UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`
`
`JOHNSON SAFETY, INC.,
`Petitioner,
`
`v.
`
`VOXX INTERNATIONAL CORPORATION
`Patent Owner.
`
`_______________
`
`
`
`Patent No. 7,245,274
`Filing Date: May 15, 2003
`Issue Date: July 17, 2007
`Title: HEADREST MOUNTABLE VIDEO SYSTEM
`_______________
`
`Inter Partes Review No. IPR2016-01070
`
`DECLARATION OF RALPH V. WILHELM
`
`i
`
`
`
`
`
`Page 1 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`TABLE OF CONTENTS
`
`Introduction ......................................................................................................... 1 
`I. 
`II.  Qualifications ....................................................................................................... 2 
`III.  Materials Reviewed ............................................................................................. 4 
`IV.  Obviousness Principles ........................................................................................ 6 
`V.  Person of Ordinary Skill in the Art ................................................................... 6 
`VI.  Overview of the ‘274 Patent ................................................................................ 7 
`VII.  The State of the Art at the Time of the Claimed Invention ........................... 12 
`A.  Chang ................................................................................................................... 12 
`B.  Mathias ................................................................................................................ 16 
`C.  Tseng.................................................................................................................... 18 
`D.  Swaim .................................................................................................................. 20 
`E.  Compaq Manual .................................................................................................. 20 
`F.  Jost ....................................................................................................................... 22 
`VIII. Claim Construction ........................................................................................... 22 
`A.  Claim 1: “coupled” .............................................................................................. 22 
`B.  Claim 1: “an internal headrest support structure” ............................................... 22 
`C.  Claim 11: “wherein the base portion accommodates a media player” ................ 23 
`D.  Claims 5 and 6: “slot-type device” ...................................................................... 23 
`IX.  Certain References Render Obvious All of the Limitations Claimed in
`Claims 1, 5-7, 9, and 11 of the ‘274 Patent ...................................................... 23 
`A.  The Combination of Chang in view of Mathias Renders Obvious Claims 1,
`5-7, and 9 of the ‘274 Patent ............................................................................... 23 
`1.  [1.0] “A video system” .................................................................................. 23 
`2.  [1.1] “a base unit coupled to an internal headrest support structure” ........... 25 
`3.  [1.2] “a door pivotally connected to the base unit by a hinge” ..................... 26 
`4.  [1.3] “the door comprising a display” ........................................................... 29 
`5.  [1.3] “the door comprising a media player comprising at least one of a
`DVD player, an MPEG player or a video game player” ............................... 30 
`
`i
`
`Page 2 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`6.  It would have been obvious to a person of ordinary skill in the art at the
`time of the '274 Patent to modify Chang as taught by Mathias to arrive at
`the claimed invention of Claim 1 .................................................................. 30 
`7.  [5.0] “wherein the video system is a slot-type device” ................................. 36 
`8.  [6.0] “wherein a slot for receiving a data media is positioned on a side of
`the door” ........................................................................................................ 37 
`9.  [7.0] “further comprising a wireless transmitter” .......................................... 38 
`10. [9.0] “further comprising a port for connecting to an external device” ........ 38 
`B.  Chang in View of Jost and Mathias Renders Obvious Claims 1, 5-7, and 9 ..... 39 
`1.  [1.0] Chang, Jost, and Mathias disclose “a video system” ........................... 39 
`2.  [1.1] Chang and Jost disclose “a base unit coupled to an internal headrest
`support structure” .......................................................................................... 39 
`3.  [1.2] Both Chang and Mathias disclose “a door pivotally connected to the
`base unit by a hinge” ..................................................................................... 41 
