UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`UNIFIED PATENTS INC.,
`Petitioner
`
`v.
`
`QURIO HOLDINGS, INC.,
`
`Patent Owner
`
`
`
`IPR2015-01991
`Patent No. 7,787,904
`
`
`
`DECLARATION OF JON WEISSMAN
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`Page 1 of 87
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`Unified Patents Exhibit 1002
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`

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`TABLE OF CONTENTS
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`I. 
`
`Introduction ...................................................................................................... 1 
`
`II. 
`
`Qualifications ................................................................................................... 2 
`
`III.  Materials Reviewed ......................................................................................... 4 
`
`IV.  Overview of the ’904 Patent and Prosecution History .................................... 4 
`
`V. 
`
`Person of Ordinary Skill in the Art .................................................................. 8 
`
`VI.  Claim Construction .......................................................................................... 8 
`
`VII.  Certain References Disclose or Suggest all of the Elements Claimed in
`the ’904 Patent. ................................................................................................ 9 
`
`A. 
`
`Claims 1-3, 12, and 16-17 would have been obvious over
`Lambourne in view of Elabbady ......................................................... 11 
`
`1. 
`
`It would have been obvious to one of ordinary skill to
`combine the teachings of Lambourne and Elabbady ................ 14 
`
`B. 
`
`Claims 1-3, 12, and 16-17 would have been obvious over Chen
`in view of Plastina 2007 ..................................................................... 25 
`
`1. 
`
`2. 
`
`3. 
`
`It would have been obvious to one of ordinary skill to
`combine the teachings of Plastina 2007 and Chen ................... 28 
`
`One of ordinary skill would have recognized that the
`control device of Chen communicates with the video
`device ........................................................................................ 30 
`
`One of ordinary skill would have recognized that the
`control device of Chen communicates to obtain
`information describing content residing at the video
`device ........................................................................................ 32 
`
`C. 
`
`Claims 4 and 7 would have been obvious over
`Lambourne/Elabbady or Chen/Plastina 2007 in further view of
`Meade .................................................................................................. 43 
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`It would have been obvious to one of ordinary skill to
`combine Meade with either the Lambourne/Elabbady
`device or the Chen/Plastina 2007 device ................................. 44 
`
`1. 
`
`D. 
`
`Claims 5 and 8 would have been obvious over
`Lambourne/Elabbady/Meade or Chen/Plastina 2007/Meade in
`view of Plastina 2003 ......................................................................... 47 
`
`1. 
`
`It would have been obvious to one of ordinary skill to
`combine Plastina 2003 with either the
`Lambourne/Elabbady/Meade device or the Chen/Plastina
`2007/Meade device ................................................................... 48 
`
`E. 
`
`Claim 9 would have been obvious over Lambourne/Elabbady
`or Chen/Plastina 2007 in further view of Dwek ................................. 50 
`
`1. 
`
`It would have been obvious to one of ordinary skill to
`combine Dwek with either the Lambourne/Elabbady
`device or the Chen/Plastina 2007 device ................................. 50 
`
`F. 
`
`Claims 10 and 18 would have been obvious over
`Lambourne/Elabbady or Chen/Plastina 2007 in view of Meade ....... 52 
`
`1. 
`
`It would have been obvious to one of ordinary skill to
`combine Meade with either the Lambourne/Elabbady
`device or the Chen/Plastina 2007 device ................................. 52 
`
`G. 
`
`Claims 10 and 18 would have been obvious over
`Lambourne/Elabbady or Chen/Plastina 2007 in further view of
`Melpignano .......................................................................................... 55 
`
`1. 
`
`It would have been obvious to one of ordinary skill to
`combine Melpignano with either the
`Lambourne/Elabbady device or the Chen/Plastina 2007
`device ........................................................................................ 56 
`
`H. 
`
`Claim 14 would have been obvious over Lambourne/Elabbady
`or Chen/Plastina 2007 in further view Weinans ................................. 59 
`
`
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`It would have been obvious to one of ordinary skill to
`combine Weinans with either the Lambourne/Elabbady
`device or the Chen/Plastina 2007 device ................................. 60 
`
`1. 
`
`I. 
`
`Claim 15 would have been obvious over Lambourne/Elabbady
`or Chen/Plastina 2007 in further view of Willson .............................. 62 
`
`1. 
