DECLARATION OF SCOTT ANDREWS
`
`I, Scott Andrews, declare as follows:
`
`I hold a B.Sc. degree in Electrical Engineering from University of
`
`
`
`1.
`
`California–Irvine and a M.Sc. degree in Electronic Engineering from Stanford
`
`University. In various positions at, among others, TRW and Toyota, I have been
`
`responsible for research and development projects relating to numerous vehicle
`
`electronic systems,
`
`information systems, and user
`
`interface systems. My
`
`qualifications are further set forth in my curriculum vitae (Exhibit A). I have been
`
`retained by Volkswagen Group of America, Inc. in connection with its petition for
`
`inter partes review of U.S. Patent No. 7,489,786 (the “’786 patent”). I have over
`
`25 years of experience in fields relevant to the ’786 patent, including vehicle
`
`infotainment systems and device integration systems.
`
`2.
`
`I have reviewed the ’786 patent, as well as its prosecution history and the
`
`prior art cited during its prosecution. I have also reviewed U.S. Patent Application
`
`Publication No. 2002/0084910 (“Owens”), U.S. Patent No. 6,175,789 (“Beckert”),
`
`U.S. Patent No. 5,774,793 (“Cooper”), U.S. Patent Application No. 2001/0028717
`
`(“Ohmura”) and U.S. Patent No. 6,559,773 (“Berry”).
`
`
`
`1
`
`1
`
`VWGoA - Ex. 1002
`Volkswagen Group of America, Inc., Petitioner
`
`
`
`I, Scott Andrews, declare as follows:
`
`I hold a B.Sc. degree in Electrical Engineering from University of
`
`
`
`1.
`
`California–Irvine and a M.Sc. degree in Electronic Engineering from Stanford
`
`University. In various positions at, among others, TRW and Toyota, I have been
`
`responsible for research and development projects relating to numerous vehicle
`
`electronic systems,
`
`information systems, and user
`
`interface systems. My
`
`qualifications are further set forth in my curriculum vitae (Exhibit A). I have been
`
`retained by Volkswagen Group of America, Inc. in connection with its petition for
`
`inter partes review of U.S. Patent No. 7,489,786 (the “’786 patent”). I have over
`
`25 years of experience in fields relevant to the ’786 patent, including vehicle
`
`infotainment systems and device integration systems.
`
`2.
`
`I have reviewed the ’786 patent, as well as its prosecution history and the
`
`prior art cited during its prosecution. I have also reviewed U.S. Patent Application
`
`Publication No. 2002/0084910 (“Owens”), U.S. Patent No. 6,175,789 (“Beckert”),
`
`U.S. Patent No. 5,774,793 (“Cooper”), U.S. Patent Application No. 2001/0028717
`
`(“Ohmura”) and U.S. Patent No. 6,559,773 (“Berry”).
`
`
`
`1
`
`1
`
`VWGoA - Ex. 1002
`Volkswagen Group of America, Inc., Petitioner
`
`
`
`
`
`3.
`
`The ’786 Patent
`
`The ’786 patent describes an audio device integration system for integrating
`
`after-market components such as satellite receivers, CD players, CD changers,
`
`MP3 players, Digital Audio Broadcast (DAB) receivers, auxiliary audio sources,
`
`and the like with factory-installed (OEM) or after-market car stereo systems. See
`
`’786 patent, col. 1, lines 7 to 12. The integration system is also described as
`
`“interface system.” See ’786 patent, col. 5, lines 14 to 15. A block diagram of the
`
`integration system is illustrated in Fig. 1 of the ’786 patent (reproduced below):
`
`4.
`
`As shown above in Fig. 1, the interface can be connected to a plurality of
`
`devices and auxiliary inputs and can be integrated with a car stereo. The interface
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`converts control signals from the car stereo into a format that is compatible with an
`
`
`
`2
`
`2
`
`
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`after-market external device, and vice versa, thus allowing commands input at the
`
`car stereo to control the external device and display of after-market external device
`
`information on the car’s display. 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. See ’786 patent, Abstract, col. 4, lines 27 to 46, col. 5,
`
`line 15 to col. 8, line 15. One or more auxiliary input sources can be integrated
`
`with the car stereo, and selected between using the controls of the car stereo. See
`
`’786 patent, Abstract, col. 4, lines 43 to 46.
