Altec
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`Lansing speakers were designed to play computer audio.
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`It would have been obvious to use the control circuitry in the ADA310
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`housing to control both the speaker and the computer (i.e., to combine to IR
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`receivers of the speaker and the IRMan), in order to, for example, reduce clutter
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`14
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`and duplication. (See Lippman Decl., Exhibit 1017, ¶ 39-41.) Additionally, it
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`would have been obvious to use audio signal processing circuitry for both the
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`ADA310 and IRMan to process the audio signals for reproduction, for example to
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`facilitate audio output. (See Lipman Decl., Exhibit 1017, ¶ 39-41.)
`
`This same combination forms the basis for Grounds 3 and 4 of the instituted
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`465 IPR. This same combination forms the basis for Grounds 3 and 4 of the
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`instituted 350 IPR.
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`The additional element addressed in this Petition—the speaker responding to
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`signals from the computer—is explicit in the Altec Lansing Manual, which states
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`that “[c]omputers that are USB (universal serial bus) equipped can control all
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`speaker functions from the desktop.” (Ex. 1011, at 3.) The computer is controlling
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`the speaker by transmitting electrical signals to which the speaker responds. In
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`addition, the reference explains that “[w]hen audio is received . . . the speaker turns
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`on automatically.” (Ex. 1011, at 4.) Again, the computer is transmitting electrical
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`signals (music signals, in this case) to which the computer responds.
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`With respect to claim 59, it would have been obvious to include an AM/FM
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`radio tuner within the housing. (See Lippman Decl., Exhibit 1017, ¶ 44.)
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`With respect to claims 75 and 76, it would have been obvious to configure
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`the MiniDisc/Nomad to output music in digital format, to allow the use of a better
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`digital-to-analog converter. It would have been obvious to include such a
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`15
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`converter within the much larger SMS, so as to avoid the need for a separate
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`housing for the D/A converter. (See Lippman Decl., Exhibit 1017, ¶ 29.)
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`This combination is detailed in the following claim charts. Bold borders
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`denote claims that are the subject of only this Petition, as opposed to claims that
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`are part of the 350 IPR but are also included below because they are parents of
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`dependent claims addressed in this Petition.
`
`’682 Patent
`1. An audio system configured to
`connect to a separate computer that is
`configured to provide audio
`information from any one of a
`plurality of sources, including digital
`music files stored on the computer and
`a network accessible by the computer,
`the audio system comprising:
`
`(a) a sound reproduction system
`comprising:
`
`a housing;
`
`WinAmp Plus IRMan Plus Altec
`Lansing ADA310 Speakers
`The combination is a powered speaker
`system (the ADA310) intended to
`connect to a personal computer, and a
`personal computer running WinAmp
`software that provided audio
`information from any one of a plurality
`of sources, including stored digital
`music files and the internet. (See MP3!,
`Ex. 1009, at 72-74 (describing how to
`play tracks and Internet streams);
`ADA310 Manual, Ex. 1011.)
`The ADA310 speaker was a sound
`reproduction device. (See ADA310
`Manual, Ex. 1011.)
`The speaker had a housing. (See
`ADA310 Manual, Ex. 1011.)
`
`
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`16
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`control circuitry located within the
`housing for receiving control
`commands;
`
`audio signal processing circuitry
`located within the housing for
`processing audio signals for
`reproduction;
`
`one or more speakers for
`reproducing audio signals processed
`by the audio signal processing
`circuitry;
`a connector configured to provide a
`physical and electrical connection
`exclusively between the sound
`reproduction system and the
`computer,
`wherein the connection includes one
`or more signal paths configured to (i)
`receive audio information from the
`computer corresponding to the
`digital music files stored on the
`computer and audio information
`from the network via the computer,
`and (ii) transmit to the computer
`signals for controlling the computer;
`and
`
`Both the ADA310 and the IRMan
`provided control circuitry to receive IR
`signals, as described below. (See
`ADA310 Manual, at 6 (IR receiver);
`IRMan Web Page, Ex. 1010, at 1
`(“IRMan can receive the infrared
`signals transmitted by all sorts of
`remotes. It converts these signals to
`computer commands understood by
`software in your PC.”).)
`The speakers had amplifiers that process
`audio signals located within the
`housing, 10W in the small speakers and
`24W in the subwoofer. (See ADA
`Manual, Ex. 1011, at 7 (5W per driver
`in the satellites).)
`There were one or more speakers
`located within the housing of at least the
`ADA310 to reproduced the processed
`audio signals, e.g., to play audio.
`The speaker necessarily had a connector
`(connections for the speaker audio)
`providing a physical and electrical
`connection exclusively between the
`speaker and the computer.
`In the combination, the connection in
`the speaker would include signal paths
`configured to (i) receive audio from the
`computer corresponding to the digital
`music files stored on the computer and
`audio from the network via the
`computer (audio to the speaker), and (ii)
`transmit to the computer, signals for
`controlling the computer (IRMan
`control signals).
`
`
`
`17
`
`

