Paper No. __________
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________________
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`BLITZSAFE TEXAS, LLC
`Patent Owner
`
`_____________________________
`
`IPR2016-00118
`Patent No. 8,155,342
`Filing Date: June 27, 2006
`Issue Date: April 10, 2012
`Title: Multimedia Device Integration System
`_____________________________
`
`
`
`DECLARATION OF PRASANT MOHAPATRA, PH.D.
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`
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`
`
`Petitioner Unified- Exhibit 1002 - Page 1
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`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________________
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`BLITZSAFE TEXAS, LLC
`Patent Owner
`
`_____________________________
`
`IPR2016-00118
`Patent No. 8,155,342
`Filing Date: June 27, 2006
`Issue Date: April 10, 2012
`Title: Multimedia Device Integration System
`_____________________________
`
`
`
`DECLARATION OF PRASANT MOHAPATRA, PH.D.
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`
`
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`
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`Petitioner Unified- Exhibit 1002 - Page 1
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`
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`Table of Contents
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`I.
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`II.
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`QUALIFICATIONS ....................................................................................... 1
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`LEVEL OF ORDINARY SKILL AND RELEVANT TIME ........................ 4
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`A.
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`PROPOSED CLAIM CONSTRUCTION ............................................ 5
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`1.
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`2.
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`“integration subsystem” ............................................................. 5
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`“multimedia device integration system” .................................... 6
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`B.
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`GROUND 1: INDEPENDENT CLAIMS 1 AND 49 AND
`DEPENDENT CLAIMS 2-4 ARE ANTICIPATED BY
`OHMURA ............................................................................................. 6
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`C. GROUND 2: INDEPENDENT CLAIMS 1 AND 49 AND
`DEPENDENT CLAIMS 2-4 ARE OBVIOUS OVER OWENS
`IN VIEW OF AHN ............................................................................. 11
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`D. GROUND 3: INDEPENDENT CLAIMS 25 AND 73 ARE
`OBVIOUS OVER OHMURA IN VIEW OF AHN ............................ 17
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`E.
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`F.
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`GROUND 4: INDEPENDENT CLAIM 97 AND
`DEPENDENT CLAIM 5 ARE OBVIOUS OVER OHMURA
`IN VIEW OF FLICK .......................................................................... 18
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`GROUND 5: INDEPENDENT CLAIM 97 AND
`DEPENDENT CLAIM 5 ARE OBVIOUS OVER OWENS
`AND AHN IN VIEW OF FLICK ........................................................ 20
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`G. GROUND 6: INDEPENDENT CLAIM 120 AND
`DEPENDENT CLAIM 6 ARE OBVIOUS OVER OHMURA
`IN VIEW OF TRANCHINA ............................................................... 20
`
`H. GROUND 7: INDEPENDENT CLAIM 120 AND
`DEPENDENT CLAIM 6 ARE OBVIOUS OVER OWENS
`AND AHN IN VIEW OF TRANCHINA ............................................. 22
`
`I.
`
`GROUND 8: DEPENDENT CLAIMS 7-10 ARE OBVIOUS
`OVER OHMURA IN VIEW OF COON ............................................ 22
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`1
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`Petitioner Unified- Exhibit 1002 - Page 2
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`
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`J.
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`GROUND 9: DEPENDENT CLAIMS 7-10 ARE OBVIOUS
`OVER OWENS AND AHN IN VIEW OF COON ............................. 24
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`K. GROUND 10: DEPENDENT CLAIM 11 IS OBVIOUS OVER
`OHMURA IN VIEW OF LUTTER ..................................................... 24
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`L.
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`GROUND 11: DEPENDENT CLAIM 11 IS OBVIOUS OVER
`OWENS AND AHN IN VIEW OF LUTTER...................................... 25
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`M. GROUND 12: DEPENDENT CLAIMS 12-18, 20-21 AND 23-
`24 ARE OBVIOUS OVER OHMURA IN VIEW OF
`MCCONNELL .................................................................................... 26
`
`N. GROUND 13: DEPENDENT CLAIMS 12-18, 20-21 AND 23-
`24 ARE OBVIOUS OVER OWENS AND AHN IN VIEW OF
`MCCONNELL .................................................................................... 27
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`O. GROUND 14: DEPENDENT CLAIM 19 IS OBVIOUS OVER
`OHMURA IN VIEW OF BECKERT .................................................. 29
`
`P.
