UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`American Honda Motor Co., Inc.
`Petitioner
`
`v.
`
`Blitzsafe Texas, LLC
`Patent Owner
`
`
`Patent No. 7,489,786
`Filing Date: December 11, 2002
`Issue Date: February 10, 2009
`Title: AUDIO DEVICE INTEGRATION SYSTEM
`
`
`
`
`Inter Partes Review No. IPR2016-01472
`
`DECLARATION OF JAMES T. GEIER
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF U.S.
`PATENT NO. 7,489,786
`
`
`
`
`
`Honda Exhibit 1014
`Page 1
`
`

`
`
`
`I, James T. Geier, hereby declare and state as follows:
`
`I.
`
`BACKGROUND AND QUALIFICATIONS
`
`
`
`1.
`
`2.
`
`A copy of my curriculum vitae is attached.
`
`I have 30 years’ experience in the communications industry designing,
`
`analyzing and implementing communications systems, wireless networks, and
`
`mobile devices.
`
`3.
`
`I received a Bachelor’s Degree in Electrical Engineering from
`
`California State University in 1985. I received a Masters Degree in Electrical
`
`Engineering from the Air Force Institute of Technology in 1990. I also received an
`
`M.B.A. from the University of Phoenix in 2001.
`
`4.
`
`From 1986 to 1989, while in the Air Force and assigned to the 1815th
`
`Operational Test and Evaluation Squadron, I tested and evaluated wired and
`
`wireless communications systems supporting the transport of military data, voice
`
`and video information worldwide. For example, this included running tests to
`
`validate performance and compatibility of different communications devices, such
`
`as secure telephones. During this time, I was also an instructor at the 1815th
`
`System Evaluation School, where I developed and taught courses on
`
`communications technologies and test methods.
`
`5.
`
`From 1990 to 1992, while in the Air Force and assigned to the
`
`Information Systems Center, I designed and implemented computer networks for
`
`
`
`2
`
`Honda Exhibit 1014
`Page 2
`
`

`
`
`
`Wright-Patterson Air Force Base. This involved testing some of the first-available
`
`
`
`routers, switches and controllers in a laboratory environment and then later
`
`designing and overseeing the installation of corresponding networks throughout
`
`Wright-Patterson Air Force Base for supporting thousands of users.
`
`6.
`
`From 1992 to 1994, while employed at Adroit Systems, Inc., I
`
`analyzed and evaluated communications technologies for use in Airborne
`
`communications platforms, such as aircraft and satellites, to support secure
`
`transport of data, voice and video information.
`
`7.
`
`From 1994 to 1996, while employed at TASC, Inc., I designed and
`
`implemented communication networks for civilian and military applications. For
`
`example, I analyzed and designed for the U.S. Department of Defense an audio /
`
`video conferencing system for use by soldiers in battlefields. I also designed a
`
`highly secure communications network supporting data, voice and video
`
`applications for a U.S. Navy attack submarine.
`
`8.
`
`From 1996 to 2000, while employed at Monarch Marking Systems, I
`
`designed and developed wireless printers and corresponding networks for
`
`customers. This included designing wireless bar code scanners having voice
`
`command recognition capabilities. In addition, I designed and implemented
`
`wireless middleware that provided an interoperable interface between
`
`incompatibility bar code scanners and servers.
`
`
`
`3
`
`Honda Exhibit 1014
`Page 3
`
`