`
`One of ordinary skill would have found it obvious to
`combine Willson with the Lambourne/Elabbady device
`or the Chen/Plastina 2007 device ............................................. 63 
`
`VIII.  Conclusion ..................................................................................................... 65 
`
`
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`iii
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`I.
`
`I, Jon Weissman, declare as follows:
`
`Introduction
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`IPR2015-01991
`U.S. Patent 7,787,904
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`
`
`1.
`
`I have been retained by Unified Patents Inc. (“Unified” or
`
`“Petitioner”) as an independent expert consultant in this proceeding before the
`
`United States Patent and Trademark Office. Although I am being compensated at
`
`my hourly rate for the time I spend on this matter, no part of my compensation
`
`depends on the outcome of this proceeding, and I have no other interest in this
`
`proceeding.
`
`
`2.
`
`I understand that this proceeding involves U.S. Patent No. 7,787,904
`
`(“the ’904 patent”) (attached as EX1001 to Unified’s petition). I understand the
`
`application for the ’904 patent was filed on November 9, 2005, as U.S. Patent
`
`Application No. 11/270,293, and the patent issued on August 31, 2010.
`
`
`3.
`
`I have been asked to consider whether one of ordinary skill in the art
`
`of the ’904 patent would understand that certain references disclose or suggest the
`
`features recited in the claims of the ’904 patent, or that the features would have
`
`been obvious based on the combination of the references. My opinions are set forth
`
`below.
`
`
`4.
`
`I have been advised that a patent claim may be obvious if the
`
`differences between the subject matter of the claim and the prior art are such that
`
`the subject matter as a whole would have been obvious at the time the invention
`
`
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`1
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`was made to a person having ordinary skill in the art. I have also been advised that
`
`several factual inquiries underlie a determination of obviousness. These inquiries
`
`include the scope and content of the prior art, the level of ordinary skill in the field
`
`of the invention, the differences between the claimed invention and the prior art,
`
`and any objective evidence of non-obviousness.
`
`
`5.
`
`I have been advised that objective evidence of non-obviousness,
`
`known as “secondary considerations of non-obviousness,” may
`
`include
`
`commercial success, satisfaction of a long-felt but unsolved need, failure of others,
`
`copying, skepticism or disbelief before the invention, and unexpected results. I am
`
`not aware of any such objective evidence of non-obviousness of the subject matter
`
`claimed in the ’904 patent at this time.
`
`
`6.
`
`In addition, I have been advised that the law requires a “common
`
`sense” approach of examining whether the claimed invention is obvious to a
`
`person skilled in the art. For example, I have been advised that combining familiar
`
`elements according to known methods is likely to be obvious when it does no more
`
`than yield predictable results.
`
`II. Qualifications
`
`
`7.
`
`I am a Full Professor of Computer Science at the University of
`
`Minnesota, the highest academic rank at a top-tier research University. Prior to this,
`
`I worked in industry for five years in the area of distributed systems. I received a
`
`
`
`2
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`B.S. from Carnegie-Mellon, and an M.S. and Ph.D. from the University of Virginia,
`
`all in Computer Science. My curriculum vitae, which includes a more detailed
`
`explanation of my background, experience, and publications, is attached as
`
`Appendix A.
`
`
`8.
`
`I am a researcher and educator in the areas of distributed systems, file
`
`systems, and cloud computing. My research has been funded by NASA, National
`
`Science Foundation, Department of Energy, and the Air Force. I have received
`
`over 20 grants for my research, for topics related to distributed systems,
`
`communications networks, and cloud computing. I have been published over 100
`
`times by well-regarded organizations such as the Association for Computing
`
`Machinery (ACM), the Institute of Electrical and Electronics Engineers (IEEE),
`
`and Usenix. I have been giving invited talks on a variety of topics related to my
`
`areas of expertise since 1993.
`
`
`9.
`
`I have served on a number of boards both as a member and as part of
`
`leadership. For example, I have served on the editorial board of journals including
`
`IEEE Transactions on Computers, IEEE Transactions on Parallel and Distributed
`
`Systems, and Cluster Computing (published by Springer). I have been serving as
`
`the steering committee chair for the ACM International Symposium on High
`
`Performance Parallel and Distributed Systems (HPDC) since 2010, the flagship
`
`conference in my area.
`
`
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`3
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`I am not an attorney and offer no legal opinions, but in the course of
`
`
`10.
