UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`Hyundai Motor Company Ltd., Hyundai Motor America, Hyundai Motor
`Manufacturing Alabama, LLC, Kia Motors Corporation, Kia Motors America, Inc.,
`and Kia Motors Manufacturing Georgia, Inc.,
`Petitioners
`
`v.
`
`
`
`
`
`Blitzsafe Texas, LLC,
`Patent Owner
`
`U.S. Patent No. 8,155,342
`Filing Date: June 27, 2006
`Issue Date: April 10, 2012
`Title: Multimedia Device Integration System
`
`
`
`Inter Partes Review No.: (Unassigned)
`
`
`
`
`
`
`
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 8,155,342
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. §§ 42.1-100, ET SEQ.
`
`TOYOTA Ex. 1022
`
`

`
`TABLE OF CONTENTS
`
`
`Page
`
`
`I.
`II.
`
`INTRODUCTION .......................................................................................... 1
`COMPLIANCE WITH FORMAL REQUIREMENTS ................................. 1
`A. Mandatory Notices Under 37 C.F.R. §§ 42.8(b)(1)-(4) ....................... 1
`1.
`Real Parties-In-Interest .............................................................. 1
`2.
`Related Matters .......................................................................... 2
`3.
`Lead and Backup Counsel ......................................................... 2
`4.
`Service Information.................................................................... 3
`Proof of Service on the Patent Owner .................................................. 3
`B.
`Power of Attorney ................................................................................ 3
`C.
`Standing ................................................................................................ 4
`D.
`Fees ....................................................................................................... 4
`E.
`III. STATEMENT OF PRECISE RELIEF REQUESTED .................................. 4
`A.
`Prior Art Patents and Publications ....................................................... 4
`B.
`Identification of Challenges and Relief Requested .............................. 5
`IV. FULL STATEMENT OF REASONS FOR REQUESTED RELIEF ............ 6
`A.
`Summary of the ’342 Patent ................................................................. 6
`B.
`The ’342 Patent’s Prosecution History .............................................. 10
`C.
`Person of Ordinary Skill in the Art .................................................... 13
`D.
`Claim Construction ............................................................................ 13
`1.
`“integration subsystem” ........................................................... 15
`2. “car audio/video system” ............................................................... 15
`4. “generated . . . for playing on the car audio/video system” ........... 16
`5. “format incompatible with the portable device” ............................ 16
`6. “device presence signal” ................................................................ 16
`Ground 1: Claims 49-52, 54, 56, 62-64, 71 and 120 are
`Anticipated by Shibasaki Under 35 U.S.C. §§ 102(a) or 102 (e)
`(pre-AIA) ............................................................................................ 17
`
`E.
`
`
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`-i-
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`

`
`TABLE OF CONTENTS
`(continued)
`
`Page
`
`F.
`
`Overview of Shibasaki ............................................................. 17
`1.
`Detailed Analysis ..................................................................... 20
`2.
`Ground 2: Claims 53, 73-78, 95, 97, 99-101, 106 and 109-111
`are Obvious Under 35 U.S.C. § 103(a) (pre-AIA) in Light of
`Shibasaki and the Knowledge of a Person of Ordinary Skill in
`the Art ................................................................................................. 42
`1.
`Detailed Analysis ..................................................................... 42
`G. Ground 3: : Claims 55, 57, 73, 79 and 80 are Obvious Under
`35 U.S.C. § 103(a) (pre-AIA) In Light Of Shibasaki And Tong ....... 54
`1.
`Overview of Tong .................................................................... 54
`2.
`Obvious to Combine Shibasaki and Tong ............................... 55
`3.
`Detailed Analysis ..................................................................... 56
`H. Ground 4: Claims 53 and 77 Are Obvious Under 35 U.S.C. §
`103(a) (pre-AIA) In Light Of Shibasaki And AVRCP 1.0 ................ 63
`1.
`Overview of AVRCP 1.0 ......................................................... 63
`2.
`Obvious to Combine Shibasaki And AVRCP 1.0 ................... 63
`3.
`Detailed Analysis ..................................................................... 64
`Ground 5: Claims 49, 73, 97, and 120 are Obvious Under 35
`U.S.C. § 103(a) (pre-AIA) In Light Of Shibasaki And A2DP
`1.0 ....................................................................................................... 69
`1.
