Trials@uspto.gov
`571-272-7822
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`
`
`
`
`Paper No. 7
`Filed: January 13, 2017
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`VOLKSWAGEN GROUP OF AMERICA, INC.,
`Petitioner,
`
`v.
`
`BLITZSAFE TEXAS, LLC,
`Patent Owner.
`____________
`
`Case IPR2016-01448
`Patent 7,489,786 B2
`____________
`
`
`
`Before JAMESON LEE, MIRIAM L. QUINN, and KERRY BEGLEY,
`Administrative Patent Judges.
`
`LEE, Administrative Patent Judge.
`
`DECISION
`Denying Institution of Inter Partes Review
`37 C.F.R. § 42.108(b)
`
`
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`

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`IPR2016-01448
`Patent 7,489,786 B2
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`
`I. INTRODUCTION
`
`Background
`A.
`On July 20, 2016, Petitioner filed a Petition (Paper 2, “Pet.”) to
`institute inter partes review of claims 1, 2, 4–8, 13, 14, 23, 24, 44, 47, 57,
`58, 60–65, 86, 88–92, 94, 97, and 98 of U.S. Patent No. 7,489,786 B2
`(Ex. 1001, “the ’786 patent”). On November 10, 2016, Patent Owner filed a
`Preliminary Response (Paper 6, “Prelim. Resp.”).
`To institute an inter partes review, we must determine that the
`information presented in the petition shows “that there is a reasonable
`likelihood that the petitioner would prevail with respect to at least 1 of the
`claims challenged in the petition.” 35 U.S.C. § 314(a). Having considered
`both the Petition and the Preliminary Response, we determine that Petitioner
`has not demonstrated a reasonable likelihood that it would prevail in
`establishing the unpatentability of any challenged claim. Thus, we do not
`institute an inter partes review of any claim of the ’786 patent.
`Related Matters
`B.
`The parties indicate that the ’786 patent was asserted in five
`infringement actions before the United States District Court for the Eastern
`District of Texas and two infringement actions before the United States
`District Court for the District of New Jersey. Pet. 1; Paper 5, 1–2. The
`’786 patent also is involved in IPR2016-00421, IPR2016-00422,
`IPR2016-01472, and IPR2016-01477. Paper 5, 2. Related U.S. Patent No.
`8,155,342 B2 is involved in IPR2016-00118, IPR2016-00418,
`IPR2016-00419, IPR2016-01445, IPR2016-01449, IPR2016-01473,
`IPR2016-01476, IPR2016-01533, IPR2016-01557, and IPR2016-01560.
`Pet. 1; Paper 5, 1–2.
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`IPR2016-01448
`Patent 7,489,786 B2
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`
`The ’786 Patent
`C.
`The ’786 patent is titled “Audio Device Integration System.”
`Ex. 1001, at [54]. It states:
`One or more after-market audio devices, such as a CD player,
`CD changer, MP3 player, satellite receiver, DAB receiver, or the
`like, is integrated for use with an existing OEM or after-market
`car stereo system, wherein control commands can be issued at
`the car stereo and responsive data from the audio device can be
`displayed on the stereo.
` Id. at Abstr. The ’786 patent also states:
`Control commands generated at the car stereo are received,
`processed, converted into a format recognizable by the audio
`device, and dispatched to the audio device for execution.
`Information from the audio device, including track, disc, song,
`station, time, and other information, is received, processed,
`converted into a format recognizable by the car stereo, and
`dispatched to the car stereo for display thereon.
`Id. Additional auxiliary sources also may be integrated together, and “a user
`can select between the [audio] device or the one or more auxiliary input
`sources by issuing selection commands through the car stereo.” Id. A
`docking station is provided for docking a portable audio or video device for
`integration with the car stereo. Id. Figures 2A–2C are reproduced below:
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`IPR2016-01448
`Patent 7,489,786 B2
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`Figure 2A illustrates an embodiment integrating a CD player with the car
`stereo; Figure 2B illustrates an embodiment integrating a MP3 player with a
`car stereo; and Figure 2C illustrates an embodiment integrating a satellite or
`DAB receiver with a car stereo. Id. at 3:14–23. A more versatile
`embodiment is shown in Figure 1:
`
`
`Figure 1 illustrates an embodiment integrating a CD player, a MP3 player, a
`satellite radio, or DAB receiver, and a number of auxiliary input sources
`with a car stereo. Id. at 3:12–13. As shown in the above Figures, central to
`the ’786 patent is an “interface” positioned between the car stereo and the
`audio device(s) and auxiliary input(s) being integrated.