`4.  [1.3] Both Chang and Mathias disclose “the door comprising a display” .... 41 
`5.  [1.4] Mathias discloses “the door comprising a media player comprising
`at least one of a DVD player, an MPEG player or a video game player” ..... 41 
`6.  It would have been obvious to a POSITA to modify Chang as taught by
`Jost and further as taught by Mathias to arrive at the claimed invention of
`Claim 1 .......................................................................................................... 42 
`7.  [5.0] Mathias discloses “wherein the video system is a slot-type device” ... 46 
`8.  [6.0] Mathias discloses “wherein a slot for receiving a data media is
`positioned on a side of the door” ................................................................... 46 
`9.  [7.0] Mathias discloses “further comprising a wireless transmitter” ............ 46 
`10. [9.0] Mathias discloses “further comprising a port for connecting to an
`external device” ............................................................................................. 46 
`C.  Chang in View of Tseng Renders Obvious Claim 11 of the ‘274 Patent ........... 46 
`1.  [11.0] “A video system” ................................................................................ 47 
`2.  [11.1] “a base portion positioned in a headrest of a vehicle seat” ................ 47 
`3.  [11.2] “wherein the base portion accommodates a media player
`comprising at least one of a DVD player, an MPEG player, or a video
`game player” .................................................................................................. 48 
`4.  [11.3] “a display pivotally connected to the base portion” ........................... 49 
`
`ii
`
`Page 3 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`5.  It would have been obvious to a person of ordinary skill in the art at the
`time of the ‘274 Patent to modify Chang as taught by Tseng to arrive at
`the claimed invention of Claim 11 ................................................................ 50 
`D.  Swaim in View of Compaq Manual Renders Obvious Claims 1, 5-7, and 9 ...... 56 
`1.  [1.0] “A video system” .................................................................................. 56 
`2.  [1.1] “a base unit coupled to an internal headrest support structure” ........... 58 
`3.  [1.2] “a door pivotally connected to the base unit by a hinge” ..................... 62 
`4.  [1.3] “the door comprising a display” ........................................................... 64 
`5.  [1.4] “the door comprising a media player comprising at least one of a
`DVD player, an MPEG player or a video game player” ............................... 64 
`6.  It would have been obvious to a person of ordinary skill in the art at the
`time of the ‘274 Patent to modify Swaim as taught by Compaq Manual to
`arrive at the claimed structure of Claim 1 ..................................................... 65 
`7.  [5.0] “wherein the video system is a slot-type device” ................................. 69 
`8.  [6.0] “wherein a slot for receiving a data media is positioned on a side of
`the door” ........................................................................................................ 69 
`9.  [7.0] “further comprising a wireless transmitter” .......................................... 71 
`10. [9.0] “further comprising a port for connecting to an external device” ........ 72 
`X.  Conclusion .......................................................................................................... 73 
`
`
`
`iii
`
`Page 4 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`
`
`I.
`
`1.
`
`I, Ralph V. Wilhelm, declare as follows:
`
`Introduction
`
`I have been retained by Johnson Safety, Inc. (“Johnson Safety” or
`
`“Petitioner”) as an independent expert consultant in this proceeding before the
`
`United States Patent and Trademark Office. Although I am being compensated at
`
`my standard rate of $500 per hour for the time I spend on this matter, no part of my
`
`compensation depends on the outcome of this proceeding, and I have no other
`
`interest in this proceeding.
`
`2.
`
`I understand that this proceeding involves U.S. Patent No. 7,245,274 (“the
`
`‘274 Patent”) (attached as Ex. 1001 to Johnson Safety’s petition). The application
`
`for the ‘274 Patent was filed on May 15, 2003, as U.S. Patent Application No.
`
`10/438,724, and the patent issued on July 17, 2007.
`
`3.
`
`I have been asked to consider whether certain references disclose or suggest
`
`the features recited in the claims of the ‘274 Patent. As explained in detail below,
`
`in my opinion, Chang (Ex. 1007) in view of Mathias (Ex. 1008) renders obvious
`
`Claims 1, 5-7, and 9 of the ‘274 Patent; Chang in view of Tseng (Ex. 1006) renders
`
`obvious Claim 11 of the ‘274 Patent; and Swaim (Ex. 1011) in view of Compaq
`
`Manual (Ex. 1012) renders obvious Claims 1, 5-7, and 9 of the ‘274 Patent.