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`GROUND 15: DEPENDENT CLAIM 19 IS OBVIOUS OVER
`OWENS AND AHN ............................................................................ 29
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`Q. GROUND 16: DEPENDENT CLAIM 22 IS OBVIOUS OVER
`OHMURA IN VIEW OF MCCONNELL AND FURTHER IN
`VIEW OF TRANCHINA ..................................................................... 30
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`R. GROUND 17: DEPENDENT CLAIM 22 IS OBVIOUS OVER
`OWENS AND AHN IN VIEW OF MCCONNELL AND
`FURTHER IN VIEW OF TRANCHINA ............................................ 30
`
`S.
`
`T.
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`GROUND 18: INDEPENDENT CLAIM 121 IS OBVIOUS
`OVER OHMURA IN VIEW OF EICHE ........................................... 30
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`GROUND 19: INDEPENDENT CLAIM 121 IS OBVIOUS
`OVER OWENS AND AHN IN VIEW OF EICHE ............................ 32
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`III. CONCLUDING STATEMENT ................................................................... 72
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`IV. APPENDIX – TABLE OF INFORMATION RELIED UPON ................... 73
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`2
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`Petitioner Unified- Exhibit 1002 - Page 3
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`I, Prasant Mohapatra, declare as follows:
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`I.
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`QUALIFICATIONS
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`1. My name is Prasant Mohapatra. My findings as set forth herein, are
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`based on my education and background in the fields discussed below.
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`2.
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`I have been retained on behalf of Kilpatrick Townsend & Stockton
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`LLP to provide this Declaration concerning technical subject matter relevant to the
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`inter partes review petition (“Petition”) concerning Blitzsafe U.S. Pat. 8,155,342. I
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`reserve the right to supplement this Declaration in response to additional evidence
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`that may come to light.
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`3.
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`I am over 18 years of age. I have personal knowledge of the facts
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`stated in this Declaration and could testify competently to them if asked to do so.
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`4. As indicated in my curriculum vitae, I currently serve as a Professor
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`of the Computer Science Department at the University of California (“UC Davis”)
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`in Davis, California. I previously chaired the Computer Science Department at UC
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`Davis from 2007 to 2013, and then served as the Interim Vice-Provost and the
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`Campus CIO during 2013-14. I have been teaching Computer Science at UC Davis
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`since 2001. Currently, I also service as an Associate Chancellor at UC Davis. Prior
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`to joining UC Davis, I was an Associate Professor in the Computer Science &
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`Engineering Department at Michigan State University from 1999 to 2001. Prior to
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`my position at Michigan State, I was an Associate Professor in the Electrical and
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`Computer Engineering Department at Iowa State University from 1993-1998. I
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`have taught undergraduate and graduate courses in the computer science and
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`engineering disciplines for more than twenty five years.
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`1
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`Petitioner Unified- Exhibit 1002 - Page 4
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`5.
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`I have held Visiting Scientist positions at Intel Corporation, Panasonic
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`Technologies, Institute of Infocomm Research (I2R), Singapore, and National ICT
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`Australia (NICTA). I have also been a Visiting Professor at the University of
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`Padova, Italy and Yonsei University, and KAIST, South Korea.
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`6.
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`I received my Ph.D. in Computer Engineering from Penn State
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`University in 1993. I also received a M.S. from the University of Rhode Island in
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`1989 and a B.S. from the National Institute of Technology located in Rourkela,
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`India in 1987.
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`7.
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`I am a fellow of the American Association for the Advancement of
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`Science (AAAS) and the Institution of Electrical and Electronics Engineers
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`(IEEE).
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`8. As further detailed in my CV, I have been awarded more than
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`$40,000,000 in grant and contract awards, many of which I have been named as the
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`Principal Investigator or Co-Principal Investigator.
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`9.
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`I have authored several books and book chapters, including books and
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`book chapters regarding various network technologies and protocols.
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`10.