`
`my work, I have had experience studying and analyzing patents and patent claims
`
`from the perspective of a hypothetical person skilled in the art. I have previously
`
`served as a technical expert in both litigations and inter partes review proceedings.
`
`III. Materials Reviewed
`
`
`11.
`
`In forming my opinions, I reviewed, among other things, the ’904
`
`Patent (EX1001), the prosecution history of the ’904 patent (EX1004), and the
`
`following:
`
`Exhibit
`EX1003
`
`Description
`IEEE 100: The Authoritative Dictionary of IEEE Standards Terms
`(7th ed., 2000) (definition of “database”)
`EX1005 U.S. Patent No. 7,571,014 to Lambourne et al.
`EX1006 U.S. Patent No. 7,483,958 to Elabbady et al.
`EX1007 U.S. Patent No. 8,479,238 to Chen et al.
`EX1008 U.S. Publication No. 2007/0048712 to Plastina et al.
`EX1009 U.S. Publication No. 2003/0073412 to Meade et al.
`EX1010 U.S. Patent Publication No. 2003/0182315 to Plastina et al.
`EX1011 U.S. Patent Publication No. 2001/0018858 to Dwek
`International Publication No. WO 2004/008693 to Melpignano
`EX1012
`EX1013
`International Publication No. WO 2002/056536 to Weinans
`EX1014 U.S. Publication No. 2003/0033413 to Willson et al.
`
`
`IV. Overview of the ’904 Patent and Prosecution History
`
` After reviewing the ’904 patent, I note that it is directed to “a system
`12.
`
`and method . . . for controlling content played by a number of media devices.”
`
`EX1001 at 1:16-19. A mobile device (such as a personal digital assistant or
`
`
`
`4
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`remote) is used to control media devices (such as a television or audio player). Id.
`
`at 4:4-9, 3:26-30. The mobile and media devices communicate wirelessly, and the
`
`mobile device obtains information (metadata) about content on the media device.
`
`Id. at 5:8-17. The mobile device stores this information in a media database, which
`
`the user uses to select content. Id. at 4:38-40. The selected content then plays at the
`
`media device. Id. at 3:18-21.
`
`
`13.
`
`Independent claim 1 recites:
`
`1. A mobile device for controlling digital content played by a plurality of
`
`media devices comprising:
`
`a) a wireless communication interface for communicating with the plurality
`
`of media devices;
`
`b) a media database; and
`
`c) a control system adapted to, for each of the plurality of media devices:
`
`i) communicate with the media device when the mobile device is
`
`within a wireless personal area network (WPAN) associated with the
`
`media device to obtain information describing content residing at the
`
`media device; and
`
`ii) store the information describing the content residing at the media
`
`device in the media database;
`
`
`
`5
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`wherein desired content is selected from the content at the media device
`
`based on the information in the media database and played at the media
`
`device when the mobile device is within the WPAN associated with the
`
`media device.
`
`
`14.
`
`Independent claim 16 reads:
`
`16. A method for controlling digital content played by a plurality of media
`
`devices comprising, for each of the plurality of media devices:
`
`obtaining information describing content residing at the media device when
`
`a mobile device is within a wireless personal area network (WPAN)
`
`associated with the media device;
`
`storing the information describing the content residing at the media device in
`
`a media database of the mobile device;
`
`selecting desired content to play from the content residing at the media
`
`device based on the media database when the mobile device is within the
`
`WPAN associated with the media device;
`
`and playing the desired content at the media device.
`
`15.
`
` The ’904 patent describes a mobile device and a media device. The
`
`mobile device and media device communicate when the mobile device is
`
`positioned to allow communication between the mobile device and the media
`
`device via the wireless communication interface of the mobile device, and the
`
`
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`6
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`mobile device. The mobile device and media device may communicate via the
`
`Bluetooth wireless communication standard, the Zigbee wireless communication
`
`standard, the Wireless Fidelity (WiFi) wireless communication standard, or the
`
`IEEE 802 wireless communication standards. EX1001 at 4:15-20. All of these
`
`standards are geographically limited—the mobile and media device must be
`
`sufficiently close to one another to communicate wirelessly.
`
` The information obtained from the media device by the mobile device
`16.
`
`is then stored in a “media database.” Id. at 4:27-33, Fig. 3. This facilitates the user
`
`interfaces (e.g., displays of the available content) shown in the ’904 patent. See id.