`
`With regard to Figure 2B, the ’786 patent describes:
`The interface 20 allows data and audio signals to be exchanged
`between the MP3 player 30 and the car radio 10, and processes
`and formats signals accordingly so that instructions and data
`from the radio 10 are processable by the MP3 player 30, and vice
`versa. Operational commands, such as track selection, pause,
`play, stop, fast forward, rewind, and other commands, are entered
`via the control panel buttons 14 of car radio 10, processed by the
`interface 20, and formatted for execution by the MP3 player 30.
`Data from the MP3 player, such as track, time, and song
`information, is received by the interface 20, processed thereby,
`and sent to the radio 10 for display on display 13. Audio from
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`IPR2016-01448
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`MP3 player 30 is selectively forwarded by the interface 20 to the
`radio 10 for playing.
`Id. at 6:11–24. Similar description is provided with respect to Figures 2A
`and 2C. Id. at 5:49–55, 6:35–43.
`Of the challenged claims, claims 1, 44, 57, 86, and 92 are
`independent. Claim 1 is directed to a system that connects an after-market
`audio device as well as one or more auxiliary input sources to a car stereo.
`In particular, claim 1 recites a first connector electrically connectable to a
`car stereo, a second connector electrically connectable to an after-market
`device, and a third connector electrically connectable to one or more
`auxiliary input sources. Id. at 21:33–38. Claim 1 also recites an interface
`that is connected between the first and second electrical connectors, and
`includes a “microcontroller pre-programmed to execute”:
`a first pre-programmed code portion for remotely controlling the
`after-market audio device using the car stereo by receiving a
`control command from the car stereo through said first
`connector in a format incompatible with the after-market
`audio device, processing the received control command into
`a formatted command compatible with the after-market audio
`device, and transmitting the formatted command to the
`after-market audio device through said second connector for
`execution by the after-market audio device;
`a second pre-programmed code portion for receiving data from
`the after-market audio device through said second connector
`in a format incompatible with the car stereo, processing the
`received data into formatted data compatible with the car
`stereo, and transmitting the formatted data to the car stereo
`through said first connector for display by the car stereo; and
`a third pre-programmed code portion for switching to one or
`more auxiliary input sources connected to said third electrical
`connector.
`Id. at 21:44–64.
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`IPR2016-01448
`Patent 7,489,786 B2
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`
`Claim 57 is directed to a system including an interface between a first
`electrical connector connectable to a car stereo and a second electrical
`connector connectable to a portable MP3 player. Claim 86 is directed to a
`system including an interface between a first electrical connector
`connectable to a car stereo and a second electrical connector connectable to
`an after-market video device. Claim 92 is directed to a system including an
`interface between a car stereo and a portable audio device. Claims 57, 86,
`and 92 each require the generation, within the interface, of a device presence
`signal that is transmitted to the car stereo to maintain the car stereo in an
`operational state. Claims 57, 86, and 92 are reproduced below:
`57. An audio device integration system comprising:
`a first electrical connector connectable to a car stereo;
`a second electrical connector connectable to a portable MP3
`player external to the car stereo
`an interface connected between said first and second electrical
`connectors for transmitting audio from a portable MP3 player
`to a car stereo, said interface including a microcontroller in
`electrical communication with said first and second electrical
`connectors,
`said microcontroller pre-programmed to execute:
`a first pre-programmed code portion for generating a
`device presence signal and transmitting the signal to
`the car stereo to maintain the car stereo in an
`operational state; and
`a second pre-programmed code portion for remotely
`controlling the MP3 player using the car stereo by
`receiving a control command from the car stereo
`through said first electrical connector in a format
`incompatible with the MP3 player, processing the
`control command into a formatted control command
`compatible with the MP3 player, and transmitting
`the formatted control command to the MP3 player
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`IPR2016-01448
`Patent 7,489,786 B2
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`
`through said second electrical connector for
`execution by the MP3 player.
`Id. at 26:13–37.
