UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TOYOTA MOTOR CORPORATION;
`
`Petitioner
`
`v.
`
`BLITZSAFE TEXAS, LLC
`
`Patent Owner
`
`Patent No. 7,489,786
`Issued: Feb. 10, 2009
`Filed: Dec. 11, 2002
`
`Inventor: Ira Marlowe
`Title: AUDIO DEVICE INTEGRATION SYSTEM
`
`Inter Partes Review No.: Unassigned
`
`
`
`
`
`DECLARATION OF THOMAS G. MATHESON, Ph.D.
`IN SUPPORT OF PETITIONER’S REQUEST FOR INTER PARTES
`REVIEW
`
`

`
`
`
`TABLE OF CONTENTS
`INTRODUCTION AND BACKGROUND....................................................1
`I.
`BACKGROUND AND QUALIFICATIONS.................................................1
`II.
`Educational Background ..............................................................................1
`A.
`Relevant Professional Experience................................................................1
`B.
`III. SUMMARY OF MY OPINIONS ...................................................................4
`A.
`Instructions...................................................................................................5
`1. Claim Interpretation .....................................................................................6
`2. Anticipation..................................................................................................7
`3. Obviousness .................................................................................................7
`4. “means-plus-function” claims....................................................................11
`B.
`Effective Filing Dates and Prior Art Patents and Printed Publications .....13
`IV. OVERVIEW OF THE TECHNOLOGY.......................................................14
`A.
`Summary of the ‘786 Patent Disclosure ....................................................14
`B.
`Summary of the Challenged Claims ..........................................................17
`C.
`Summary of the Prosecution History of the ‘786 Patent ...........................19
`D.
`The “Problem” the ‘786 Patent Claims to Solve .......................................22
`V.
`CLAIM CONSTRUCTION ..........................................................................26
`VI. ALL CHALLENGED CLAIMS OF THE ‘786 PATENT ARE
`UNPATENTABLE ..................................................................................................35
`VII. CLAIM CHARTS..........................................................................................35
`A. Ground 1: Claims 57, 58, 60, 64, 86, 88, 90, 92, 94, and 97 are obvious
`based on JP ‘954 in view of Lau ..........................................................................35
`1. Disclosure of JP ‘954 .................................................................................35
`2. Disclosure of Lau .......................................................................................36
`3. Obvious to Combine Lau with JP ‘954......................................................37
`4. Claims 57, 58, 60 and 64 are obvious based on JP ‘954 in view of Lau, as
`shown below:.....................................................................................................41
`5. Claim 86—Obvious to provide a “video device” and process “video
`information” ......................................................................................................51
`6. Claim 92 .....................................................................................................62
`B. Ground 2: Claim 44 is obvious based on JP ‘954 in view of Lau and
`Bhogal...................................................................................................................80
`1. Description of Bhogal and Motivation to Combine...................................80
`2. “storage area” .............................................................................................81
`3. “interface” ..................................................................................................82
`
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`i
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`

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`
`
`4. Remotely controlling..................................................................................83
`C. Ground 3: Claims 1, 2, 4, 7, 8, 13, 14, 23, and 24 are obvious based on JP
`‘954 in view of Sony XR-C5120 and Sony XA-C30...........................................92
`1. Disclosure Sony XR-C5120 and Sony XA-C30........................................93
`2. The first, second, and third connectors ......................................................94
`3. The “interface” ...........................................................................................95
`4.
`the first pre-programmed code portion ......................................................96
`5. The second pre-programmed code portion ................................................96
`6. The third pre-programmed code portion....................................................96
`7. Obvious to process “track and time” and “title and artist” information ....97
`8. Use of control buttons ................................................................................98
`9. Channeling audio........................................................................................98
`10. Motivation to Combine ..............................................................................98
`D. Ground 4(a): Claims 5 and 24 are obvious based on JP ‘954 in view of
`Sony XR-C5120, Sony XA-C30 and known bus technology........................... 115
`1. Plug and play mode................................................................................. 115
`2. USB ......................................................................................................... 116
`E.
`Ground 4(b): Claims 65, 89 and 98 are obvious based on JP ‘954 in view
`of Lau and known bus technology .................................................................... 118
`F.