`
`1
`
`Page 5 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`II. Qualifications
`4. My curriculum vitae, which includes a more detailed summary of my
`
`background, experience, and publications, is attached as Appendix A.
`
`5.
`
`I am currently the President of Wilhelm Associates, LLC, a consulting firm
`
`that I founded in 2001. The firm specializes in automotive electronics, telematics,
`
`systems engineering, data communications between systems and devices, and
`
`product/market and business strategies. In this role, I provide advice and
`
`assistance in the development and use of market assessment methodologies,
`
`product requirement definitions, product design, product and market strategy, and
`
`product implementation in my areas of technical expertise.
`
`6.
`
`I received a Bachelor of Science degree in Electrical Engineering from
`
`Cornell University in 1967, a Doctor of Philosophy degree in Ceramic
`
`Engineering/Material Science from Rutgers University in 1972, a Master of
`
`Business Administration degree in Operations and Strategy from the University of
`
`Michigan in 1987, and an Executive Management Program certificate from the
`
`University of Illinois in 1985.
`
`7.
`
`I was a Senior Research Scientist from 1971 to 1978 at General Motors
`
`Research Laboratories. Thereafter, from 1978 to 1984, I worked in General
`
`Motors Corporation’s AC Spark Plug Division as the Supervisor and Department
`
`Head of Materials Development.
`
`2
`
`Page 6 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`8.
`
`From 1984 to 2001, I worked at the AC Spark Plug Division and Delphi
`
`Delco Electronics Corporation, having held various positions. I was the
`
`Department Head of Advanced Instruments & Display from 1984 to 1989 and in
`
`this role, our technical group developed automotive applications using a variety of
`
`flat panel displays using a range of active and passive display technologies. Next,
`
`from 1989 to 1994, I was a Director of Advanced Development/Systems
`
`Integration. In this role, I oversaw the design and development of automotive
`
`technology systems, including, for example, a precursor system to the OnStar
`
`telematics system, navigation systems, advanced engine control systems, night
`
`vision systems, millimeter wave-based radar systems, wireless transmission of data
`
`and audio, and digital audio systems. From 1994 to 1997, I was a Vice President
`
`of Engineering for Asia/Pacific based in Singapore, and oversaw product launches
`
`for audio, powertrain control, and security systems, as well as the co-development
`
`of advanced systems with Toyota, Honda, Holdens, Daewoo, and other vehicular
`
`OEMs. From 1997 to 2001, I was a Product Line Manager in the Mobile Multi-
`
`Media Systems division. In this role, I managed product lines covering telematics,
`
`navigation, RSAV, and DSRC systems, some of which were later acquired and
`
`installed in vehicles by Toyota, General Motors, Honda, and Ford. Specifically in
`
`the RSAV (Rear Seat Audio Video) system development, our engineering group
`
`focused on entertainment systems that included flat panel displays, voice
`
`3
`
`Page 7 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`recognition systems, knob and touch screen input, and playback with tape and
`
`DVD media. One embodiment of this entertainment system development was
`
`designed and sold for production installation into Ford vehicles during this time
`
`period.
`
`9.
`
`In sum, I have over 40 years of experience in the field of automotive
`
`technologies and systems as a researcher, developer, inventor, technical leader, and
`
`consultant. My work has involved automotive electronic component technology,
`
`including human machine interface issues involving components such as displays,
`
`infotainment and entertainment systems, and the playback of audio and video for
`
`both front and rear seat vehicular passengers.
`
`III. Materials Reviewed
`10.