`
`
`
`
`
`
`9.
`
`Since 2000, I have been an independent consultant working under the
`
`business name Wireless-Nets, Ltd., where I have been analyzing and designing
`
`wireless devices, communications systems and applications. As examples, I have
`
`designed and tested voice-over-Wi-Fi user devices and networks, designed and
`
`implemented drivers for Bluetooth transceivers, and implemented microcontroller-
`
`based audio encoding for operation over ZigBee wireless networks.
`
`II. ASSIGNMENT AND MATERIALS REVIEWED
`10.
`I submit this declaration in support of the Petition for Inter Partes
`
`Review of U.S. Patent No. 7,489,786 (“the ‘786 patent”).
`
`11.
`
`I am not currently, and have not previously been, an employee of
`
`Honda Motor Co., Ltd. or any of its affiliates or subsidiaries, including American
`
`Honda Motor Co., Inc. (“Honda”) and Honda of America Mfg., Inc.
`
`12.
`
`I am being compensated for my time at a rate of $300 per hour. My
`
`compensation is in no way dependent upon the substance of the opinions I offer
`
`below, or upon the outcome of Honda’s petition for inter partes review (or the
`
`outcome of such an inter partes review, if a trial is initiated).
`
`13.
`
`I have been asked to provide certain opinions relating to the
`
`patentability of the ‘786 patent. Specifically, I have been asked to provide my
`
`opinion regarding (i) the level of ordinary skill in the art to which the ‘786 patent
`
`
`
`4
`
`Honda Exhibit 1014
`Page 4
`
`

`
`
`
`pertains and (ii) the patentability of claims 1, 5, 6, 7, 8, 10, 14, 57, 60, 61, 62, 64,
`
`
`
`and 65.
`
`14. The opinions expressed in this declaration are not exhaustive of my
`
`opinions on the patentability of claims 1, 5, 6, 7, 8, 10, 14, 57, 60, 61, 62, 64, and
`
`65. Therefore, the fact that I do not address a particular point should not be
`
`understood to indicate any agreement on my part that any claim otherwise
`
`complies with the patentability requirements.
`
`15.
`
`I have reviewed the ‘786 patent and its prosecution history in forming
`
`my opinions in this declaration.
`
`16.
`
`I have reviewed the following prior art to the ‘788 patent:
`
`a)
`
`U.S. Patent No. 6,629,197 to Bhogal et al. (“Bhogal”) (Ex.
`
`1004);
`
`b)
`
`c)
`
`U.S. Patent No. 6,559,773 to Berry (“Berry”) (Ex. 1005);
`
`Japanese Unexamined Patent Application Publication No. JP
`
`2001-128280A to Onishi et al. (“Onishi”) (Exs. 1006 & 1007
`
`(English translation));
`
`d)
`
`U.S. Patent Application Publication No. 2001/0028717 A1 to
`
`Ohmura et al. (“Ohmura”) (Ex. 1008);
`
`e)
`
`European Patent Application No. EP 0 953 486 A2 to Okagaki
`
`et al. (“Okagaki”) (Ex. 1009);
`
`
`
`5
`
`Honda Exhibit 1014
`Page 5
`
`

`
`
`
`
`
`
`f)
`
`U.S. Patent Application Publication No. 2002/0084910 A1 to
`
`Owens et al. (“Owens”) (Ex. 1010);
`
`g)
`
`Japanese Unexamined Utility Model Application Publication
`
`No. JP H7-6954 to Ouchida (“JP ‘954”) (Exs. 1011 and 1012
`
`(English translation));
`
`h)
`
`U.S. Patent Application Publication No. 2001/0025376 to
`
`Knobl (“Knobl”) (Ex. 1013); and
`
`III. LEVEL OF ORDINARY SKILL IN THE ART
`17.
`
`I understand that a patent must be written such that it can be
`
`understood by a “person of ordinary skill” in the field of the patent.
`
`18.
`
`I understand that this hypothetical person of ordinary skill in the art is
`
`considered to have the normal skills and knowledge of a person in the technical
`
`field at issue. I understand that factors that may be considered in determining the
`
`level of ordinary skill in the art include: (1) the education level of the inventor; (2)
`
`the types of problems encountered in the art; (3) the prior art solutions to those
`
`problems; (4) rapidity with which innovations are made; (5) the sophistication of
`
`the technology; and (6) the education level of active workers in the field.
`
`19.
`
`It is my opinion that in December 2002, a person of ordinary skill in
`
`the art relevant to the ‘786 patent would have had at least a Bachelor’s degree in
`
`electrical engineering or equivalent science/engineering degree and at least two
`
`
`
`6
`
`Honda Exhibit 1014
`Page 6
`
`