`
`5.
`
`The interface includes a microcontroller performing the described functions
`
`(see, e.g., ’786 patent, at col. 8, lines 46 to 64, col. 9, lines 45 to 67, col. 10, lines
`
`49 to 62, col. 11, lines 30 to 46, col. 12, lines 4 to 14).
`
`
`
`
`6.
`
`The Disclosures of Owens, Beckert, and Cooper
`Claims 1, 2, 13, 14, 23, 24, 44 and 47
`
`Owens, Beckert, and Cooper describe systems and methods for integrating
`
`electronic devices with a vehicle audio system.
`
`7.
`
`Owens describes an expandable automotive multimedia system having a bus
`
`for integrating, e.g., MP3 players, CD players, TV monitors, VCRs, or game
`
`stations, to the vehicle’s OEM head unit and speaker system, subject to control at
`
`the head unit, which “offers enormous versatility for a traveling family.” See
`
`3
`
`3
`
`
`
`Owens, ¶¶ [0006]–[0010], [0025]–[0026]. The bus carries “control commands
`
`from the head unit to the modules, and commands from the modules to the head
`
`unit.” See Owens, ¶ [0027].
`
`8.
`
`Beckert describes a vehicle computer system designed to integrate and
`
`control, e.g., audio, navigation, and communication systems, which “allows for
`
`easy expandability.” See Beckert, col. 2, lines 8 to 30. The system includes three
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`modules: a support module, a faceplate module and computer module. The support
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`module includes a logic unit, “which is responsible for facilitating communication
`
`among peripheral devices,” and which can be implemented as a microprocessor or
`
`other processing device. See Beckert, col. 5, lines 40 to 55.
`
`9.
`
`Cooper describes a docking system for interfacing a variety of devices
`
`having different control and command formats to a bus having a known universal
`
`signal format, providing “ease of manufacture and updating the system to
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`accommodate new models and makes of cellular telephones, as well as changes to
`
`command signal structure of existing cellular telephones and devices.” See Cooper,
`
`col. 1, lines 19 to 23 and col. 2, lines 16 to 20. An interface device includes a
`
`microcontroller “which 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.”
`
`See Cooper, col. 3, lines 12 to 22 and col. 4, lines 34 to 39.
`
`4
`
`4
`
`
`
`10.
`
` Owens, Beckert, and Cooper describe “an audio device integration system
`
`comprising a first connector electrically connectable to a car stereo.” Owens
`
`describes “an expandable system” for “serial additional of modules,” such as A/V
`
`sources, and further describes a “bus cable” connecting the head unit to the
`
`modules, including to an A/V interface module. See Owens, Abstract, ¶¶ [0006]
`
`and [0025]. 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. See Beckert, col. 2, lines 8 to 11 and col. 5, lines 3 to 6.
`
`Cooper describes a system for connecting a plurality of cellular telephones to an
`
`automotive electronics and communications system; a cable (shown as no. 44 in
`
`Fig. 2) connects the interface unit to a bus connector of the electronics and
`
`communications system. See Cooper, Abstract, col. 3, lines 42 to 45, and Figs. 1
`
`and 2.
`
`11. Owens, Beckert, and Cooper describe “a second connector electrically
`
`connectable to an after-market audio device external to the car stereo.” Owens
`
`describes that A/V devices (i.e. 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. See Owens, ¶ [0026]. 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. See Beckert, col.
`
`5
`
`5
`
`
`
`5, lines 28 to 38. Cooper describes a cable (shown as no. 40 in Fig. 2) connecting
`
`the interface unit with a cellular phone. See Cooper, col. 3, lines 29 to 41 and Fig.
`
`2.
`
`12. Owens, Beckert, and Cooper describe “a third connector electrically
`
`connectable to one or more auxiliary input sources external to the car stereo and
`
`the after-market audio device.” Owens describes “auxiliary plugs” (shown as no.
`
`12 in Fig. 1) for connection to an auxiliary audio source (shown as no. 13 in Fig. 1)
`
`such as a cassette tape deck or an MP3 player to the head unit. See Owens, ¶
`
`[0025] and Fig. 1. 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).” See Beckert, col. 5, lines 28 to 38.