`Overview of A2DP 1.0 ............................................................ 69
`2.
`Obvious to Combine Shibasaki And A2DP 1.0 ....................... 69
`3.
`Detailed Analysis ..................................................................... 70
`CONCLUSION ............................................................................................. 74
`
`I.
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`-ii-
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`V.
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`

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` -
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`EXHIBIT LIST
`
`Exhibit No. Description
`
`1001
`
`1002
`
`1003
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`U.S. Patent No. 8,155,342 (“’342 patent”)
`
`File History of U.S. Patent No. 8,155,342
`
`Declaration of Chris Kyriakakis, Ph.D.
`
`Joint Claim Construction Chart from Blitzsafe Texas, LLC v. Honda
`Motor Co., Ltd. et al., 2:15-cv-01274 (E.D. Tex.)(lead case)
`
`Plaintiff’s Disclosure Of Asserted Claims And Infringement
`Contentions (with Appendices A-D) from Blitzsafe Texas, LLC v.
`Honda Motor Co., Ltd. et al., 2:15-cv-01274 (E.D. Tex.)(lead case)
`
`U.S. Patent No. 7,110,755 (“Shibasaki”)
`
`Optimize Bluetooth Car Kit Design, Implementation, Nov. 17,
`2003 (“Tong”)
`
`Bluetooth Audio/Video Remote Control Profile, v. 1.0, May 22,
`2003 (“AVRCP 1.0”)
`
`Bluetooth Advanced Audio Distribution Profile, v. 1.0, May 22,
`2003 (“A2DP 1.0”)
`
`IPR2016-00118, Paper 19 (“IPR ’118”)
`
`IPR2016-00418, Paper 13 (“IPR ’418”)
`
`
`
`
`
`

`
`
`I.
`
`INTRODUCTION
`
`Pursuant to 35 U.S.C. §§ 311-319 and 37 C.F.R. § 42, Petitioners
`
`Hyundai Motor Company (“HMC”), Hyundai Motor America (“HMA”),
`
`Hyundai Motor Manufacturing Alabama, LLC (“HMMA”), Kia Motors
`
`Corporation (“KMC”), Kia Motors America, Inc. (“KMA”), and Kia Motors
`
`Manufacturing Georgia, Inc. (“KMMG”) (collectively, “Hyundai and Kia”
`
`or “Petitioners”) respectfully request Inter Partes Review of claims 49, 50,
`
`51, 52, 53, 54, 55, 56, 57, 62, 63, 64, 71, 73, 77, 78, 79, 80, 95, 97, 99, 100,
`
`101, 102, 103, 106, 109, 110, 111 and 120 of U.S. Patent 8,155,342 (Ex.
`
`1001, the “’342 patent”), which is currently assigned to Blitzsafe Texas LLC
`
`(“Blitzsafe”) according to the US Patent and Trademark Office assignment
`
`records. There is a reasonable likelihood that Petitioners will prevail with
`
`respect to at least one of the claims challenged herein.
`
`II.
`COMPLIANCE WITH FORMAL REQUIREMENTS
`A. Mandatory Notices Under 37 C.F.R. §§ 42.8(b)(1)-(4)
`1.
`Real Parties-In-Interest
`Hyundai Motor Company (“HMC”), Hyundai Motor America
`
`(“HMA”), Hyundai Motor Manufacturing Alabama, LLC (“HMMA”), Kia
`
`Motors Corporation (“KMC”), Kia Motors America, Inc. (“KMA”), and Kia
`
`Motors Manufacturing Georgia, Inc. (“KMMG”) (collectively, “Hyundai
`
`and Kia” or “Petitioners”) are the real parties-in-interest.
`
`
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`
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`-1-
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`

`
`
`
`2.
`Related Matters
`The ’342 patent is subject to the following pending actions: Blitzsafe
`
`Texas, LLC v. Nissan Motor Co., Ltd. et al., 2-15-cv-01276, July 16, 2015
`
`(E.D. TX); Blitzsafe Texas, LLC v. Toyota Motor Corp. et al., 2:15-cv-
`
`01277, July 16, 2015 (E.D. TX); Blitzsafe Texas, LLC v. Volkswagen Group
`
`of Am., Inc. et al., 2-15-cv-01278, July 16, 2015 (E.D. TX); Blitzsafe Texas,
`
`LLC v. Hyundai Motor Co. et al., 2-15-cv-01275, July 16, 2015 (E.D. TX);
`
`Blitzsafe Texas, LLC v. Honda Motor Co., Ltd. et al., 2-15-cv-01274, July
`
`16, 2015 (E.D. TX); IPR2016-00118, IPR2016-00418 and IPR2016-00419.
