UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
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`American Honda Motor Co., Inc.
`Petitioner
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`v.
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`Blitzsafe Texas, LLC
`Patent Owner
`
`
`Patent No. 8,155,342
`Filing Date: June 27, 2006
`Issue Date: April 10, 2012
`Title: MULTIMEDIA DEVICE INTEGRATION SYSTEM
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`Inter Partes Review No. IPR2016-01473
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`
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`DECLARATION OF JAMES T. GEIER
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF U.S.
`PATENT NO. 8,155,342
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`I, James T. Geier, hereby declare and state as follows:
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`I.
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`BACKGROUND AND QUALIFICATIONS
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`1.
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`2.
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`A copy of my curriculum vitae is attached.
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`I have 30 years’ experience in the communications industry designing,
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`analyzing and implementing communications systems, wireless networks, and
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`mobile devices.
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`3.
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`I received a Bachelor’s Degree in Electrical Engineering from California
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`State University in 1985. I received a Masters Degree in Electrical Engineering
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`from the Air Force Institute of Technology in 1990. I also received an M.B.A.
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`from the University of Phoenix in 2001.
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`4.
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`From 1986 to 1989, while in the Air Force and assigned to the 1815th
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`Operational Test and Evaluation Squadron, I tested and evaluated wired and
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`wireless communications systems supporting the transport of military data, voice
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`and video information worldwide. For example, this included running tests to
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`validate performance and compatibility of different communications devices, such
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`as secure telephones. During this time, I was also an instructor at the 1815th
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`System Evaluation School, where I developed and taught courses on
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`communications technologies and test methods.
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`5.
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`From 1990 to 1992, while in the Air Force and assigned to the
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`Information Systems Center, I designed and implemented computer networks for
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`Wright-Patterson Air Force Base. This involved testing some of the first-available
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`routers, switches and controllers in a laboratory environment and then later
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`designing and overseeing the installation of corresponding networks throughout
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`Wright-Patterson Air Force Base for supporting thousands of users.
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`6.
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`From 1992 to 1994, while employed at Adroit Systems, Inc., I analyzed
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`and evaluated communications technologies for use in Airborne communications
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`platforms, such as aircraft and satellites, to support secure transport of data, voice
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`and video information.
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`7.
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`From 1994 to 1996, while employed at TASC, Inc., I designed and
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`implemented communication networks for civilian and military applications. For
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`example, I analyzed and designed for the U.S. Department of Defense an audio /
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`video conferencing system for use by soldiers in battlefields. I also designed a
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`highly secure communications network supporting data, voice and video
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`applications for a U.S. Navy attack submarine.
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`8.
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`From 1996 to 2000, while employed at Monarch Marking Systems, I
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`designed and developed wireless printers and corresponding networks for
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`customers. This included designing wireless bar code scanners having voice
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`command recognition capabilities. In addition, I designed and implemented
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`wireless middleware that provided an interoperable interface between
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`incompatibility bar code scanners and servers.
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`2
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`9.
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`Since 2000, I have been an independent consultant working under the
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`business name Wireless-Nets, Ltd., where I have been analyzing and designing
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`wireless devices, communications systems and applications. As examples, I have
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`designed and tested voice-over-Wi-Fi user devices and networks, designed and
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`implemented drivers for Bluetooth transceivers, and implemented microcontroller-
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`based audio encoding for operation over ZigBee wireless networks.
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`II. ASSIGNMENT AND MATERIALS REVIEWED
`10.
`I submit this declaration in support of the Petition for Inter Partes
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`Review of U.S. Patent No. 8,155,342 (“the ‘342 patent”).
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`11.
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`I am not currently, and have not previously been, an employee of Honda
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`Motor Co., Ltd., or any of its affiliates or subsidiaries, including American Honda
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`Motor Co., Inc. and Honda of America Mfg., Inc.
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`12.
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`I am being compensated for my time at a rate of $300 per hour. My
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`compensation is in no way dependent upon the substance of the opinions I offer
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`below, or upon the outcome of Honda’s petition for inter partes review (or the
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`outcome of such an inter partes review proceeding, if a trial is initiated).
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`13.