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`I have authored or co-authored more than 300 journal and conference
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`papers regarding topics related to the computer science and electrical engineering
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`disciplines.
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`11.
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`I have received numerous awards for my work, including the HP Labs
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`Innovation Award in 2011, 2012, and 2013; Best Paper Awards from IFIP
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`Networking (2014), ACM BodyNets (2013), IEE ICCCN (2013), the International
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`Symposium on Wireless Personal Multimedia Communications (2011), and IEEE
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`2
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`Petitioner Unified- Exhibit 1002 - Page 5
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`Wireless Mobile Computing (WiMob) Conference (2009); and the Outstanding
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`Engineering Faculty Award, College of Engineering, UC Davis, 2011.
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`12.
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`I have also given numerous keynote address, distinguished lectures,
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`and invited talks at conferences and Universities in the networking technology area
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`including: IEEE International Conference on Intelligent Sensors, Sensor Networks
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`and Information Processing, Singapore, April, 2014; International Symposium on
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`IT Convergence Engineering, Pohang, Korea, June 2013; Kumoh National Institute
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`of Technology, Korea, June 2013; Hotmesh Workshop, IEEE WOWMOM, San
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`Francisco, CA, June 2012; International Conference on Mobile Wireless Networks,
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`Beijing, Dec. 2011; Distinguished Lecture Series, University of Nebraska-Lincoln,
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`Dec. 2011; International Symposium on IT Convergence Engineering, Pohang,
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`Korea, July 2011; IEEE International Conference on Advanced Information
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`Networking and Applications (AINA), Singapore, March 2011; National
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`Conference on Computer Network Education, Nanjing, China, Dec. 2010; IEEE
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`HotMesh Workshop, Kos Island, Greece, June 2009; CARMEN Workshop,
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`ICTMobile Summit, Santander, Spain, June 2009; Trusted Internet Workshop,
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`Hyderabad, India, December 2003; and the ICPP Workshop on Distributed
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`Multimedia Systems, Toronto, August, 2000.
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`II. SCOPE OF WORK
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`13.
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`I have been retained by Kilpatrick Townsend & Stockton LLP,
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`counsel for Petitioner as a technical expert in this matter. I am compensated for
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`my services. No part of my compensation is dependent on my opinions or on the
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`
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`3
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`Petitioner Unified- Exhibit 1002 - Page 6
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`
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`outcome of this proceeding. I have no financial interest in any of the parties to this
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`proceeding.
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`14.
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`I have been asked by counsel for Petitioner to offer an expert opinion
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`on the validity of all claims of U.S. Patent 8,155,342 (the “’342 Patent” or “the
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`Patent), attached as Exhibit 1001. In connection with my analysis, I have reviewed
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`the ’342 Patent and its prosecution history, as well as the patent and documents
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`cited herein. For convenience, the materials I considered in arriving at my
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`opinions are listed in Appendix A. Abbreviations used herein are indicated in the
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`Appendix for the prior art references relied upon. I have also grouped the claim
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`charts at the end of this declaration.
`II. LEVEL OF ORDINARY SKILL AND RELEVANT TIME
`15.
`I have been advised that the ’342 Patent claims priority to a
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`continuation-in-part application filed March 3, 2005, which is a continuation-in-
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`part of application filed December 10, 2003, which is a continuation-in-part of
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`application filed on December 11, 2002, now Patent No. 7,489,786. I have not
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`been asked to express any opinion whether the claims are supported by the earlier
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`applications. Instead, I have been asked to assume at present that the claims are
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`entitled to an effective filing date of December 10, 2003 or December 11, 2002.
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`16.
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`I have been advised that “a person of ordinary skill in the relevant
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`field” is a hypothetical person to whom one could assign a routine task with
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`reasonable confidence that the task would be successfully carried out. I have been
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`advised that the relevant time frame for assessing validity of the ’342 Patent is
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`prior to December 10, 2003 or December 11, 2002. I am further advised that one
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`4
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`Petitioner Unified- Exhibit 1002 - Page 7
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`of ordinary skill in the art is presumed to be familiar with all relevant prior art in
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`the field of the invention.