`
`U.S. Patent No. 7,489,786 (the “’786 patent”), a parent patent to the
`
`'342 patent, is also at issue in the above-listed district court cases, and was
`
`previously the subject of the following litigations: Marlowe Patent Holdings
`
`LLC v. DICE Electronics, LLC et al., 3:10-cv-01199 (D. NJ); and Marlowe
`
`Patent Holdings LLC v. Ford Motor Company, 3:10-cv-07044 (D. NJ). Both
`
`of these cases settled by June 2015. In addition, claims of the ’786 patent are
`
`presently undergoing inter partes review in Case No. IPR2015-00421.
`
`Lead and Backup Counsel
`
`3.
`Lead counsel is Paul R. Steadman, Reg. No. 43,932, of DLA Piper
`
`LLP (US), 203 North LaSalle Street, Suite 1900, Chicago, Illinois 60601-
`
`1293; paul.steadman@dlapiper.com, 312.368.2135 (phone), 312.251.2850
`
`
`
`
`
`-2-
`
`

`
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`(fax). Backup counsel is Matthew D. Satchwell, Reg. No. 58,870, of DLA
`
`Piper LLP (US), 203 North LaSalle Street, Suite 1900, Chicago, Illinois
`
`60601-1293; matthew.satchwell@dlapiper.com, 312.368.4000 (phone), 312.
`
`236-7516 (fax); Gianni Minutoli, Reg. No. 41,198, of DLA Piper LLP (US),
`
`11911 Freedom Drive, Suite 300; Reston, VA 20190;
`
`gianni.minutoli@dlapiper.com, 703-773-4045 (phone), 703-773-5200 (fax);
`
`and Nicholas Panno, Reg. No. 68,513, of DLA Piper LLP (US), 11911
`
`Freedom Drive, Suite 300; Reston, VA 20190;
`
`nicholas.panno@dlapiper.com, 703-773-4157 (phone), 703-773-5200 (fax).
`
`Service Information
`
`4.
`Service information for lead and back-up counsel is provided in the
`
`designation of lead and back-up counsel above.
`
`B.
`
`Proof of Service on the Patent Owner
`
`As identified in the attached Certificate of Service, a copy of this
`
`Petition in its entirety is being served to the Patent Owner’s attorney of
`
`record at the address listed in the USPTO’s records by overnight courier
`
`pursuant to 37 C.F.R. § 42.6.
`
`C.
`
`Power of Attorney
`
`Powers of attorney are being filed with designation of counsel in
`
`accordance with 37 C.F.R. § 41.10(b).
`
`
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`-3-
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`
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`D.
`
`Standing
`
`In accordance with 37 C.F.R. §42.104(a), Petitioners certify that the
`
`’342 patent is available for inter partes review and that Petitioners are not
`
`barred or estopped from requesting an inter partes review challenging the
`
`patent claims on the grounds identified in this Petition.
`
`E.
`
`Fees
`
`The undersigned authorizes the Director to charge the fee specified by
`
`37 C.F.R. § 42.15(a) and any additional fees that might be due in connection
`
`with this Petition to Deposit Account No. 50-3266.
`
`III.
`A.
`
`STATEMENT OF PRECISE RELIEF REQUESTED
`
`Prior Art Patents and Publications
`
`The claims of the ’342 patent have an effective filing date no earlier
`
`than June 27, 2006, which is the filing date of the application that issued as
`
`the ’342 patent. Petitioners rely upon the following patents and publications,
`
`all of which are prior art to the claims of the ’342 patent:
`
` U.S. Patent No. 7,110,755 to Shibasaki et al. (“Shibasaki”, Ex.
`
`1006) was filed on July 22, 2002, published as U.S. Publication No. 2003-
`
`0032419 on February 13, 2003, and issued on September 19, 2006.
`
`Shibasaki is prior art to the ’342 patent under at least 35 U.S.C. §§ 102(a)
`
`and (e) (pre-AIA).