`Ground 4(c): Claim 47 is obvious based on JP ‘954 in view of Bhogal 120
`G. Ground 5: Claims 6 and 10 are obvious based on JP ‘954 in view of Sony
`XR-C5120, Sony XA-C30 and Lau .................................................................. 122
`H. Ground 6: Claims 61, 62, and 63 are obvious based on JP ‘954 in view of
`Lau and Sony XR-C5120 .................................................................................. 127
`I.
`Ground 7: Claims 57 and 86 are obvious in view of Bhogal................. 134
`VIII. CONCLUSION........................................................................................... 136
`
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`
`
`EXHIBITS
`
`Description
`U.S. Patent No. 7,489,786 (“the ‘786 Patent”)
`File History of U.S. Patent No. 7,489,786
`International Publication No. WO 01/67266 A1 (“Lau)
`U.S. Patent No. 6,175,789 (“Beckert”)
`U.S. Patent Publication No. 2001/0028717 A1 (“Ohmura”)
`Japanese Unexamined Patent Application No. H7-6954 to Ouchida
`(“JP ‘954”)
`Certified translation of Ex. 1006
`Sony XR-C5120 FM/AM Cassette Car Stereo Operating
`Instructions (“Sony XR-C5120 Manual”)
`Sony XA-C30 Service Manual (“Sony XA-C30 Manual”)
`U.S. Patent No. 6,629,197 (“Bhogal”)
`Sony XR-C5120R FM/AM Cassette Car Stereo Operating
`Instructions (“Sony XR-C5120R Manual”)
`Claim Construction Ruling in 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).
`NEC µPD75004 Data Sheet
` Merriam Webster, definition of “device” (www.merriam-
`webster.com/dictionary/device)
`
`
`
`iii
`
`
`
`Exhibit
`1101
`1102
`1103
`1104
`1105
`1106
`
`1107
`1108
`
`1109
`1110
`1111
`
`1112
`
`1113
`1114
`
`
`
` 
`
`

`
` 
`I.
`
`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
`
`INTRODUCTION AND BACKGROUND
`1.
`I have been retained by counsel for Toyota Motor Corporation
`
`(“Toyota” or “Petitioner”), and asked to review and provide my opinion on the
`
`patentability of claims 1, 2, 4-8, 10, 13, 14, 23, 24, 44, 47, 57, 58, 60-65, 86, 88-
`
`92, 94, 97, and 98 of U.S. Patent 7,489,786 (Ex. 1001, “the ʼ786 Patent”). I am
`
`being compensated for my time at my normal consulting rate of $350 per hour. My
`
`compensation is not contingent on the outcome of this proceeding or the content of
`
`my opinions.
`
`II. BACKGROUND AND QUALIFICATIONS
`A. Educational Background
`2.
`In 1974, I received a B.S. in Physics from Abilene Christian
`
`University. In 1976, I received an M.A. in Physics from the University of Oregon.
`
`In 1980, I received a Ph.D. from the University of Oregon in Physics. In 1998, I
`
`received an M.B.A. from The Wharton School of Business at the University of
`
`Pennsylvania.
`
`B. Relevant Professional Experience
`3. While working on my technical degrees I taught laboratory courses in
`
`Electronics and Instrumentation and published papers on applications of
`
`microcomputers to signal processing. The experimental apparatus that I developed
`
`as part of my thesis research in experimental Solid State Physics was a highly
`
`automated, multiple-computer instrumentation system capable of controlling
`
` 
`
`

`
`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
`
`laboratory equipment (including 100-amp currents through a superconducting
`
`solenoid) while automatically measuring and analyzing low-frequency
`
`electromagnetic signals from Silicon ICs under vacuum, near zero Kelvin, and in a
`
`high magnetic field.
`
`4. While working at AT&T Bell Laboratories most of my work focused
`
`on the design of large digital systems, including investigation of both low-
`
`bandwidth and high-bandwidth networks. As part of that work, I designed
`
`network-interface integrated circuits that were fabricated and used in prototype
`
`network systems. I also researched and built an automated system that
`
`automatically designed fabrication-ready single-chip microcomputers/controllers
`
`starting from a high level specification.