`
`
`
`years of experience in signal processing and/or electronic system design, or would
`
`
`
`have at least four years of experience in signal processing and/or electronic system
`
`design.
`
`20. Based on my experience and education, I consider myself to have had
`
`at least ordinary skill in the art as of December 11, 2002 (and through today) with
`
`respect to the field of technology implicated by the ‘786 patent.
`
`IV. LEGAL STANDARDS
`21.
`
`I have been informed and I understand that a patentability analysis is
`
`performed from the viewpoint of a hypothetical person of ordinary skill in the art.
`
`I understand that “the person of ordinary skill” is a hypothetical person who is
`
`presumed to be aware of the universe of available prior art as of the time of the
`
`invention at issue.
`
`22.
`
`I understand that a patent claim is unpatentable as anticipated when a
`
`single piece of prior art describes every element of the claimed invention, either
`
`expressly or inherently, and arranged in the same way as in the claim. For inherent
`
`anticipation to be found, it is required that the missing descriptive material is
`
`necessarily present in the prior art. I understand that, for the purpose of an inter
`
`partes review, prior art that anticipates a claim can include both patents and printed
`
`publications from anywhere in the world. I understand that some claims are written
`
`
`
`7
`
`Honda Exhibit 1014
`Page 7
`
`

`
`
`
`in dependent form, in which case they incorporate all of the limitations of the
`
`
`
`claim(s) on which they depend.
`
`23.
`
`I understand that a patent claim is unpatentable as obvious if the
`
`subject matter of the claim as a whole would have been obvious to a person of
`
`ordinary skill in the art as of the time of the invention at issue. I understand that the
`
`following factors must be evaluated to determine whether the claimed subject
`
`matter is obvious: (1) the scope and content of the prior art; (2) the difference or
`
`differences, if any, between the scope of the claim of the patent under
`
`consideration and the scope of the prior art; and (3) the level of ordinary skill in the
`
`art at the time the patent was filed. Unlike anticipation, which allows
`
`consideration of only one item of prior art, I understand that obviousness may be
`
`shown by considering more than one item of prior art. Moreover, I have been
`
`informed and I understand that so-called objective indicia of non-obviousness, also
`
`known as “secondary considerations,” like the following are also to be considered
`
`when assessing obviousness: (1) commercial success; (2) long-felt but unresolved
`
`needs; (3) copying of the invention by others in the field; (4) initial expressions of
`
`disbelief by experts in the field; (5) failure of others to solve the problem that the
`
`inventor solved; and (6) unexpected results. I also understand that evidence of
`
`objective indicia of non-obviousness must be commensurate in scope with the
`
`claimed subject matter.
`
`
`
`8
`
`Honda Exhibit 1014
`Page 8
`
`

`
`
`
`V. CLAIM CONSTRUCTION
`24.
`I understand that in an inter partes review, claim terms are to be
`
`
`
`construed according to the broadest reasonable construction of those terms.
`
`25. For purposes of my opinion, for the term “interface,” I have applied
`
`the definition “a physical unit that connects one device to another and that has a
`
`functional and structural identity separate from that of both connected devices.”
`
`26. For purposes of my opinion, for the term “portable,” I have applied
`
`the definition “capable of being carried by a user.”
`
`27. For purposes of my opinion, for the term “device presence signal,” I
`
`have applied the definition “a signal indicating that an audio device (claim 57) or
`
`video device (claim 86) or portable audio device (claim 92), other than the car
`
`stereo, is connected to the interface.”
`
`28. With respect to the other terms in the ’786 patent’s claims, I have
`
`applied the plain and ordinary meaning of those claim terms when comparing the
`
`claims to the prior art.
`
`VI. PATENTABILITY ANALYSIS
`A. Claims 57, 60, 61, 64, and 65 are rendered obvious by Bhogal,
`Berry, and Onishi
`
`29.
`
`In my opinion, the limitations of claims 57, 60, 61, 64, and 65 are
`
`rendered obvious by the combination of Bhogal, Berry, and Onishi.
`
`1.
`
`Bhogal
`
`
`
`9
`
`Honda Exhibit 1014
`Page 9
`
`