`
` Optimize Bluetooth Car Kit Design, Implementation (“Tong”,
`
`
`
`
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`-4-
`
`

`
`
`Ex. 1007) was published on Nov. 17, 2003. Tong is prior art to the ’342
`
`patent under at least 35 U.S.C. § 102(b) (pre-AIA).
`
` Bluetooth Audio/Video Remote Control Profile, v. 1.0, May 22,
`
`2003 (“AVRCP 1.0”, Ex. 1008) bears a copyright date of 2003. AVRCP 1.0
`
`is prior art to the ’342 patent under at least 35 U.S.C. § 102(b) (pre-AIA).
`
` Bluetooth Advanced Audio Distribution Profile, v. 1.0, May 22,
`
`2003 (“A2DP 1.0”, Ex. 1009) bears a copyright date of 2003. A2DP 1.0 is
`
`prior art to the ’342 patent under at least 35 U.S.C. § 102(b) (pre-AIA).
`
`B.
`
`Identification of Challenges and Relief Requested
`
`In accordance with 35 U.S.C. § 311, Petitioners request cancelation of
`
`claims 49, 50, 51, 52, 53, 54, 55, 56, 57, 62, 63, 64, 71, 73, 77, 78, 79, 80,
`
`95, 97, 99, 100, 101, 102, 103, 106, 109, 110, 111 and 120 of the ’342 patent
`
`in view of the following grounds:
`
`Ground 1: Claims 49-52, 54, 56, 62-64, 71 and 120 are Anticipated
`
`by Shibasaki Under 35 U.S.C. §§ 102(a) or 102(e) (pre-AIA);
`
`Ground 2: Claims 53, 73-78, 95, 97, 99-101, 106 and 109-111 are
`
`Obvious Under 35 U.S.C. § 103(a) (pre-AIA) in Light of Shibasaki and the
`
`Knowledge of a Person of Ordinary Skill in the Art;
`
`Ground 3: Claims 55, 57, 73, 79 and 80 are Obvious Under 35 U.S.C.
`
`§ 103(a) (pre-AIA) in Light of Shibasaki and Tong;
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`
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`-5-
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`Ground 4: Claims 53 and 77 are Obvious Under 35 U.S.C. § 103(a)
`
`(pre-AIA) in Light of Shibasaki and AVRCP 1.0; and
`
`Ground 5: Claims 49, 73, 97, and 120 are Obvious Under 35 U.S.C.
`
`§ 103(a) (pre-AIA) in Light of Shibasaki and A2DP 1.0.
`
`IV. FULL STATEMENT OF REASONS FOR REQUESTED
`RELIEF
`
`A.
`
`Summary of the ’342 Patent
`
`The ’342 patent is directed to a “multimedia device integration
`
`system” that integrates a car stereo or video system (also referred to as “car
`
`radio”) and one or more external or “after-market” devices, such as a CD
`
`changer or an MP3 player, that may otherwise be incompatible with the car
`
`stereo. See Ex. 1001 at abstract; 2:58-3:24 and FIGS. 1 and 18. In the
`
`context of the ’342 Patent, this integration is provided by an “integration
`
`subsystem,” which is separate from the car stereo and the external device. Id.
`
`at 3:25-32. The integration subsystem includes a wireless interface that
`
`establishes a wireless communications channel between the car stereo and
`
`the external device in some embodiments. Id. at 5:7-30 and FIG. 18.
`
`The integration subsystem also converts control signals from the car
`
`stereo into a format that is compatible with an after-market external device,
`
`thus allowing commands input at the car stereo to control the external
`
`device. Id. at 34:9-32. With reference to Figure 18 of the ’342 patent below,
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`-6-
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`

`
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`the control panel 920 of the car audio/video system 910 may be used to
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`control the operation of an external device (portable audio/video device 924)
`
`as a result of wireless interface 916 transmitting the control signals from the
`
`car audio/video system 910 to the portable audio/video device 924 by
`
`wireless link 922, and integration subsystem 932 converting the received
`
`control signals into a format compatible with the portable audio/video device
`
`924. Id. at 33:57-34:1, 34:19-32. Similarly, the integration subsystem 932
`
`receives data from the portable audio/video device 924 and converts the data
`
`into a format compatible with car audio/video system 910. A wireless
`
`interface 926 (identical to the wireless interface 916 of the car audio/video
`
`system 910) sends the converted data by the wireless link 922 to allow
`
`information, such as artist, song title, and track and time information, to be
`
`displayed on display 918 of car audio/video system 910. Id. at 34:9-18,
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`34:32-42. The integration subsystem 932 includes a microcontroller
`
`configured to perform the format conversion for signals sent by the car
`
`stereo to the external device and/or by the external device to the car stereo.
