HTC Corporation and HTC America, Inc.
`Petitioner Demonstratives
`
`HTC Corporation and HTC America, Inc.
`v.
`Advanced Audio Devices, LLC
`
`Case IPR2014-01154
`Patent No. 6,587,403 B1
`
`Oral Hearing
`September 17, 2015
`
`HTC, Ex. 1025
`HTC v. Advanced Audio Devices
`IPR2014-001154
`
`
`Petitioner Demonstratives
`
`HTC Corporation and HTC America, Inc.
`v.
`Advanced Audio Devices, LLC
`
`Case IPR2014-01154
`Patent No. 6,587,403 B1
`
`Oral Hearing
`September 17, 2015
`
`HTC, Ex. 1025
`HTC v. Advanced Audio Devices
`IPR2014-001154
`
`
`
`PTAB Instituted Grounds
`(Institution Decision, Paper 6, at 22)
`
`IPR2014-01154
`
`HTC Demonstrative 403-2
`
`
`
`Ground 1- Anticipation by Nathan ‘259 (Ex. 1002)
`
`Element
`
`Challenged Claim
`
`Petition
`(Paper 1)
`
`2014
`Schmandt
`Declaration
`(Ex. 1007)
`
`Reply
`(Paper
`21)
`
`1.Pre.
`
`1.A
`
`1.B
`
`1.C
`
`1.D
`
`1.E
`
`1.E(1)
`
`1.E(2)
`
`A music jukebox configured for storing a music library therein,
`said music jukebox comprising;
`A housing
`
`An audio data receiver arranged to receive audio data from
`outside the housing
`audio output structure located at least partially within the
`housing for outputting audio signals;
`data storage memory in the housing for storing audio data
`received from outside the housing through the audio data
`receiver;
`said music jukebox including a user interface comprising;
`
`a display device located at least partially within the housing,
`said display device providing a display which is viewable from
`outside the housing,
`a plurality of manually operable function controllers on the
`housing;
`
` ¶¶84,101
`
` ¶¶85,101
`
` ¶¶86,101
`
` ¶¶87,101
`
` ¶¶88,101
`
`¶¶89,101
`
`¶¶90,101
`
`¶¶91-93,101
`
`16:14-17:1
`
`
`17:2-3
`
`
`17:4-17
`
`
`17:18-20:9
`
`
`18:10-19:6
`
`
`
`19:7-13
`
`
`19:14-20:1
`
`
`
`20:2-9
`
`
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`2015
`Schmandt
`Rebuttal
`Declaration
`(Ex. 1010)
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`IPR2014-01154
`
`* Element not disputed by AAD
`HTC Demonstrative 403-3
`
`
`
`Ground 1- Anticipation by Nathan ‘259 (Ex. 1002)
`
`Element
`
`Challenged Claim
`
`1.F
`
`1.G
`
`1.H
`
`1.I
`
`1.J
`
`1.K
`
`said music jukebox configured such that a music library of sound tracks is
`storable in digital form in the data storage memory as a result of audio
`data being received from outside the housing through the audio data
`receiver;
`said music jukebox configured such that said music library is organizable
`into a master song list;
`
`at least one group of sound tracks wherein each group comprises at least
`one sound track selected from the master song list;
`
`wherein said music jukebox is configured such that indicia of said master
`song list and indicia of at least one group of sound tracks are displayable
`on said display;
`
`wherein said music jukebox is configured such that said plurality of
`manually operable function controllers is useable to select a group of
`sound tracks stored in the data storage memory;
`and operate the music jukebox such that said music jukebox outputs
`audio signals through said audio output structure.