`
`5.
`
`In 1984, I founded Silicon Design Labs (later named Silicon Compiler
`
`Systems), an IC CAD company that commercialized “Silicon Compilation.”
`
`(Silicon Compilation is the application of language compiler and related
`
`programming techniques to IC design and layout.) We also provided custom IC
`
`design services and sold libraries of standardized IC circuit designs and layouts. I
`
`performed marketing and engineering functions, managing groups that developed
`
`IC layout, analysis, extraction, and Silicon Compilation tools. During this period I
`
`published several technical papers on our IC design tools. Although our tools were
`
`general-purpose electronic- and IC-design tools, most of our customers focused on
`
` 
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`

`
`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
`
`custom processor and controller design. Among such customers was General
`
`Motors, which was interested in designing custom ICs for automotive use.
`
`6. My consulting over the last dozen years has primarily involved system
`
`design and analysis, including electronic circuit and software design. My clients
`
`have included electronics circuit and parts suppliers, CAD companies, and
`
`automotive electronics and systems companies.
`
`7.
`
`I was previously retained as an expert by Ford Motor Company in the
`
`case of Marlowe Patent Holdings LLC v. Ford Motor Company, 3:10-cv-07044
`
`(D. NJ), in which the ‘786 Patent was asserted against Ford. During that
`
`proceeding, I presented expert declarations regarding aspects of claim construction
`
`and invalidity of the ‘786 Patent and also presented a tutorial on automotive audio
`
`systems and bus technology to District Court Judge Peter G. Sheridan.
`
`8.
`
`In the past five years, I have been deposed or testified in the following
`
`matters:
`
` I.E.E. International Electronics & Engineering, S.A. and IEE Sensing,
`
`Inc. v. TK Holdings Inc. and Takata-Petri A.G., in the Eastern District
`
`of Michigan, (Case No. 2:10-CV-13487-GER-MJH). 5-15-2012 and
`
`6-25-2013.
`
` Lightspeed Aviation Inc. v. Bose Corporation, in a JAMS Arbitration,
`
`(JAMS REF. NO.: 1390000156). 5-13-2014 to 5-15-2014.
`
` 
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`3
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`

`
`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
`
`9. My complete academic background, professional experience, and
`
`publications are set forth in my Curriculum Vitae, a copy of which is attached
`
`hereto as Attachment A.
`
`III. SUMMARY OF MY OPINIONS
`10.
`It is my opinion that each of the claims of the ‘786 Patent challenged
`
`by the Petitioner (claims 1, 2, 4-8, 10, 13, 14, 23, 24, 44, 47, 57, 58, 60-65, 86, 88-
`
`92, 94, 97, and 98) are invalid. The invalidity of these claims is shown by at least
`
`the following Grounds of Unpatentability:
`
` Ground 1: Claims 57, 58, 60, 64, 86, 88, 90, 91, 92, 94, and 97 are
`
`obvious based on JP ‘954 in view of Lau
`
` Ground 2: Claim 44 is obvious based on JP ‘954 in view of Lau and
`
`Bhogal
`
` Ground 3: Claims 1, 2, 4, 7, 8, 13, 14, 23, and 24 are obvious based
`
`on JP ‘954 in view of Sony XR-C5120 and Sony XA-C30
`
` Ground 4(a): Claims 5 and 24 are obvious based on JP ‘954 in view of
`
`Sony XR-C5120, Sony XA-C30 and known bus technology
`
` Ground 4(b): Claims 65, 89, and 98 are obvious based on JP ‘954 in
`
`view of Lau and known bus technology
`
` Ground 4(c): Claim 47 is obvious based on JP ‘954 in view of Bhogal
`
` 
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`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
`
` Ground 5: Claims 6 and 10 are obvious based on JP ‘954 in view of
`
`Sony XR-C5120, Sony XA-C30 and Lau
`
` Ground 6: Claims 61, 62, and 63 are obvious based on JP ‘954 in
`
`view of Lau and Sony XR-C5120
`
` Ground 7: Claims 57 and 86 are obvious in view of Bhogal
`
`11.