`
`Id. at 34:63-35:16, 38:10-48, FIG. 24.
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`-7-
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`The integration subsystem can be positioned either in the portable
`
`audio/video device as shown in FIG. 18 above or in the car system as shown
`
`in FIG. 23 below. In the latter case, the integration subsystem functions
`
`identically to the integration subsystem positioned in the portable
`
`audio/video device. Id. at 37:56-38:8.
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`-8-
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`The ’342 patent describes the integration subsystem 932 generating a
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`“device presence signal” that it transmits to the car system 910 to maintain
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`the car system 910 in a state responsive to the portable device 924, such as
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`“prevent[ing] the car stereo from shutting off, entering a sleep mode, or
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`otherwise being unresponsive to signals and/or data from an external
`
`source.” Id. at 16:52-62, 35:1-4.
`
`The ’342 patent also describes embodiments of the integration
`
`subsystem that include a voice recognition subsystem 1336. The voice
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`-9-
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`

`
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`recognition subsystem 1336 receives spoken commands from a user (e.g.,
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`received through a microphone or otherwise transmitted to the integration
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`subsystem) and processes them into a format compatible with the device
`
`electronics of the portable device for execution thereby. Id. at 36:53-37:29.
`
`B.
`
`The ’342 Patent’s Prosecution History
`
`The application for the ’342 patent, U.S. App. No. 11/475,847 (“the
`
`’847 application), was filed on June 27, 2006. See Ex. 1002 at 1. The ’847
`
`application is a continuation-in-part of U.S. App. No. 11/071,667 (filed
`
`March 3, 2005, abandoned), U.S. App. No. 10/732,909 (filed December 10,
`
`2003, abandoned), and U.S. App. No. 10/316,961 (filed December 11, 2002,
`
`issued as U.S. Patent No. 7,489,786). See Ex. 1002 at 2. The first disclosure
`
`of a wireless integration system that connects to both a car audio system and
`
`a portable device wirelessly is in the ’847 application. Portions of the file
`
`history pertinent to the issues in this Petition are summarized below.
`
`In a first Non-Final Office Action dated May 28, 2009, all pending
`
`claims were rejected under 35 U.S.C. § 103(a) as unpatentable over U.S.
`
`Patent No. 6,539,358 (“Coon”) in view of U.S. Pub. No. 2002/0009978
`
`(“Dukach”). Ex. 1002 at 648-665. In response, the Applicant canceled all
`
`pending claims and distinguished the new claims from Coon and Dukach on
`
`the basis that neither reference teaches or suggests “wherein said integration
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`-10-
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`
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`subsystem obtains, using said wireless communication link, information
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`about an audio file stored on, or received by, the portable device, transmits
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`the information to the car audio/video system for subsequent display of the
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`information on a display of the car audio/video system, instructs the portable
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`device to play the audio or video file in response to a user selecting the audio
`
`file using controls of the car audio/video system, and receives audio
`
`generated by the portable device over said wireless communication link for
`
`playing on the car audio/video system.” Ex. 1002 at 702-737.
`
`In response, the Examiner issued a Final Office Action dated March 5,
`
`2010, rejecting all claims. Some claims were rejected on the ground of non-
`
`statutory obviousness-type double patenting over parent U.S. Patent No.
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`7,489,786 (“the ’786 patent”). Other claims were rejected under 35 U.S.C. §
`
`102(e) as anticipated by U.S. Pub. No. 2004/0117442 (“Thielen”) or under
`
`35 U.S.C. § 103(a) as unpatentable over Thielen in view of U.S. Patent No.
`
`7,031,477 (“Mella”). Ex. 1002 at 774-785. The Applicant filed a Request for
`
`Continued Examination with a Terminal Disclaimer over the ’786 patent and
`
`amended other claims without specifically addressing the 102 and 103
`
`rejections. Ex. 1002 at 799.