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`I have been asked to provide certain opinions relating to the patentability
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`of the ’342 patent. Specifically, I have been asked to provide my opinion
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`regarding (i) the level of ordinary skill in the art to which the ’342 patent pertains
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`3
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`and (ii) the patentability of claims 49, 53, 54, 56, 57, 62, 66, 70, 73, 77, and 78 of
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`the ‘342 patent.
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`14. The opinions expressed in this declaration are not exhaustive of my
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`opinions on the patentability of claims 49, 53, 54, 56, 57, 62, 66, 70, 73, 77, and
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`78. Therefore, the fact that I do not address a particular point should not be
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`understood to indicate any agreement on my part that any claim otherwise
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`complies with the patentability requirements.
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`15.
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`I have reviewed the ‘342 patent, its prosecution history, and the papers in
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`Case IPR2016-00418 and Case IPR2016-00118 in forming my opinions in this
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`declaration.
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`16.
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`I have reviewed prior art to the ‘342 patent, including the following:
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`a)
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`U.S. Patent Application Publication No. 2003/0215102
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`b)
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`c)
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`d)
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`e)
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`("Marlowe") (Ex. 1009);
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`US 2003/007649 A1 (“Riggs”) (Ex. 1012);
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`DE 10101702 A1 (“Plagge”) (Ex. 1011);
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`U.S. Patent No. 6,629,197 (“Bhogal”) (Ex. 1013);
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`U.S. Patent Application Publication No. US 2003/0171834 A1
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`(“Silvester”) (Ex. 1014);
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`f)
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`U.S. Patent Application Publication No. US 2005/0281414 A1
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`(“Simon”) (Ex. 1015);
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`4
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`g)
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`Canadian Patent Application Publication No. CA 2347648
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`("Kandler") (Ex. 1016).
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`III. LEVEL OF ORDINARY SKILL IN THE ART
`17.
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`I understand that a patent must be written such that it can be understood
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`by a “person of ordinary skill” in the field of the patent.
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`18.
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`I understand that this hypothetical person of ordinary skill in the art is
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`considered to have the normal skills and knowledge of a person in the technical
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`field at issue. I understand that factors that may be considered in determining the
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`level of ordinary skill in the art include: (1) the education level of the inventor; (2)
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`the types of problems encountered in the art; (3) the prior art solutions to those
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`problems; (4) rapidity with which innovations are made; (5) the sophistication of
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`the technology; and (6) the education level of active workers in the field.
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`19.
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`It is my opinion that in June 2006, a person of ordinary skill in the art
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`relevant to the ‘342 patent would have had: at least a Bachelor’s degree in
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`electrical engineering or equivalent science/engineering degree and at least two
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`years of experience in signal processing and/or electronic system design, or would
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`have at least four years of experience in signal processing and/or electronic system
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`design.
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`5
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`20. Based on my experience and education, I consider myself to have been a
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`person of at least ordinary skill in the art as of June 2006 (and through today) with
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`respect to the field of technology implicated by the ‘342 patent.
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`IV. LEGAL STANDARDS
`21.
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`I have been informed and I understand that a patentability analysis is
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`performed from the viewpoint of a hypothetical person of ordinary skill in the art. I
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`understand that “the person of ordinary skill” is a hypothetical person who is
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`presumed to be aware of the universe of available prior art as of the time of the
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`invention at issue.
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`22.
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`I understand that a patent claim is unpatentable as anticipated when a
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`single piece of prior art describes every element of the claimed invention, either
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`expressly or inherently, and arranged in the same way as in the claim. For inherent
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`anticipation to be found, it is required that the missing descriptive material is
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`necessarily present in the prior art. I understand that, for the purpose of an inter
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`partes review, prior art that anticipates a claim can include both patents and printed
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`publications from anywhere in the world. I understand that some claims are
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`written in dependent form, in which case they incorporate all of the limitations of
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`the claim(s) on which they depend.
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`23.