`
`at Fig. 5. Using the stored information, the user can then, from the mobile device,
`
`select content that will be played at the media device. Id. at 3:18-21.
`
` The ’904 patent suggests “there [was] no way of easily ascertaining
`17.
`
`the content available on . . . different media devices and controlling or selecting the
`
`content played by these media devices using a mobile device,” prior to the filing of
`
`the ’904 patent. EX1001 at Abstract. I do not agree.
`
` Systems for controlling playback and selecting content using a
`18.
`
`separate controller were well-known in the art. The technologies described in
`
`the ’904 patent, for example, Bluetooth interface, hand-held computing, and
`
`wireless network technologies, were well-established prior to the filing date of
`
`the ’904 patent.
`
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`V.
`
`Person of Ordinary Skill in the Art
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`19.
`
`In my opinion, a person of ordinary skill in the art of the ’904 patent
`
`before November 9, 2005, would have had (i) a B.S. degree in electrical
`
`engineering or computer science and approximately two years of industry
`
`experience or (ii) a master’s degree in computer science or electrical engineering.
`
`VI. Claim Construction
`
`
`20.
`
`I have been advised that the first step of assessing the validity of a
`
`patent claim is to interpret or construe the meaning of the claim.
`
`
`21.
`
`I have been advised that in post-grant review proceedings before the
`
`U.S. Patent and Trademark Office, a patent claim receives the broadest reasonable
`
`construction in light of the specification of the patent in which it appears. I have
`
`also been advised that this means the claim terms are given their ordinary and
`
`customary meaning as would be understood by one of ordinary skill in the art,
`
`unless that meaning is inconsistent with the specification of the patent.
`
`
`22.
`
`I have reviewed the constructions provided by the petitioner in its
`
`petition for inter partes review of the ’904 patent that accompanies my declaration.
`
`Unified proposes that the term “media database” means “a collection of logically
`
`related data describing media stored together,” the term “when the mobile device is
`
`within the WPAN associated with the media device” means “when the mobile
`
`device is positioned to allow communication between the mobile device and the
`
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`media device via the wireless communication interface of the mobile device,” and
`
`that the term “if the mobile device is simultaneously within the WPAN associated
`
`with a first one of the plurality of media devices and the WPAN associated with a
`
`second one of the plurality of media devices” means “if the mobile device is
`
`positioned to allow communication between the mobile device and both the first
`
`and the second media device via the wireless communication interface of the
`
`mobile device.”
`
`
`23.
`
`In my opinion, these constructions are consistent with how one of
`
`ordinary skill in the art would have understood the claim terms. The adoption of
`
`these constructions, or any other proper construction under the broadest reasonable
`
`construction, would not change my opinions set forth below.
`
`VII. Certain References Disclose or Suggest all of the Elements Claimed in
`the ’904 Patent.
`
`
`24.
`
`In my opinion, claims 1-3, 12, and 16-17 would have been obvious
`
`under § 103(a) over U.S. Patent No. 7,571,014 (“Lambourne,” EX1005) in view of
`
`U.S. Patent 7,483,958 (“Elabbady,” EX1006).
`
`
`25.
`
`In my opinion, claims 1-3, 12, and 16-17 would have been obvious
`
`under § 103(a) over U.S. Patent No. 8,479,238 (“Chen,” EX1007) in view of U.S.
`
`Publication 2007/0048712 (“Plastina 2007,” EX1008).
`
`
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`9
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`In my opinion, claims 4 and 7 would have been obvious under
`
`
`26.
`
`§ 103(a) over either the Lambourne/Elabbady device or the Chen/Plastina 2007
`
`device in further view of U.S. Publication 2003/0073412 (“Meade,” EX1009).
`
`27.
`
`
`
`In my opinion, claims 5, 6, and 8 would have been obvious under §
`
`103(a) over either the Lambourne/Elabbady/Meade device or the Chen/Plastina
`
`2007/Meade device in further view and U.S. Publication 2003/0182315 (“Plastina
`
`2003,” EX1010).
`
`28.
`
`
`
`In my opinion, claim 9 would have been obvious under § 103(a) over
`
`either the Lambourne/Elabbady device or the Chen/Plastina 2007 device in further
`
`view of U.S. Publication 2001/0018858 (“Dwek,” EX1011).
`
`
`29.