`
`In this Declaration, I provide the explanation and support for my
`
`opinion that each of the challenged claims are invalid based on these grounds.1
`
`A.
`12.
`
`Instructions
`I am not an attorney. My analysis and opinions are based on my
`
`expertise in this technical field, as well as the instructions I have been given by
`
`counsel for the legal standards relating to patentability.
`
`13. The materials I have reviewed in connection with my analysis include
`
`the ʼ786 Patent, its file history, and the exhibits referenced herein.
`
`14.
`
`I understand that unpatentability in this proceeding must be proven by
`
`a preponderance of the evidence, and this is the standard I have used throughout
`
`my declaration. Further, I understand that each patent claim is considered
`
`separately for purposes of unpatentability.
`
`                                                       
`1 I have provided my opinions regarding additional grounds of unpatentability of
`the challenged claims relying on the Lau reference in a separate declaration, which
`I understand Petitioners will submit in connection with a separate inter partes
`review petition.
`
` 
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`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
`
`15. My analysis assumes that a “person having ordinary skill in the art,”
`
`or “PHOSITA” at the time of the alleged invention would have had at least a
`
`Bachelor’s degree in electrical engineering or equivalent science/engineering
`
`degree and at least two years of experience in signal processing and/or
`
`electronic system design, or would have at least four years of experience in
`
`signal processing and/or electronic system design. Based on my education and
`
`experience, I believe I would have been a person of ordinary skill in the art in
`
`regard to the ’786 patent.
`
`1. Claim Interpretation
`I have also been instructed that in an Inter Partes Review, claims are
`
`16.
`
`given their ordinary and customary meaning, as understood by a PHOSITA at the
`
`time of the invention, taking into consideration the language of the claims, the
`
`specification, and the prosecution history of record construed in light of how a
`
`PHOSITA would understand the claims. I have also been informed that the Board
`
`construes claims during Inter Partes Review according to the “broadest reasonable
`
`interpretation” in view of the specification to the PHOSITA. Therefore, it is my
`
`understanding that what is to be considered includes the claims, the patent
`
`specifications and drawings, and the prosecution history, including any art listed by
`
`the Examiner or the Applicant. It is my understanding that information external to
`
`the patent, including expert and inventor testimony and unlisted prior art, are to be
`
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`6
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`

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`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
`
`considered in construing the claims only if ambiguities remain. However, expert
`
`testimony may be useful in helping to explain the technology. In my analysis, I
`
`have considered and applied the proposed claim constructions of the Petitioners,
`
`unless otherwise indicated.
`
`2. Anticipation
`I am informed that a patent claim is unpatentable as “anticipated” if
`
`17.
`
`each and every feature of the claim is found in a single prior art reference. Claim
`
`limitations that are not expressly found in a prior art reference are inherent if the
`
`prior art necessarily functions in accordance with, or includes, the claim
`
`limitations. I further understand that inherency requires more than probabilities or
`
`possibilities that the claim element is disclosed in a prior art reference.
`
`3. Obviousness
`It is my understanding that a patent cannot be properly granted for
`
`18.
`
`subject matter that would have been obvious to a person of ordinary skill in the art
`
`at the time of the alleged invention, and that a claim directed to such obvious
`
`subject matter is invalid under 35 U.S.C. § 103(a). In assessing the obviousness of
`
`claimed subject matter, it is my understanding that one should evaluate
`
`obviousness over the prior art from the perspective of one of ordinary skill in the
`
`art at the time the application was filed (and not from the perspective of a either a
`
`layman or a genius in that art). The question of obviousness is to be determined
`
`based on the following:
`
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`7
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`
`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
`
` the scope and content of the prior art; 

`
` the differences between the prior art and the claim under construction;
`
`and
`
` the level of ordinary skill in the art.
`
`19.
`
`It is my further understanding that in developing an opinion as to
`
`whether certain claimed subject matter would have been obvious, one should
`
`consider any differences between the prior art and the claimed subject matter.