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`I understand that a patent claim is unpatentable as obvious if the subject
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`matter of the claim as a whole would have been obvious to a person of ordinary
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`6
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`skill in the art as of the time of the invention at issue. I understand that the
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`following factors must be evaluated to determine whether the claimed subject
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`matter is obvious: (1) the scope and content of the prior art; (2) the difference or
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`differences, if any, between the scope of the claim of the patent under
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`consideration and the scope of the prior art; and (3) the level of ordinary skill in the
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`art at the time the patent was filed. Unlike anticipation, which allows consideration
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`of only one item of prior art, I understand that obviousness may be shown by
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`considering more than one item of prior art. Moreover, I have been informed and I
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`understand that so-called objective indicia of non-obviousness, also known as
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`“secondary considerations,” like the following are also to be considered when
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`assessing obviousness: (1) commercial success; (2) long-felt but unresolved needs;
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`(3) copying of the invention by others in the field; (4) initial expressions of
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`disbelief by experts in the field; (5) failure of others to solve the problem that the
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`inventor solved; and (6) unexpected results. I also understand that evidence of
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`objective indicia of non-obviousness must be commensurate in scope with the
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`claimed subject matter.
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`V. PRIORITY DATE ANALYSIS
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`24.
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`I have been asked to opine on the disclosure and support for the subject
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`matter claimed in claims 49, 53, 54, 56, 57, 62, 66, 70, 73, 77, and 78 of the ‘342
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`patent. In forming my opinions, I reviewed the following patent applications
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`appearing on the face of the ‘342 patent:
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`• U.S. Patent App. No. 10/316,961 (“the ‘961 application”) (Ex. 1021, Ex.
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`1022, & Ex. 1023), filed December 11, 2002, and which issued as U.S.
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`Patent No. 7,489,786;
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`• U.S. Patent App. No. 10/732,909 (“the ‘909 application”) (Ex. 1018, Ex.
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`1019, & Ex. 1020), filed December 10, 2003, and which was abandoned;
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`• U.S. Patent App. No. 11/071,667 (“the ‘667 application”) (Ex. 1004 &
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`1005), filed March 3, 2005, and which was abandoned; and
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`• U.S. Patent App. No. 11/475,847 (“the ‘847 application”) (Ex. 1002 &
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`Ex. 1003), filed June 27, 2006, and which issued as the ‘342 patent
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`25. Claims 49 and 73 (including claims 53, 54, 56, 57, 62, 66, 70, 77, and 78,
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`which are dependent upon either claims 49 or claim 73) each require an integration
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`subsystem in communication with a car audio system and first wireless interface in
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`communication with an integration subsystem, said first wireless interface
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`establishing a wireless communication link with a second wireless interface in
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`communication with a portable device. Specifically, I have been asked to opine on
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`the disclosure and support for these claimed features of claims 49 and 73. In my
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`opinion, these claimed features do not appear in any one of the applications above
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`that were filed before the filing of the ‘847 application.
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`26. The ‘961 application does not disclose any wireless communications
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`between a portable device, integration subsystem, or car audio system. In my
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`opinion, the disclosure of the ‘961 application does not reasonably convey that the
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`inventor of the ‘342 patent was in possession of the subject matter claimed in
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`claims 49 or 73 at the time of the filing of that application.
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`27. The ‘909 application discloses a wireless communication link, but only
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`between an integration system and a car stereo. Specifically, the ‘909 application
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`described in FIGs. 8a and 8b an embodiment of the invention with a docking
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`station including a multimedia device integration system, where a portable device
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`could be docked at the docking station. File History of 10/732,909, Ex. 1020, at
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`1031. The ‘909 application stated that “the integration system could wirelessly
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`communicate with the car stereo or car video system.” Id. Additionally, originally
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`filed claims 5, 6, 19, and 20 of the ‘909 application recited limitations where the
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`“integration device” and “car stereo” are either “wirelessly connected” or
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`connected by a “Bluetooth wireless connection.” Id. at 1034-36. Other than this
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`sentence, the ‘909 application did not contain any other disclosure of a wireless
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`communication link. Because claims 49 and 73 require a wireless link between a
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`portable device and an integration subsystem (i.e., the “integration device”), rather
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`than between the integration subsystem and the car audio system, it is my opinion
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`that the disclosure of the ‘909 application does not reasonably convey that the
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`inventor of the ‘342 patent was in possession of the subject matter claimed in
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`claims 49 or 73 at the time of the filing of that application.