`
`Petition
`(Paper 1)
`
`2014
`Schmandt
`Declaration
`(Ex. 1007)
`
`Reply
`(Paper
`21)
`
`20:10-20
`
`
`¶¶94,101
`
`*
`
`2015
`Schmandt
`Rebuttal
`Declaration
`(Ex. 1010)
`*
`
`21:1-6
`
`
`21:7-15
`
`
`21:16-
`22:13
`
`
`22:14-23:4
`
`
`23:5-14
`
`
`¶¶95.101
`
`11:1-12
`
`¶50
`
`¶¶96,101
`
`11:13-
`12:4
`
`¶50
`
`¶¶97-98,101
`
`12:5-13:1 ¶51
`
`¶¶99,101
`
`13:2-10
`
`¶52
`
`¶¶100,101
`
`*
`
`*
`
`* Element not disputed by AAD
`
`IPR2014-01154
`
`HTC Demonstrative 403-4
`
`
`
`Grounds 2 and 3 under 35 USC 103(a)
`Motivations to Combine
`
`Ground References
`
`Petition
`(Paper 1)
`
`2014
`Schmandt
`Declaration
`(Ex. 1008)
`
`Reply
`(Paper 21)
`
`2015
`Schmandt
`Rebuttal
`Declaration
`(Ex. 1010)
`¶¶15,55
`
`2
`
`3
`
`Nathan ‘259 (Ex.
`1002)+ Nathan ‘255
`(Ex. 1003)
`Sound Blaster (Ex.
`1004) + Lucente (Ex.
`1005) + Ozawa (Ex.
`1006)
`
`27:6-
`28:16
`
`36:5-
`42:5
`
`¶¶115-118
`
`15:9-16
`
`¶¶149-170
`
`17:6-23:13
`
`¶¶56-71
`
`IPR2014-01154
`
`HTC Demonstrative 403-5
`
`
`
`Nathan ‘259
`
`
`
`Nathan ‘255
`
`IPR2014-01154
`
`HTC Demonstrative 403-6
`
`
`
`Nathan ‘255
`
`•
`
`•
`
`New Selection Acquisition Mode:
`•
`“… the manager can access the mode of new
`selection acquisition by touching a button located
`on the touch screen.” (¶91)
`“The NSAM module is the new selections
`acquisition mode module. When this mode is
`activated, a new control screen appears. This mode
`is designed to assist the manager regarding the
`location or fast and efficient acquisition of titles of
`musical selections.” (¶92)
`“…a third panel for scanning the title database, for
`private use, to allow the system manager or owner
`to examine the database containing the available
`titles via the audiovisual data distribution network
`to control and retrieve said titles” (¶41)
`Customer Browsing and Selection Mode
`•
`“The CBSM module is the customer browsing and
`selection mode module. Access to this module is
`triggered from the "in service" mode by touching
`the screen. When the customer touches the screen,
`the screen display disappears to make room for a
`menu provided for powerful browsing assisted by
`digitized voice messages to guide the user in his
`choice of musical selections.” (¶99)
`“The first title selection panel proceeding to help
`customers find and select a desired title” (¶41)
`
`•
`
`IPR2014-01154
`
`HTC Demonstrative 403-7
`
`
`
`Nathan ‘259
`
`“A first object of the invention is to propose an apparatus which allows selection and downloading of digital
`data, and reproduction of these digital data for domestic apparatus or use of the device for karaoke.” (¶2)
`“Another object of the invention is to devise a modular device which allows the user to develop a design
`allowing storage of a plurality of audio or video or audiovisual information selections. This object is achieved by
`a second mass storage module (108) allowing the recording of a plurality of digitized audiovisual data.” (¶¶8-9)
`
`IPR2014-01154
`
`HTC Demonstrative 403-8
`
`
`
`
`
`Nathan ‘259
`
`The selection graphics
`screen shown in Fig. 10
`is displayed by button
`(1025) from any zone of
`the playback graphics
`screen. (¶74)
`
`Front (10) includes a red
`button (1019) which allows
`the “purchase" function
`described below. (¶46)
`This remote control device
`can trigger display of the
`graphics screen located in
`FIG. 9 when the "purchase"
`key equivalent to (1019) of
`the remote control is
`pressed. (¶46)
`
`Available songs (¶74)
`
`Purchase, check
`PIN/credit card,
`download (¶¶68-73)
`
`Select, add to
`queue (¶74))
`
`IPR2014-01154
`
`HTC Demonstrative 403-9
`
`
`
`Ground 2- Nathan ‘259 (Ex. 1002) in view of Nathan
`‘255 (Ex. 1003)
`
`Element
`
`Challenged Claim
`
`Petition
`(Paper 1)
`
`2014
`Schmandt
`Declaration
`(Ex. 1007)
`
`Reply
`(Paper
`21)
`
`1.Pre.