`
`In my opinion, claims 10 and 18 would have been obvious under §
`
`103(a) over either the Lambourne/Elabbady device or the Chen/Plastina 2007
`
`device in further view of International Publication WO 2004/08693 (“Melpignano,”
`
`EX1012).
`
`30.
`
`
`
`In my opinion, claims 10 and 18 would have been obvious under §
`
`103(a) over either the Lambourne/Elabbady device or the Chen/Plastina 2007
`
`device in further view of International Publication No. WO 2002/056536 to
`
`Weinans (“Weinans,” EX1013).
`
`
`
`10
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`In my opinion, claims 10 and 18 would have been obvious under §
`
`
`31.
`
`103(a) over either the Lambourne/Elabbady device or the Chen/Plastina 2007
`
`device in further view of U.S. Publication 2003/0033413 (“Willson,” EX1014).
`
`A. Claims 1-3, 12, and 16-17 would have been obvious over
`Lambourne in view of Elabbady
`
`32.
`
` For the reasons described below, it is my opinion that Lambourne in
`
`view of Elabbady would have rendered claims 1-3, 12, and 16-17 obvious to one
`
`of ordinary skill in the art prior to the earliest filing date of the ’904 patent.
`
` Like the ’904 patent, Lambourne describes techniques for remotely
`33.
`
`controlling media players. Zone players 102, 104, and 106 (or 200) may be audio
`
`devices. EX1001 at 4:63-67. Each player includes a network interface 202, an
`
`audio processing circuit 210 and an audio amplifier 214. See id. at 6:18-27, Fig. 2A.
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`Fig.
`
`
`
` Controller 1401 is shown in 34.
`
`2B (right). The controller “control[s]
`
`operations of one or more zone players
`
`(e.g., the zone player 200) through a RF
`
`interface corresponding
`
`to
`
`the RF
`
`interface 216 of FIG. 2A.” Id. at 7:27-34.
`
` The wireless communication between the controller and the zone
`35.
`
`players may be “based on an industry standard (e.g., infrared, radio, wireless
`
`standard IEEE 802.11a, 802.11b or 802.11g).” Id.
`
`
`1 Lambourne discloses several controllers, which are assigned different reference
`
`numerals in different figures. These include controllers 140, 142, 240, and 110.
`
`EX1005 at 7:23-25 (“[C]ontroller 240, which may correspond to the controlling
`
`device 140 or 142 of FIG. 1.”); id. at 8:19-21 (“[C]ontroller 270 . . . may
`
`correspond to the controller 240 of FIG. 2B.”); id. at 14:6-10 (“The computing
`
`device may correspond to the device 110 of FIG. 1 and be configured to control
`
`operations of the zone players installed in a complex.”). The controllers are
`
`interchangeable, and for convenience, all controllers are referred to as “controller
`
`140.”
`
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` These communications necessarily occur when the controller device is
`36.
`
`positioned to allow communication between the controller and the zone players,
`
`because these communication methods are limited in range.
`
` The controller includes a user interface, including screen 242 and
`37.
`
`buttons 244, 246, and 248. Id. at 7:43-50. For example, “‘music’ button 248
`
`activates a music menu, which allows the selection of an audio source (e.g., a
`
`song) to be added to a zone player’s music queue for playback.” Id. at 7:59-61; see
`
`also id. at 2:41-46. Lambourne does not explicitly discose how the data used to
`
`create the music menu is stored or displayed.
`
` Elabbady describes a “media catalog” describing multimedia that is
`38.
`
`content available on multiple devices. EX1006 at 2:9-12, 6:8-11, 11:11-15.
`
` Media catalog service 203 collects information and creates the media
`39.
`
`catalog 205. See id. at Fig. 3, 6:8-15. Media catalog service 203 receives metadata
`
`from the media libraries of multiple devices within a media sharing environment
`
`200. Id. at 7:16-24. Media catalog service 203 uses the metadata to create a media
`
`catalog consisting of “aggregated information,” id. at 6:19-21, “about media
`
`content that is available for sharing between at least some of the connected
`
`devices,” id. at 6:8-11.
`
` Media catalog service 203 converts this information into a markup
`40.
`
`language file, id. at 6:37-52, and “can make a cached copy of the metadata from
`
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`multiple media libraries,” id. 12:13-16. The catalog may also be output over a
`
`network to another device. Id. at 2:6:12, 11:11-20.