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`28. The ‘667 application contains a statement that “in all embodiments of the
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`present invention, communication between the after-market device and a car stereo
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`or video system can be accomplished with known wireless technologies, such as
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`Bluetooth.” The ‘667 application, Ex. 1005 at p. 842. Other than this sentence,
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`neither the ‘667 application nor its originally filed claims contained any other
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`disclosure of a wireless communication link that the ‘961 application and the ‘909
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`application did not already contain. Claims 49 and 73 require specifically that the
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`wireless communication link is established by a first wireless interface in
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`communication with an integration subsystem, and that the wireless
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`communication link is established with a second wireless interface in
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`communication with a portable device, and because the ‘667 application contains
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`no such disclosure of a first wireless interface, second wireless interface, and
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`integration subsystem in the configuration required by claims 49 and 73, it is my
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`opinion that the disclosure of the ‘667 application does not reasonably convey to a
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`person of ordinary skill in the art that the inventor of the ‘342 patent was in
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`possession of the subject matter claimed in claims 49 or 73 at the time of the filing
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`of that application.
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`29. Because neither the ‘961 application, ‘909 application, nor the ‘667
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`application sufficiently describe the subject matter claimed in claims 49 and 73, it
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`is my opinion that no application filed prior to the ‘847 application reasonably
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`conveys that the inventor of the ‘342 patent was in possession of the subject matter
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`claimed in independent claims 49 and 73, or dependent claims 53, 54, 56, 57, 62,
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`66, 70, 77 and 78 of the ‘342 patent.
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`VI. CLAIM CONSTRUCTION
`30.
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`I understand that in an inter partes review, claim terms and phrases are to
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`be construed according to the broadest reasonable construction of those terms.
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`31. For purposes of my opinion, for the phrase “integration subystem,” I
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`have applied the definition: “A subsystem to perform at least: (1) connecting one
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`or more portable devices or inputs to the car audio/video system via an interface,
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`(2) processing and handling signals, audio, and/or video information, (3) allowing
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`a user to control the one or more portable devices via the car audio/video system,
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`and (4) displaying data from the one or more portable devices on the car
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`audio/video system.”
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`32. For purposes of my opinion, for the phrase “car audio/video system,” I
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`have applied the definition: “a car audio system, a car video system, or a car audio
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`and video system.”
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`33. For purposes of my opinion, for the phrase “device presence signal,” I
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`have applied the definition: “a signal indicating that a portable device is connected
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`to the car audio/video system through the integration subsystem.”
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`34. With respect to the other terms in the ’342 patent’s claims, I have applied
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`the plain and ordinary meaning of those claim terms, under their broadest
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`reasonable construction, when comparing the claims to the prior art.
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`VII. PATENTABILITY ANALYSIS
`A. Combination of Marlowe and Plagge Renders Obvious Claims 49,
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`53, 54, 56, 62, 66, 70, 73, 77, and 78 of the ‘342 Patent
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`35.
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`In my opinion, the combination of Marlowe and Plagge discloses all of
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`the limitations described in claims 49, 53, 54, 56, 62, 66, 70, 73, 77, and 78 and
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`renders those claims obvious.
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`36. Marlowe is directed to an “audio device integration system” for
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`integrating one or more after-market audio devices with an existing OEM or after-
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`market car stereo systems. Marlowe, Ex. 1009, at Abstract. Once integrated,
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`“control commands can be issued at the car stereo and responsive data from the
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`audio device can be displayed on the car stereo.” Id. Examples of after-market
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`audio devices that may be integrated via the system described in Marlowe include
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`CD players, CD changers, MP3 players, satellite receivers, and DAB receivers. Id.
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`37. Marlowe discloses a known problem in using after-market devices with
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`car stereos: original equipment manufacturers often produce car stereos having CD
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`players or CD changers that use proprietary buses and protocols, which made the
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`car stereos inoperable with after-market audio devices not made by the same
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`manufacturer. Id. at [0005].
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`38. Marlowe teaches an “interface” to address this problem. Id. at [0042].