`
`When doing so, each claim should be considered in its entirety and separately from
`
`any other claims. While one should consider any differences between the claimed
`
`invention and the prior art, he or she should also assess the obviousness or non-
`
`obviousness of the entirety of a claim covering an alleged invention, not merely
`
`some portion of it. One way to decide whether one of ordinary skill in the art
`
`would combine what is described in various references is to determine whether it
`
`was obvious to try such a combination. In this determination, it is important to
`
`analyze the inferences and creative steps that a person of ordinary skill in the art
`
`would take.
`
`20.
`
`It is my further understanding that when there is a design need or
`
`market pressure to solve a problem and there are a finite number of identified,
`
`predictable solutions, a person of ordinary skill would have good reason to pursue
`
`the known options within his or her technical grasp. If that pursuit likely leads to
`
` 
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`8
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`

`
`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
`
`the anticipated success, it is likely that the alleged invention is a product, not of
`
`innovation, but of ordinary skill and common sense. In that case, the fact that a
`
`combination was obvious to try might show that the alleged invention was obvious.
`
`Further, when a combination of familiar features or elements does no more than
`
`yield predictable results, it is likely to be obvious.
`
`21.
`
`It is my further understanding that when a work is available in one
`
`field of endeavor, design incentives and other market forces can prompt variations
`
`of it in the same field or in a different field. If there is a known problem and a
`
`person of ordinary skill in the art can implement a predictable variation that
`
`matches the claim, it is likely that the claim is invalid for being obvious. For the
`
`same reason, if a technique has been used to improve one device and a person of
`
`ordinary skill in the art would recognize that it would improve similar devices in
`
`the same way, using that technique is obvious unless its actual application is
`
`reasonably considered to be beyond his level of ordinary skill.
`
`22.
`
`I am informed that, while not absolute, the principles relating to a
`
`“motivation,” “suggestion,” or “teaching” in the prior art to combine references are
`
`useful in analyzing whether an invention is obvious. I am informed that the
`
`suggestion or motivation may be either explicit or implicit, and may come from
`
`knowledge generally available to a PHOSITA, from the nature of the problem to
`
`be solved, or from a combination of these factors. The test for an implicit
`
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`9
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`
`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
`
`motivation, suggestion, or teaching is what the combined teachings, knowledge of
`
`a PHOSITA, and the nature of the problem to be solved as a whole would have
`
`suggested to those of ordinary skill in the art. The problem examined is not the
`
`specific problem solved by the invention, but the general problem that confronted
`
`the inventor before the invention was made.
`
`23.
`
`I am also informed that evidence of a “motivation,” “suggestion,” or
`
`“teaching” is not always required in determining whether an invention is obvious.
`
`Neither a particular motivation nor the alleged purpose of the patentee controls the
`
`investigation of obviousness. One of ordinary skill in the art is not confined only to
`
`prior art that attempts to solve the same problem as the patent claim. Common
`
`sense discloses that familiar items may have obvious uses beyond their primary
`
`purposes.
`
`24.
`
`I understand that multiple references can be combined to show that a
`
`claim is obvious. Any need or problem known in the field and addressed by a
`
`claim can provide a reason for combining multiple references in the manner
`
`claimed. To determine whether there was an apparent reason to combine those
`
`references in the way a patent claims, I may look to interrelated teachings of
`
`multiple patents, to the effects of demands known to the design community or
`
`present in the marketplace, and to the background knowledge possessed by a
`
`person of ordinary skill in the art.
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`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
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`25.
`
`In an obviousness analysis, it is my understanding that there are
`
`“secondary considerations” that should be analyzed if they apply. I am told that
`
`these considerations include (a) whether the prior art teaches away from the
`
`claimed invention, (b) whether there was a long felt but unresolved need for the
`
`claimed invention, (c) whether others tried but failed to make the claimed
`
`invention, (d) skepticism of experts, (e) whether the claimed invention was
`
`commercially successful, (f) whether the claimed invention was praised by others,
`
`and (g) whether the claimed invention was copied by others.
`
`4. “means-plus-function” claims
` It is my understanding is that a means plus function limitation is a
`
`26.