`
`
`
`
`
`
`30. Bhogal describes a digital audio unit that can emulate a CD-changer
`
`unit. Bhogal, Ex. 1004, at 3:1-20. Bhogal recognized that, at the time Bhogal was
`
`filed in November 2000, “CD-changer units and car stereo units [were] designed so
`
`that they are compatible only if they are made by the same manufacturer.” Id. at
`
`4:57-62. Bhogal addressed this problem via an “emulator unit” that “resides as an
`
`intermediary unit between” a car stereo (also referred to as the “base unit”) and a
`
`CD-changer. Id. at 5:34-39.
`
`31.
`
`In one mode of operation described in Bhogal called the “pass-thru
`
`mode,” the emulator unit “receives and forwards commands from the [car stereo]
`
`to the CD-changer unit and also receives and forwards data from the CD-changer
`
`unit to the [car stereo.]” Id. at 7:39-42. The emulator unit can process commands
`
`from the car stereo into a format understandable by the CD-changer, and it can
`
`process data from the CD-changer into a format understandable by the car stereo.
`
`Id. at 7:12-35, 8:21-29.
`
`32. Figure 2 below shows the interaction between the car stereo, emulator
`
`unit, and CD-changer of Bhogal.
`
`
`
`10
`
`Honda Exhibit 1014
`Page 10
`
`

`
`
`
`
`
`
`
`
`Id. at FIG. 2.
`
`33. Bhogal describes an alternative mode of operation called the “end-unit
`
`mode,” where the “emulator unit replaces the CD-changer unit entirely and
`
`emulates the presence of a CD-changer unit.” Id. at 47-49. In the end-unit mode,
`
`digital audio files (including MP3 files) can be stored on the emulator unit itself,
`
`and upon receiving commands from the car stereo unit, can return digital audio
`
`data or other data stored in the emulator unit. Id. at 6:45-48; 7:54-8:1. Because
`
`audio files may be stored in emulator unit, it may also be used as a stand-alone,
`
`portable, digital audio player. Id. at 10:29-32.
`
`34.
`
`In another mode of operation called the “combination mode,” the
`
`emulator unit can act as an intermediary between a CD-changer unit and car stereo
`
`in the pass-thru mode, but it may also operate in the end-unit mode and send digital
`
`audio data stored in the emulator itself to the car stereo unit. Id. at 8:4-29.
`
`
`
`11
`
`Honda Exhibit 1014
`Page 11
`
`

`
`
`
`
`2.
`
`Berry
`
`
`
`35. Berry discloses an “electronic accessory display/control system” that
`
`can interact with multiple devices on a dynamic local network in a vehicle. Berry,
`
`Ex. 1005, at Abstract, 2:1-3. The system allows new portable electronic accessory
`
`devices to connect to and interact with other devices on the network. Id. at
`
`Abstract, 2:43-59. Examples of such portable devices include a cellular phone,
`
`MP3 audio player, and a palm-sized PC or personal digital assistant. Id. at 3:51-54.
`
`36. The system includes a control panel/display subsystem 10 with
`
`“standard embedded features such as an audio tuner or CD player.” Id. at 2:48-52,
`
`2:60-61, FIG. 1. A human-machine interface (HMI) controller inside the control
`
`panel/display subsystem 10 interfaces and communicates with the devices on the
`
`network. Id. at 3:24-27.
`
`37. The HMI controller has access to a memory which stores a plurality of
`
`“interface specifiers,” or drivers. Id. at 3:27-31. Each interface specifier defines
`
`interaction between a display subsystem and a particular portable device. Id. at
`
`2:5-11, 3:27-31, 3:66-4:6. Based on an identified display type and device type, the
`
`HMI controller loads a corresponding interface specifier in order to support
`
`communication between the control panel/display subsystem and the portable
`
`device. Id. at 3:27–39, 3:62–7:9, 5:14–40, 6:26–27, 6:45–50.
`
`
`
`12
`
`Honda Exhibit 1014
`Page 12
`
`

