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`PATENT NO. 8,155,342
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
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`VOLKSWAGEN GROUP OF AMERICA, INC.
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`Petitioner
`v.
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`BLITZSAFE TEXAS, LLC
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`Patent Owner
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`
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`Patent No. 8,155,342
`Issue Date: April 10, 2012
`Title: MULTIMEDIA DEVICE INTEGRATION SYSTEM
`__________________________________________________________________
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`PATENT OWNER’S PRELIMINARY RESPONSE
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`Case No. IPR2016-01445
`__________________________________________________________________
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`TABLE OF CONTENTS
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`INTRODUCTION ........................................................................................... 1
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`SUMMARY OF ARGUMENTS .................................................................... 1
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`I.
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`II.
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`III. CLAIM CONSTRUCTION ............................................................................ 6
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`IV. CLAYTON IS NOT PRIOR ART................................................................... 7
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`V.
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`THE PETITION SUFFERS FROM EVIDENTIARY DEFICIENCIES ...... 27
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`A.
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`The Alleged Grounds Rely On Unfiled Prosecution History
`“Evidence” ........................................................................................... 27
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`B.
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`The Andrews Declaration Is Fatally Deficient ................................... 29
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`VI. PETITIONER HAS NOT DEMONSTRATED A REASONABLE
`LIKELIHOOD OF SUCCESS FOR THE GROUNDS ADVANCED
`IN THE PETITION AND THE PETITION SHOULD BE DENIED .......... 31
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`A.
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`B.
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`C.
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`D.
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`E.
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`Requirements for Showing Obviousness Under 35 U.S.C. §
`103. ...................................................................................................... 31
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`The Petition Fails to Address Each Claim Element of
`Independent Claims 49, 73, 97, and 120. ............................................ 33
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`Independent Claims 49, 73, 97, and 120 Are Not Obvious
`Because the Proposed Combinations Fail to Establish
`Fundamental Requirements ................................................................. 40
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`Independent Claims 49, 73, 97, and 120 Are Not Obvious Over
`the Silvester Combination ................................................................... 43
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`Dependent Claims 50-57, 62-64, 66, 68, 70, 71, 74-80, 94, 95,
`99-103, 106, 109-111, 113, 115 Are Not Obvious ............................. 46
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`VII. CONCLUSION .............................................................................................. 46
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`ii
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`TABLE OF AUTHORITIES
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`IPR2016-01445
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`PATENT NO. 8,155,342
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` Page(s)
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`Cases
`Apple, Inc. v. Contentguard Holdings, Inc.,
`IPR2015-00355 (PTAB, June 26, 2015) ............................................................ 31
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`C.B. Distributors, Inc. v. Fontem Holdings 1 B.V.,
` IPR2013-00387 (PTAB, Dec. 24, 2014) ........................................................... 32
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`Cisco Sys., Inc., v. C-Cation Techs., LLC,
`IPR2014-00454 (PTAB, Aug. 29, 2014) ............................................................ 32
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`GN Resound A/S v. Oticon A/S,
`IPR2015-00103 (PTAB, June 18, 2015) ........................................................ 4, 38
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`Graham v. John Deere Co.,
`383 U.S. 1 (1966) .........................................................................................passim
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`Indus. v. Zipshade Indus.,
`IPR2015-00488 (PTAB, July 24, 2015) ............................................................. 32
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`In re Kahn,
`441 F.3d 977 (Fed. Cir. 2006) ............................................................................ 31
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`KSR Int’l Co. v. Teleflex Inc.,
`550 U.S. 398 (2007) .....................................................................................passim
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`Plant Science, Inc. v. The Andersons, Inc.,
`IPR2014-00939 (PTAB, Dec. 17, 2014) ............................................................ 32
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`Wright Medical Technology, Inc. v. Orthophoenix, LLC,
`IPR2014-00912 (PTAB, Dec. 16, 2014) ........................................................ 3, 29
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`Zimmer Biomet Holdings, Inc. v. Four Mile Bay, LLC,
`IPR2016-00011 (PTAB, April 1, 2016) ......................................................... 3, 29
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`Statutes
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`35 U.S.C. § 103 ........................................................................................................ 31
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`35 U.S.C. § 314(a) ..................................................................................................... 6
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`iii
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`Other Authorities
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`37 CFR § 42.6(a)(3) ................................................................................... 2, 5, 29, 32
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`37 CFR § 42.22(a)(2) ........................................................................................... 4, 33
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`37 CFR § 42.63(a) ................................................................................................ 2, 28
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`37 CFR § 42.104(b)(4) ............................................................................... 4, 5, 33, 38
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`EXHIBIT LIST
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`Exhibit #
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`Exhibit Name
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`2001
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`2002
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`2003
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`U.S. Pat. App. No. 11/071,667 Published as U.S. Pat. App. Pub.