`86. A device for integrating video information for use with a car
`stereo, comprising:
`a first electrical connector connectable to a car stereo;
`a second electrical connector connectable to an after-market
`video device external to the car stereo;
`an interface connected between said first and second electrical
`connectors for transmitting video information from the
`after-market video device to the car stereo, the interface
`including a microcontroller in electrical communication with
`said
`first
`and
`second
`electrical
`connectors,
`said
`microcontroller pre-programmed to execute:
`a first pre-programmed code portion for generating a
`device presence signal and transmitting the signal to
`the car stereo through said first electrical connector
`to maintain the car stereo in an operational state
`responsive to signals generated by the after-market
`video device.
`Id. 28:40–56.
`92. An audio device integration system comprising:
`a car stereo;
`a portable audio device external to the car stereo;
`an interface connected between the car stereo and the portable audio
`device, the interface including a microcontroller pre-programmed
`to execute:
`first pre-programmed means for generating a device presence
`signal and transmitting the signal to the car stereo to
`maintain the car stereo in an operational state;
`second pre-programmed means for remotely controlling the
`portable audio device using the car stereo by receiving a
`control command from the car stereo in a format
`incompatible with the portable audio device, processing
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`IPR2016-01448
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`the control command into a formatted control command
`compatible with
`the portable audio device, and
`transmitting the formatted control command to the
`portable audio device for execution thereby; and
`means for transmitting audio from the portable audio device
`to the car stereo.
`Id. at 29:11–31.
`Claim 44 is directed to an apparatus for docking a portable device for
`integration with a car stereo. It includes an interface connected between the
`data port and the car stereo, and is reproduced below:
`44. An apparatus for docking a portable device for integration with a
`car stereo comprising:
`a storage area remote from a car stereo for storing the portable
`device;
`a docking portion within the storage area for communicating and
`physically mating with the portable device;
`a data port in communication with the docking portion, the data
`port connectable with a device for integrating the portable
`device with the car stereo; and
`an interface connected to said data port and to the car stereo, said
`interface channeling from the portable device to the car stereo
`said interface including a microcontroller in electrical
`communication with the portable device through said data
`port and the car stereo, said microcontroller pre-programmed
`to execute first program code for remotely controlling the
`portable device using the car stereo by processing control
`commands generated by
`the car stereo in a format
`incompatible with the portable device into formatted control
`commands compatible with
`the portable device, and
`dispatching formatted control commands to the portable
`device for execution thereby.
`Id. at 25:1–22.
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`IPR2016-01448
`Patent 7,489,786 B2
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`
`Evidence Relied Upon
`D.
`Petitioner relies on the following references:
`
`
`
`Reference
`
`Owens
`
`Beckert
`
`Cooper
`
`Pub. Date
`
`Exhibit
`
`U.S. Pub. No. 2002/0084910 A1
`
`July 4, 2002
`
`Ex. 1003
`
`U.S. Patent No. 6,175,789 B1
`
`Jan. 16, 2001 Ex. 1004
`
`U.S. Patent No. 5,774,793
`
`June 30, 1998 Ex. 1005
`
`Ohmura
`
`U.S. Pub. No. 2001/0028717 A1 Oct. 11, 2001 Ex. 1006
`
`U.S. Patent No. 6,559,773 B1
`
`Berry
`
`Petitioner also relies on the Declaration of Scott Andrews. Ex. 1002.
`
`May 6, 2003 Ex. 1007
`
`The Asserted Grounds
`E.
`Petitioner asserts the following grounds of unpatentability:
`Claims Challenged
`Basis
`References
`Owens, Beckert, and
`§ 103(a)
`Cooper
`Owens, Beckert, Cooper,
`and Ohmura
`
`1, 2, 13, 14, 23, 24, 44, and 47
`
`7 and 8
`4, 5, 6, 57, 58, 60, 63, 64, 65,
`86, 88, 89, 90, 91, 92, 94, 97,
`and 98
`
`§ 103(a)
`
`§ 103(a)
`
`Owens, Beckert, Cooper,
`and Berry
`Owens, Beckert, Cooper,
`Berry, and Ohmura
`
`61 and 62
`
`§ 103(a)
`
`II. ANALYSIS
`The question of obviousness is resolved on the basis of underlying
`factual determinations including: (1) the scope and content of the prior art;
`(2) any differences between the claimed subject matter and the prior art;
`(3) the level of ordinary skill in the art; and (4) objective evidence of
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`nonobviousness. Graham v. John Deere Co., 383 U.S. 1, 17–18 (1966).