`
`Cooper describes that multiple cell phones may be separately connected to the
`
`interface unit through multiple “cradle members.” See Cooper, claim 4 and Fig. 1.
`
`13. Owens, Beckert, and Cooper describe “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.” 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 functions (such
`
`6
`
`6
`
`
`
`as choosing between different A/V sources). See Owens, ¶¶ [0009], [0010] and
`
`[0034]. 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.” See Beckert, col. 5,
`
`lines 28 to 38 and 40 to 55, and Fig. 2. Cooper describes an interface unit (shown
`
`as no. 36 in Fig. 2) connected via cables (shown as 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 be output on the
`
`audio/communication system of the vehicle. See Cooper, col. 3, lines 29 to 45, col.
`
`4, lines 11 to 20, and Figs. 1 and 2. The interface device includes a
`
`microcontroller, “which 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.”
`
`See Cooper, col. 3, lines 12 to 22; 4:34-39.
`
`14. Owens, Beckert, and Cooper describe 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
`
`7
`
`7
`
`
`
`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.” Owens describes that the head unit has manual controls which allow the
`
`vehicle driver some control over the entire system; the bus carries control
`
`commands from the head unit to the modules, and commands from the modules to
`
`the head unit. See Owens, ¶ [0006] and [0027], and Fig. 2. Beckert describes that
`
`the computer has a voice recognition device that permits the user to verbally enter
`
`commands, which “can be used for controlling most operating modes of the
`
`vehicle computing platform,” and the connection of “many peripheral devices” to
`
`the computing platform. See Beckert, col. 4, lines 23 to 27, col. 5, lines 28 to 36.
`
`Beckert describes that its system runs on an open platform operating system, which
`
`enables the addition of new systems to the vehicle by installing new programs. See
`
`Beckert, col. 2, lines 8 to 30. This implies that once the appropriate software for a
`
`new peripheral device is installed, the system in Beckert integrates the device and
`
`transforms commands to or from the peripheral device into the right format.
`
`Cooper describes “pre-programmed” compatibility processing: As discussed
`
`above, Cooper describes an interface device that includes a microcontroller “which
`
`contains, in its non-volatile memory, a data control program having a plurality of
`
`8
`
`8
`
`
`
`firmware drivers;” these drivers “have the operating circuitry and commands
`
`necessary for controlling the selected cellular telephone,” each of which has
`
`“individual special command signal requirements specific to the unit’s operation.”
`
` See Cooper, col. 3, lines 12 to 22, col. 4, lines 11 to 20, col. 4, lines 34 to 39, col.
`
`4, line 65 to col. 5, line 4, col. 5, lines 33 to 38, col. 5, lines 53 to 64. The after-
`
`market cell phones can be controlled through commands from the automotive head
`
`unit. See Cooper, col. 3, lines 29 to 41, col. 3, lines 42 to 45, col. 4, line 65 to col.
`
`5, line 4, and Fig. 2.
`
`15. Owens, Beckert, and Cooper describe 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.” Beckert describes that the support module, which can be implemented as a
`
`microprocessor, contains circuitry that can receive data from the serial devices and
`
`convert the data into a “parallel format.” See Beckert, col. 5, lines 53 to 55 and col.
`
`8, lines 16 to 23. As discussed above, the description in Beckert generally implies
`
`format conversion between the computing platform and the peripheral devices.
`
`Further, the system may display information on the faceplate display. See Beckert,
`
`col. 4, lines 17 to 22 and Fig. 1. As discussed above, Cooper describes that the
`
`9
`
`9
`
`
`
`microcontroller in the interface unit can select the proper hardware and/or
`
`firmware to interface with a particular cell phone; the system further has the
`
`capability “for passing the audio output signal of the cellular telephone to the bus
`
`connector and thus to the automotive electronics and communications system.” See
`
`Cooper, col. 3, lines 12 to 22, col. 4, lines 34 to 39, col. 4, line 65 to col. 5, line 4,
`
`col. 5, lines 33 to 38, col. 5, lines 53 to 64 and col. 4, lines 11 to 20. Cooper also
`
`describes that an LCD screen may be provided in a convenient location in the car
`
`to “display information normally shown on the display screen of a cellular
`
`telephone.” See Cooper, col. 4, lines 4 to 10.