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`No. 2005/0239434
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`IPR2016-00418 Decision
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`IPR2016-00419 Decision
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`v
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`I.
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`INTRODUCTION
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`Patent Owner, Blitzsafe Texas, LLC (“Patent Owner”), submits this
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`Preliminary Response to the Petition filed by Volkswagen Group of America, Inc.
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`(“Petitioner”) requesting inter partes review of Claims 49-57, 62-64, 66, 68, 70,
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`71, 73-80, 94, 95, 97, 99-103, 106, 109-111, 113, 115, and 120 (the “Challenged
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`Claims”) of U.S. Patent No. 8,155,342 (“the ’342 Patent”). The Petition is
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`severely deficient for myriad reasons and should not be instituted.
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`SUMMARY OF ARGUMENTS
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`II.
`As a preliminary matter, Clayton is not prior art to the ’342 Patent because
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`the effective filing date of Claims 49-54, 56, 62-64, 66, 68, 70, 71, 73-78, 94, 95,
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`97, 99-101, 106, 109-111, 113, 115, and 120 is March 3, 2005. The
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`aforementioned Claims are entitled to the benefit of the filing date of U.S. Patent
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`Application No. 11/071,667 (“the ’667 Application”) (Ex. 2001) because the ’342
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`Patent specifically references the ’667 Application and the ’667 Application
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`sufficiently supports each limitation of the aforementioned Claims. Because
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`Petitioner does not assert Clayton’s provisional application number 60/651,961
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`(“the ’961 provisional) as prior art, Petitioner effectively concedes that the ’961
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`provisional application does not satisfy the written description requirement and
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`that Clayton is only available as prior art as of its non-provisional filing date,
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`December 8, 2005. Thus, Clayton is not prior art and the Board must deny
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`1
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`institution of Ground 1.
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`With respect to Grounds 1 and 2, Patent Owner respectfully submits that the
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`alleged obviousness grounds are severely deficient. First, the Petition is not
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`accompanied by sufficient evidence to substantiate its positions because the
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`Petition cites to prosecution-history “evidence” that is not part of the record as an
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`exhibit. The Board requires that “[a]ll evidence must be filed in the form of an
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`exhibit.” 37 C.F.R. § 42.63(a). Despite this requirement, Petitioner materially
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`supports each obviousness allegation and its sole proposed claim construction with
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`excerpts or paraphrases to the prosecution history of the ’342 Patent.
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`Notwithstanding the inaccuracies and lack of context surrounding the unsupported
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`excerpts and paraphrases, Petitioner’s obviousness allegations depend on the
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`alleged prosecution events for a motivation or reason to combine references for
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`each of its proposed grounds. Because the lack of supporting evidence renders the
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`obviousness grounds deficient, the Board must deny institution on all grounds.