`
`
`
`
`
`
`38. Once communication is supported, the control panel/display
`
`subsystem may interact with the portable device such as by “processing user input
`
`events, processing device events, rendering graphic displays, and sending
`
`commands to devices. Id. at 5:35-40.
`
`3. Onishi
`
`39. Onishi describes an on-vehicle audio device, or a head unit, that may
`
`be connected to a portable Mini Disc (MD) recorder/player. Onishi, Ex. 1007, at
`
`[0002], [0004], [0012]. The on-vehicle audio device contains a CD player as well
`
`as a tuner. Id. at [0020]. The on-vehicle audio device may receive audio sound
`
`from an external audio device via an AUX input terminal. Id. at [0020].
`
`40. A user of the on-vehicle audio device can choose between the CD
`
`player, tuner, or the input from the AUX terminal as the audio source to be output
`
`from the speakers of the vehicle. Id. at [0023], [0063]-[0065]. When the MD
`
`recorder/player is connected to the on-vehicle audio device via the AUX terminal,
`
`sound from the MD recorder/player can be sent to the on-vehicle audio device. Id.
`
`at [0026], [0067],
`
`41. Additionally, display information from the MD recorder/player can
`
`also be sent to the output on the on-vehicle audio device, id. at [0025], [0030],
`
`[0068], [0073], and operation information signals from the on-vehicle audio device
`
`may be sent to the MD recorder/player. Id. at [0026], [0028], [0069]-[0071].
`
`
`
`13
`
`Honda Exhibit 1014
`Page 13
`
`

`
`
`
`
`
`
`42. Figure 5 of Onishi depicts an MD recorder/player connecting, via
`
`headphone terminal 21, to on-vehicle audio device 50:
`
`
`
`
`
`Id. at FIG. 5, [0060], [0066]-[0068].
`
`4.
`
`Claim 57
`
`
`
`14
`
`Honda Exhibit 1014
`Page 14
`
`

`
`
`
`
`
`
`43.
`
`In my opinion, Claim 57 is obvious over the combination of Bhogal,
`
`Berry, and Onishi.
`
`a)
`“a first electrical connector connectable to a car
`stereo,” “a second electrical connector connectable to a
`portable MP3 player external to the car stereo,” and “an
`interface connected between said first and second electrical
`connectors for transmitting audio from a portable MP3
`player to a car stereo”
`
`44. Bhogal discloses a car stereo unit 202 (car stereo), a CD-changer unit
`
`204, and an emulator unit 206 (interface) that “resides as an intermediary unit
`
`between them.” Bhogal, Ex. 1004, at 5:11-43, FIG. 2. Bhogal discloses
`
`“transmitting audio” from the CD-changer unit to a car stereo, as one of the
`
`functions performed by emulator unit 206 in Bhogal is “returning digital audio
`
`data” to the car stereo unit. Id. at 9:41-50, 7:36-46, 8:10-14. Bhogal further
`
`discloses that “[p]hysical cables may be used to connect the emulator unit with the
`
`car stereo/base unit and/or the CD-changer unit,” and also that the emulator unit is
`
`preferably a “portable” device. Id. at 5:44-47; 4:46-47.
`
`45. Based on these teachings, it is my opinion that a person of ordinary
`
`skill in the art at the time of the filing of the ‘786 patent would have understood
`
`Bhogal to teach the use of electrical connectors to connect the emulator unit with
`
`the car stereo and with the CD-changer unit via physical cables.
`
`b)
`
`“portable MP3 player”
`
`
`
`15
`
`Honda Exhibit 1014
`Page 15
`
`