`
`In forming my opinions, I have reviewed the following documents:
`
` U.S. Patent No. 7,245,274 (attached as Ex. 1001 to Petitioner’s petition);
`
` The Prosecution History of the ‘274 patent (attached as Ex. 1002 to
`
`Petitioner’s petition);
`
` U.S. Patent Application Publication No. 2004/0130616 to Tseng
`
`(“Tseng,” attached as Ex. 1006 to Petitioner’s petition);
`
` U.S. Patent No. 6,871,356 to Chang (“Chang,” attached as Ex. 1007 to
`
`Petitioner’s petition);
`
`4
`
`Page 8 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
` International Publication No. WO 00/38951 to Mathias (“Mathias,”
`
`attached as Ex. 1008 to Petitioner’s petition);
`
` The Prosecution History of U.S. Patent Application No. 10/688,611 (“the
`
`‘611 App.) (attached as Ex. 1010 to Petitioner’s petition);
`
` U.S. Patent No. 6,685, 016 to Swaim et al. (“Swaim,” attached as Ex.
`
`1011 to Petitioner’s Petition);
`
` Compaq, Hardware Guide, Compaq Tablet PC TC1000 Series, document
`
`part no. 280133-001 (Nov. 2002) (“Compaq Manual,” attached as Ex.
`
`1012 to Petitioner’s Petition);
`
` PC Magazine, December 3, 2002 Issue, mentioning the TC1000 from
`
`Compaq Manual (attached as Ex. 1014 to Petitioner’s Petition) and PC
`
`Magazine, April 8, 2003 Issue, mentioning and showing the TC1000
`
`from Compaq Manual (attached as Ex. 1015 to Petitioner’s Petition),
`
`collectively, “PC Magazine TC1000 Articles.” In my opinion, PC
`
`Magazine is, and was at the time of the ‘274 Patent, well-known to be a
`
`widely distributed printed publication; and
`
` U.S. Patent No. 6,883,870 to Jost (“Jost,” attached as Ex. 1016 to
`
`Petitioner’s Petition).
`
`5
`
`Page 9 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`IV. Obviousness Principles
`11.
`
`I have been advised that a patent claim may be invalid as obvious if the
`
`differences between the subject matter patented and the prior art are such that the
`
`subject matter as a whole would have been obvious at the time the invention was
`
`made to a person having ordinary skill in the art. I have also been advised that
`
`several factual inquiries underlie a determination of obviousness. These inquiries
`
`include the scope and content of the prior art, the level of ordinary skill in the field
`
`of the invention, the differences between the claimed invention and the prior art,
`
`and any objective evidence of non-obviousness.
`
`12.
`
`I also have been advised that the law requires a “common sense” approach
`
`of examining whether the claimed invention is obvious to a person skilled in the
`
`art. For example, I have been advised that combining familiar limitations
`
`according to known methods is likely to be obvious when it does no more than
`
`yield predictable results.
`
`13.
`
`I have followed these principles in my analysis below.
`
`V.
`
`Person of Ordinary Skill in the Art
`14. The ‘274 Patent was filed on May 15, 2003. In my opinion, a person of
`
`ordinary skill in the art (“POSITA”) in May 2003 would possess a BS in electrical,
`
`mechanical, and/or computer science/engineering and/or some experience in
`
`6
`
`Page 10 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`connection with consumer automotive electronics and the basic principles and
`
`processes used in automotive design at the time.
`
`VI. Overview of the ‘274 Patent
`15. The ‘274 Patent relates to a portable video system that can be coupled to a
`
`vehicle headrest. Ex. 1001 at 3:6-8. The patent describes perceived problems in
`
`the prior art, specifically that known methods of mounting video systems to
`
`headrests do not allow for the video player and video screen to be removed from
`
`the vehicle. Id. at 1:10-25. The ‘274 Patent states that video systems that are not
`
`removable only allow users to use the video systems while occupying the vehicle,
`
`and only from particular vantage points within the vehicle. Id. Further, the ‘274
`
`Patent states that there is a risk of theft of video systems that are not removable
`
`from the vehicle while the vehicle is unattended. Id.