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`Second, the Andrews Declaration is deficient because Mr. Andrews fails to
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`identify a level of ordinary skill in the art and explain how a person having
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`ordinary skill in the art would understand and modify the references. Expert
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`testimony that does not disclose the underlying facts or data on which the opinion
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`is based is entitled to little or no weight. 37 C.F.R. § 42.65(a). Where a Petition
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`relies on expert testimony, the Board has held that the expert’s failure to show how
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`a person of ordinary skill in the art would interpret the references or modify the
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`references is fatal to an obviousness analysis. See, e.g., Wright Medical
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`Technology, Inc. v. Orthophoenix, LLC, IPR2014-00912, Paper 9 at 1 (December
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`16, 2014) (Institution denied). The Board has also held expert declarations to be
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`unpersuasive for providing broad conclusory statements. See, Zimmer Biomet
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`Holdings, Inc. v. Four Mile Bay, LLC, IPR2016-00011, Paper 8 at 11 (April 1,
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`2016) (Institution denied). The Andrews Declaration does not identify a level of
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`ordinary skill in the art. The Andrews Declaration is devoid of any explanations as
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`to how a person having ordinary skill in the art would (1) understand the prior art,
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`and (2) modify the prior art references to teach a claim limitation. Because of
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`these deficiencies, the Andrews Declaration fails to disclose underlying facts for
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`which it bases its obviousness conclusions on; neglects to show how a person of
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`ordinary skill in the art would understand or modify the references; and merely
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`amounts to broad conclusory statements. The Board should find the Andrews
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`Declaration unpersuasive, afford the Andrews Declaration no weight, and find
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`each obviousness allegation to be unsupported and fatally deficient. Accordingly,
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`the Petition should be denied institution on all grounds.
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`Third, the Petition is deficient because the alleged grounds fail to address a
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`number of claim elements. The Board requires that “[t]he petition must specify
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`where each element of the claim is found in the prior art patents or printed
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`publications relied upon.” 37 C.F.R. § 42.104(b)(4). The Board also requires “[a]
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`full statement of the reasons for the relief requested, including a detailed
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`explanation of the significance of the evidence.” 37 C.F.R. § 42.22(a)(2). Each
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`obviousness ground addresses only select portions of limitations of the
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`independent Claims 49, 73, 97, and 120. Petitioner’s claim charts do not cure
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`these deficiencies because this Board has expressly held that claim charts alone are
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`not enough to show a reasonable likelihood of success and that merely presenting
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`citations and quotes in claim charts alone is a violation of 37 C.F.R.
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`§ 42.104(b)(4). See, GN Resound A/S v. Oticon A/S, IPR2015-00103, Paper 13 at 6
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`(June 18, 2015) (“It is a requirement of a Petition to align the evidence and
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`arguments with the various limitations of the Challenged Claims.”). Accordingly,
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`the Board must deny institution on all grounds because the Petition fails to meet
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`the fundamental threshold of addressing each claim element.
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`Fourth, the Silvester combination fails to satisfy the required KSR and
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`Graham tests because the Petition does not identify the level of ordinary skill in
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`the art; does not identify the differences between the claims and the asserted
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`references; neglects to provide a fact-based rationale for combining the references;
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`and does not explain the specific ways the references are to be combined.
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`Additionally, Silvester does not disclose or suggest “audio generated by the
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`portable device” as required by Claims 47, 73, 97, and 120. Accordingly, the
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`institution must be denied in its entirety.
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`Last, in addition to the above deficiencies, Petitioner’s request for inter
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`partes review should be denied for at least the following reasons addressed more
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`fully below in this Preliminary Response:
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`(1) The Petition fails to construe several claim terms.
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`(2) The Petition does not “specify where each element of the claim is found
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`in the prior art patents or printed publications relied upon,” as required by
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`37 C.F.R. § 42.104(b)(4), because the Petition has at least one of the following
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`deficiencies: (i) failing to map each claim term to a specific teaching from an
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`asserted reference; (ii) providing citations to the asserted references that do not
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`teach the claim elements against which such citations are applied; and
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`(iii) mischaracterizing the citations to the asserted references.
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`(3) The Petition fails to identify the difference(s) between the claims and the
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`asserted references as required by Graham v. John Deere Co., 383 U.S. 1, 17–18
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`(1966).
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`(4) The Petition fails to identify the level of skill in the art as required by
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`Graham, 383 U.S. 1, 17–18.
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`(5) The Petition improperly attempts to support its assertions of obviousness
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`with mere conclusory statements and by impermissibly incorporating by reference
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`arguments from the Andrews Declaration in violation of 37 C.F.R. § 42.6(a)(3).
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`Due to at least these deficiencies, the Petition does not establish “a
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`reasonable likelihood that the Petitioner would prevail with respect to at least one
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`of the claims challenged in the Petition.” 35 U.S.C. § 314(a). Patent Owner
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`explicitly reserves the right to provide further distinctions between the prior art and
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`the Challenged Claims. The deficiencies of the Petition noted herein, however, are
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`sufficient for the Board to find that Petitioner has not met its burden to
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`demonstrate a reasonable likelihood that it would prevail in showing
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`unpatentability of any of the Challenged Claims. Patent Owner, therefore,
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`respectfully requests denial of the Petition.