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`17. By virtue of my education, experience, and training in academia and
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`industry, I am familiar with the level of skill in the art of the ’342 Patent in the
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`relevant timeframe. The specification calls for familiarity with multimedia
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`communications in a vehicle. These topics are included in a typical undergraduate
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`computer science degree curriculum. Therefore, in my opinion, a person of
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`ordinary skill in the art would have had an undergraduate degree in computer
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`science or computer engineering, or equivalent work experience, including
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`familiarity with wireless transmission of audio and video.
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`A.
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`PROPOSED CLAIM CONSTRUCTION
`
`Claim Terms.
`1.
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`“integration subsystem”
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`18. The ’342 Patent simply shows a box labelled “Integration subsystem”
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`in the portable device or the car stereo in Figs. 18-23. “Integration” is defined as it
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`is used in the claims as obtaining information about the audio file, transmitting a
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`control command to select a file, and instructing the audio device to transmit the
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`file (8:64-9:19). These functions are described being handled by a microcontroller
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`in the car stereo (13:9-19). Figs. 18, 20 & 22 show the integration subsystem as a
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`box in the portable device. Thus, this would be understood by one of skill in the
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`art to be a processor in the car stereo or the portable device along with software
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`5
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`Petitioner Unified- Exhibit 1002 - Page 8
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`and memory. Accordingly, the broadest reasonable interpretation of a “integration
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`subsystem” is a processor and associated software and memory.
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`2.
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`“multimedia device integration system”
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`19. The ’342 Patent describes a multimedia system as “The present
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`invention further provides a multimedia device integration system that allows for
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`the wireless integration of a portable audio and/or video device with a car audio
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`and/or video system.” (5:46-49). It also describes a stereo display for information
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`about the audio or video files. Since the portable device could be audio or video,
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`audio alone is clearly intended to be covered, with the “multi” in multimedia either
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`indicating it is one of many media, or it include the further described and claimed
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`display of information about the audio (or video) files. Accordingly the broadest
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`reasonable interpretation of a “multimedia device integration system” is a system
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`that provide audio or video and a display.
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`B. GROUND 1: INDEPENDENT CLAIMS 1 AND 49 AND
`DEPENDENT CLAIMS 2-4 ARE ANTICIPATED BY OHMURA
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`20. Fig. 2 of Ohmura shows a car audio apparatus 100 with a display 24
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`that communicates wirelessly with various portable devices.
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`6
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`Petitioner Unified- Exhibit 1002 - Page 9
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`21. Fig. 7 of Ohmura shows the external play list D12 displayed on the car audio
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`display:
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`7
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`Petitioner Unified- Exhibit 1002 - Page 10
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`
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`Claim 1.
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`22. Claim 1 requires a portable device be wirelessly interfaced with a car
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`stereo, and that the user select audio files on the portable device using the car
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`stereo controls, and that information about the audio file be displayed on the car
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`stereo display. As supported in the claim chart below, Ohmura shows portable
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`audio apparatuses 200a and 200b which wirelessly communicate (in-car radio
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`communication) with the car stereo. The user selects music on the portable
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`apparatus using the car stereo controls (e.g., 108 in Fig. 2). The play list from the
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`portable device is displayed on the car stereo display (D12, Fig. 7).
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`23. The elements of the claim have been labelled with letters (e.g., [A]) in
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`the chart below for ease of understanding. The preamble recites a “multimedia
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`8
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`Petitioner Unified- Exhibit 1002 - Page 11
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`device integration system” which comprises the claimed element [A] “integration
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`subsystem” and [B] first and second wireless interfaces. Such an integration
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`system is shown in Ohmura, which has both components. The claimed [A]
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`“integration subsystem” is shown by the operating system 106 and CPU 101 of the
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`car stereo in Fig. 2, or the operating system 207 and CPU 203 of the portable
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`apparatus, and inherent associated memory. The wireless interfaces are shown by
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`the “transmission/reception modules” 110 (car stereo) and 205 (portable
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`apparatus).
