`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`In re Application of: Paul D. Arling
`and Patrick H. Hayes
`
`
`Patent No.: 8,243,207
`
`Filed: September 29, 2009
`
`Issued: August 14, 2012
`
`
`
`Declaration of
`James T. Geier
`
`In Support of the Petition for Inter
`Partes Review of U.S. Patent No.
`8,243,207
`
`Assignee: Universal Electronics Inc.
`
`Title: SYSTEM AND METHOD
`FOR MONITORING REMOTE
`CONTROL TRANSMISSIONS
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`DECLARATION OF JAMES T. GEIER
`
`Background and Qualifications
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`1. My name is James T. Geier. I am the founder and principal consultant for
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`Wireless-Nets. I have 30 years experience in the communications industry
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`designing, analyzing and implementing communications systems, wireless
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`networks, and mobile devices.
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`2.
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`I earned my Masters of Science in Electrical Engineering from the Air
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`Universal Remote Control Exhibit 1003: Page 1
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`Force Institute of Technology in 1990. I received my Bachelor of Science in
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`Electrical Engineering from California State University in 1985.
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`3.
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` I served in the U.S. Air Force from 1977 to 1992 as a Commissioned
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`Officer where I worked as a Communications System Engineer for six years, as a
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`Systems Test Engineer for four years and a Systems Design Engineer for three
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`years. After the Air Force, I worked in private industry for eight years before
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`founding my current company, Wireless-Nets, Ltd. in April, 2000.
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`4.
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`In my role as a Communications Systems Engineer for the U.S. Air Force
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`from 1977 to 1983, I performed acceptance testing of newly-designed radar
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`systems and maintained automatic tracking radar systems in support of tactical Air
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`Force operations worldwide at the 75th TCF. From 1986 to 1989, I performed
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`analog, digital, and protocol tests on various government wireless computer
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`networks and developed testing approaches and methods as a Systems Test
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`Engineer for the AFCC Operational Test and Evaluation Center as a Lieutenant.
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`From 1990 to 1992 I served as a Captain at the Information Systems Center, where
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`I evaluated the effectiveness of wireless LAN technology for use in mobile and
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`portable military environments, represented the Air Force as part of the IEEE
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`802.11 Wireless LAN standards development and designed and implemented
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`large-scale LANs and WANs for various government organizations.
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`5. After the Air Force, I was employed by Adroit Systems, where I
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`Universal Remote Control Exhibit 1003: Page 2
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`researched and analyzed wireless communications technologies for use in U.S.
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`Department of Defense airborne platforms. In addition, I was employed by TASC,
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`Inc., where Ianalyzed and developed communications systems for various
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`applications, such as data communications on submarines and within electrical
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`power plants, and designed and implemented databases for various applications,
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`such as narcotics tracking systems. In addition, I was employed by Monarch
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`Marking Systems, where I designed and developed wireless middleware that
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`coordinated communications among various systems components, such as bar code
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`scanners, printers and application servers.
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`6. As a consultant for Wireless-Nets, Ltd., I have designed and
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`implemented wireless systems for various applications. For example, I designed
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`and implemented a wireless system that includes a transmitting device with a
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`keypad, joystick or other input device that would generate a code indicating
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`actuation of the input device and transmit the code to a receiver. The receiver
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`would decode the code and generate and transmit commands to control various
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`other devices.
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`7.
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`I have authored over a dozen books on mobile and wireless topics,
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`including Designing and Deploying 802.11n Wireless Networks (Cisco Press),
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`Implementing 802.1X Security Solutions (Wiley), Wireless Networking Handbook
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`(New Riders) and Network Re-engineering (McGraw- Hill).
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`Universal Remote Control Exhibit 1003: Page 3
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`8.
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`I have been an active participant within IEEE standards organizations,
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`such as the IEEE 802.11 Working Group, and the Wi-Fi Alliance and have served
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`as Chairman of the IEEE Computer Society, Dayton Section, and various
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`conferences.