`
`16. Owens, Beckert, and Cooper describe “a third pre-programmed code portion
`
`for switching to one or more auxiliary input sources connected to said third
`
`electrical connector.” Owens describes that the A/V interface module is “connected
`
`to an A/V source selector module which serves as a switching unit between various
`
`A/V inputs and a monitor, subject to control at the head unit.” See Owens, ¶
`
`[0009]. A mode button on the head unit allows the user to switch between a “CD
`
`player, CDC, A/V source selector, and auxiliary modes”. See Owens, ¶ [0037]. In
`
`Beckert, the support module can be connected to a multitude of peripheral devices,
`
`such as a CD-ROM changer. See Beckert, col. 5, lines 28 to 38.
`
`17. Owens, Beckert, and Cooper describe that “the car stereo further comprises
`
`an Original Equipment Manufacturer (OEM) car stereo connected to said first
`
`10
`
`10
`
`
`
`electrical connector.” Cooper describes that the docking system interfaces cell
`
`phones to “the automotive electronics and communications system,” referring to
`
`the OEM car stereo. See Cooper, col. 2, lines 59 to 67.
`
`18. Owens, Beckert, and Cooper describe that “commands are input by a user
`
`using one or more control buttons or presets on the car stereo.” Owens describes
`
`that commands may be input by buttons on the head unit. See e.g. Owens, ¶¶
`
`[0006] and [0037]. Beckert further describes that the faceplate display has
`
`faceplate keys. See Beckert, col. 4, lines 18 to 23.
`
`19. Owens, Beckert, and Cooper describe that “audio signals from the one or
`
`more auxiliary input sources are selectively channeled to the car stereo by said
`
`interface.” As discussed above, Owens describes that the head unit may be
`
`attached to auxiliary sources through a bus, which carries audio signals; pressing
`
`the mode button on the head unit enables the user to switch between, for example,
`
`different auxiliary sources. See Owens, ¶¶ [0025], [0032], and [0037]. Beckert
`
`describes that the support module includes an audio signal processor for sound
`
`processing and driving digital to analog converters “for a six channel audio
`
`output.” See Beckert, col. 6, lines 6 to 20. In Cooper, the audio from a cell phone is
`
`channeled through the interface to the automotive audio and communicative
`
`systems. See Cooper, col. 4, lines 11 to 20.
`
`11
`
`11
`
`
`
`20. Owens, Beckert, and Cooper describe “a bus connection established between
`
`the after-market audio device and said interface.” Owens provides a bus connected
`
`to the head unit for serial additional of modules for expanding the system; the bus
`
`is continuous through each module. See Owens, Abstract and ¶ [0025]. Beckert
`
`describes that the support module includes a USB (Universal Serial Bus) port that
`
`connects to peripheral devices. See Beckert, col. 5, lines 28 to 38.
`
`21. Owens, Beckert, and Cooper describe that “the bus connection comprises a
`
`Universal Serial Bus (USB) connection.” Beckert describes that the support
`
`module connects to peripheral devices via a USB connection. See Beckert, col. 5,
`
`lines 28 to 38.
`
`22. Owens, Beckert, and Cooper describe “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.” Owens and Beckert describe systems for
`
`integrating audio devices with a car stereo. One example of a connectable device in
`
`Owens is a game station (a portable device). Cooper describes a docking station
`
`that has a “cradle member,” remote from the car’s head unit, for storing cell
`
`phones; a cradle member may hold more than one cell phone, and more than one
`
`cradle member may be provided. See Cooper, col. 3, lines 5 to 11 and Fig. 2.
`
`23. Owens, Beckert, and Cooper describe “a docking portion within the storage
`
`area for communicating and physically mating with the portable device.” Cooper
`
`12
`
`12
`
`
`
`describes that the interface unit, which transfers data to the cell phone, may be
`
`either separate or incorporated into the cradle member. See Cooper, col. 3, lines 5
`
`to 15.