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`24. Although other claims specify the location of the “integration
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`subsystem,” claim 1 does not, and is met by either location. The functions in
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`element [C] of controlling the portable device with the car stereo controls is shown
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`in paragraph 0111 quoted below. Paragraph 0204, quoted below, shows both the
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`display of the music list, seen in Fig. 7, copied above, and the selection by the user.
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`The performance of these functions by the integration subsystem, CPU 101, is
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`shown in the flow chart of Fig. 4 and the quoted language of paragraph 0099
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`below.
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`25. Claim 49. Claim 49 is similar to claim 1, but leaves out that the
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`“integration subsystem in communication with the portable device,” and instead
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`recites the second wireless interface is with the portable device, instead of with the
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`car audio/video system. This thus covers the integration subsystem being
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`9
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`Petitioner Unified- Exhibit 1002 - Page 12
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`
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`electrically connected to the car stereo, but wirelessly connecting with the portable
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`device. This is shown in Ohmura, as discussed above with respect to claim 1. The
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`differences between claim 49 and claim 1 are shown in the chart at the end of this
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`Declaration.
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`26. Claims 2-4. Claim 2 says “wherein said integration subsystem is
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`positioned within the portable device.” This is shown in Ohmura, where an
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`operating system
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`interface 207 and CPU 203 comprise
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`the “integration
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`subsystem.” The use of the portable device CPU instead of the car stereo CPU was
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`described in Ohmura, and varying the location would be obvious to one of skill in
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`the art:
`
`“[0232] The method of controlling the audio apparatus in
`the above embodiments and their modifications is
`implemented by the CPUs inside these apparatuses
`executing the control program stored in the concentrated
`control unit 20 that performs system control of the audio
`apparatus 100 and portable audio apparatus 200, etc.
`Furthermore, providing such a control program stored in
`a program storage medium separately will also allow the
`control unit of another audio apparatus, etc. to execute
`the above-described control processing.”
`
`27. Claim 3 recites “wherein said first wireless interface is positioned
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`within the portable device.” This is shown in Ohmura in the chart above with
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`10
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`Petitioner Unified- Exhibit 1002 - Page 13
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`“apparatus main unit 201a [portable audio player] is provided with …a
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`transmission/reception module 205 [first wireless interface] ….” See Fig. 2.
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`28. Claim 4 recites “wherein said second wireless interface is positioned
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`within the car audio/video system.” This is shown in Ohmura in the chart above
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`with “a transmission/reception module 110” [second wireless interface] in “car-
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`mounted audio apparatus” 100 (See Fig. 2).
`
`C. GROUND 2: INDEPENDENT CLAIMS 1 AND 49 AND
`DEPENDENT CLAIMS 2-4 ARE OBVIOUS OVER OWENS IN
`VIEW OF AHN
`
`29. Owens was cited against the great-grandparent of the ’342 Patent, a
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`wired system. Owens shows a car stereo “head unit 10” which connects to various
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`add-on modules, including a “CDC (compact disc changer) 15” and an A/V
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`interface module connecting to a variety of other devices, as shown in Fig. 1
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`below.
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`30. Owens Fig. 1:
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`11
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`Petitioner Unified- Exhibit 1002 - Page 14
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`31. Owens shows a car stereo LCD display 21 and various controls in Fig.
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`10. The mode button can select various portable AV modules or the CDC (select
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`button 26). The display indicates the portable device selected (22, 23) and the
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`CDC tracks are displayed just like the tracks of the single CD player in the stereo.
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`32. Owens Fig. 10:
`
`12
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`Petitioner Unified- Exhibit 1002 - Page 15
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`33. Ahn is also directed to providing music from a portable device to a car
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`stereo, but using a wireless Bluetooth connection. In particular, as shown in Fig. 1,
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`Ahn streams music over the internet wirelessly to a mobile device 30, which then
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`provides the music via a wireless Bluetooth connection to a car stereo (car kit 40).
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`34. Ahn Fig 1:
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`Ahn shows in Fig. 2 a Bluetooth transceiver 38 in mobile device 30, and a
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`Bluetooth transceiver 400 in the car stereo 40.