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`9. A copy of my latest curriculum vitae (C.V.) is attached as Appendix A.
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`Status as Independent Expert Witness
`
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`10.
`
`I have been retained in this matter by Universal Remote Control, Inc.
`
`("Petitioner" or "URC") to provide an analysis of the scope and content of U.S.
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`Patent No. 8,243,207 (hereinafter the "'207 patent") relative to the state of the art at
`
`the time of the earliest application underlying the '207 Patent. In particular, my
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`analysis relates only to claims 12-15. I have also been retained to provide analysis
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`regarding what a person of ordinary skill in the art related to universal remote
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`control devices and home entertainment systems would have understood at the
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`time of the earliest application underlying the '207 patent.
`
`11.
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`I am being compensated at the rate of $300 per hour for my work. My fee
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`is not contingent on the outcome of any matter or on any of the technical positions
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`I explain in this declaration. I have no financial interest in Petitioner.
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`12.
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`I have been informed that Universal Electronics Inc. (hereinafter referred
`
`to as "Patent Owner") owns the '207 Patent. I have no financial interest in the
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`Universal Remote Control Exhibit 1003: Page 4
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`Patent Owner or the '207 patent nor to my recollection have I ever had any contact
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`with the Patent Owner, or the inventors of the '207 patent, Paul Arling or Patrick
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`Hayes.
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`Description of the Relevant Field and the Relevant Timeframe
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`13.
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`I have carefully reviewed the '207 Patent.
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`14. For convenience, all of the information that I considered in arriving at my
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`opinions is listed in Appendix B.
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`15. Based on my review of these materials, I believe that the relevant field
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`for purposes of the '207 Patent is the remote control and configuration of home
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`entertainment systems. I have been informed that the relevant timeframe runs from
`
`around 2001 through 2012.
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`16. As described in above, I have extensive experience in the relevant field,
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`including experience relating to wireless communications and coordination of
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`system components. Based on my experience, I have an established understanding
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`of the relevant field in the relevant timeframe.
`
`The Person of Ordinary Skill in the Relevant Field in the Relevant Timeframe
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`17.
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`I have been informed that "a person of ordinary skill in the relevant field"
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`is a hypothetical person to whom an expert in the relevant field could assign a
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`routine task with reasonable confidence that the task would be successfully carried
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`out. I have been informed that the level of skill in the art is evidenced by the prior
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`Universal Remote Control Exhibit 1003: Page 5
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`art references. The prior art discussed herein demonstrates that a person of ordinary
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`skill in the art, at the time the '207 patent was filed, would have a bachelors degree
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`in electrical engineering, telecommunications, or computer science (or an
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`equivalent degree) with two years experience in the communications industry and
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`was aware of programmable universal remote controls, home systems with
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`components controllable by remote controls and/or other components and
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`configurable setups for the home systems.
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`18. Based on my experience, I have an understanding of the capabilities of a
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`person of ordinary skill in the relevant field. I have supervised, directed, and
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`instructed many such persons over the course of my career.
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`Background of the Technology
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`19.
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`In home entertainment systems, there are multiple configurations of
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`input, or source, devices and output, or destination, devices that may be used to
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`accomplish various desired activities. For instance, if a user wants to watch a
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`movie, a chosen input/device could be the DVD player, and the chosen
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`output/destination device could be the TV. Alternatively, if the user wants to listen
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`to music, the input/source could be the tuner, and the output/destination could be
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`the amplifier.
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`20.
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`In general, remote controls were developed to control electronic home
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`appliances, such as televisions, stereos, and related devices, including those that
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`Universal Remote Control Exhibit 1003: Page 6
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`may be part of a home entertainment system.
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`21. A programmable universal remote control serves to allow a user to
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`aggregate the command functions performed by multiple remote controls into a
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`single device. A programmable universal remote control, once configured for, or
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`matched to, a user's equipment, serves to control multiple remote controllable
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`electronic appliances via a single control device. Universal remote control devices
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`are particularly useful for controlling home entertainment, or home automation
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`systems. These systems utilize multiple devices, often of different manufacturers,
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`in concert in order to perform certain desired activities, such as watching a movie,
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`listening to music, etc. A single remote control that may be used to control all
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`devices is particularly useful.