`

`(b) a remote control device configured
`to transmit signals representing at least
`a first type of command from a user
`and a second type of command from a
`user to the control circuitry of the
`sounds reproduction system,
`wherein the first type of command is
`a command to control a user function
`of the sound reproduction system
`and the second type of command is a
`command to control a user function
`of the computer,
`
`wherein the control circuitry is
`configured to receive the signals
`from the remote control and, in
`response to receiving such signals:
`(i) control the user function of the
`sound reproduction system when the
`user issues a command of the first
`type, and (ii) transmit to the
`computer, via a signal path of the
`connector, a signal for controlling
`the user function of the computer
`when the user issues a command of
`the second type.
`
`  
`
`The speaker remote and the IRMan
`remote were configured to transmit
`signals representing first and second
`types of commands from a user to
`control circuitry, as described below.
`
`The first type of command (i.e., from
`the speaker remote) would control a
`user function of the sound reproduction
`device (e.g., volume) and the second
`(i.e., from the IRMan remote) would
`control a user function of the MP3
`player software running on the
`computer (e.g., stop or play). (See
`ADA310 Manual, Ex. 1011, at 7
`(showing the remote); IRMan Web
`Page, Ex. 1010, at 1 (“Imagine
`controlling Winamp with a normal
`remote to choose exactly the song you
`want.”).)
`The control circuitry would receive the
`signals from the remote and (i) control
`the user function of the sound
`reproduction device if the command
`was of the first type (i.e., from the
`speaker remote), and (ii) transmitted to
`the computer, via a signal path of the
`connector, a signal for controlling the
`user function of the computer if the user
`issued a command of the second type
`(i.e., from the IRMan remote). (See
`ADA310 Manual, Ex. 1011, at 7
`(showing the remote and describing its
`operation); IRMan Web Page, Ex. 1010,
`at 1 (“Imagine controlling Winamp with
`a normal remote to choose exactly the
`song you want.”).)
`
`
`
`18
`
`