`
`24. Owens, Beckert, and Cooper describe “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.” Cooper describes that external cables with
`
`compatible jacks (a data port) may attach the interface unit to the cellular phone for
`
`connecting the cellular phone to the car stereo. See Cooper, col. 4, lines 52 to 59.
`
`Further, Owens describes various “plugs” and an “adaptor harness” for connecting
`
`external devices to the car stereo (see nos. 18, 33, and 35 in Fig. 1). See Owens, ¶¶
`
`[0025], [0026], and Figs. 1 and 7. Beckert describes a USB connection for
`
`connecting peripheral devices to the support module, and thus integrating the
`
`devices into a car’s automotive system. See Beckert, col. 5, lines 28 to 38.
`
`25. Owens, Beckert, and Cooper describe “an interface connected to said data
`
`port and to the car stereo, said interface channeling audio 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
`
`13
`
`13
`
`
`
`device into formatted control commands compatible with the portable device, and
`
`dispatching formatted control commands to the portable device for execution
`
`thereby.” 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 functions (such as choosing between different A/V sources). See Owens,
`
`¶¶ [0009], [0010] and [0034]. Owens further describes that the head unit has
`
`manual controls which allow the vehicle driver some control over the entire
`
`system; the bus carries control commands from the head unit to the modules, and
`
`commands from the modules to the head unit. See Owens, ¶ [0006] and [0027], and
`
`Fig. 2. 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.” See Beckert, col. 5,
`
`lines 28 to 38 and 40 to 55, and Fig. 2. Beckert further describes that the computer
`
`has a voice recognition device that permits the user to verbally enter commands,
`
`which “can be used for controlling most operating modes of the vehicle computing
`
`platform,” and the connection of “many peripheral devices” to the computing
`
`14
`
`14
`
`
`
`platform. See Beckert, col. 4, lines 23 to 27, col. 5, lines 28 to 36. Beckert
`
`describes that its system runs on an open platform operating system, which enables
`
`the addition of new systems to the vehicle by installing new programs. See
`
`Beckert, col. 2, lines 8 to 30. This implies that once the appropriate software for a
`
`new peripheral device is installed, the system in Beckert integrates the device and
`
`transforms commands to or from the peripheral device into the right format.
`
`Cooper describes an interface unit (shown as no. 36 in Fig. 2) connected via cables
`
`(shown as 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 be output on the audio/communication system of the
`
`vehicle. See Cooper, col. 3, lines 29 to 45, col. 4, lines 11 to 20, and Figs. 1 and 2.
`
`Further, Cooper describes “pre-programmed” compatibility processing: As
`
`discussed above, the interface device includes a microcontroller “which 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,” each of which has “individual special
`
`command signal requirements specific to the unit’s operation.” See Cooper, col. 3,
`
`lines 12 to 22, col. 4, lines 11 to 20, col. 4, lines 34 to 39, col. 4, line 65 to col. 5,
`
`line 4, col. 5, lines 33 to 38, col. 5, lines 53 to 64. The after-market cell phones can
`
`15
`
`15
`
`
`
`be controlled through commands from the automotive head unit. See Cooper, col.
`
`3, lines 29 to 41, col. 3, lines 42 to 45, col. 4, line 65 to col. 5, line 4, and Fig. 2.
`
`26. Owens, Beckert, and Cooper describe that the “data port comprises an RS-
`
`232 or Universal Serial Bus (USB) connection.” Beckert describes that the support
`
`module connects to peripheral devices via a USB connection. See Beckert, col. 5,
`
`lines 28 to 38.
`
`27. Owens, Beckert, and Cooper all address problems related to systems and
`
`methods for integrating electronic devices with a vehicle audio system, like the
`
`’786 patent. It would have been mere routine adaptation to include the
`
`compatibility processing feature of Beckert in the integration system of Owens.
`
`Owens describes an “expandable” system and wants to achieve “versatility” (see
`
`Owens, ¶¶ [0006] and [0010]) and Beckert provides for “easy expandability” and
`
`integrating “diverse and separate systems” (see Beckert, col. 2, lines 8 to 11).
`
`Adding the compatibility processing feature of Beckert would have merely been
`
`the use of a known technique (compatibility processing) to improve a similar
`
`device (Owens) in the same way.