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`22. As illustrated by the references discussed below, a person of ordinary
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`skill in the art, in the relevant timeframe, was aware of associating keys on a
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`remote control with command values and sending a command value to a device in
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`order to configure that device to use certain input/source devices and/or
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`output/destination audio visual devices according to the user’s chosen activity.
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`This person was also aware of transferring commands or other data from a
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`computer to another device, including, but not limited to a remote control.
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`Universal Remote Control Exhibit 1003: Page 7
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`The '207 Patent
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`23. The '207 patent is titled SYSTEM AND METHOD FOR ACTIVITY
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`BASED CONFIGURATION OF AN ENTERTAINMENT SYSTEM and relates
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`to a system in which a command value corresponding to an activity key of a
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`controlling device is associated with a configuration of an entertainment device in
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`which at least one of a plurality of devices is selected as an audio visual input
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`source device for the entertainment device and at least one of the plurality of
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`devices is selected as an audio visual output destination device for the
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`entertainment device. When the entertainment device receives a signal from the
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`controlling device, the entertainment device is configured according to the
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`configuration associated with the command value that corresponds to the activity
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`key of the controlling device. '207 patent, Abstract.
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`24. The '207 patent also describes that technology was known in the art
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`regarding controlling various components of a home entertainment center. A
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`review of the prior art reveals that all of the functionality claimed in the claims at
`
`issue from the '207 patent was well known in the art at the time the '207 patent was
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`filed.
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`25.
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`I am informed that the '207 patent issued from U.S. Patent Application
`
`No. 12/569,121 (the "'121 application"), filed on September 29, 2009 and claims
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`no priority. It is my understanding that all of the art discussed below qualifies as
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`
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`Universal Remote Control Exhibit 1003: Page 8
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`prior art to the '207 patent.
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`Claim Interpretation
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`26.
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`In proceedings before the USPTO, I understand that the claims of an
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`unexpired patent are to be given their broadest reasonable interpretation in view of
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`the specification from the perspective of one skilled in the art, according to 37
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`C.F.R. § 42.100(b).
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`27. Generally, the use of different claim terms suggests distinct objects being
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`described. The use of the terms "device" and "appliance" in the claims of the '207
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`patent would thus suggest that the claims are referring to two distinct objects. The
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`'207 patent specification, however, uses these terms interchangeably, effectively
`
`giving them the same meaning. In one example, the ‘207 patent explains "[i]f the
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`selected destination device is not powered on, in a preferred embodiment at step
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`620 a request may be issued to controlling device 100 via bidirectional
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`communication link 130 to transmit a 'power on' command to the destination
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`appliance." The '207 patent at col. 7, ll. 33-37 (emphasis added). However, step
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`620 is labeled "Request remote to power on dest. device." Id. at Fig. 6 (emphasis
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`added). That is, the specification uses the terms "appliance" and "device" to refer
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`to the same object. Accordingly, for the purposes of this declaration, I will
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`consider the terms "device" and "appliance" as used in the claims of the ‘207
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`patent to be interchangeable with each other, which happens to also be the broadest
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`Universal Remote Control Exhibit 1003: Page 9
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`reasonable construction of these two terms in light of the specification.
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`28. An "activity key," as used in the '207 patent, and in accordance with the
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`broadest reasonable construction, is simply any key or button on the remote control
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`that corresponds to a configuration of the system. The '207 patent does not
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`explicitly define what an activity key is, but describes an activity key as
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`corresponding to a command value, which is associated with a configuration of the
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`system. See Abstract; col. 6, ll. 41-43.
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`Unpatentability Based on Prior Art in the Present Proceedings
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`29.