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`
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`13
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`Petitioner Unified- Exhibit 1002 - Page 16
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`35. Ahn Fig. 2:
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`
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`36. Claim 1 requires a portable device be wirelessly interfaced with a car
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`stereo, and that the user select audio files on the portable device using the car
`
`stereo controls, and that information about the audio file be displayed on the car
`
`stereo display. As supported in the claim chart below, Owens shows portable
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`audio apparatuses, such as CDC 15 and modules connected by a bus to A/V
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`Interface module 30, which communicate with the car stereo. The user selects
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`music on the portable apparatus using the car stereo controls (Fig. 10). The data
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`from the portable device is displayed on the car stereo display (Fig. 10.). It would
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`be obvious to substitute the Bluetooth interface of Ahn for the wired bus of Owens.
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`37. The preamble’s “multimedia device integration system” is shown by
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`its claimed elements, [A] “integration subsystem” and [B] first and second wireless
`
`interfaces, with [A] performing the control and display functions of element [C].
`
`Such an integration system is shown in Owens and Ahn, which have both
`
`14
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`Petitioner Unified- Exhibit 1002 - Page 17
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`
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`components. The claimed [A] “integration subsystem” is shown by the “master
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`microprocessor” of the car stereo in Fig. 9 of Owens, and inherent associated
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`memory. The wireless interfaces are shown by the “transmission/reception
`
`modules” 110 (car stereo) and 205 (portable apparatus) of Ahn.
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`38. The functions in element [C] of controlling the portable device with
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`the car stereo controls is shown in the quoted paragraphs quoted below, with the
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`operations being performed by the master microprocessor as described in
`
`paragraph 0034 quoted in element A. As described in paragraph 0037, the mode
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`button can select the car stereos built in CD, or the external, portable multi-CD
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`CDC. The selection of the track for the CD applies to the external CDC, as
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`described in paragraph 0039 as operating “similarly.” Finally, the described
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`display of status information about the track would apply to both the internal CD
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`player and the external CDC.
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`39.
`
`It would be obvious to combine Owens and Ahn. Both are directed to
`
`connecting mobile devices that provide music to a car stereo. One of skill in the
`
`art would look to Ahn to provide a more flexible wireless connection in place of
`
`the wired connection of Owens. The combination would provide controls from the
`
`car stereo, and display the music selections on the car stereo display, as described
`
`in Owens, with the wireless connection described in Ahn. Paragraphs 0040-0041
`
`of Owens describe wireless remote control of the system already, and this use of
`
`15
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`Petitioner Unified- Exhibit 1002 - Page 18
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`wireless would cause one to look for wireless implementations of the data and
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`other control functions, as shown in Ahn. At the time of the ’342 priority date, it
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`was obvious to support both wired and wireless add-on devices, as described in
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`McConnell (see claim 17 discussion below). Ahn describes the user interface and
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`music selection in the portable device, which is one of the embodiments
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`contemplated in the ’342 Patent. It would be obvious to one of skill in the art that
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`a driver would want to control a portable device from the car stereo, while a
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`passenger in the back seat would want to control from the portable device (see,
`
`e.g., Owens para. 0010), and ideally both would be supported or it would be a
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`matter of design choice which to select.
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`40. Claim 49. Claim 49 is similar to claim 1, but leaves out that the
`
`“integration subsystem in communication with the portable device,” and instead
`
`recites the second wireless interface is with the portable device, instead of with the
`
`car audio/video system. This thus covers the integration subsystem being
`
`electrically connected to the car stereo, but wirelessly connecting with the portable
`
`device. Owen shows the controller in the car stereo, while Ahn adds the wireless
`
`interface as described above with respect to claim 1.
`
`41.
`
`It would be obvious to one of skill in the art that a driver would want
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`to control a portable device from the car stereo, while a passenger in the back seat
`
`would want to control from the portable device (see, e.g., Owens para. 0010), and
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`16
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`Petitioner Unified- Exhibit 1002 - Page 19
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`
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`ideally both would be supported or it would be a matter of design choice which to
`
`select to have the integration subsystem. The differences between claim 49 and
`
`claim 1 are shown in the chart at the end of the Mohapatra Declaration.
`
`42. Claims 2-4. Claim 2 says “wherein said integration subsystem is
`
`positioned within the portable device.” This is shown in Ahn, where a “data
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`processing and control unit 36” comprise the “integration subsystem,” with the
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`functionality being obvious to move from the car stereo of Owen.