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`III. CLAIM CONSTRUCTION
`Patent Owner disagrees with Petitioner’s sole proposed claim construction of
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`“integration system.” The Petition should be denied institution on all grounds for
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`failure to construe the claims as set forth below and for failure to explain how the
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`construed claims are unpatentable in accordance with the constructions set forth
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`below.
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`Previously, in IPR2016-00418 and IPR2016-00419, the Board construed the
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`’342 Patent’s claim terms under their broadest reasonable construction in light of
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`the patent’s specification. (Ex. 2002 at 7; Ex. 2003 at 8.) In doing so, the Board
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`expressly construed the certain terms. For the purposes of this IPR only, Patent
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`Owner proposes that the Board adopt the same constructions as reproduced below.
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`Integration Subsystem: The Board construed the term as “A subsystem to
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`perform at least: (1) connecting one or more portable devices or inputs to the car
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`audio/video system via an interface, (2) processing and handling signals, audio,
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`and/or video information, (3) allowing a user to control the one or more portable
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`devices via the car audio/video system, and (4) displaying data from the one or
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`more portable devices on the car audio/video system.”
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`Car Audio/Video System: The Board construed the term as “a car audio
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`system, a car video system, or a car audio and video system.”
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`Device Presence Signal: The Board construed the term as “a signal
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`indicating that a portable device is connected to the car audio/video system through
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`the integration subsystem.
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`IV. CLAYTON IS NOT PRIOR ART
`Clayton is not prior art to the ’342 Patent with respect to at least Claims 49-
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`54, 56, 62-64, 66, 68, 70, 71, 73-78, 94, 95, 97, 99-101, 106, 109-111, 113, 115,
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`and 120.
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`Claims 49-54, 56, 62-64, 66, 68, 70, 71, 73-78, 94, 95, 97, 99-101, 106, 109-
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`111, 113, 115, and 120 of the ’342 Patent are entitled to the benefit of the filing
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`date of U.S. Patent Application No. 11/071,667 (“the ’667 Application”)
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`(Ex. 2001), filed on March 3, 2005. The ’342 Patent makes specific reference to
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`the ’667 Application. (See Ex. 1001 at 1, “Related U.S. Application Data.”) Each
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`limitation of Claims 49-56, 62-64, 66, 68, 70, 71, 73-78, 94, 95, 97, 99-101, 106,
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`109-111, 113, 115, and 120 is sufficiently supported by the ’667 Application. The
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`support for each limitation of the claims as described in the ’667 Application is set
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`forth in the charts below, thus demonstrating that the inventor, Ira Marlowe,
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`conceived of and constructively reduced to practice the claimed invention prior to
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`the filing date of the Clayton application (Ex. 1006). Thus, the effective filing date
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`of the ’342 Patent, in particular at least Claims 49-54, 56, 62-64, 66, 68, 70, 71, 73-
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`78, 94, 95, 97, 99-101, 106, 109-111, 113, 115, and 120, is March 3, 2005 which
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`antedates the filing date of the Clayton application.
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`Petitioner does not assert that Clayton is prior art as of the filing date of its
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`provisional application number 60/651,961 (“the ’961 provisional) and thus
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`effectively concedes that the ’961 provisional does not satisfy the written
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`description requirement. Nonetheless, Patent Owner submits that the ’961
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`provisional does not sufficiently support Clayton and does not satisfy the written
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`description requirement. Clayton is not available as prior art of the ’961
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`provisional’s filing date and is only available as prior art as of its non-provisional
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`filing date, December 8, 2005. Thus, Clayton is not prior art.
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`The chart below sets forth in greater detail where each limitation of each of
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`the Claims finds support in the ’667 Application (all cites in the chart below are to
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`Exhibit 2001).