`
`1.A
`
`1.B
`
`1.C
`
`1.D
`
`1.E
`
`1.E(1)
`
`1.E(2)
`
`A music jukebox configured for storing a music library therein,
`said music jukebox comprising;
`A housing
`
`An audio data receiver arranged to receive audio data from
`outside the housing
`audio output structure located at least partially within the
`housing for outputting audio signals;
`data storage memory in the housing for storing audio data
`received from outside the housing through the audio data
`receiver;
`said music jukebox including a user interface comprising;
`
`a display device located at least partially within the housing,
`said display device providing a display which is viewable from
`outside the housing,
`a plurality of manually operable function controllers on the
`housing;
`
`¶119, ¶135
`
`¶120, ¶135
`
`¶121, ¶135
`
`¶122, ¶135
`
`¶123, ¶135
`
`¶124, ¶135
`
`¶125, ¶135
`
`¶126, ¶135
`
`28:18-29:4
`
`
`29:5-9
`
`
`29:10-19
`
`
`29:20-30:4
`
`
`30:5-11
`
`
`
`30:12-17
`
`
`30:18-31:7
`
`
`
`31:8-32:5
`
`
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`2015
`Schmandt
`Rebuttal
`Declaration
`(Ex. 1010)
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`IPR2014-01154
`
`* Element not disputed by AAD
`HTC Demonstrative 403-10
`
`
`
`Ground 2- Nathan ‘259 (Ex. 1002) in view of
`Nathan ‘255 (Ex. 1003)
`
`Element
`
`Challenged Claim
`
`Petition
`(Paper 1)
`
`2014
`Schmandt
`Declaration
`(Ex. 1007)
`
`Reply
`(Paper
`21)
`
`1.F
`
`1.G
`
`1.H
`
`1.I
`
`1.J
`
`1.K
`
`said music jukebox configured such that a music library of sound tracks is
`storable in digital form in the data storage memory as a result of audio
`data being received from outside the housing through the audio data
`receiver;
`said music jukebox configured such that said music library is organizable
`into a master song list;
`
`at least one group of sound tracks wherein each group comprises at least
`one sound track selected from the master song list;
`
`wherein said music jukebox is configured such that indicia of said master
`song list and indicia of at least one group of sound tracks are displayable
`on said display;
`wherein said music jukebox is configured such that said plurality of
`manually operable function controllers is useable to select a group of
`sound tracks stored in the data storage memory;
`and operate the music jukebox such that said music jukebox outputs
`audio signals through said audio output structure.