`One seeking to establish obviousness based on more than one reference also
`must articulate sufficient reasoning with rational underpinnings to combine
`teachings. See KSR Int’l Co. v. Teleflex, Inc., 550 U.S. 398, 418 (2007).
`Neither Petitioner nor Patent Owner proposes anything specific to
`reflect the level of ordinary skill in the art. We determine, however, that in
`this case no express articulation in that regard is necessary and that the level
`of ordinary skill in the art is reflected by the prior art of record. See Okajima
`v. Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001); In re GPAC Inc.,
`57 F.3d 1573, 1579 (Fed. Cir. 1995); In re Oelrich, 579 F.2d 86, 91 (CCPA
`1978).
`A. Claim Construction
`In an inter partes review, claim terms in an unexpired patent are
`interpreted according to their broadest reasonable construction in light of the
`specification of the patent in which they appear. 37 C.F.R. § 42.100(b);
`Cuozzo Speed Techs., LLC v. Lee, 136 S. Ct. 2131, 2142–46 (2016).
`Consistent with that standard, claim terms also are given their ordinary and
`customary meaning, as would be understood by one of ordinary skill in the
`art in the context of the entire disclosure. See In re Translogic Tech., Inc.,
`504 F.3d 1249, 1257 (Fed. Cir. 2007). There are, however, two exceptions
`to that rule: “1) when a patentee sets out a definition and acts as his own
`lexicographer,” and “2) when the patentee disavows the full scope of a claim
`term either in the specification or during prosecution.” Thorner v. Sony
`Computer Entm’t Am. LLC, 669 F.3d 1362, 1365 (Fed. Cir. 2012).
`
`If an inventor acts as his or her own lexicographer, the definition must
`be set forth in the specification with reasonable clarity, deliberateness, and
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`precision. Renishaw PLC v. Marposs Societa’ per Azioni, 158 F.3d 1243,
`1249 (Fed. Cir. 1998). It is improper to add into a claim an extraneous
`limitation, i.e., one that is added wholly apart from any need for the addition.
`See, e.g., Hoganas AB v. Dresser Indus., Inc., 9 F.3d 948, 950 (Fed. Cir.
`1993); E.I. du Pont de Nemours & Co. v. Phillips Petroleum Co., 849 F.2d
`1430, 1433 (Fed. Cir. 1988). Although it is improper to read a limitation
`from the specification into the claims, In re Van Geuns, 988 F.2d 1181, 1184
`(Fed. Cir. 1993), claims still must be read in view of the specification of
`which they are a part. Microsoft Corp. v. Multi-Tech Sys., Inc., 357 F.3d
`1340, 1347 (Fed. Cir. 2004).
`Only terms which are in controversy need to be construed, and only to
`the extent necessary to resolve the controversy. See Wellman, Inc. v.
`Eastman Chem. Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011); Vivid Techs.,
`Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999).
`“interface”
`1.
`Of all challenged claims, claims 1, 44, 57, 86, and 92 are independent,
`
`and each recites an “interface.”
`Claims 1, 57, and 86 require the interface to be connected between a
`first electrical connector and a second electrical connector, where the first
`connector is connectable to a car stereo and the second connector is
`connectable to an after-market audio device (claim 1), a portable MP3 player
`(claim 57), or an after-market video device (claim 86). Claim 92 requires
`the interface to be connected between the car stereo and a portable audio
`device. Claim 44 recites a docking portion that mates with a portable
`device, and an interface that is connected to the car stereo as well as to a data
`port that communicates with the docking portion.
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`Also, claim 57 recites that the interface is “for transmitting audio from
`a portable MP3 player to a car stereo”; claim 86 recites that the interface is
`“for transmitting video information from the after-market video device to the
`car stereo”; claim 1 recites that the interface is “for channeling audio signals
`to the car stereo from the after-market audio device”; claim 44 recites an
`interface for “channeling audio from the portable device to the car stereo”;
`and claim 92 recites that the interface includes a microcontroller
`pre-programmed to execute “means for transmitting audio from the portable
`audio device to the car stereo.”
`Neither party proposes a construction for the term “interface.” With
`regard to an “interface,” the Specification states:
`Thus, as can be readily appreciated, the interface 20 of the
`present invention allows for the integration of a multitude of
`devices and inputs with an OEM or after-market car radio or
`stereo.