`
`The Examiner issued a second Non-Final Office Action dated
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`February 15, 2011, rejecting all claims under 35 U.S.C. § 102(e) as
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`-11-
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`

`
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`anticipated by U.S. Patent No. 7,493,645 (“Tranchina”) or under 35 U.S.C. §
`
`103(a) as unpatentable over Tranchina in view of U.S. Patent No. 6,134,456
`
`(“Chen”). Ex. Ex. 1002 at 882-909. The Applicant amended the claims to
`
`require that the integration subsystem instructs the portable device to play
`
`the audio file (as opposed to an audio or video file as previously presented)
`
`in response to a user selecting the audio file using controls of the car
`
`audio/video system. The Applicant argued that Tranchina and Chen fail to
`
`teach or suggest this feature. Ex. 1002 at 962-988.
`
`In response, the Examiner issued a second Final Office Action dated
`
`November 29, 2011, in which all claims were again rejected under 35 U.S.C.
`
`§ 102(e) as anticipated by Tranchina or under 35 U.S.C. § 103(a) as
`
`unpatentable over Tranchina in view of Chen. The Examiner cited to
`
`different portions of Tranchina to find the teaching that the integration
`
`subsystem instructs the portable device to play the audio file in response to a
`
`user selecting the audio file using controls of the car audio/video system. Ex.
`
`1002 at 1002 at 990-1018. The Applicant responded by amending two
`
`claims to correct dependencies and arguing in greater detail that Tranchina
`
`does not teach an integration subsystem that instructs a portable device to
`
`play an audio file in response to a user selecting the audio file using controls
`
`of a car audio/video system. Ex. 1002 at 1052-1078. A Notice of Allowance
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`-12-
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`

`
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`without detailed reasons for allowance was mailed February 16, 2012. Ex.
`
`1002 at 1079-1081. After minor amendments to correct errors in the
`
`specification, the ’342 patent issued on April 10, 2012. Ex. 1002 at 1125.
`
`C.
`
`Person of Ordinary Skill in the Art
`
`A person of ordinary skill in the art (“POSITA”) at the time of the
`
`alleged invention of the ’342 patent would have had at least at least a
`
`Bachelor’s Degree in Electrical Engineering or equivalent
`
`science/engineering degree and at least two years’ experience in signal
`
`processing and/or electronic system design, or at least four years’
`
`experience in signal processing and/or electronic system design. Ex. 1003
`
`¶25.
`
`D. Claim Construction
`In accordance with 37 C.F.R. § 42.104(b)(3), Petitioners provide the
`
`following statement regarding construction of the ’342 patent claims. A
`
`claim subject to inter partes review receives the “broadest reasonable
`
`interpretation” (“BRI”) in light of the specification. 37 C.F.R. § 42.100(b).
`
`The Patent Owner in the pending litigations has argued that many of the
`
`claim terms at issue should be given their plain meaning. See generally, Ex.
`
`1004. The Patent Owner, however, has construed some of the limitations of
`
`the ’342 patent. The limitations that have been construed by the Patent
`
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`-13-
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`

`
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`Owner and that are pertinent to the challenged claims are discussed below.
`
`In presenting this Petition, unless otherwise stated, the grounds set
`
`forth herein are based on (1) claim constructions adopted by the Panel in
`
`IPR2016-00418, Paper No. 13 (Ex. 1011) in an institution decision; (2) the
`
`proposed claim constructions offered by the Patent Owner in Blitzsafe Texas,
`
`LLC v. Honda Motor Co., Ltd. et al., 2:15-cv-01274 (E.D. Tex.)(lead case);
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`or (3) for terms where Patent Owner has not explicitly offered a claim
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`construction, on Petitioners understanding of Patent Owner’s claim
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`construction based upon Patent Owner’s infringement contentions submitted
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`in Blitzsafe Texas, LLC v. Honda Motor Co., Ltd. et al., 2:15-cv-01274 (E.D.
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`Tex.)(lead case). See generally, Ex. 1005 at appendices A, B.
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`Petitioners do not concede that any claim interpretation impliedly or
`
`expressly proposed by Patent Owner is appropriate for the district court
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`litigation, where a different legal standard applies to the construction of the
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`asserted claim terms. Petitioners present these interpretations to the Board
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`for consideration in determining the BRI because Patent Owner considers
`
`them proper, and therefore necessarily within the scope of the BRI.
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`Petitioners further submit these interpretations under 35 U.S.C. § 301(a)(2),
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`which encourages submission of claim construction materials to prevent
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`patentees from arguing broad interpretations under Phillips while
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`simultaneously arguing narrow constructions as the BRI.