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`I have been informed that a patent claim can be found unpatentable as
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`anticipated when each and every claim limitation is found within a single reference
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`or is a necessary part of a claim limitation. I understand that an anticipation
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`analysis involves a consideration of (1) the scope and content of the prior art; (2)
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`the differences between the claimed inventions and the prior art; and (3) the level
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`of ordinary skill in the pertinent art.
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`30.
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`I have been informed that a patent claim can be found unpatentable as
`
`obvious where the differences between the subject matter sought to be patented
`
`and the prior art are such that the subject matter as a whole would have been
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`obvious at the time the invention was made to a person having ordinary skill in the
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`relevant field. I understand that an obviousness analysis involves a consideration of
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`(1) the scope and content of the prior art; (2) the differences between the claimed
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`Universal Remote Control Exhibit 1003: Page 10
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`inventions and the prior art; (3) the level of ordinary skill in the pertinent art; and
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`(4) secondary considerations of non-obviousness.
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`31. My analysis of these considerations is set forth in the following sections.
`
`The ‘831 Publication Teaches All Elements Recited by Claims 12-15 of the
`'207 Patent.
`
`32.
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`I am informed that U.S. Patent Publication No. 2003/0120831 to Dubil et
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`al. (the "'831 publication") was published June 26, 2003, almost eight years before
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`filing date of the '207 patent is thus prior art to the '207 patent under at least 35
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`U.S.C. § 102(b). The '831 publication discloses a remote control that identifies
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`which particular devices are to be used as input and as output in a multi-component
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`system according to an activity set. The '831 publication at ¶[0017]. An
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`entertainment device is configured according to the activity set to use the identified
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`devices. See id. at ¶¶[0009], [0019]. The '831 publication discloses setting up the
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`configurations using the remote control, controlling appliances using the remote
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`control, and configuring the remote control according to the selected configuration.
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`Id. at ¶¶[0009], [0031]. The '831 publication further discloses downloading
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`configurations from a computing device. Id. at ¶[0034].
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`33.
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`In my opinion, the '831 publication teaches each and every limitation of
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`claims 12-15 of the '207 patent.
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`Universal Remote Control Exhibit 1003: Page 11
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`Claim 12
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`34.
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`In my opinion, the '831 publication discloses a method for configuring an
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`audio visual entertainment device in communication with a plurality of devices for
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`an activity. See '831 publication at Fig. 1 (VCR 113 is an audio visual
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`entertainment device in communication with at least cable receiver 114, satellite
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`received 115, audio system 11 and television 110); ¶[0019] (VCR 113 can be
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`configured to use different inputs and/or outputs for different activity sets).
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`35.
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`In my opinion, the '831 publication discloses associating a command
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`value corresponding to an activity key of a controlling device with a configuration
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`of the entertainment device. See the '831 publication at ¶[0031] (an activity set
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`(configuration of the entertainment device) is associated with a key (activity key)
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`on the remote control (the controlling device)). One skilled in the art would
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`recognize that the activity key must be designated with a value (command value)
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`by which to reference that key. Thus the command value corresponding to the
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`activity key is associated with the configuration of the entertainment device.
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`36.
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`In my opinion, the '831 publication discloses that the configuration of the
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`entertainment device can comprise at least one of the plurality of devices being
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`used as an audio visual input source device for the entertainment device and at
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`least one of the plurality of devices being used as an audio visual output
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`destination device for the entertainment device. See the '831 publication at
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`Universal Remote Control Exhibit 1003: Page 12
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`¶[0018], [0019].
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`37.
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`In my opinion, the '831 publication discloses causing the entertainment
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`device to access and use the configuration associated with the command value
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`corresponding to the activity key of the controlling device in response to the
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`entertainment device receiving from the controlling device a signal which includes
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`the command value corresponding to the activity key of the controlling device.