`
` The compiled catalog “provides information about selected media
`41.
`
`content identified in the media catalog to a user for possible selection.” Id. at
`
`11:11-20, 8:61-62. The catalog may be “search[ed] the media catalog, brows[ed]
`
`the search results, [or used to] select[] a media item for playback, etc.” Id. at 12:18-
`
`21.
`
`1.
`
`It would have been obvious to one of ordinary skill to
`combine the teachings of Lambourne and Elabbady
`In my opinion, including the media catalog service of Elabbady in the
`
`
`42.
`
`controller of Lambourne would have been obvious to one of ordinary skill in the
`
`art.
`
` Given Lambourne’s disclosure of a “music menu,” one of ordinary
`43.
`
`skill would have been motivated to use the media cataloging service 203 and media
`
`catalog 205 of Elabbady to easily implement this feature. EX1005 at 7:59-61;
`
`Lambourne’s controller 140 would then store the information describing the
`
`content residing at the zone player in a collection of logically related data. One of
`
`ordinary skill would have been motivated to make this combination, because
`
`Elabbady provides a way of implementing the music menu advertised by
`
`Lambourne.
`
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` One of ordinary skill could have easily made this combination
`44.
`
`because controller 140 includes a network interface, memory, and “a processor
`
`coupled to the memory.” EX1005 at 3:6-21; 8:19-28. Designing the controller to
`
`pull data into a database would have been a simple programing task well within the
`
`ability of one of ordinary skill.
`
`45.
`
` Given the disclosure of Lambourne, one of ordinary skill would be
`
`motivated to include this feature, because caching metadata for the music menu
`
`would reduce network communication and therefore improve performance and
`
`enhance the ability to remotely control multimedia, as both Elabbady and
`
`Lambourne advocate. EX1006 at 1:44-52; EX1005 at 2:5-13.
`
`
`
` As further explained below, 2 the combination of Lambourne and 46.
`
`Elabbady teaches all elements of claims 1-3, 12, and 16-17 of the ’904 patent, and
`
`renders claims 1-3, 12, and 16-17 obvious to one of skill in the art.
`
`Claim 1:
`[1.0] A mobile
`device
`for
`controlling digital
`content played by
`a
`plurality
`of
`media
`devices
`comprising:
`
`2 All emphasis in the claim charts in this petition is added unless otherwise noted.
`
`Exemplary Disclosure of Prior Art
`Lambourne discloses a controller (the claimed “mobile
`device”) for controlling “a number of multimedia players” or
`“zone players” (the claimed “plurality of media devices”).
`EX1005 at Abstract. For example, Lambourne states:
`[O]ne or more controlling devices . . . are used to
`control zone players 102, 104 and 106 as shown
`in FIG. 1. [They] are preferably portable and
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`[1.1] a) a wireless
`communication
`interface
`communicating
`with the plurality
`of media devices;
`
`for
`
`[1.2] b) a media
`database; and
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`U.S. Patent 7,787,904
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`remotely control the zone players via wireless
`means (e.g., infrared, radio, wireless standard
`IEEE 802.11b or 802.11g). . . . [C]ontrolling
`device 140 . . . is configured to manage audio
`sources and audio characteristics of all the zone
`players regardless [of] where the controlling
`device . . . is located in a house . . . .
`Id. at 6:7-17.
`Lambourne discloses that the controller includes a wireless
`“network interface” (the claimed “wireless communication
`interface”) for communicating with the plurality of media
`devices. Id. at 3:6-12. For example, Lambourne discloses:
`The controlling devices 140 and 142 are
`preferably portable and remotely control the zone
`players via wireless means (e.g., infrared, radio,
`wireless standard IEEE 802.11b or 802.11g).
`see also
`id.
`Id.
`(“The
`at 6:10-13;
`at 8:38-41
`controller [140] includes . . . a RF interface 280 that facilitates
`wireless communication with a zone player . . . .”).
`Lambourne discloses that the controller displays a list of
`available media content. See id. at Fig. 3C (portion, below).
`Elabbady discloses media catalog
`service 203, which generates
`metadata and creates a media
`catalog
`that
`is a collection of
`logically related data describing
`media stored together. For example,
`Elabbady discloses:
`is configured
`to provide
`[M]edia LS 207
`metadata to media [catalog service] CS 203 about
`media content that at least its host device has
`available for sharing . . . [and] generates at least
`one media library that can be provided to media
`CS 203 over network 204 and subsequently
`aggregated into, or otherwise used to create, the
`resulting media catalog.