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`“integration subsystem”
`
`1.
`The term “integration subsystem” appears in challenged claims 49,
`
`50, 53-57, 73, 74, 77-80, 97, 99, 102, 103, 106 and 120. The PTAB has
`
`previously construed this term in IPR2016-00118, Paper 19, and IPR2016-
`
`00418, Paper 13, as “a subsystem to perform at least: (1) connecting one or
`
`more portable devices or inputs to the car audio/video system via an
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`interface, (2) processing and handling signals, audio, and/or video
`
`information, (3) allowing a user to control the one or more portable devices
`
`via the car audio/video system, and (4) displaying data from the one or more
`
`portable devices on the car audio/video system.” Ex. 1010 at 11; Ex. 1011 at
`
`15.
`
`2.
`
`“car audio/video system”
`
`The term “car audio/video system” appears in challenged claims 49-
`
`51, 53, 54, 56, 57, 73-75, 77, 78, 97, 99, 106 and 120. The PTAB has
`
`previously construed this term in IPR2016-00418, Paper 13, as “a car audio
`
`system, a car video system, or a car audio and video system.” Ex. 1011 at
`
`16.
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`“generated . . . for playing on the car audio/video
`4.
`system”
`
`The term “generated . . . for playing on the car audio/video system”
`
`appears in challenged claims 49 and 73 and has been construed by the Patent
`
`Owner to mean “produced by the portable device during playback.” Ex.
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`1004 at 47.
`
`5.
`
`“format incompatible with the portable device”
`
`The term “format incompatible with the portable device” appears in
`
`challenged claims 53, 77 and 97, and has been construed by the Patent
`
`Owner to be interpreted by its plain meaning. Specifically, according to the
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`Patent Owner’s infringement contentions, this limitation is met when a
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`control command from a car audio/video system is transmitted over a
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`Bluetooth link to a Bluetooth-compatible device. Ex. 1004 at 50.
`
`6.
`
`“device presence signal”
`
`The term “device presence signal” appears in challenged claims 56
`
`and 106, and has been construed by the Patent Owner to be interpreted by its
`
`plain meaning or as “a signal indicating an audio device is present.” Ex.
`
`1004 at 54. The PTAB, however, has previously construed this term in
`
`IPR2016-00418, Paper 13, as “a signal indicating that a portable device is
`
`connected to the car audio/video system through the integration subsystem.”
`
`Ex. 1011 at 17.
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`E. Ground 1: Claims 49-52, 54, 56, 62-64, 71 and 120 are
`Anticipated by Shibasaki Under 35 U.S.C. §§ 102(a) or 102 (e)
`(pre-AIA)
`1. Overview of Shibasaki
`Shibasaki is directed to a car audio apparatus that forms a network
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`with information terminals using a Bluetooth (BT) connection. The car audio
`
`apparatus acquires attribute information from information terminals and
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`determines and collects music files based on the attribute information. A list
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`of the music files is displayed on a display of the car audio apparatus. Ex.
`
`1006 at Abstract. For example, as shown in Figure 1, a piconet is formed by
`
`a car audio apparatus 10 and one or more information terminals 20 (mobile
`
`telephone 20-1, MP3 player 20-2/20-3, and/or PDA 20-4). Ex. 1006 at 8:63-
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`9:5.
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`-17-
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`The car audio apparatus 10 is shown in greater detail in Figure 2. The
`
`car audio apparatus 10 includes, inter alia, a system control section 101, an
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`operation section 107, a data processing section 109, a playback section 111,
`
`a display section 113, and a BT transmission/reception section 115. The
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`control section 101 controls the components of the car audio apparatus 10.
`
`The operating section 107 accepts user inputs. The BT transmission/
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`reception section 115 communicates with other components of the piconet
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`(e.g., MP3 players or other media devices). The data processing section
`
`processes music data received through the BT transmission/reception section
`
`115. The playback section 111 converts the music data into sound. The
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`display section 113 displays music data. Ex. 1006 at 10:4-53.
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`
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`Figure 4 shows how the car audio apparatus 10 communicates with
`
`the other devices in the piconet and processes information. This includes
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`requesting and receiving information about the music available on a device
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`20 (e.g., steps 411, 413, 421, 423); displaying this information (e.g., step
`
`427); and instructing the device 20 to play music, receiving the music from
`
`the device 20, and playing the music (e.g., steps 429-435). Ex.1006 at 12:27-
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`33 and 13:16-58.