`
`
`
`
`
`
`46. Bhogal discloses that emulator unit 206 itself can store digital MP3
`
`audio files, Ex. 1003 at 6:45-48, 7:54-60, and that it can be used as a “stand-alone,
`
`portable, digital audio player.” Id. at 10:29-32.
`
`47. Berry discloses integrating an “MP3 audio player 41” with a car
`
`stereo via the HMI controller in the car stereo loading the appropriate interface
`
`specifier for the MP3 audio player. See Berry, Ex. 1004, 3:51-57, 3:62-4:9.
`
`48.
`
`In my opinion, it would have been obvious for one of ordinary skill in
`
`the art as of the filing date of the ‘786 patent to combine Berry’s teaching of
`
`integrating a portable MP3 player to a car stereo with Bhogal’s teaching of
`
`integrating a CD-changer unit to a car stereo via an emulator unit.
`
`49. Both Bhogal and Berry recognized a problem that car stereos were
`
`typically designed in manufacture to operate with limited devices. See Bhogal, Ex.
`
`1043, 4:57-62; Berry, Ex. 1005, 1:39-45.
`
`50. Bhogal also acknowledges that car stereos have difficulty integrating
`
`with “newer portable digital audio device[s], such as an MP3 player.” Id. at 1:66-
`
`2:3. Bhogal’s emulator unit contains a CD-changer unit specification database 312
`
`that stores the specifiers for integrating CD-changer units with car stereos. See id.
`
`at 7:1-4, FIG. 3. Berry uses the same concept of “interface specifiers” stored in a
`
`memory to integrate portable devices like MP3 players to a car stereo. See Berry,
`
`Ex. 1005, 3:62-4:9.
`
`
`
`16
`
`Honda Exhibit 1014
`Page 16
`
`

`
`
`
`
`
`
`51.
`
`It would have been obvious for one of ordinary skill in the art to apply
`
`the techniques taught in Berry to modify the emulator unit in Bhogal to interface
`
`not only with after-market CD-changer units, but also with various other portable
`
`devices including portable MP3 players. Such modification would have increased
`
`the versatility of the emulator unit of Bhogal, and would have yielded a predictable
`
`result.
`
`c)
`“said interface including a microcontroller in
`electrical communication with said first and second
`electrical connectors, said microcontroller pre-programmed
`to execute”
`
`52. Bhogal discloses an interface with a pre-programmed microcontroller.
`
`Bhogal discloses that its emulator unit is “preferably embodied in a mobile or
`
`portable package and has a basic computer architecture,” Bhogal, Ex. 1004, at
`
`3:48-50, including a CPU, RAM, ROM, and other hardware. Id. at 3:64-4:7. The
`
`functionality of the emulator unit is achieved through the hardware and software
`
`(which may be stored in the RAM or ROM) within the emulator unit. Id. at 6:56-
`
`60. It is my opinion that Bhogal teaches a microcontroller that operates by
`
`executing pre-programmed code portions.
`
`d)
`“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 command to the MP3 player
`
`
`
`17
`
`Honda Exhibit 1014
`Page 17
`
`

`
`
`
`
`
`
`through said second electrical connector for execution by
`the MP3 player”
`
`53. Bhogal discloses that typically, car stereos are designed to
`
`communicate only with CD-changers made by the same manufacturer. Bhogal,
`
`Ex. 1004, at 4:57-62.
`
`54. The emulator unit in Bhogal contains a “CD-changer unit
`
`specification database 312” which “contains operational information about various
`
`models of CD-changer units and the manner in which emulator unit 302 can
`
`interface with a particular type of CD-changer unit.” Id. at 7:1-4, FIG. 3. A
`
`signal/command interpreter unit 314 inside the emulator unit monitors for signals
`
`and commands from the car stereo intended for the selected type of CD-changer.
`
`Id. at 7:12-24.
`
`55. For example, when a user of the car stereo presses controls on the car
`
`stereo for changing CDs or for obtaining information about CDs, the emulator unit
`
`captures the commands and “performs appropriate processing.” Id. at 8:21-26. In
`
`doing so, the emulator unit “operates in a particular manner that is compatible with
`
`the CD-changer to which the emulator unit is connected.” Id. at 7:7-11.
`
`e)
`“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”
`
`56. Onishi discloses an on-vehicle audio device 50 (a car stereo) that
`
`includes a source selector 63. Onishi, Ex. 1007, at [0060], [0063], FIG. 5. Source
`
`
`
`18
`
`Honda Exhibit 1014
`Page 18
`
`