`
`32:6-13
`
`
`
`32:14-20
`
`
`33:1-2
`
`
`33:3-4
`
`
`33:5-6
`
`
`33:7-11
`
`
`¶129
`¶135
`
`¶130
`¶135
`
`¶131
`¶135
`
`¶132
`¶135
`
`¶133
`¶135
`
`¶134
`¶135
`
`*
`
`**
`
`**
`
`**
`
`**
`
`*
`
`2015
`Schmandt
`Rebuttal
`Declaration
`(Ex. 1010)
`*
`
`**
`
`**
`
`**
`
`**
`
`*
`
`* Element not disputed by AAD
`** No response by AAD to additional
`teachings of Nathan ‘255
`
`IPR2014-01154
`
`HTC Demonstrative 403-11
`
`
`
`Motivation to Combine
`Sound Blaster, Lucente, and Ozawa
`
`“In my opinion, a person of ordinary skill in the art would consider the teachings of each of Sound Blaster,
`Lucente, and Ozawa to be pertinent in designing a digital audio player, such as a computer with digital audio
`playback capability… A person of ordinary skill in the art would therefore consider Sound Blaster, Lucente, and
`Ozawa to be within the same field and would naturally consider the teachings of one to be relevant to the
`other…
`“In my opinion, a person of ordinary skill in the art would recognize that the functionality provided by the
`software taught by Sound Blaster, including recording and storing audio files, would provide similar benefits in
`a portable personal computer using a touch screen interface, such as the pen computer discussed in Lucente,
`for the same reason they would be beneficial in a personal computer (whether a desktop or laptop) using an
`interface such as a mouse… Lucente teaches that the touch screen computer it describes is intended to
`maintain the capability to be used for a wide range of software programs… In light of this overlap, and the
`similarity between the audio subsystems and audio input and output hardware of Sound Blaster and Lucente, a
`person of ordinary skill in the art would be motivated to combine a system with the flexibility, portability, and
`ease of use of Lucente with the audio management capabilities of Sound Blaster. Similarly, a person of ordinary
`skill in the art would recognize that the downloaded library of Ozawa could be improved using the
`organizational methods (e.g. sorting into playlists) of Sound Blaster…
`“In my opinion, combining the elements claimed by Challenged Claims of the 403 Patent into a single unit
`would not produce any benefits that would not be readily apparent to a person of ordinary skill in the art
`familiar with the teachings of Sound Blaster, Lucente, and Ozawa.”
`Ex. 1007 (Schmandt Decl., ¶¶ 167-169)
`Petition (Paper 1) at 36-42
`
`IPR2014-01154
`
`HTC Demonstrative 403-14
`
`
`
`Compatible Hardware
`
`
`
`M-Wave Audio
`subsystem
`Headphone port
`Microphone port
`Line in/out ports
`
`Schmandt Rebuttal Declaration:
`•
`[S]ound functionality for a variety of computing devices,
`including laptops and tablets with touch screens, was well-
`known at the time of the alleged invention, and a person of
`ordinary skill in the art would understand that the basic
`software concepts illustrated in Sound Blaster, including the
`use and management of playlists, could be adapted to work
`in a variety of computer systems having the appropriate
`hardware to play back sound files stored in memory, and
`would have a reasonable expectation of success… Ex. 1010,
`¶61.
`[A] person of ordinary skill in the art would understand the
`teachings of the Sound Blaster reference to be applicable to
`other types of busses or connections beyond the specific ISA
`example used on that particular card. Id., ¶62.
`The purpose of using a standard bus such as ISA, PCI, or MCA
`is to provide a common interface for hardware designers to
`allow their components to connect. Adapting hardware such
`as a sound card to utilize a known bus standard would have
`been a routine task well within the ability of a person of
`ordinary skill in the art, and would not have required undue
`experimentation. Id.
`Lucente discloses the use of Mwave Audio. Mwave audio was
`SoundBlaster compatible. Id., ¶63.
`
`•
`
`•
`
`•
`
`IPR2014-01154
`
`HTC Demonstrative 403-15
`
`
`
`Compatible Hardware
`
`Petition at 39:
`•
`Ozawa describes a portable audio device that
`uses personal computer technology (e.g. ISA,
`AT and PCT buses - Ozawa at 7: 27- 38; 9: 15-
`23) for the input and storage of audio, along
`with dedicated push-button controls such as
`direction, input and mode keys (e.g. fast-
`forward, play, rewind, stop and pause keys)
`are on the front panel of the housing for
`controlling playback of stored audio. The
`Ozawa device allows a user to selectively
`download music from a network service
`center, save that music to a hard disc within
`the player, and listen to music through
`headphones. The Ozawa device fits in a
`single rectangular housing and includes a
`CPU, RAM, hard disc for storing audio data,
`LCD display, 20 modem, headphone terminal
`and microphone terminal on its upper
`surface.