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`Marlowe discloses an interface 20 being electrically connected to an after-market
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`CD player/changer 15 as well as a car radio 10. Id. at [0042] and FIG. 2A. The
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`interface 20 “allows the CD player 15 to be controlled by the control buttons 14 of
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`the radio 10” and also “allows information from the CD player 15, such as track,
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`disc, time, and song information, to be retrieved therefrom, processed and
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`formatted by the interface 20, [and] sent to the display 13 of the radio 10.” Id. The
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`interface can receive commands generated at the car stereo and convert them into a
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`format recognizable by the after-market audio device, as well as receive
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`information from the audio device and convert it into a format recognizable by the
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`car stereo. Id. at [0010].
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`39. Plagge discloses an interface emulator for integrating an after-market
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`MP3 player with a motor vehicle radio. Plagge, Ex. 1011 at [0005], [0006],
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`[0008]. Plagge identifies that MP3 players are frequently inoperable with motor
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`vehicle radios and Plagge thus describes retrofitting a motor vehicle radio already
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`present in the motor vehicle to include an interface emulator. Id.
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`40. Plagge, at FIG. 1, describes a motor vehicle audio device 1 having an
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`interface 2 for a CD changer and an audio input 3 for CD data. Id. at [0015], FIG.
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`1. Interface emulator 4 connects to the motor vehicle audio device 1 via interface
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`2. Id.
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`41. Plagge also teaches that interface emulator 4 has a wireless interface 5
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`which allows it to communicate wirelessly with an MP3 player 7. Id. The
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`interface emulator 4 converts control and status signals coming from the motor
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`vehicle audio device 1 into a format compatible with the MP3 player and converts
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`status signals coming from the MP3 player into a format that emulates a CD
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`changer that motor vehicle device 1 is accustomed to communicating with. Id.
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`42.
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`In my opinion, Marlowe in view of Plagge discloses all of the limitations
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`of claims 49 and 73.
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`43. Claim 49 is directed to “an integration subsystem in communication with
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`a car audio/video system.” Marlowe teaches each of the elements of an
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`integration subsystem, which is a subsystem that (1) connects one or more external
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`devices or inputs to an existing car stereo or video system via an interface, (2)
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`processes and handles signals, audio, and/or video information, (3) allows a user to
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`control the external devices via the car stereo or video system, and (4) displays
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`data from the devices on the car stereo or video system. Marlowe describes an
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`interface that “allows for a plurality of disparate audio devices to be integrated
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`with an existing car radio for use therewith.” Marlowe, Ex. 1009 at [0044].
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`44. Marlowe also describes processing and handling signals, audio, and/or
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`video information. See Marlowe, Ex. 1009 at [0075], [0089], and [0090]. For
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`example, Marlowe discloses “converting command signals issued from an after-
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`market or OEM car stereo into a format compatible with one or more external
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`audio devices connected to the present invention.” Marlowe, Ex. 1009 at [0089].
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`45. Marlowe further describes allowing a user to control the external devices
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`via the car stereo or video system. For example, Marlowe discloses “monitor[ing]
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`the control panel buttons of the car stereo for MP3 operational commands. . . . [I]f
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`a command is received, step 148 invokes step 150, wherein the received command
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`is converted into a format recognizable by the MP3 player connected to the present
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`invention.” Marlowe, Ex. 1009 at [0075].
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`46.
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`In addition, Marlowe also describes displaying data from the devices on
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`the car stereo or video system. For example, Marlowe discloses retrieving data
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`“from the MP3 player, including track, time, title, and song information, formatted,
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`and transmitt[ing] to the car stereo for display by the car stereo.” Marlowe, Ex.
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`1009 at [0074].
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`47. Claim 49 also requires “a first wireless interface in communication with
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`said integration subsystem.” Plagge discloses that interface emulator 4 (the
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`integration subsystem) includes a wireless interface 5. Plagge, Ex. 1011 at [0015],
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`FIG. 1.
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`48. Claim 49 further requires the “first wireless interface establishing a
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`wireless communication link with a second wireless interface in communication
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`with a portable device external to the car audio/video system.” Marlowe discloses
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`integrating portable audio devices with a car stereo (car audio/video system),
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`Marlowe, Ex. 1009 at [0101]. Plagge describes that MP3 player 7 (external
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`portable device) includes a wireless interface 9 (second wireless interface).