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`8
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`Claim Limitation
`49[p]2. A multimedia device integration
`system, comprising:
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`49[1] an integration subsystem in
`communication with a car audio/video
`system;
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`Support in ’667 Application1
`FIG. 10 is a block diagram showing an
`alternate embodiment of the multimedia
`device integration system of the present
`invention, indicated generally at 600,
`wherein the interface 630 is
`incorporated within a car stereo or car
`video system 610. The interface 630 is
`in electrical communication with the
`control panel buttons 620, display 615,
`and associated control circuitry 625 of
`the car stereo or video system 610.
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`[0127-128]
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`FIG. 10 is a block diagram showing an
`alternate embodiment of the multimedia
`device integration system of the present
`invention, indicated generally at 600,
`wherein the interface 630 is
`incorporated within a car stereo or car
`video system 610. The interface 630 is
`in electrical communication with the
`control panel buttons 620, display 615,
`and associated control circuitry 625 of
`the car stereo or video system 610. The
`interface 630 could be manufactured on
`a separate printed circuit board
`positioned within the stereo or video
`system 610, or on one or more existing
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`1 In general the Claims are also supported by material in the original application for
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`the ’786 Patent; however, this chart focuses on the material added in continuations-
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`in-part and is meant to be exemplary.
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`2 Claims separated by limitation for ease of reference.
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`9
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`49[2] and 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,
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`circuit boards of the stereo or video
`system 610. An after-market device 635
`can be put into electrical communication
`with the interface 630 via a port or
`connection on the car stereo or video
`system 610, and integrated for use with
`the car stereo or video system 610.
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`[0127-128]
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`The integration system of the present
`invention provides for control of a
`portable audio or video device, or other
`device, through the controls of the car
`stereo or video system. As such,
`controls on the steering wheel, where
`present, may also be used to control the
`portable audio device or other device.
`Further, in all embodiments of the
`present invention, communication
`between the after-market device and a
`car stereo or video system can be
`accomplished using known wireless
`technologies, such as Bluetooth.
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`[0126-127]
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`49 [3] wherein said integration
`The device 635 can be controlled using
`the control panel buttons 620 of the car
`subsystem obtains, using said wireless
`stereo or video system 610, and
`communication link, information about
`information from the device 635 is
`an audio file stored on the portable
`formatted by the interface 630 and
`device, transmits the information to the
`displayed in the display 615 of the car
`car audio/video system for subsequent
`stereo or video system 610.
`display of the information on a display
`[0128]
`of the car audio/video system,
`49 [4] instructs the portable device to
`Additionally, control commands
`generated at the car stereo or car video
`play the audio file in response to a user
`device 610 are converted by the
`selecting the audio file using controls of
`the car audio/video system, and receives
`interface 630 into a format (protocol)
`10
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`audio generated by the portable device
`over said wireless communication link
`for playing on the car audio/video
`system.
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`compatible with the multimedia device
`635, and are dispatched thereto for
`execution. A plurality of multimedia
`devices could be integrated using the
`interface 630, as well as one or more
`auxiliary input sources 640. The after-
`market device 635 could comprise any
`audio, video, or telecommunications
`device, including, but not limited to, a
`CD player, CD changer, digital media
`player (e.g., MP3 player, MP4 player,
`WMV player, Apple iPod, or any other
`player), satellite radio (e.g., XM, Sirius,
`Delphi, etc.), video device (e.g., DVD
`player), cellular telephone, or any other
`type of device or combinations thereof.
`[0128]
`FIG. 10 is a block diagram showing an
`alternate embodiment of the multimedia
`device integration system of the present
`invention, indicated generally at 600,
`wherein the interface 630 is
`incorporated within a car stereo or car
`video system 610.
`[0127]
`FIG. 10 is a block diagram showing an
`alternate embodiment of the multimedia
`device integration system of the present
`invention, indicated generally at 600,
`wherein the interface 630 is
`incorporated within a car stereo or car
`video system 610.
`[0127]
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`Further, in all embodiments of the
`present invention, communication
`between the after-market device and a
`car stereo or video system can be
`accomplished using known wireless
`11
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`50. The system of claim 49, wherein
`said integration subsystem is positioned
`within the car audio/video system.
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`51. The system of claim 50, wherein
`said first wireless interface is positioned
`within the car audio/video system.
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`52. The system of claim 51, wherein
`said second wireless interface is
`positioned within the portable device.