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`43. Claim 3 recites “wherein said first wireless interface is positioned
`
`within the portable device.” This is shown in Ahn in the chart above. See Fig. 2.
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`44. Claim 4 recites “wherein said second wireless interface is positioned
`
`within the car audio/video system.” This is shown in Ahn in the chart above. (See
`
`Fig. 2).
`
`D. GROUND 3: INDEPENDENT CLAIMS 25 AND 73 ARE
`OBVIOUS OVER OHMURA IN VIEW OF AHN
`
`45. Music Streaming - Claims 25, 73. These claims are directed to the
`
`standard feature of streaming music in addition to playing stored music.
`
`Independent claim 25 is the same as claim 1, except the audio file is “received by”
`
`instead of “stored on” the portable device (e.g., the portable device is a radio, or
`
`streams received music). The claim charts at the end of this Declaration are
`
`marked to show the differences of claims 25 and 73 from claim 1. Claim 73 is the
`
`17
`
`Petitioner Unified- Exhibit 1002 - Page 20
`
`
`
`same as claim 49, except the audio file is “received by” instead of “stored on” the
`
`portable device. One of skill in the art would recognize that the external player of
`
`Ohmura could be a radio or other device that would stream (receive) music. Thus,
`
`there would be motivation to combine with Ahn, which shows a streaming device,
`
`that then transmits the streamed music to the car stereo via a Bluetooth connection.
`
`As shown in Fig. 1, Ahn streams music over the internet to a mobile device 30,
`
`which then provides the music to a car stereo (car kit 40): “[0036] The music-data-
`
`providing server 10 may transmit streaming music data and non-streaming general
`
`music data according to the user's selection.”
`
`E. GROUND 4: INDEPENDENT CLAIM 97 AND DEPENDENT
`CLAIM 5 ARE OBVIOUS OVER OHMURA IN VIEW OF
`FLICK
`
`46.
`
` Claims 5, 97 - Incompatible control signals. These claims are
`
`directed to the standard feature of converting between different command
`
`protocols, such as was done by Blitzsafe’s own earlier products, as described in the
`
`1998 article Blitzsafe Integration Device:
`
`“Leaping forward to 1998, Blitzsafe has created a new
`line of CD integration device with DMX (or Digital
`Multiplexing) technology. …they actually recognize the
`protocol of the factory radio and communicate with it
`through the use of a microprocessor. In other words, the
`Blitzsafe unit communicates with the factory head unit
`
`18
`
`Petitioner Unified- Exhibit 1002 - Page 21
`
`
`
`and the CD changer and acts as a translator.” Blitzsafe
`Integration Device.
`
`47. Claim 97 is similar to claim 1, but adds that the car stereo control
`
`commands are in a format incompatible with the portable device, and are re-
`
`formatted. The claim charts at the end of this Declaration are marked to show the
`
`differences between claims 97 and claim 1. Claim 5, dependent on claim 1, has the
`
`same limitation. This format translation was well known as demonstrated by
`
`Patent Owner’s own prior product described in Blitzsafe Integration Device, which
`
`describes a protocol translator for an after-market CD for a car. The specific
`
`translation being command conversion is inherently understood from Blitzsafe
`
`Integration Device and is explicitly described in Flick. It would be obvious to
`
`combine Ohmura with Flick because both relate to car stereos and Flick describes
`
`wireless command conversion between different car systems:
`
`“[0062] This provides for a relatively simple and
`straightforward approach to interface or cooperate with a
`vehicle having a data communications bus 26, and
`wherein the controller 25 is advantageously compatible
`with a number of different vehicles.” Flick.
`
`48. Blitzsafe Integration Device makes it clear that conversion, or
`
`translation, between devices of two different manufacturers is desired in the
`
`market.