`Ex. 1001, 5:33–36.
`As mentioned earlier, the interface 20 of the present invention
`allows for a plurality of disparate audio devices to be integrated
`with an existing car radio for use therewith.
`Id. at 6:4–7.
`Data from the MP3 player, such as track, time, and song
`information, is received by the interface 20, processed thereby,
`and sent to the radio 10 for display on display 13. Audio from
`the MP3 player 30 is selectively forwarded by the interface 20 to
`the radio 10 for playing.
`Id. at 6:19–24. Thus, the Specification refers to the interface receiving
`information from an audio device and forwarding information to the car
`stereo, and to the interface allowing integration of a plurality of disparate
`audio devices with a car radio.
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`IPR2016-01448
`Patent 7,489,786 B2
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`In the decision instituting inter partes review in related
`
`IPR2016-00421, we noted that during prosecution, the applicants of the ’786
`patent distinguished U.S. Patent No. 6,993,615 B2 (“Falcon”) in part by
`arguing that the reference failed to disclose an interface connected between a
`car stereo and an external audio source. Ex. 2003, 15. We further noted that
`in distinguishing the invention from Falcon, the applicants stated:
`“[Falcon’s graphical user interface] is an entirely different concept than the
`interface of the present invention, which includes a physical interface device
`connected between a car stereo system and an external audio source (e.g., a
`plurality of auxiliary input sources).” Id. (citing Ex. 1102, 0267 (IPR2016-
`00421)).
`
`Construing the term “interface” in light of the Specification, other
`language in the claims, as well as the prosecution history, we determine
`that—interface is a physical unit that connects one device to another and
`that has a functional and structural identity separate from that of both
`connected devices. This is the same construction as that we articulated in
`IPR2016-00421. Id.
`
`In the specific context of claims 1 and 86, the connected devices are
`the car stereo and an after-market device. In the specific context of
`claims 44, 57, and 92, the connected devices are the car stereo and a portable
`device. Each of claims 1, 44, 57, 86, and 92 further requires the interface to
`include a microcontroller.
`“integration” and “integrated”
`2.
`Petitioner states:
`
`The ’786 patent states that “the term ‘integration’ or
`‘integrated’ is intended to mean connecting one or more external
`devices or inputs to an existing car radio or stereo via an
`
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`interface, processing and handling signals and audio channels,
`allowing a user to control the devices via the car stereo, and
`displaying data from the devices on the radio. Ex. 1001 at 4:47–
`52.
`Pet. 8. An express construction of either “integration” or “integrated” is
`unnecessary, beyond noting, as Petitioner has, what the Specification states
`about those terms, and that the statement explicitly requires an “interface,”
`which we have construed above.
`
`B. Alleged Obviousness of Claims 1, 2, 13, 14, 23,
`24, 44, and 47 over Owens, Beckert, and Cooper
`We have reviewed the Petition and the Preliminary Response, and
`
`determine that Petitioner has not shown a reasonable likelihood that it would
`prevail in establishing the unpatentability of any of claims 1, 2, 13, 14, 23,
`24, 44, and 47 as obvious over Owens, Beckert, and Cooper.
`
`Petitioner has failed to articulate, with reasonable clarity (1) what
`element of which prior art reference is relied on to meet which element of
`each claim, and (2) what element from which reference is combined with
`what element of which other reference or references, and in what manner, to
`meet what element of each claim. Petitioner has not sufficiently identified
`differences between the claimed invention and the prior art, as well as the
`manner in which the prior art teachings are combined to account for such
`differences.
`
`Claims 1, 2, 13, 14, 23, and 24
`1.
`With regard to the recitation in claim 1 of “[a]n audio device
`
`integration system comprising a first connector electrically connectable to a
`car stereo,” Petitioner states:
`
`Owens describes “an expandable system” for “serial
`additional of modules” such as A/V sources, and further
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`describes a “bus cable” connecting the head unit to the modules,
`including to an A/V interface module. Ex. 1003, Abstract,
`¶¶ [0006], [0025]; Ex. 1002, ¶ 10. Beckert describes a vehicle
`computer system that is capable of integrating diverse and
`separate systems and can serve as, e.g., a multimedia
`entertainment system. Ex. 1004, 2:8–11, 5:36; Ex. 1002, ¶ 10.