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`See the '831 publication at ¶[0019] (when an activity key is pressed on the remote
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`control (controlling device), VCR 113 (the entertainment device) must receive a
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`signal from the remote control that includes the command value corresponding to
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`the selected activity key, so that VCR 113 knows which input and output devices
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`to use for the selected activity key, and in order to provide the video and audio
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`information to the television, VCR 113 must inherently access and use the
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`configuration associated with the sent command value).
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`38.
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`In my opinion, the '831 publication discloses displaying in a display
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`associated with the entertainment device a graphical user interface for allowing a
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`user to select at least one of the plurality of devices to be used in the configuration.
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`See the '831 publication at ¶[0031].
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`39.
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`In my opinion, the '831 publication discloses the user selection of at least
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`one of the plurality devices to be used in the configuration comprising one or more
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`signals received from the controlling device having data indicative of an appliance.
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`Universal Remote Control Exhibit 1003: Page 13
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`This functionality is inherent in such a system. For VCR 113 (the entertainment
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`device) to be configured to use the desired input and output devices (appliances)
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`according to the selected activity, VCR 113 must receive signals from the remote
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`control (controlling device) that indicate the appliances (input or output devices) to
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`be used in the configuration. To the extent this feature is not inherent, it would
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`have been obvious to one skilled in the art reading the ‘831 publication since the
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`system described therein is specifically intended to allow a user to control a home
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`theatre system, including the selected components therein through one or more
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`signals from the remote control.
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`40.
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`In my opinion, the '831 publication discloses the one or more signals
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`being transmitted from the controlling device to the entertainment device in
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`response to an activation of a one or more keys of the controlling device which are
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`associated within the controlling device to an appliance being selected for use in
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`the configuration. See the '831 publication at ¶[0018], ¶[0019] (the activity key is
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`associated within the remote control to all appliances being selected for use in the
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`configuration and to the entertainment device); id. at ¶[0009] (the entertainment
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`device, being a component of the system, is sent signals from the remote control).
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`41.
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`In my opinion, the '831 publication discloses the controlling device
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`further using the activation of the one or more keys to automatically configure
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`itself. See the '831 publication at ¶¶[0022], [0037] (when an activity key is chosen,
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`Universal Remote Control Exhibit 1003: Page 14
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`the controlling device automatically configures itself to associate the keys of the
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`remote control with different components).
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`42.
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`In my opinion, the '831 publication discloses that an activation of one or
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`more command keys of the controlling device will cause the controlling device to
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`communicate commands to the one or more of the audio visual source device and
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`the audio visual output destination device. See the '831 publication at ¶[0009].
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`Claim 13
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`43.
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`In my opinion, the '831 publication discloses a method for configuring an
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`audio visual entertainment device in communication with a plurality of devices for
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`an activity. See '831 publication at Fig. 1 (VCR 113 is an audio visual
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`entertainment device in communication with at least cable receiver 114, satellite
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`received 115, audio system 11 and television 110); ¶[0019] (VCR 113 can be
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`configured to use different inputs and/or outputs for different activity sets).
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`44.
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`In my opinion, the '831 publication discloses associating a command
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`value corresponding to an activity key of a controlling device with a configuration
`
`of the entertainment device. See the '831 publication at ¶[0031] (an activity set
`
`(configuration of the entertainment device) is associated with a key (activity key)
`
`on the remote control (the controlling device). One skilled in the art would
`
`recognize that the activity key must be designated with a value (command value)
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`by which to reference that activity key. Thus the command value corresponding to
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`
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`Universal Remote Control Exhibit 1003: Page 15
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`the activity key is associated with the configuration of the entertainment device.
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`45.
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`In my opinion, the '831 publication discloses that the configuration of the
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`entertainment device can comprise at least one of the plurality of devices being
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`used as an audio visual input source device for the entertainment device and at
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`least one of the plurality of devices being used as an audio visual output
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`destination device for the entertainment device. See the '831 publication at
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`¶[0018], [0019].
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`46.
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`In my opinion, the '831 publication discloses causing the entertainment
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`device to access and use the configuration associated with the command value
`
`corresponding to the activity key of the controlling device in response to the
`
`entertainment device receiving from the controlling device a signal which includes
`
`the command value corresponding to the activity key of the controlling device.