`
`19
`
`Petitioner Unified- Exhibit 1002 - Page 22
`
`
`
`F. GROUND 5: INDEPENDENT CLAIM 97 AND DEPENDENT
`CLAIM 5 ARE OBVIOUS OVER OWENS AND AHN IN VIEW
`OF FLICK
`49. Claims 5, 97- Incompatible control signals. As described above,
`
`these claims are directed to the standard feature of converting between different
`
`command protocols, such as was done by Blitzsafe’s own earlier products. The
`
`specific translation being command conversion is obvious from one reading
`
`Blitzsafe Integration Device and is explicitly described in Flick. It would be
`
`obvious to combine Owens and Ahn with Flick because all relate to car stereos and
`
`Flick describes wireless command conversion between different car systems, as
`
`well as the reasons described in the preceding ground.
`
`G. GROUND 6: INDEPENDENT CLAIM 120 AND DEPENDENT
`CLAIM 6 ARE OBVIOUS OVER OHMURA IN VIEW OF
`TRANCHINA
`
`50. Claims 6, 120 - Incompatible display data. These claims are
`
`directed to the standard feature of converting between different data protocols,
`
`such as was done by Blitzsafe’s own earlier products, as described in Blitzsafe
`
`Integration Device. Claim 120 is similar to claim 1, but adds that the data from the
`
`portable device is in a format incompatible with the car stereo, and is reformatted.
`
`The differences between claim 120 and claim 1 is highlighted in the chart at the
`
`end of this Declaration. This limitation is also in claim 6, dependent on claim 1.
`
`This is described in the ’342 patent as the data for the display (e.g., song list),
`
`20
`
`Petitioner Unified- Exhibit 1002 - Page 23
`
`
`
`which can be converted between video formats. This is a standard practice which
`
`the ’342 patents admits is provided by commercially available chips:
`
`“The interface 690 could convert between composite and
`red/green/blue (RGB) video signals, and vice versa, using
`commercially-available video format conversion chips
`such
`as
`the TDA8315, TDA4570, TDA3567,
`TDA3566A, and TDA3569A video conversion chips
`manufactured by Philips Corp., and the AL251 and
`AL250 video conversion chips manufactured by
`Averlogic Technologies, Inc., or any other suitable video
`conversion chips.” ’342 Patent 29:51-59.
`
`51. Tranchina describes conversion for video in a “Vehicle display
`
`device” as referenced in the chart below. It would be obvious to combine
`
`Tranchina with Ohmura because Ohmura shows providing display data from a
`
`portable device to a car stereo display which would need to be converted if in a
`
`different format. The desire to incorporate add-on devices of different
`
`manufactures is shown in Blitzsafe Integration Device. The conversion between
`
`video formats was pervasively known, thus making the combination obvious. For
`
`example Perry describes a “A video standards converter (VSC)” for doing such a
`
`conversion:
`
`“A video standards converter (VSC) ….. The first and
`second video standards may be different. The first input
`
`21
`
`Petitioner Unified- Exhibit 1002 - Page 24
`
`
`
`module may be adapted to convert an analog video signal
`to a digital signal.” Perry, Abstract
`
`H. GROUND 7: INDEPENDENT CLAIM 120 AND DEPENDENT
`CLAIM 6 ARE OBVIOUS OVER OWENS AND AHN IN VIEW
`OF TRANCHINA
`52. Claims 6, 120 - Incompatible display data. These claims are
`
`directed to the standard feature of converting between different data protocols,
`
`such as was done by Blitzsafe’s own earlier products, as described in Blitzsafe
`
`Integration Device. As described in the preceding ground, Tranchina describes
`
`conversion for video in a “Vehicle display device” as referenced in the chart
`
`below. It would be obvious to combine Tranchina with Owens and Ahn because
`
`Owens and Ahn show providing display data from a portable device to a car stereo
`
`display which would need to be converted if in a different format. The conversion
`
`between video formats was pervasively known, as shown by Perry discussed in the
`
`preceding ground, and as shown in detail in Tranchina as quoted and described in
`
`the preceding ground. Other reasons for obviousness to combine in the preceding
`
`ground apply equally to combining with Owens and Ahn.
`
`I.
`
`GROUND 8: DEPENDENT CLAIMS 7-10 ARE OBVIOUS
`OVER OHMURA IN VIEW OF COON
`
`53. Voice recognition, speech synthesizer. These claims add standard
`
`voice recogni
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