`Cooper describes a system for connecting a plurality of cellular
`telephones to an automotive electronics and communication
`system; a cable (no. 44 in Fig. 2) connects the interface unit to a
`bus connector of the electronics and communications system.
`Ex. 1005, Abstract, 3:42–45, Figs. 1, 2; Ex. 1002, ¶ 10.
`Pet. 14. The first sentence appears to identify the bus cable of Owens as the
`claimed first connector. If so, the significance of the cited disclosures from
`Beckert and Cooper is not explained. It is unclear whether Petitioner also
`asserts that each of Beckert and Cooper also discloses such a first connector
`connectable to a car stereo, and if so, which element of Beckert and Cooper
`constitutes such a first connector. For instance, the cited disclosure of
`Cooper refers to a cable, an interface unit, and a bus connector. It is further
`unclear whether Petitioner is combining multiple elements from the
`disclosures of Owens, Beckert, and Cooper to meet the recited first
`connector, and if so, then in what manner. We note that the cited disclosure
`of Cooper does not refer to any car stereo. With respect to this claim
`limitation pertaining to a first connector connectable to a car stereo, the
`claim chart provided by Petitioner on page 25 of the Petition does not
`provide further clarity. Indeed, the assertions are made even more unclear,
`because the claim chart no longer identifies any disclosure from Beckert for
`the “first connector” limitation.
`
`With regard to the recitation in claim 1 of “a second connector
`electrically connectable to an after-market audio device external to the car
`stereo,” Petitioner states:
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`Owens describes that A/V devices (e.g., after-market
`
`audio devices), such as TV monitors, VCRs, tuners, game
`stations, etc., may be connected to a “source selector” which is
`connected to the A/V interface module. Ex. 1003, ¶ [0026];
`Ex. 1002, ¶ 11. Beckert describes that the “support module” is
`connected to a USB hub, which provides connections to
`peripheral devices, such as CD-ROM changers, TV tuners, etc.
`Ex. 1004, 5:28–38; Ex. 1002, ¶ 11. Cooper describes a cable
`(no. 40 in Fig. 2) connecting the interface unit with a cellular
`phone. Ex. 1005, 3:29–41, Fig. 2; Ex. 1002, ¶ 11.
`Pet. 15. The above-quoted text identifies two elements from Owens (source
`selector and A/V interface module), two elements from Beckert (support
`module and USB hub), and two elements from Cooper (cable and interface
`unit). It is unclear which one of those elements Petitioner relies on as the
`claimed second connector, and what is the significance of all the other
`identified elements in the mix. It is unclear whether Petitioner is relying on
`a combination of elements from multiple references to meet the claimed
`second connector, and if so, then in what manner. With respect to this claim
`limitation pertaining to a second connector connectable to a car stereo, the
`claim chart provided by Petitioner on page 26 of the Petition does not
`provide further clarity, and shares the same uncertainties.
`
`With regard to the recitation in claim 1 of “a third connector
`electrically connectable to one or more auxiliary input sources external to
`the car stereo and the after-market audio device,” Petitioner states:
`
`Owens describes “auxiliary plugs” (no. 12 in Fig. 1) for
`connection of an auxiliary audio source (no. 13 in Fig. 1), such
`as a cassette tape deck or an MP3 player, to the head unit.
`Ex. 1003, ¶ [0025], Fig. 1; Ex. 1002, ¶ 12. Beckert’s system is
`connectable to multiple external devices. For example, Beckert
`describes that “[t]he USB hub 70 provides connections to many
`peripheral devices (e.g., 128 devices).” Ex. 1004, 5:28–38;
`Ex. 1002, ¶ 12. Cooper describes that multiple cell phones may
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`be separately connected to the interface unit through multiple
`“cradle members.” Ex. 1005, claim 4, Fig. 1; Ex. 1002, ¶ 12.