`
`IPR2014-01154
`
`HTC Demonstrative 403-16
`
`
`
`Compatible Software
`Touch-screen tablets/laptops
`Including IBM Tablets
`running Windows by 1997
`[I]n 1997 Fujitsu sold tablet
`computers running the
`Windows 95 operating system,
`such as the Fujitsu Stylistic
`1200. The Fujitsu Stylistic
`featured a touch-screen display
`along with a row of dedicated
`touch-sensitive controls
`immediately under the touch
`screen, including controls for
`sound playback, and a pen that
`could be pressed against the
`touch screen to achieve the
`same functions as left or right
`mouse clicks on a Windows 95
`machine without a touch
`screen:
`Ex.1007, ¶ 49
`
`Ex. 1007, App. J
`
`U.S. Patent No. 5,983,073… describes a laptop computer with
`a touch screen that could operate with a GUI based operating
`system such as Microsoft Windows 3.1
`Ex.1007, ¶ 50
`
`Ex. 1007, App. W
`
`IPR2014-01154
`
`HTC Demonstrative 403-17
`
`
`
`Contingent Motion to Amend
`
`References of record or known to AAD teaching additional elements of AAD
`proposed changes
`Teachings of reference
`
`Reference
`
`Schmandt Opposition
`Declaration (Ex. 1023)
`
`Opposition to
`Motion to Amend
`(Paper 22)
`8:8-9:16
`
`Nathan ‘259 (Ex. 1002) in view of
`Nathan ‘255
`Sound Blaster (Ex. 1004) in view of
`Lucente and Ozawa
`Sound Blaster in view of Nathan ‘259
`and Nathan ‘255
`Logan (Ex. 1018)
`
`Looney (Ex. 1020)
`
`Yankowski (Ex. 1019)
`
`Nathan ‘259: ¶¶ 74, 77, Fig. 10
`
`Sound Blaster: 2-25
`
`Sound Blaster: 2-25
`
`Abstract, Fig. 2, (item 211), 9:4–6,
`11:22–28, 30:4–58
`Figs. 14–16, 7:45–62, 9:52–
`59, 10:35–58
`10:48–63, Fig. 5
`
`Windows 95 CD player (Ex. 1007, App. I) App. I at 239–40
`
`9:17-10:20
`
`11:1-13:5
`
`14:1-8
`
`14:8-14
`
`14:17-20
`
`14:20-15:4
`
`¶¶ 9,10
`
`¶¶11-14
`
`¶¶15-17
`
`¶22
`
`¶23
`
`¶20
`
`¶¶ 18–23
`
`IPR2014-01154
`
`HTC Demonstrative 403-18
`
`
`
`Contingent Motion to Amend
`
`References of record or known to AAD teaching additional elements of AAD
`proposed changes
`Teachings of reference
`
`Reference
`
`Yavelow (Ex. 1007, App. G)
`
`Ex. 1007, App. G, Fig. 15-5.
`
`WinPlay 3 (See Ex. 1007, ¶ 36)
`
`(See Ex. 1007, ¶ 36)
`
`15:19-16:3
`
`Opposition to
`Motion to Amend
`(Paper 22)
`15:15-19
`
`Schmandt Opposition
`Declaration (Ex. 1023)
`
`¶ 19
`
`¶ 19
`
`Additional reference teaching additional elements of AAD proposed changes
`
`Reference
`
`Teachings of reference
`
`Winamp (Ex. 1021) in view of Lucente,
`Ditzik (Ex. 1022), and Ozawa
`
`See Frankel Decl (Ex. 1021), ¶¶ 5-
`11
`
`Schmandt Opposition
`Declaration (Ex. 1023)
`
`¶¶ 24-46
`
`Opposition to
`Motion to Amend
`(Paper 22)
`18:6-21:17
`(Motivation to
`combine)
`21:18-25:2 (original)
`25:3-12 (proposed
`changes)
`
`IPR2014-01154
`
`HTC Demonstrative 403-19
`
`
`
`Conclusion
`
`PTAB should invalidate and cancel
`challenged claims based on instituted grounds
`
`IPR2014-01154
`
`HTC Demonstrative 403-20
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