`
`See the '831 publication at ¶[0019] (when an activity key is pressed on the remote
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`control (controlling device), VCR 113 (the entertainment device) must receive a
`
`signal from the remote control that includes the command value corresponding to
`
`the selected activity key, so that VCR 113 knows which input and output devices
`
`to use for the selected activity key, and in order to provide the video and audio
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`information to the television, VCR 113 must inherently access and use the
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`configuration associated with the sent command value).
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`47.
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`In my opinion, the '831 publication discloses the configuration of the
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`Universal Remote Control Exhibit 1003: Page 16
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`entertainment device downloaded into the entertainment device from a computing
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`device in communication with the entertainment device. See the '831 publication
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`at ¶[0034]. The ‘831 publication specifically discusses collecting information from
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`users about the configuration that is downloaded from a computer. To the extent
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`this feature is not inherent, in light of the disclosure in the ‘831 publication of
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`downloading at least information from users regarding the configuration, it would
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`have been obvious to create and download the configuration itself.
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`48.
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`In my opinion, the '831 publication discloses a configuration of the
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`controlling device in which an activation of one or more command keys of the
`
`controlling device will cause the controlling device to communicate commands to
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`the one or more of the audio visual source device and the audio visual output
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`destination device is downloaded into the controlling device from a computing
`
`device in communication with the controlling device. See the '831 publication at
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`¶[0032] (teaching that a remote control can be updated or customized via an
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`Internet-based service, and thus from a computing device in communication with
`
`the controlling device). One skilled in the art understands that the Internet
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`interconnects computer devices and, therefore, in order for the remote control to be
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`updated or customized via the Internet, the remote control necessarily must be in
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`communication with computing devices. Furthermore, a remote control, by
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`design, communicates commands to the controlled devices. Therefore this element
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`Universal Remote Control Exhibit 1003: Page 17
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`is inherent. In addition, this functionality would have been obvious to one skilled
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`in the art with knowledge of the '831 publication as a way to facilitate the creation
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`of such configurations.
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`Claim 14
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`49.
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`In my opinion, the '831 publication discloses a method for configuring an
`
`audio visual entertainment device in communication with a plurality of devices for
`
`an activity. See '831 publication at Fig. 1 (VCR 113 is an audio visual
`
`entertainment device in communication with at least cable receiver 114, satellite
`
`received 115, audio system 11 and television 110); ¶[0019] (VCR 113 can be
`
`configured to use different inputs and/or outputs for different activity sets).
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`50.
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`In my opinion, the '831 publication discloses receiving at the
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`entertainment device from a controlling device a configuration request signal,
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`wherein the configuration request signal includes a command value corresponding
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`to an activity key of a controlling device. See the '831 publication at ¶[0019]
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`(VCR 113 can be configured to use different inputs and/or outputs). In order for
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`VCR 113 (the entertainment device) to be configured to use the desired input and
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`output devices, it must receive a signal indicating the requested configuration.
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`This signal is thus a "configuration request signal." For VCR 113 to know which
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`configuration to use, it must receive an indication of the activity key selected on
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`the remote control. One skilled in the art would recognize that this indication is
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`Universal Remote Control Exhibit 1003: Page 18
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`sent in the form of the command value associated with the activity key. See id. at
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`¶[0031] (a command value is associated with an activity key of the remote control.
`
`An activity set (configuration of the entertainment device) is associated with a key
`
`(activity key) on the remote control (the controlling device)). One skilled in the art
`
`would recognize that the activity key must be designated with a value (command
`
`value) by which to reference that activity key of the remote control. Thus the
`
`command value corresponds to the activity key of the remote control.
`
`51.