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`Plagge, Ex. 1011 at [0016], FIG. 1. Plagge describes that interface emulator 4 is
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`able to communicate, via wireless interfaces 5 and 9, with an MP3 player 7. Id.
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`49. Claim 49 additionally requires that the integration subsystem “obtains,
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`using said wireless communication link, information about an audio file stored on
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`the portable device, transmits the information to the car audio/video system for
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`subsequent display of the information on a display of the car audio/video system,
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`instructs the portable device to play the audio file in response to a user selecting
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`the audio file using controls of the car audio/video system.” Marlowe teaches that
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`interface 20 can receive commands generated at the car stereo and convert them
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`into a format recognizable by the after-market audio device, as well as receive
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`information from the audio device and convert it into a format recognizable by the
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`car stereo. Id. at [0010]. The interface 20 “allows the CD player 15 to be
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`controlled by the control buttons 14 of the radio 10” and also “allows information
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`from the CD player 15, such as track, disc, time, and song information, to be
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`retrieved therefrom, processed and formatted by the interface 20, [and] sent to the
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`display 13 of the radio 10.” Id. Such information can come from CD tracks stored
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`on discs in the CD player. Id. at [0043]. Marlowe teaches that the interface 20 can
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`process “[o]perational commands such as track selection, pause, play, stop, fast
`
`forward, rewind, and other commands” which are entered via car radio 10 and send
`
`them to the portable device to be executed. Marlowe, Ex. 1009 at [0044]; see also
`
`[0075].
`
`50. Claim 49 further requires that the integration subsystem “receives audio
`
`generated by the portable device over said wireless communication link for playing
`
`on the car audio/video system.” Marlowe discloses connecting the MP3 player to
`
`the car stereo system, “allowing audio from the MP3 player to be played through
`
`the car stereo.” Marlowe, Ex. 1009 at [0074].
`
`51. The limitations of claim 73 are identical to the limitations of claim 49,
`
`except that claim 73 requires that the information obtained by the integration
`
`subsystem is “received by” the portable device, rather than “stored on” the portable
`
`device. Marlowe discloses that interface 20 can integrate not only CD players but
`
`
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`17
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`also devices that receive audio files to be played back such as an MP3 player, a
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`
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`satellite receiver, or a DAB receiver. Marlowe, Ex. 1009 at [0041], [0044], [0045],
`
`FIGS. 2A, 2B, 2C.
`
`52.
`
`In my opinion, it would have been obvious for one of ordinary skill in the
`
`art at the time of the filing of the ‘342 patent to combine the teachings of Marlowe
`
`and Plagge to arrive at the subject matter claimed in claims 49 and 73.
`
`53. Marlowe discloses using its interface unit to integrate a portable audio
`
`device with a car stereo, but it describes the interface unit and portable audio
`
`device being docked together or being connected physically. Marlowe, Ex. 1009 at
`
`[0101]. Plagge also teaches integrating portable audio devices, such as a portable
`
`MP3 player, to a car audio system. Plagge, Ex. 1011 at [0002], [0015].
`
`54. Like the interface of Marlowe, the interface emulator of Plagge converts
`
`control signals coming from the car audio system into a format compatible with the
`
`portable device, and it converts information coming from the portable device to a
`
`format compatible with the car audio system. See Plagge, Ex. 1011 at [0008]; see
`
`also Plagge, Ex. 1011 at [0018].
`
`55. But unlike the interface of Marlowe, the interface emulator of Plagge is
`
`designed to communicate with a portable device via a wireless communication
`
`link. See Plagge, Ex. 1011 at [0015], [0016].
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`56. Marlowe and Plagge both sought to solve the same problem of
`
`connecting incompatible portable devices to car audio systems. In my opinion, at
`
`the time of the filing of the ‘342 patent, wireless technologies such as Bluetooth
`
`were well known in the art as a substitute for cables that traditionally connected
`
`portable devices. See JENNIFER BRAY & CHARLES F. STURMAN, BLUETOOTH 1.1
`
`CONNECT WITHOUT CABLES xxiii, 2nd ed. 2002, Ex. 1017; see also id. at 1.
`
`57.