`
`16. To solve this problem, the ‘274 Patent discloses a video system that can
`
`purportedly be mounted to a headrest and subsequently removed from the headrest.
`
`Ex. 1001 at 3:34-42. Such is accomplished by fixing a “docking station 303” to
`
`“an internal support structure 305,” the docking station being able to receive, and
`
`hold in place, the video system. Id. at 3:10-35, FIGS. 3A-C.
`
`17. According to the ‘274 Patent, the video system can be subsequently
`
`disconnected from the docking station and operated autonomously from the
`
`docking station and headrest. Id. at 3:32-45. Once disconnected, the ‘274 Patent
`
`7
`
`Page 11 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`discloses that the video system can be connected to an optional battery or to an AC
`
`or DC current to supply power to the video system. Id.
`
`18. The basic components of the claimed invention are shown in FIGS. 3A and
`
`3C, reproduced below:
`
`
`
`19. As shown above, the docking station 303 is secured to an internal headrest
`
`support structure 305. FIG. 3A shows the video system has a base portion 307
`
`mounted in the docking station, while FIG. 3C shows the video system
`
`disconnected from the docking station. The docking station can be secured to the
`
`internal headrest support structure by a catch 401 or screw 402. Ex. 1001 at 3:20-
`
`30.
`
`8
`
`Page 12 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`20. Once the docking station is secured to the headrest, the video system may be
`
`inserted into the docking station. Id. To allow for the video system to be inserted,
`
`the docking station includes a quick release mechanism for securing and releasing
`
`the video system. Id. at 4:38-42. This is shown in FIGS. 7A and 7B, reproduced
`
`below:
`
`
`
`
`
`21. As shown above in FIG. 7A, the ‘274 Patent discloses that the quick release
`
`mechanism “can include a button 702 for releasing a latch 703, which is secured to
`
`the video system by pressing the video system 701 securely into the docking
`
`station 303.” Id. at 4:39-55. The latch mechanism 703 latches into a bottom
`
`portion of the video system 701. Id. A spring 704 secures the latch 703 in place.
`
`Then, the button 702 can be pressed to release the video system. Id.
`
`22. Alternatively, as shown above in FIG. 7B, the ‘274 Patent discloses that
`
`a rear portion 705 of the video system 701 can be secured by a convex
`portion 706 that fits within a concave portion 707 in the docking
`
`9
`
`Page 13 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`station 303. As the video system 701 is pressed into the docking
`station 303, a wall of the docking station 708 flexes away from the
`rear portion of the video player until the convex portion 706 is aligned
`with the concave portion 707. The convex portion 706 and the
`concave portion 707 cooperate to secure the video system 701 to the
`docking station 303.
`Ex. 1001 at 4:49-65.
`
`23. The video system described in the ‘274 Patent is a “slot-type video system”
`
`that has a slot that receives a media stored on a medium, such as DVDs, MPEG
`
`layer 3 disks, or video game disks. Id. at 3:11-19.
`
`24.
`
`In one embodiment, the slot for receiving the medium is on the side, as
`
`shown in FIGS. 3A and 3B, reproduced below:
`
`
`
`10
`
`Page 14 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`25. As shown above, the video system includes a base portion 307 (marked in
`
`diagonal lines above) and a video screen portion 306 attached to the base potion
`
`307 by a hinge 304. Id. at 3:20-35. The hinge 304 allows the video screen portion
`
`to pivot away from the base portion. Id. In the embodiment shown in FIGS. 3A
`
`and 3B, above, when the video system is secured in the docking station 303,
`
`pivoting the video screen portion 306 away from the base portion 307 allows a user
`
`access to a slot 302 for inserting media stored on a medium. Id.
`
`26.