`EX1006 at 7:18-24; see also id. at 12:13-15 (“Media catalog
`
`
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`[1.3] c) a control
`system adapted to,
`for each of
`the
`plurality of media
`devices:
`
`i)
`[1.4]
`communicate with
`the media device
`when the mobile
`device is within a
`wireless personal
`area
`network
`(WPAN)
`associated with the
`media device
`to
`obtain information
`describing content
`residing
`at
`the
`media device; and
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`IPR2015-01991
`U.S. Patent 7,787,904
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`service 203 can make a cached copy of the metadata from
`multiple media libraries.”).
`Lambourne
`discloses that the
`controller includes
`memory
`282,
`loaded with “one
`or more application
`modules 284 that
`can be executed by
`the microcontroller
`276,” as well as a
`wireless
`interface
`280, which perform the functions of the claimed control
`system. See EX1005 at 8:19-28, Fig. 2C.
`Lambourne discloses that the controller and the zone players
`(the claimed media devices) communicate via a wireless
`interface.3 For example, Lambourne discloses:
`The controller 270 includes a network interface
`280 . . . that facilitates wireless communication
`with a zone player via a corresponding RF
`interface
`thereof.
`In one embodiment,
`the
`commands . . . are sent via the RF interfaces.
`Id. at 8:38-41; see also id. at 6:6-13 (“The controlling devices
`140 and 142 are preferably portable and remotely control the
`zone players via wireless means (e.g., infrared, radio, wireless
`standard IEEE 802.11b or 802.11g).”), 7:28-32, 8:38-41.
`Lambourne discloses that the controller obtains information
`regarding the content residing at the media device. For
`example, Lambourne discloses
`the following steps: 1) choosing an audio source
`
`
`3 This accords with the ’904 patent’s description of the wireless communication
`
`interface. EX1001 at 4:15-20 (noting “Bluetooth . . . , (WiFi). . . , IEEE 802.11”).
`
`
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`from one of the zone players in the group,
`2) checking
`if
`the chosen audio source
`is
`available locally . . . .and 4) playing the audio
`source on each of the zone players.
`Id. at 10:1-9; see also id. at 7:34-38, 10:47-50, 14:17-19.
`Lambourne
`Similarly,
`that
`discloses
`“‘music’
`button 248 activates a music
`menu, which allows
`the
`selection of an audio source
`(e.g., a song) to be added to
`a zone player’s music queue
`for playback.” Id. at 7:59-
`61, 10:47-50, 14:17-19, Fig.
`3C. And Lambourne also
`discloses:
`When a particular audio source is being played in
`the zone player 200, a picture, if there is any,
`associated with
`the audio source may be
`transmitted from the zone player 200 to the
`controller 240 for display.
`Id. at 7:34-38. Lambourne also shows controller 140
`displaying the information obtained, which describes content
`residing at the zone players. See id. at Figs. 3C, 7A.
`Further, Lambourne discloses that the controller obtains
`information from the zone players when the mobile device is
`positioned to allow communication between the mobile
`device and the media device via the wireless communication
`interface of the mobile device. Id. at 8:38-41 (teaching RF
`interfaces), 6:7-17 (teaching the use of infrared, radio).4
`
`4 In my opinion, these communications inevitably occur when the mobile device is
`
`positioned to allow communication between the mobile device and the media
`
`device, because these communication methods are limited in range.
`
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`As discussed with reference to element 1.2, Elabbady
`discloses:
`to provide
`is configured
`[M]edia LS 207
`metadata to media [catalog service] CS 203 about
`media content that at least its host device has
`available for sharing.
`. . . [M]edia LS 207
`generates at least one media library that can be
`provided to media CS 203 . . . and subsequently
`aggregated into, or otherwise used to create, the
`resulting media catalog.
`EX1006 at 7:18-24; see also id. at 12:13-15 (“Media catalog
`service 203 can make a cached copy of the metadata from
`multiple media libraries.”).
`Lambourne discloses that content is selected from the content
`at the media device based on the information in the media
`database. See EX1005 at Fig. 3C, 7:59-61 (“The “music”
`button 248 activates a music menu, which allows the selection
`of an audio source (e.g., a song) to be added to a zone player’s
`music queue for playback.”); see also id.