`
`
`
`selector 63 accepts audio signals input from the on-vehicle device’s tuner and CD
`
`
`
`player, as well as audio signals received by the on-vehicle device’s AUX input
`
`terminal 55. Id. at [0064], FIG. 5. A system controller 60 in the on-vehicle device
`
`controls which of these audio signals is selected by the source selector and output
`
`through speakers. Id. at [0065].
`
`57. Onishi describes at least two methods for the system controller 60 to
`
`detect that an AUX device is present. In one method, the system controller
`
`recognizes display information DD received from the AUX device through AUX
`
`input terminal 55. Id. at [0082]. In another method, the AUX input terminal 55
`
`contains a voltage detector. Id. at [0083]. Based on the voltage detection, the
`
`system controller 60 determines if an AUX device is present. Id.
`
`58. When an AUX device has been detected, “a control is performed”
`
`(i.e., a device presence signal is sent) to the source selector 63 to select the AUX
`
`input as the audio source. Id. at [0084], FIG. 6 (S105). Consequently, analog
`
`audio signals from the MD player/recorder are output as sound from the vehicle
`
`speakers, id. at [0085], FIG. 6 (S106), and the car stereo is maintained in an
`
`operational state.
`
`59.
`
`If an AUX device is not present, the display of the on-vehicle device
`
`is updated to reflect that the MD player/recorder is not connected, and the on-
`
`vehicle device is powered off. Id. at [0082], FIG. 6 (S117).
`
`
`
`19
`
`Honda Exhibit 1014
`Page 19
`
`

`
`
`
`
`
`
`60.
`
`In my opinion, a person of ordinary skill in the art would have been
`
`motivated to combine the teaching of the device presence signal in Onishi with the
`
`emulator unit of Bhogal, in view of Berry. Bhogal recognizes that car stereos
`
`typically contain various components, including a “tuner” and “CD-player,” that
`
`users may select and switch between. Bhogal, Ex. 1004, 5:16-19. Berry
`
`recognized this as well. Berry, Ex. 1005, at 2:48-52, FIG. 1.
`
`61.
`
`It would have been obvious for one of ordinary skill in the art as of
`
`the filing date of the ‘786 patent to add the device detection feature and device
`
`presence signal taught in Onishi to the emulator unit taught by Bhogal, in view of
`
`Berry. As shown in Onishi, it was a known practice for a car stereo to power off if
`
`it does not receive a signal from a recognized device. See Onishi, Ex. 1007 at FIG.
`
`6 (S117), [0082], [0085]. It would have been obvious to add the device presence
`
`signal feature to the emulator unit so that it could keep the car stereo from
`
`powering off or otherwise being unresponsive to signals and data from the
`
`connected CD changer, portable MP3 player, or other external device.
`
`62. Because both the emulator unit of Bhogal and the system controller of
`
`Onishi were principally programmed to communicate with external audio devices,
`
`modifying the emulator unit with the device presence signal feature of Onishi
`
`would not require a substantial redesign of the emulator unit.
`
`
`
`20
`
`Honda Exhibit 1014
`Page 20
`
`

`
`
`
`
`
`
`63. As detailed in the claim chart below, it is my opinion that the
`
`limitations of claim 57 are taught by the combination of Bhogal, Berry, and Onishi.
`
`‘786 Patent, Claim
`57
`An audio device
`integration system
`comprising:
`
`a first electrical
`connector
`connectable to a car
`stereo;
`
`a second electrical
`connector
`connectable to a
`
`Bhogal (Ex. 1004), Berry (Ex. 1005), and Onishi (Ex. 1006
`& 1007)
`To the extent that the preamble is found to be limiting, see, e.g.,
`Bhogal at Abstract (“A method for processing digital audio data
`is presented. A control signal for a CD-changer unit is received
`and interpreted by a digital audio unit that stores digital audio
`data/files and that determines a CD-changer unit operation that
`would be performed by the CD-changer unit in response to the
`CD-changer unit receiving the control signal. The digital audio
`unit then emulates the CD-changer unit operation. The CD-
`changer unit to be emulated by the digital audio unit can be
`selected. The digital audio data stored by the digital audio unit
`can be organized as virtual CD-ROMs. By emulating the
`operations of multiple types of CD-changer units, a single digital
`audio unit can be inserted in many different digital audio
`systems, thereby extending the functionality of a digital audio
`system to include storage of softcopy digital audio files that may
`be accessed through controls and commands for a CD-changer
`unit.”).
`See also id. at FIG. 2.
`See, e.g., Bhogal at 5:16-23 (“Car stereo unit 202 represents one
`or more stereo components, such as a tuner, CD-player,
`equalizer, etc., that may be found in the dashboard of a vehicle
`for easy access by a user. Car stereo unit 202, which can be
`understood as a type of base unit, is assumed to have user
`controls 208 for requesting the loading/unloading and playback
`of CDs stored within a CD-changer unit.”;
`Id. at 5:44-47 (“These units may be linked through a variety of
`communication links. Physical cables may be used to connect
`the emulator unit with the car stereo/base unit and/or the CD-
`changer unit.”);
`See also id. at 4:41-47, 5:67-6:4, FIG. 2.
`See, e.g., Bhogal at 4:36-41 (“4:36-41 – “More specifically,
`though, the present invention is directed to providing a digital
`audio device for interfacing with other audio devices and
`
`
`
`21
`
`Honda Exhibit 1014
`Page 21
`
`