`
`28. Additionally, pre-programming the system, as described, for example, in
`
`Cooper, allows the user to “just plug the [device] into the interface system, and
`
`have the device work without the user having to manually change switch settings
`
`or load or unload software into the device for operation with the specific [device].”
`
`16
`
`16
`
`
`
`See Cooper, col. 1, lines 43 to 47. Using pre-programmed instead of programmable
`
`compatibility would have merely been the simple substitution of known elements
`
`for one another to obtain predictable results.
`
`
`
`The Disclosures of Owens, Beckert, Cooper, and Ohmura – Claims 7 and 8
`
`
`29. Ohmura describes connecting portable audio devices in a vehicle to the
`
`vehicle audio system, so that the passengers in the vehicle can access media
`
`content stored on those portable devices, and control playback of that media
`
`content on the vehicle audio system by presenting information related to the media
`
`content (e.g., title, artist, and time information). See Ohmura, ¶¶ [0027], [0028],
`
`[0112], and Fig. 7.
`
`30. Owens, Beckert, Cooper, and Ohmura describe
`
`that
`
`the “second
`
`preprogrammed code portion processes data generated by the after-market audio
`
`device including track and time information” and that the “second preprogrammed
`
`code portion processes data generated by the after-market audio device including
`
`song title and artist information.” Ohmura discloses that a user may play audio
`
`content from a connected portable device through a vehicle audio system. A music
`
`data list of the portable audio apparatus is generated and displayed on the display
`
`screen of the audio system; the music data list shows “titles, artist names and data
`
`17
`
`17
`
`
`
`volumes, etc. and shows the content of the music data retained in the portable
`
`audio apparatus.” See Ohmura, ¶ [0112]; Figs. 4 and 7.
`
`31. Owens, Beckert, Cooper, and Ohmura all address problems related to
`
`integrating electronic devices with a vehicle audio system, like the ’786 patent.
`
`And, including data regarding audio content described by Ohmura, such as track
`
`and time information, song title, and artist information, in the data exchanged in
`
`the integration systems of Owens, Beckert, and Cooper, e.g., for “allow[s] the
`
`passenger in the vehicle to select contents information to be received from the
`
`portable audio apparatus.” See Ohmura, ¶ [0028]. Adding data regarding audio
`
`content would have merely been the combination of conventional elements
`
`yielding predictable results, and the application of a known technique to a known
`
`device.
`
`
`
`The Disclosures of Owens, Beckert, Cooper, and Berry
`Claims 4 to 6, 57, 58, 60, 63 to 65, 86, 88 to 92, 94 and 97
`
`
`32. Like the ‘786 patent, Owens, Beckert, and Cooper, Berry relates to a system
`
`for integrating electronic devices with a vehicle audio system. Berry describes a
`
`reconfigurable display for a vehicle, expandable to detect the coupling of an
`
`electronic accessory (such as a cellular phone, an MP3 player, palm-sized PC, or
`
`personal digital assistant) and to display a corresponding interface on a human-
`
`machine interface (HMI) display, so that the HMI may be dynamically constructed
`18
`
`18
`
`
`
`in response to the electronic accessories present in the system. See Berry, col. 1,
`
`line 1 to col. 2, line 27 and col. 3, lines 40 to 57.
`
`33. Owens, Beckert, Cooper, and Berry describe that “the after-market audio
`
`device further comprises a CD player, CD changer, MP3 player, Digital Audio
`
`Broadcast (DAB) receiver, or satellite receiver connected to said second electrical
`
`connector.” Owens describes that an MP3 player and a CDC (compact disc
`
`changer) can be connected through the auxiliary port of the head unit. See Owens,
`
`¶ [0025]. Beckert describes that the support module may connect to a peripheral
`
`device such as a CD-ROM changer. See Beckert, col. 5, lines 28 to 38. Further,
`
`Berry describes that electronic accessories, such as an MP3 player, may be
`
`connected to the described system. See Berry, col. 3, lines 40 to 57.