`
`way of writing a limitation of a claim that generally follows the format of using the
`
`word “means” followed by stating a “function” that the claimed “means” is to
`
`perform, as claiming “a means for digging a hole.” In my understanding, such
`
`limitations only cover the structure disclosed in the specification and clearly linked
`
`to performing the function stated in the means-plus-function limitation, that being
`
`the so-called “corresponding structure” for the claimed function.
`
`27.
`
`It is my further understanding that to evaluate the scope of a means-
`
`plus-function limitation you first look for the stated function. You then look to the
`
`specification to see what structure, if any, is disclosed in the specification that
`
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`
`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
`
`might perform the designating function. Thereafter, you must see if such structure
`
`is clearly linked to performing the function.
`
`28. As a special case, if the corresponding structure for a means-plus-
`
`function limitation includes something like a programmable computer, then it is
`
`my understanding that the supporting specification must disclose some form of
`
`algorithm corresponding to the performance of the claimed function, and failure to
`
`provide disclosure of such an algorithm renders the claim invalid for being
`
`indefinite, as the claimed “means” has no definite corresponding structure.
`
`29.
`
`It is my further understanding that construction of a means-plus-
`
`function claim requires two steps: (1) identifying the claimed function and (2)
`
`determining what corresponding structure in the specification performs the claimed
`
`function, where when the corresponding structure is a programmable computer
`
`processor, the specification must disclose an algorithm that is clearly linked to the
`
`claimed function by the specification or prosecution history.
`
`30.
`
`It is my further understanding that once the function and
`
`corresponding structure of a means-plus-function limitation have been identified,
`
`that limitation will be invalidated if the prior art discloses the identical structure or
`
`an equivalent structure performing the same function. I further understand that a
`
`structure disclosed by the prior art will invalidate a means-plus-function limitation
`
`if the disclosed function performs the same function, in the same way, to yield the
`
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`12
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`
`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
`
`same result, and where the differences between the structure found in the prior art
`
`and any disclosed in the specification are insubstantial. I have used that
`
`methodology in forming the opinions set forth in this declaration.
`
`B.
`
`31.
`
`Effective Filing Dates and Prior Art Patents and Printed
`Publications
`I am informed that the claims of the ‘786 Patent (Ex. 1001) have an
`
`effective filing date no earlier than December 11, 2002, which is the date the
`
`application for the ‘786 Patent was filed.
`
`32. Petitioners rely on the following patents and publications, all of which
`
`I understand are prior art to all claims of the ‘786 Patent.
`
`33.
`
`I understand the following references qualify as prior art:
`
` Ex. 1103 – International Publication Number WO 01/67266 A1
`
`(“Lau”).
`
` Ex. 1104 – U.S. Patent No. 6,175,789 (“Beckert”)
`
` Ex. 1105 – U.S. Patent Publication No. 2001/0028717 A1 (“Ohmura”)
`
` Ex. 1106 – Japanese Unexamined Patent Application No. H7-6954 to
`
`Ouchida (“JP ‘954”) (Ex. 1107 is a certified translation)
`
` Ex. 1108 – Sony XR-C5120 FM/AM Cassette Car Stereo Operating
`
`Instructions (“Sony XR-C5120 Manual”) bears a copyright date of
`
`1999.
`
` 
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`13
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`

`
`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
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` Ex. 1109 – Sony XA-C30 Service Manual (“Sony XA-C30 Manual”)
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`bears a copyright date of 1999.
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` Ex. 1110 – U.S. Patent No. 6,629,197 (“Bhogal”)
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` Ex. 1111 – Sony XR-C5120R FM/AM Cassette Car Stereo Operating
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`Instructions (“Sony XR-C5120R Manual”) bears a copyright date of
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`1999.
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`IV. OVERVIEW OF THE TECHNOLOGY
`A.
`Summary of the ‘786 Patent Disclosure
`34. The '786 patent is directed to an “audio device integration system”
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`that integrates a car stereo (also referred to as “car radio”) and one or more external
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`or “after-market” devices, such as a CD changer or an MP3 player. See Ex. 1101
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`(the ‘786 Patent) at abstract and FIG. 1. In the context of the ‘788 patent, this
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`integration is provided by an “interface,” which is separate from the car stereo and
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`the external device. Id.