`
`In another embodiment described in the ‘274 Patent, the base portion
`
`alternatively receives the data medium. A door 502 that also includes the video
`
`screen and other controls pivots away from a base portion 503 via a hinge 504 to
`
`allow the media player to be accessed and the data medium to be inserted after
`
`opening a cover 510. FIGURE 5A illustrates the video system with the door
`
`closed, while FIGURE 5D illustrates what is seen when the door is open, both of
`
`which are reproduced below:
`
`
`
`11
`
`Page 15 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`27. The ‘274 Patent further discloses that the video system may have input and
`
`output ports, including audio/visual input and output ports 802, a headphone port
`
`803, and a power port 804. Ex. 1001 at 4:66-5:4.
`
`VII. The State of the Art at the Time of the Claimed Invention
`28. The inventor of the ‘274 Patent does not claim to have invented installing
`
`video systems that include the capability of playing DVDs, MPEGs, or video
`
`games in headrests, or the use of a pivotable display. Indeed, each of these
`
`components was known in the art. See Ex. 1001 at 1:10-25. Further, while the
`
`inventor of the ‘274 Patent claims that removable video systems were not known in
`
`the prior art (see id.), removable video systems were indeed known, contrary to
`
`that stated in the ‘274 Patent.
`
`A. Chang
`29. U.S. Patent No. 6,871,356 to Chang (“Chang”) was filed on February 7,
`
`2003. Ex. 1007. Chang discloses a video system that “includes a first video
`
`source, a second video source, a first video monitor, a second video monitor, an
`
`audio signal receiver, and a wireless transmitter.” Chang, Ex. 1007 at Abstract.
`
`The video system of Chang provides a video source 52 for playing media to be
`
`displayed on a video monitor in a vehicle (Ex. 1007 at 4:50-60), as shown in FIG.
`
`2 below:
`
`12
`
`Page 16 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`
`
`30. Chang discloses a screen structure 416 mounted within the rear of a headrest
`
`of a vehicle. Ex. 1007 at 12:13-26, Fig. 7A. To accomplish such, Chang discloses
`
`a housing 418 that is embedded into a headrest of a vehicle, as shown in FIG. 13B
`
`(Ex. 1007, at 12:29-32), below:
`
`
`
`13
`
`Page 17 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`31. Chang further discloses that the housing “includes a plurality of apertures
`
`478 (FIG. 9A) that cooperate with mounting hardware, such as screws, to secure
`
`the housing 418 to the headrest 412,” (Id. at 14:1-10), as shown below in FIG. 9A:
`
`
`
`
`
`32. These screws run through the back of the housing 418 and into the headrest
`
`to secure the housing in place within the interior of the headrest. Id. To attach the
`
`screen structure to the housing, a hinge (436, 444) pivotally connects the screen
`
`structure to the housing as shown in FIGS. 8A and 9B of Chang, reproduced
`
`below:
`
`14
`
`Page 18 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`
`33. FIGS. 11A and 11B of Chang, reproduced below, illustrate the pivotal
`
`connection of the screen structure 416 relative to the housing 418.
`
`
`
`15
`
`Page 19 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`B. Mathias
`34. PCT Application Publication No. WO 00/38951 to Mathias et al.
`
`(“Mathias”) published on July 6, 2000, from an international application filed on
`
`December 28, 1999, which claims priority to U.S. Provisional Application No.
`
`60/113,876, filed on December 28, 1998.
`
`35.
`
`In one embodiment, Mathias discloses an “integrated visual display/digital
`
`media player in the form of an LCD/DVD unit or video display system and a
`
`docking member which is movably mounted within a console.” Ex. 1008 at 3:2-4.