`
`
`
`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
`
`
`
`providing emulation of a CD-changer unit.”);
`Id. at 9:57-10:5 (“The advantages of the present invention
`should be apparent in view of the detailed description of the
`invention that is provided above. The present invention emulates
`a CD-changer unit while also storing digital audio data in a
`plurality of softcopy formats. The stored digital audio data can
`be organized as virtual CD-ROMs. Many different types of CD-
`changer units are commercially available, and these CD-changer
`units can only be operated with certain types of audio
`components or units. By emulating the operations of multiple
`types of CD-changer units, the present invention enables a single
`digital audio device to be inserted in many different
`configurations of digital audio systems. The present invention
`thereby extends the functionality of a digital audio system to
`include storage of softcopy digital audio files that may be
`accessed through controls and commands for a CD-changer
`unit.”);
`Id. at 6:45-48 (“Examples of the types of digital audio files that
`may be stored within the emulator unit include, without
`limitation, ".WAV", ".WMA", ".AU", ".MIDI", ".VOC",
`".MP2", and ".MP3" formatted files.”);
`See also Bhogal at 4:57-62, 5:30-32, FIG. 2.
`See, e.g., Berry at 3:51-57 (“Examples of electronic accessories
`connected to the network in FIG. 2 include a cellular phone 40,
`an MP3 audio player 41, and a palm-sized PC or personal digital
`assistant (PDA) 42. Once connected to the network 36, these
`accessories will communicate core functionality control signals
`and messages with a particular display subsystem.”);
`See also Berry at 3:62-4:9.
`See, e.g., Bhogal at 5:32-39 (“In a typical car stereo system, a car
`stereo unit interfaces directly with a CD-changer through an
`appropriate cable linking the two units. In accordance with a
`preferred embodiment of the present invention, emulator unit
`206 resides as an intermediary unit between car stereo unit 202
`and CD-changer unit 204. Emulator unit 206 interfaces and
`communicates with both the car stereo unit and the CD-changer
`unit.”);
`Id. at 7:39-42 (“In a first manner, the emulator unit merely
`
`
`
`22
`
`Honda Exhibit 1014
`Page 22
`
`

`
`
`
`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
`
`
`
`receives and forwards commands from the base unit to the CD-
`changer unit and also receives and forwards data from the CD-
`changer unit to the base unit.”);
`Id. at 8:21-29 (“As the user presses controls on the base unit for
`changing CDs or for obtaining information about CDs, the base
`unit generates commands for a CD-changer unit. However,
`unbeknownst to the base unit, the emulator unit captures the CD-
`changer commands and performs the appropriate processing.
`The emulator unit returns digital audio data and information
`about CDs and tracks in a manner expected by the base unit.”);
`Id. at 3:48- (“The present invention is a digital audio system that
`is preferably embodied in a mobile or portable package and has
`a basic computer architecture. …);
`Id. at 3:56-60 (“The functionality of the emulator unit may be
`accomplished through a variety of hardware and software within
`the emulator unit. The software may be stored in a combination
`of ROM and RAM and may be updated with newer versions of
`software.”)
`See also id. at 3:64-47, 5:44-4