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`53. The system of claim 49, wherein
`said integration subsystem receives a
`control command issued at the car
`audio/video system in a format
`incompatible with the portable device,
`processes the control command into a
`formatted command compatible with the
`portable device, and dispatches the
`processed control command to the
`portable device for execution thereby.
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`IPR2016-01445
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`PATENT NO. 8,155,342
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`technologies, such as Bluetooth.
`[0126]
`Further, in all embodiments of the
`present invention, communication
`between the after-market device and a
`car stereo or video system can be
`accomplished using known wireless
`technologies, such as Bluetooth.
`[0126], Fig. 10
`Additionally, control commands
`generated at the car stereo or car video
`device 610 are converted by the
`interface 630 into a format (protocol)
`compatible with the multimedia device
`635, and are dispatched thereto for
`execution.
`
`The present invention also includes
`logic for converting signals from an
`OEM car stereo system for use with a
`digital media device such as an MP3,
`MP4, or Apple iPod player. Shown
`below are code samples for allowing
`commands and data to be exchanged
`between a Ford car stereo and an Apple
`iPod device:
`
` 3
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` TABLE 3 //decoding Ford "play"
`command :41-C0-80-CA-01+ if (
`ACP_rx_ready == ON ) {
`ACP_rx_ready = OFF; ACP_rx_taddr =
`ACP_rx_buff[1]; ACP_rx_saddr =
`ACP_rx_buff[2]; ACP_rx_data1 =
`ACP_rx_buff[3]; ACP_rx_data2 =
`ACP_rx_buff[4]; ACP_rx_data3 =
`ACP_rx_buff[5]; if ( (ACP_rx_saddr ==
`0x80) ) { switch ( ACP_rx_taddr ) {
`case 0xC0: if ( ACP_rx_data1 ==
`0xCA) { if ( ACP_rx_data2 == 0x01 ) {
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`PATENT NO. 8,155,342
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`flags.ACP_play_req = 1; } break; }
`break; } }
`
`In the code portion shown in Table 3, a
`"Play" command selected by a user at
`the controls of a Ford OEM car stereo is
`received, and portions of the command
`are stored in one or more buffer arrays.
`Then, as shown below in Table 4, the
`decoded portions of the command stored
`in the one or more buffer arrays are used
`to construct a "Play/Pause" command in
`a format compatible with the Apple
`iPod device, and the command is sent to
`the Apple iPod for execution thereby:
`
` 4
`
` TABLE 4 // encoding iPod
`"play/pause" command 0xFF 0x55 0x03
`0x02 0x00 0x01 0xFA if (
`iPod_play_req == ON ) { iPod_play_req
`= OFF; iPod_tx_data[0] = 0x55;
`iPod_tx_data[1] = 0x03;
`iPod_tx_data[2] = 0x02;
`iPod_tx_data[3] = 0x00;
`iPod_tx_data[4] = 0x01;
`iPod_tx_counter = 5; iPod_tx_ready =
`ON; }
`
`[0110-0111,0128]
`The device 635 can be controlled using
`the control panel buttons 620 of the car
`stereo or video system 610, and
`information from the device 635 is
`formatted by the interface 630 and
`displayed in the display 615 of the car
`stereo or video system 610.
`[0128]
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`54. The system of claim 49, wherein
`said integration subsystem receives data
`generated by the portable device in a
`format incompatible with the car
`audio/video system, processes the data
`into formatted data compatible with the
`car audio/video system, and transmits
`the processed data to the car audio/video
`system for subsequent display of the
`processed data on a display of the car
`
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`audio/video system.
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`56. The system of claim 49, wherein
`said integration subsystem generates a
`device presence signal and transmits the
`device presence signal to the car
`audio/video system to maintain the car
`audio/video system in a state responsive
`to the portable device.
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`If a positive determination is made in
`step 106, a CD handling process,
`indicated as block 108, is invoked,
`allowing the CD player/changer to
`exchange data and audio signals with
`any existing car stereo system.
`Beginning in step 110, a signal is
`generated by the present invention
`indicating that a CD player/changer is
`present, and the signal is continuously
`transmitted to the car stereo.