`
`In my opinion, it would have been obvious to one of ordinary skill in the
`
`art at the time of the filing of the ‘342 patent to apply the wireless capability of the
`
`interface emulator of Plagge to the interface of Marlowe to improve its versatility
`
`and ease of use. Such modification would have yielded a predictable result.
`
`58. The tables below show how each limitation of claim 49 is met by
`
`Marlowe in view of Plagge.
`
`Claim 49
`(a) A multimedia
`device integration
`system,
`comprising:
`
`(b) an integration
`subsystem in
`
`Marlowe and Plagge
`To the extent the Board determines the preamble is a
`limitation, it is disclosed as follows:
`
`Marlowe at [0002]:
`“The present invention relates to an audio device integration
`system. More specifically, the present invention relates to 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.”
`Marlowe at [0044]:
`
`
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`communication
`with a car
`audio/video
`system; and
`
`(c) a first wireless
`interface in
`communication
`with said
`integration
`subsystem, said
`first wireless
`interface
`establishing a
`wireless
`communication
`
`
`
`“FIG. 2b is a block diagram showing an alternate embodiment
`of the present invention, wherein an MP3 player 30 is
`integrated with an OEM or after-market car radio 10 via
`interface 20. 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.”
`
`Marlowe at [0075]:
`“In steps 146, the present invention monitors the control panel
`buttons of the car stereo for MP3 operational commands.
`Examples of such commands include track forward, track
`reverse, play, stop, fast forward, rewind, track program,
`random track play, and other similar commands. In step 148,
`if a command is not detected, step 146 is reinvoked.
`Otherwise, if a command is received, step 148 invokes step
`150, wherein the received command is converted into a
`format recognizable by the MP3 player connected to the
`present invention. For example, in this step, a command
`issued from a HONDA car radio is converted into a format
`recognizable by an MP3 player manufactured by
`PANASONIC, Inc. Any conceivable command from any type
`of car radio can be formatted for use by an MP3 player of any
`type or manufacture. Once the command has been formatted,
`step 152 is invoked, wherein the formatted command is
`transmitted to the MP3 player and executed. Step 140 is then
`re-invoked, so that additional processing can occur.”
`Plagge at [0011]:
`“In another preferred specific embodiment, the interface
`emulator and the playback device for digital audio signals
`stored in compressed form are therefore designed as separate
`units. In this context, an interface is preferably allocated to
`each playback device and interface emulator, in particular an
`interface for wireless data transmission, over which the
`control signals and status signals can be transmitted.”
`
`Plagge at [0015]:
`
`
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`20
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`link with a second
`wireless interface
`in communication
`with a portable
`device external to
`the car
`audio/video
`system,
`
`(d) wherein said
`integration
`subsystem obtains,
`using said wireless
`communication
`
`
`
`“. . . Vehicle audio device 1 is connected to an interface
`emulator 4 via interface 2. Interface emulator 4 is also
`designed to include a wireless interface 5. Interface emulator
`4 is able to communicate with an MP3 player 7, which is
`situated in a mounting unit 6, over wireless interface 3. . . .”
`
`Plagge at [0016]:
`“Mounting unit 6 includes mechanical connecting means and
`electrical plug connections (not shown) by means of which
`the MP3 player can be connected to a vehicle electrical
`system 8 and to the audio input 3 of vehicle radio 1. In
`addition, MP3 player 7 is designed to have a wireless
`interface 9. . . .”
`
`Plagge at [0018]:
`“The main object of the interface emulator 4 is to convert the
`control signals and status signals of vehicle audio device 1
`and MP3 player 7. The control signals and status signals
`transmitted by vehicle audio device 1 over interface 2 are
`adapted for a CD changer. Interface emulator 4 receives these
`signals and converts them to a format for MP3 player 7. The
`converted control signals and status signals are then sent by
`interface emulator 4 over air interface 5, and received and
`executed by MP3 player 7 via air interface 9. Conversely,
`MP3 player 7 sends its status signals via wireless interface 9;
`these status signals are received via wireless interface 5 of
`interface emulator 4. Interface emulator 4 converts the status
`signals of MP3 player 7 to status signals of a CD changer and
`transmits them to vehicle radio 1 via interface 2. . . .”
`
`Plagge at [0004].
`Marlowe at [0042]:
`“. . . The interface 20 is el