`

`25. The audio system of claim 1
`wherein the sound reproduction
`system is configured to respond to
`signals received from the computer.
`
`26. The audio system of claim 25
`wherein signals to the computer and
`signals from the computer to the sound
`reproduction system are transmitted
`via a signal path of the connector.
`28. An audio system configured to
`connect to a computer that has a
`plurality of user functions, a subset of
`the user functions relating to control of
`audio information, the audio system
`comprising:
`
`(a) a sound reproduction system
`comprising:
`
`a housing;
`
`The speakers were configured to
`respond to signals received from the
`computer.
`“Computers that are USB (universal
`serial bus) equipped can control all
`speaker functions from the desktop.”
`(ADA310 Manual, Ex. 1011, at 3.) This
`is done with software that runs on the
`computer, using a graphic user
`interface. (Id.) The control necessarily
`would be accomplished by electrical
`signals to which the speaker would
`respond.
`In addition, the ADA310 speaker did
`not have a power switch but, instead,
`“[w]hen audio is received . . . the
`speaker turns on automatically.” (Id., at
`4.) Thus, the speaker also responded to
`music signals from the computer.
`The signals to the computer and signals
`from the computer to the sound
`reproduction system are transmitted via
`a signal path of the connector.
`
`The combination includes a powered
`system configured to connect to a
`personal computer that had a plurality
`of user functions, not all of which
`related to control of audio information.
`For example, the computer could run
`other types of software.
`The ADA310 speaker was a sound
`reproduction device. (See ADA310
`Manual, Ex. 1011.)
`The speaker had a housing. (See
`ADA310 Manual, Ex. 1011.)
`
`
`
`19
`
`

`

`control circuitry located within the
`housing for receiving control
`commands;
`
`audio signal processing circuitry
`located within the housing for
`processing audio signals for
`reproduction;
`
`one or more speakers for
`reproducing audio signals processed
`by the audio signal processing
`circuitry; and
`
`a connector configured to provide a
`physical and electrical connection
`exclusively between the sound
`reproduction system and the
`computer,
`
`wherein the connection includes one
`or more signal paths configured to (i)
`receive audio information from the
`computer, and (ii) transmit the
`computer signals for controlling the
`computer; and
`
`Both the ADA310 and the IRMan
`provided control circuitry, as described
`below. (See ADA310 Manual, Ex. 1011,
`at 6 (IR receiver); IRMan Web Page,
`Ex. 1010, at 1 (“Irman can receive the
`infrared signals transmitted by all sorts
`of remotes. It converts these signals to
`computer commands understood by
`software in your PC.”).)
`The speakers had amplifiers that process
`audio signals located within the
`housing, 10W in the small speakers and
`24W in the subwoofer. (See ADA
`Manual, Ex. 1011, at 7 (5W per driver
`in the satellites).)
`There were one or more speakers
`located within the housing to reproduce
`the processed audio signals, e.g., to play
`audio. (See ADA310 Manual, Ex.
`1011.)
`The speaker necessarily had a connector
`(connections for the speaker audio) that
`would have been at least partially within
`the housing, providing a physical and
`electrical connection exclusively
`between the speaker and the computer.
`In that combination, the connection in
`the speaker would include signal paths
`configured to (i) receive audio from the
`computer corresponding to the digital
`music files stored on the computer and
`audio from the network via the
`computer (audio to the speaker), and (ii)
`transmit to the computer, signals for
`controlling the computer (IRMan
`control signals).
`
`
`
`20
`
`

`

`(b) a remote control device configured
`to transmit signals representing at least
`a first type of command from a user
`and a second type of command from a
`user to the control circuitry of the
`sound reproduction device,
`wherein the first type of command is
`a command to control a user function
`of the sound reproduction system
`and the second type of command is a
`command to control a user function
`of the computer relating to control of
`audio information,
`
`wherein the control circuitry is
`configured to receive the signals
`from the remote control and, in
`response to receiving such signals:
`(i) control the user function of the
`sound reproduction system when the
`user issues a command of the first
`type, and (ii) transmit to the
`computer, via a signal path of the
`connector, a signal for controlling
`the user function of the computer
`when the user issues a command of
`the second type.
`
`  
`
`The speaker remote and the IRMan
`remote were configured to transmit
`signals representing first and second
`types of commands from a user to
`control circuitry.
`
`The first type of command (i.e., from
`the speaker remote) would control a
`user function of the sound reproduction
`device (e.g., volume) and the second
`(i.e., from the IRMan remote) controlled
`a user function of the MP3 player
`software running on the computer (e.g.,
`stop or play). (See ADA310 Manual, at
`7 (showing the remote); IRMan Web
`P