`
`34. Owens, Beckert, Cooper, and Berry describe that the “interface further
`
`comprises a plug-and-play mode for automatically detecting a device type of the
`
`after-market audio device connected to said second electrical connector and
`
`integrating the after-market audio device based upon the device type.” Owens
`
`describes that the master microprocessor “sends and receives signals to the various
`
`peripherals in clocked time slots” and “polls the system to see what peripheral
`
`modules have been installed and their status;” the system may further detect when
`
`a particular audio source, such as an auxiliary unit, is attached. See Owens, ¶¶
`
`[0034] and [0037]. Cooper describes that the cable pinout wiring of the interface
`
`19
`
`19
`
`
`
`unit automatically indicates and selects the internally stored hardware and
`
`firmware needed to properly interface the system with the specific cellular
`
`telephone unit. See Cooper, col. 5, lines 60 to 64. In Berry, the described network
`
`recognizes the coupling of a new device to the network and interacts with all the
`
`network resources as appropriate to enable operation of the new device within the
`
`network. See Berry, col. 3, lines 40 to 57.
`
`35. Owens, Beckert, Cooper, and Berry describe that the “interface generates a
`
`device presence signal for maintaining the car stereo in a state responsive to
`
`processed data and audio signals.” Owens describes that the master microprocessor
`
`sends and receives signals to the various peripherals and polls the system to see
`
`what peripheral modules have been installed and their status. See Owens, ¶ [0034].
`
`Cooper describes that an external signal path cable connects the interface unit with
`
`a selected cell phone for communicating control signals therebetween for
`
`controlling and/or monitoring the operation of a selected cellular telephone. See
`
`Cooper, col. 3, lines 28 to 31. Berry describes that “HMI controller 34 detects the
`
`presence of a new electronic accessory” and that “objects for processing device
`
`events provide notification to the display subsystem of state changes occurring
`
`within the electronic accessory device.” See Berry, col. 3, lines 66 to 67, col. 5,
`
`lines 56 to 63.
`
`20
`
`20
`
`
`
`36. Owens, Beckert, Cooper, and Berry describe an “audio device integration
`
`system” and a “device for integrating video information” including “a first
`
`electrical connector connectable to a car stereo.” Owens describes “an expandable
`
`system” for “serial additional[sic] of modules,” such as A/V sources, and further
`
`describes a “bus cable” connecting the head unit to the modules, including to an
`
`A/V interface module. See Owens, Abstract, ¶¶ [0006] and [0025]. 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. See
`
`Beckert, col. 2, lines 8 to 11 and col. 5, lines 3 to 6. Cooper describes a system for
`
`connecting a plurality of cellular telephones to an automotive electronics and
`
`communications system; a cable (shown as no. 44 in Fig. 2) connects the interface
`
`unit to a bus connector of the electronics and communications system. See Cooper,
`
`Abstract, col. 3, lines 42 to 45, and Figs. 1 and 2. Berry describes an audio/video
`
`integration system with an HMI that includes a plurality of shortcut buttons (first
`
`electrical connection) to create shortcuts to menu screens for device functionality
`
`embedded in subsystem such as a CD player or AM/FM radio. See Berry, col. 2,
`
`lines 43 to 55 and col. 2, line 60 to col. 3, lines 5.
`
`37. Owens, Beckert, Cooper, and Berry describe “a second electrical connector
`
`connectable to a portable MP3 player external to the car stereo” and “a second
`
`electrical connector connectable to an after-market video device external to the car
`
`21
`
`21
`
`
`
`stereo.” Owens describes that the auxiliary cable may connect to an MP3 player,
`
`and that the A/V interface module (which is connected to the head unit via a bus
`
`cable) may connect, through the source selector, to a TV monitor, a VCR, or a
`
`game station. See Owens, ¶¶ [0025] and [0026]. Beckert describes that one
`
`peripheral device that may be connected to the support module is a TV-tuner. See
`
`Beckert, col. 5, lines 28 to 38. Further, Berry describes that electronic accessories,
`
`such as an MP3 player, palm sized PC, or personal digital assistant (PDA) may be
`
`connected to the system. See Berry, col. 3, lines 40 to 57.
`
`38. Owens, Beckert, Cooper, and Berry describe “an interface connected
`
`between said first and second electrical connectors for transmitting audio from a
`
`portable MP3 player to a car stereo, s
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