`
`Thus, in this embodiment of Mathias, the video player is a component of the
`
`display. FIG. 4 of Mathias is reproduced below:
`
`
`
`
`
`
`
`16
`
`Page 20 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`36. Mathias states that a “video display system 30 includes a DVD player 32
`
`and a screen 40 integrated in a screen console 38 forming a video player unit 79
`
`releasably attached to a housing panel 80.” Ex. 1008 at 10:2-4. Mathias further
`
`states that a “screen console 38 is moveably associated with” a housing 34, such
`
`that the screen console “is rotatably or pivotally associated with the housing 34
`
`through the use of a torque hinge.” Ex. 1008 at 8:15-17. The screen console 38 of
`
`Mathias may also be removed from the housing 34, as shown in FIG. 5,
`
`reproduced below:
`
`37.
`
`In another embodiment of Mathias, a base unit includes the DVD player,
`
`rather than the screen console, as shown in FIG. 1, reproduced below:
`
`
`
`17
`
`Page 21 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`
`
`38. Figure 1 of Mathias shows a housing 34 which includes a DVD player 32,
`
`while a display pivots out from the housing 34. Ex. 1008 at 6:17-19. Further,
`
`Mathias suggests “this video display system 30 could also be mounted to other
`
`interior components located within the automobile, including, but not limited to,
`
`seat backs, center consoles, etc.” Ex. 1008 at 11:14-17.
`
`C. Tseng
`39. U.S. Patent Application Publication No. 2004/0130616 to Tseng (“Tseng”)
`
`is a publication of an application filed on January 3, 2003. Ex. 1006. Tseng
`
`discloses a video system having a video screen connected to an “audio/video”
`
`source by a hinge, where the audio/video source may be capable of playing various
`
`18
`
`Page 22 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`types of media, including CDs, DVDs, and video games. Ex. 1006 at [0004],
`
`claim 9. The audio/video source is attached to the back of a headrest of a vehicle.
`
`Id. at [0004], [0007]. The video system of Tseng is shown in FIGS. 1 and 2,
`
`reproduced below:
`
`
`
`
`
`19
`
`Page 23 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`D.
`Swaim
`40. U.S. Patent No. 6,685,016 to Swaim et al. (Ex. 1011) was filed on December
`
`1, 2001. Swaim discloses “an entertainment system, comprising an entertainment
`
`device, a suspension platform, and an optional storage bag” which may include a
`
`DVD player and a viewing screen, that is strapped to seats in a vehicle. Ex. 1011
`
`at 4:65-5:1, 7:35-42. FIG. 7 illustrates the overall system, reproduced below:
`
`
`
`E. Compaq Manual
`
`41. Compaq, Hardware Guide, Compaq Tablet PC TC1000 Series, document
`
`part no. 280133-001 (Ex. 1012) is a hardware manual for the Compaq Tablet PC
`
`TC1000, published in November 2002. Compaq Manual discloses a tablet PC
`
`(“TC1000”) capable of playing digital media, as TC1000 allows users to connect a
`
`20
`
`Page 24 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`media drive (such as a DVD drive), via an external MultiBay or via USB. Ex.
`
`1012 at 4-1. Compaq Manual further states “when you insert a diskette, CD, or
`
`DVD into the system, the tablet PC can play the medium.” Ex. 1012 at 4-8. The
`
`TC1000 depicted in Compaq Manual is shown below:
`
`
`
`Ex. 1012 at 2-18.
`
`42. Additionally, Exs. 1014 and 1015 (collectively “PC Magazine TC1000
`
`Articles”) are each excerpts from various issues of PC Magazine, dated December
`
`3, 2002 and April 8, 2003, respectively. PC Magazine is a well-known printed
`
`publication. As such, these PC Magazine TC1000 Articles are each § 102(a) art.
`
`In my opinion, each disclose a TC1000 unit to a person of ordinary skill in the art.
`
`The Compaq Manual also represents (1) the understanding of a POSITA with
`
`21
`
`Page 25 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`respect to the disclosure in the TC1000 in the PC Magazine articles, as well as (2)
`
`what the TC 1000 inherently discloses.
`
`F.