`Importantly, this signal prevents the car
`stereo from shutting off, entering a sleep
`mode, or otherwise being unresponsive
`to signals and/or data from an external
`source. If the car radio is an OEM car
`radio, the CD player presence signal
`need not be generated. Further, the
`signal need not be limited to a CD
`player device presence signal, but
`rather, could be any type of device
`presence signal (e.g., MP3 player device
`presence signal, satellite receiver
`presence signal, video device presence
`signal, cellular telephone presence
`signal, or any other type of device
`presence signal). Concurrently with step
`110, or within a short period of time
`before or after the execution of step 110,
`steps 112 and 114 are invoked. In step
`112, the audio channels of the CD
`player/changer are connected
`(channeled) to the car stereo system,
`allowing audio from the CD
`player/changer to be played through the
`car stereo. In step 114, data is retrieved
`by the present invention from the CD
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`player/changer, including track and time
`information, formatted, and transmitted
`to the car stereo for display by the car
`stereo. Thus, information produced by
`the external CD player/changer can be
`quickly and conveniently viewed by a
`driver by merely viewing the display of
`the car stereo. After steps 110, 112, and
`114 have been executed, control passes
`to step 116.
`
`[0088]
`The after-market device 635 could
`comprise any audio, video, or
`telecommunications device, including,
`but not limited to, a CD player, CD
`changer, digital media player (e.g., MP3
`player, MP4 player, WMV player,
`Apple iPod, or any other player),
`satellite radio (e.g., XM, Sirius, Delphi,
`etc.), video device (e.g., DVD player),
`cellular telephone, or any other type of
`device or combinations thereof.
`[0128]
`The after-market device 635 could
`comprise any audio, video, or
`telecommunications device, including,
`but not limited to, a CD player, CD
`changer, digital media player (e.g., MP3
`player, MP4 player, WMV player,
`Apple iPod, or any other player),
`satellite radio (e.g., XM, Sirius, Delphi,
`etc.), video device (e.g., DVD player),
`cellular telephone, or any other type of
`device or combinations thereof.
`[0128]
`FIG. 11a is a diagram showing an
`alternate embodiment of the present
`invention, indicated generally at 645,
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`62. The system of claim 49, wherein the
`portable device comprises a portable
`digital media player.
`
`63. The system of claim 62, wherein the
`portable digital media player comprises
`a video device, a portable media center,
`a portable media player, an MP3 player,
`an MP4 player, a WMV player, an
`Apple iPod, or an Apple video iPod.
`
`64. The system of claim 49, wherein the
`portable device comprises a cellular
`telephone.
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`wherein a cellular telephone 670 is
`integrated for use with a car stereo. The
`telephone 670 is in electrical
`communication with the interface 665,
`which receives data from the cellular
`telephone and formats same for
`displaying on the display 650 of the car
`stereo or video system 660. Commands
`for controlling the telephone 670 can be
`entered using the control panel buttons
`655 of the car stereo or video system
`660. The commands are processed by
`the interface 665, converted into a
`format (protocol) compatible with the
`telephone 670, and transmitted to the
`telephone 670 for processing thereby.
`Additionally, audio from the telephone
`670 can be channeled to the car stereo or
`video system 660 via the interface 665
`and played through the speakers of the
`car stereo or video system 660. For
`example, if the telephone 670 is
`provided with the ability to download
`songs or music, such songs or music can
`be selected using the car stereo or video
`system 660 and played therethrough
`using the interface 665. It should be
`noted that control of the cellular
`telephone could be provided using one
`or more displays (e.g., LCD) of a car
`video system. Moreover, control of the
`cellular telephone 670 is not limited to
`the use of buttons on the car stereo or
`video system 660, and indeed, a
`software or graphically-driven menu or
`interface can be used to control the
`cellular telephone. The device 645 could
`include one or more of the circuits
`disclosed in FIGS. 3a-3d and modified
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`for use with the cellular telephone 670.
`
`FIG. 11b is a flowchart showing
`processing logic, indicated generally at
`647, for integrating a cellular telephone
`with a car radio. Beginning in step 649,
`a determination is made as to whether
`the existing car stereo is powered on. If
`a negative determination is made, step
`651 is invoked, wherein the present
`invention enters a standby mode and
`waits for the car stereo to be powered
`on. If a positive determination is made,
`step 653 is invoked, wherein a second
`determination is made as to whether th