`
`In my opinion, the '831 publication discloses causing the command value
`
`corresponding to the activity key of the controlling device included in the
`
`configuration request signal to be automatically associated with a configuration of
`
`the entertainment device wherein the configuration of the entertainment device
`
`comprises at least one of the plurality of devices being used as an audio visual
`
`input source device for the entertainment device and at least one of the plurality of
`
`devices being used as an audio visual output destination device for the
`
`entertainment device. See the '831 publication at ¶[0019] (an activity set defines a
`
`configuration of the entertainment device, where at least one of the plurality of
`
`devices is used as an audio visual input source device and at least one of the
`
`plurality of devices is used as an audio visual output destination device); ¶[0031]
`
`(an activity set (configuration of the entertainment device) is associated with a key
`
`(activity key) on the remote control (the controlling device). One skilled in the art
`
`
`
`Universal Remote Control Exhibit 1003: Page 19
`
`
`
`
`
`would recognize that the activity key must be designated with a value (command
`
`value) by which to reference that activity key. Thus the command value is
`
`automatically associated with the activity key and thus with a configuration of the
`
`entertainment device.
`
`52.
`
`In my opinion, the '831 publication discloses causing the entertainment
`
`device to access and use the configuration associated with the command value
`
`corresponding to the activity key of the controlling device in response to the
`
`entertainment device subsequently receiving from the controlling device a
`
`command signal which includes the command value corresponding to the activity
`
`key of the controlling device. See '831 publication at ¶[0019] (when an activity
`
`key is pressed on the remote control (controlling device), VCR 113 (the
`
`entertainment device) must receive a signal from the remote control that includes
`
`the command value corresponding to the selected activity key, so that VCR 113
`
`knows which input and output devices to use for the selected activity key, and in
`
`order to provide the video and audio information to the television, VCR 113 must
`
`inherently access and use the configuration associated with the sent command
`
`value).
`
`Claim 15
`
`53.
`
`In my opinion, the '831 publication discloses the method as recited in
`
`claim 14, comprising causing the entertainment device to display in a display
`
`
`
`Universal Remote Control Exhibit 1003: Page 20
`
`
`
`
`
`associated with the entertainment device, in response to receiving the configuration
`
`request signal, a graphical user interface for allowing a user to select at least one of
`
`the plurality of devices to be used in the configuration for the entertainment device.
`
`See the '831 publication at ¶[0031].
`
`Niles in Combination With the '831 Publication and / or the ‘204 Patent
`Teaches All Elements Recited by Claims 12-15 of the '207 Patent.
`
`54.
`
`I am informed that the "IntelliControl Reference Manual," by Niles
`
`("Niles") is dated April of 2002, more than seven years before the filing date of the
`
`'207 patent, and is thus prior art to the '207 patent under at least 35 U.S.C. §
`
`102(b). Niles discloses a system including "an ergonomically designed RF (radio
`
`frequency) Tabletop Remote Control and an 'intelligent' Main System Unit (MSU).
`
`Niles at p. 1. Niles teaches that the "Main System Unit is the 'brain' of the
`
`IntelliControl system. Once a RF command is issued from the Tabletop Remote,
`
`the MSU processes the command and controls all functions of the system." Id. at
`
`p. 4. The Main System Unit also stores configurations associated with home
`
`theater equipment, and keys on the remote control are associated with
`
`configurations to access the respective configuration upon actuation of the
`
`appropriate key. Id. at pp. 25-27. Configurations may be downloaded from a
`
`computing device and a menu or other display of available inputs and outputs of
`
`the theatre system may be displayed. Id at p. 26.
`
`
`
`Universal Remote Control Exhibit 1003: Page 21
`
`
`
`
`
`55.
`
`I am informed that U.S. Patent No. 4,527,204 (the "'204 patent") issued
`
`July 2, 1985, almost 25 years before the '207 patent was filed, and is thus prior art
`
`to the '207 patent under at least 35 U.S.C. § 102(b). The ‘204 patent relates to a
`
`hand held remote control unit that produces command signals to control a video
`
`tape recorder and an associated television receiver in an entertainment system. For
`
`exam
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