`
`Jost
`
`43. U.S. Patent No. 6,883,870 to Jost (Ex. 1016) issued April 26, 2005, from an
`
`application filed March 20, 2002. Jost discloses a headrest for a vehicle
`
`configured to house a monitor. Ex. 1016, 3:5-35.
`
`VIII. Claim Construction
`
`44.
`
`I have been advised that the first step of assessing the validity of a patent
`
`claim is to interpret or construe the meaning of the claim.
`
`45.
`
`I understand that Petitioner has proposed the constructions set forth below.
`
`A. Claim 1: “coupled”
`
`46.
`
`I understand that Petitioner has proposed to construe the term “coupled” as
`
`its ordinary, reasonable, and broad meaning of “connected.”
`
`B. Claim 1: “an internal headrest support structure”
`
`47.
`
`I understand that Petitioner has proposed to construe the term “an internal
`
`headrest support structure” in light of the specification as “a support structure, all
`
`or a part of which is disposed inside a headrest.”
`
`22
`
`Page 26 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`C. Claim 11: “wherein the base portion accommodates a media
`player”
`
`48.
`
`I understand that Petitioner has proposed to construe the term “wherein the
`
`base portion accommodates a media player” in light of the specification as “the
`
`base portion, and not the display, incorporates a media player.”
`
`D. Claims 5 and 6: “slot-type device”
`
`49.
`
`I understand that Petitioner has proposed to construe the term “slot-type
`
`device” as “a device that has a slot that receives a data media into a mechanism for
`
`accessing data stored on the medium.”
`
`IX. Certain References Render Obvious All of the Limitations Claimed in
`Claims 1, 5-7, 9, and 11 of the ‘274 Patent
`A. The Combination of Chang in view of Mathias Renders Obvious
`Claims 1, 5-7, and 9 of the ‘274 Patent
`
`50.
`
`It is my opinion that Chang in view of Mathias renders claims 1, 5-7, and 9
`
`of the ‘274 Patent obvious, as set forth below.
`
`1.
`
`[1.0] “A video system”
`
`51. Chang discloses a video system. Chang discloses “[a] mobile video system”
`
`that “includes a first video source, a second video source, a first video monitor, a
`
`second video monitor, an audio signal receiver, and a wireless transmitter.” Ex.
`
`1007, Abstract. The video system of Chang provides a video source 52 for playing
`
`media to be displayed on a video monitor. Ex. 1007, 4:50-60; see also Chang,
`
`FIG. 2, below:
`
`23
`
`Page 27 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`
`52. Mathias also discloses a video system because Mathias discloses an
`
`“integrated visual display/digital media player in the form of an LCD/DVD unit or
`
`video display system and a docking member which is movably mounted within a
`
`console.” Ex. 1008, 3:1-7; see also Mathias, FIG. 4, below:
`
`
`
`
`
`24
`
`Page 28 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`2.
`
`[1.1] “a base unit coupled to an internal headrest support
`structure”
`
`53. Chang discloses “a base unit coupled to an internal headrest support
`
`structure.” Chang discloses a housing 418 that is embedded into a headrest of a
`
`vehicle. Ex. 1007, 12:28-32; see also Chang, FIG. 13B, below:
`
`
`54. Chang further discloses that the housing “includes a plurality of apertures
`
`478 (FIG. 9A) that cooperate with mounting hardware, such as screws, to secure
`
`the housing 418 to the headrest 412.” Ex. 1007, 14:1-10; see also Chang, FIG. 9,
`
`below:
`
`25
`
`Page 29 of 94
`
`PETITIONER'S EXHIBIT 1013
`
`

`
`
`In my opinion, it is clear that these screws must run through the back of the
`
`
`
`55.
`
`housing 418 and into the headrest to secure the housing to the interior of the
`
`headrest.
`
`56. As such, Chang explicitly discloses securing the housing to the interior of
`
`the headrest, i.e., coupling a base unit to an internal headrest support structure.
`
`3.
`
`[1.2] “a door pivotally connected to the ba