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`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
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`‘786 Patent Figure 1
`35. The interface converts control signals from the car stereo into a format
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`that is compatible with an external device, thus allowing commands input at the car
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`stereo to control the external device. With reference to Figure 2B of the ‘786
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`Patent below, the control panel buttons 14 of the car radio 10 may be used to
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`control the operation of an external device (MP3 player 30) as a result of interface
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`20 converting the control signals from the car radio 10 into a format compatible
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`with the MP player. Ex. 1101 at 6:1-19. Similarly, the interface receives data
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`from the external device and converts the data into a format compatible with car
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`radio 10 to allow information, such as artist, song title, and track and time
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`information, to be displayed on display 13 of car radio 10. Ex. 1101 at 6:19-24.
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`The interface includes a microcontroller programmed to perform the format
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`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
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`conversion for signals sent by the car stereo to the external device and signals sent
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`by the external device to the car stereo. Ex. 1101 at 8:31-9:7.
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`‘786 Patent Figure 2B
`36. The ‘786 patent also describes the interface providing one or more
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`auxiliary inputs (auxiliary inputs 35 in Figure 2E below) to allow additional audio
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`devices to be connected. Ex. 1101 at 7:23-29. This allows the audio from devices
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`connected to an auxiliary input to be selected under control of the microcontroller,
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`while the interface channels the audio at the selected input to the car stereo. Ex.
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`1101 at 7:30-37.
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`37. The ‘786 Patent also describes the interface generating a “device
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`presence signal” that it transmits to the car stereo to maintain the car stereo in an
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`operational state, such as “prevent[ing] the car stereo from shutting off, entering a
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`sleep mode, or otherwise being unresponsive to signals and/or data from an
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`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
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`external source.” Ex. 1101 at 12:29-35; 13:15-19; FIGs. 4A and 4B. The device
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`presence signal is sent during the condition where radio is determined to be in CD
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`player mode. Ex. 1101 at 12:22-24 and 13:7-10.
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`‘786 Patent Figure 4B
`B.
`Summary of the Challenged Claims
`38. The ‘786 Patent involves an audio device integration system that
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`
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`interfaces one or more after-market audio devices, such as a CD changer, to an
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`existing OEM car stereo system. The system converts command and data signals
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`so they can be exchanged between the car stereo and the otherwise incompatible
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`audio device or devices, generating signals as needed to make everything work
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`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
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`together so audio signals from the audio devices are played through the car stereo.
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`The general configuration is shown in the block diagram below.
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`39.
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`Independent claim 1 generally recites an interface comprising: 1) a
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`connector connectable to a car stereo, 2) connectors connectable to two (or a
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`plurality of) audio devices, and 3) a microcontroller that a) processes commands
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`from the car stereo into a format compatible with one of the audio devices and
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`transmits them to that audio device, and b) processes data from one of the audio
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`devices into a format compatible with the car stereo and transmits them to the car
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`stereo for display. Claim 1 also requires the microcontroller to switch or select
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`audio devices.
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`40.
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`Independent claim 86 generally recites an integration system
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`comprising 1) a first connector connected to a car stereo, 2) a second connector
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`connected to an after-market video device, and 3) an interface including a
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`microcontroller that generates and transmits a device presence signal to the car
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`stereo. The device presence signal maintains the car stereo in an operational state
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`responsive to signals generated by the video device.
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`Declaration of Thomas G. Matheson
`U.S. Patent No. 7,489,786
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`41.
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`Independent claims 57 and 92 are similar. They generally recite, with
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`some variation in particular elements, an interface comprising: 1) a connector
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`connectable to a car stereo, 2) a connector connectable to an audio device, and 3) a
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`microcontroller that a) generates a “device presence signal” that maintains the car
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`stereo in an operational state and b) processes commands from the car stereo into a
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`format compatible with one of the audio devices and transmits them to that audio
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`device. They recite different audio devices: claim 57 recites an MP3 player, and
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`claim 92 recites a portable audio device.
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`42.
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`Independent claim 44 generally recites a docking apparatus for a
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`portable device comprising: 1) a storage area for the portable dev