`Pet. 15. The first sentence appears to identify the auxiliary plugs of Owens
`as the claimed third connector. If so, the significance of the cited disclosure
`from Beckert and Cooper is not explained. It is unclear whether Petitioner
`also asserts that each of Beckert and Cooper also discloses such a third
`connector, and if so, which element of Beckert and Cooper constitutes such
`a third connector. For instance, the cited disclosure of Cooper refers to an
`interface unit and multiple cradle members. The cited disclosure of Beckert
`refers to a USB hub, but the USB hub already has been identified by
`Petitioner in connection with the second connector of claim 1. It is further
`unclear whether Petitioner is combining multiple elements from the
`disclosures of Owens, Beckert, and Cooper to meet the recited third
`connector, and if so, then in what manner. With respect to this claim
`limitation pertaining to a third connector connectable to one or more
`auxiliary input sources, the claim chart provided by Petitioner on page 26–
`27 of the Petition does not provide further clarity. Actually, Petitioner’s
`assertions are made even more unclear, because in the claim chart Petitioner
`identifies still a further element from Cooper, the docking station.
`
`With regard to the recitation in claim 1 of “an interface connected
`between said first and second electrical connectors for channeling audio
`signals to the car stereo from the after-market audio device, said interface
`including a microcontroller in electrical communication with said first and
`second electrical connectors,” Petitioner states:
`
`Owens describes an A/V interface module connected
`between the bus and the “source selector,” which in turn is
`connected to A/V sources; Owens further describes a “master
`microprocessor” that performs all of the system selection
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`functions (such as choosing between different A/V sources).
`Ex. 1003, ¶¶ [0009]-[0010], [0034]; Ex. 1002, ¶ 13.
`
`Beckert describes a support module (the interface)
`connected to a computer module (first electrical connection) and
`a USB hub (second electrical connection), for connection to
`peripheral devices such as a CD-ROM changer; the support
`module contains a logic unit that can be implemented as a
`microprocessor,
`and
`“is
`responsible
`for
`facilitation
`communication among the peripheral devices
`.
`.
`. and
`coordinating the functionality of the entertainment system.”
`Ex. 1004, 5:28–38, 5:40–55; Fig. 2; Ex. 1002, ¶ 13.
`
`Cooper describes an interface unit (no. 36 in Fig. 2)
`connected via cables (nos. 40 and 44 in Fig. 2) to the audio and
`communications system of the vehicle and one or more cell
`phones; the system enables audio output of the connected cellular
`phones to be output on the audio/communication system of the
`vehicle. Ex. 1005, 3:29–45, 4:11–20, Figs. 1, 2; Ex. 1002, ¶ 13.
`The interface device includes a microcontroller that “contains, in
`its non-volatile memory, a data control program having a
`plurality of firmware drivers;” these drivers “have the operating
`circuitry and commands necessary for controlling the selected
`cellular telephone.” Ex. 1005, 3:12–22; 4:34–39; Ex. 1002, ¶ 13.
`Pet. 16–17. The first sentence appears to identify the A/V interface module
`of Owens as the claimed interface. If so, the significance of the cited
`disclosures from Beckert and Cooper is not explained. It is unclear whether
`Petitioner is combining multiple elements from the disclosures of Owens,
`Beckert, and Cooper to meet the recited interface, and if so, then in what
`manner. We note also that none of the cited disclosures refers to channeling
`audio signals to the car stereo from the after-market audio device, which is a
`part of the limitation at issue. With respect to this claim limitation
`pertaining to an interface, the claim chart provided by Petitioner on page 27–
`29 of the Petition does not provide further clarity.
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`Additionally, assuming that Petitioner has relied on Owen’s A/V
`
`interface module as the claimed interface, the limitation at issue still is not
`met. That is because the claim limitation requires a microprocessor in the
`interface. Petitioner has cited to the presence of a master microprocessor.
`But that master microprocessor is located within the car stereo and not in the
`A/V interface module. Ex. 1003 ¶¶ 33–34, Fig. 9.
`
`On pages 23–24, the Petition includes a discussion of the reasoning to
`combine teachings from the various references. However, the reasoning
`provided is excessively generic and does not make a meaningful clarification
`of what specific elements of which reference are combined with what
`specific elements of what other reference or references, and in what manner.
`
`For instance, Petitioner states: “It would have been mere routine
`adaptation to include the compatibility processing feature of Beckert in the
`integration system of Owens.” Pet. 23. In that regard, however, Petitioner
`(1) does not identify what elements are referred to as the “compatibility
`processing feature” of Beckert, (2) does not identify which elements of
`Owens and Beckert correspond to which claim elements, respectively, and
`(3) does not explain the particular manner of combining teachings on the
`level of the specific elements claimed. Also, Petitioner states:
`pre-programming the system “for the communication of
`incompatible audi