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`-19-
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`2.
`
`Detailed Analysis
`a.
`
`Claim 49
`
`Claim: 49
`[a]. A
`multimedia
`device
`integration
`system,
`comprising:
`
`[b] an
`integration
`subsystem in
`communication
`with a car
`audio/video
`system; and
`
`
`Shibasaki discloses a multimedia device integration
`system. Ex. 1003 at 29-30.
`
`
`FIG. 1 is a block diagram to show the
`information processing system wherein
`machines in a Bluetooth radio communication
`system are connected so that they can
`communicate with each other. The
`information processing system shown in the
`figure has a car audio apparatus 10 as an
`information processing apparatus used as a
`master and a mobile telephone 20-1, an MP3
`(MPEG-1 Audio Layer-3) player 20-2, an
`MP3 player 20-3, and a PDA (Personal
`Digital Assistant) 20-4 as information
`terminals used as slaves.
`Ex. 1006 at 8:63-9:5.
`Shibasaki discloses an integration subsystem in
`communication with a car audio/video system. Ex. 1003 at
`30-33.
`
`For example, Shibasaki discloses a system for (1)
`connecting one or more Bluetooth devices to the car
`audio/video system via a Bluetooth interface, (2)
`processing and handling signals, audio, and/or video
`information, (3) allowing a user to control portable devices
`via the car audio/video system, and (4) displaying data
`from the portable devices on the car audio/video system.
`In Shibasaki, the “integration subsystem” includes the BT
`Transmission/Reception section 115, system control
`section 101, and data processing section 109:
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`Ex. 1006 FIG. 2; see also id. at 8:11-12 (“FIG. 2 is a block
`diagram to show the detailed configuration of a car audio
`apparatus”).
`
`In the following passage, Shibasaki discloses that the
`integration subsystem (i.e., the BT
`Transmission/Reception section 115, system control
`section 101, and data processing section 109 of Figure 2)
`is in communication with the rest of the car audio/video
`subsystem because it channels the received music stream
`to the playback section 111 to “perform play processing”:
`When a user’s playback instruction of the music
`piece in the music list edited at step S429 is
`accepted through the operation section 107, the
`playback instruction is transmitted to the MP3
`player 20-2 having the music file corresponding to
`the given playback instruction through the BT
`radio communication system (step S433), and the
`car audio apparatus 10 performs streaming of
`encoding the received music file in real time and
`performing play processing (step S435).
`Ex. 1006 at 13:41-51; see also id. at 10:44-46 (“The
`playback section 111 converts the music data . . . into
`sound for output. . .”)
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`Ex. 1006 FIG. 1; see also id. at 8:8-10 (“FIG. 1 is a block
`diagram to show the schematic configuration of an
`information processing system according to a first
`embodiment of the invention”).
`
`
`The information processing system shown in
`the figure has a car audio apparatus 10 as an
`information processing apparatus used as a
`master and a mobile telephone 20-1, and MP3
`(MPEG-1 Audio Layer-3) player 20-2, an
`MP3 player 20-3, and a PDA (Personal
`Digital Assistant) 20-4 as information
`terminals used as slaves.
`A Bluetooth module (BT module) (not
`shown) is installed in each of the machines
`and the machines each in which the BT
`module is installed (BT machines) make up a
`network (piconet) in which the BT modules
`enable the BT machines to communicate with
`each other. The information processing
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`system shown in FIG. 1 assumes that a
`plurality of users have information terminals
`20 such as the mobile telephone 20-1, the
`MP3 player 20-2, the MP3 player 20-3, and
`the PDA 204 in which the BT modules are
`installed ride together in a vehicle having the
`car audio apparatus 10 in which the BT
`module is installed, for example.
`Ex. 1006 at 8:67 – 9:16.
`Shibasaki discloses a first wireless interface in
`communication with said integration subsystem, said first
`wireless interface establishing a wireless communication
`link with a second wireless interface in communication
`with a portable device external to the car audio/video
`system. Ex. 1003 at 33-34.
`
`For example, Shibasaki expressly discloses providing
`wireless connectivity between portable electronic devices,
`and depicts a first and second wireless interface which
`together establish a wireless communication link between
`a portable