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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`
`
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`Inter Partes Review No. IPR2016-01473
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`PETITION FOR INTER PARTES REVIEW
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`TABLE OF CONTENTS
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`Page
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`B.
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`C.
`D.
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`IV.
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`V.
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`Introduction ..................................................................................................... 1
`I.
`II. Grounds for Standing Pursuant to 37 C.F.R. § 42.104(a) .............................. 2
`III. The ‘342 Patent ............................................................................................... 2
`A.
`Prosecution History of the ‘342 Patent ................................................ 2
`B.
`Priority Date of the ‘342 Patent............................................................ 3
`Identification of Challenge Pursuant to 37 C.F.R. § 42.104(b) ..................... 5
`A.
`37 C.F.R. § 42.104(b)(1): Claims For Which Inter Partes
`Review Is Requested ............................................................................ 5
`37 C.F.R. § 42.104(b)(2): The Prior Art and Specific Grounds
`On Which The Challenge to the Claims Is Based ................................ 5
`37 C.F.R. § 42.104(b)(3): Claim Construction ................................... 6
`37 C.F.R. § 42.104(b)(4): How the Construed Claims are
`Unpatentable ......................................................................................... 8
`37 C.F.R. § 42.104(b)(5): Supporting Evidence ................................. 8
`E.
`There Is a Reasonable Likelihood That at Least One Claim of the ‘342
`Patent Is Unpatentable .................................................................................... 9
`A. Ground 1: Claims 49, 53, 54, 56, 62, 66, 70, 73, 77, and 78 are
`unpatentable under 35 U.S.C. § 103(a) by Marlowe in view of
`Plagge ................................................................................................... 9
`1.
`Claims 49 and 73...................................................................... 11
`2.
`Claims 53, 54, 77, and 78 ........................................................ 18
`3.
`Claim 56 ................................................................................... 19
`4.
`Claim 62 ................................................................................... 20
`5.
`Claims 66 and 70...................................................................... 20
`B. Ground 2: Claim 57 is unpatentable under 35 U.S.C. § 103(a)
`by Marlowe in view of Plagge and in further view of Riggs ............. 22
`C. Ground 3: Claims 49, 53, 54, 56, 62, 66, 70, 73, 77, and 78 are
`unpatentable under 35 U.S.C. § 103(a) by Marlowe in view of
`Plagge and in further view Bhogal ..................................................... 23
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`TABLE OF CONTENTS
`(continued)
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`Page
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`E.
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`F.
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`D. Ground 4: Claims 49, 53, 62, 66, 70, 73, and 77 are
`unpatentable under U.S.C. § 102(b) by Silvester ............................... 26
`1.
`Claims 49 and 73...................................................................... 27
`2.
`Claims 53 and 77...................................................................... 35
`3.
`Claim 62 ................................................................................... 37
`4.
`Claims 66 and 70...................................................................... 37
`Ground 5: Claims 54, 56, and 78 are unpatentable under U.S.C.
`§ 103(a) by Silvester (Ex. 1012) in view of Simon (Ex. 1013) ......... 38
`1.
`Claim 56 ................................................................................... 39
`2.
`Claims 54 and 78...................................................................... 40
`Ground 6: Claim 57 is unpatentable under U.S.C. § 103(a) by
`Silvester in view of Kandler ............................................................... 42
`G. Ground 7: Claims 49, 53, 54, 56, 62, 66, 70, 73, 77, and 78 are
`unpatentable under U.S.C. § 103(a) by Simon in view of
`Bhogal................................................................................................. 43
`1.
`Claims 49 and 73...................................................................... 43
`2.
`Claims 53, 54, 77, and 78 ........................................................ 49
`3.
`Claim 56 ................................................................................... 51
`4.
`Claim 62 ................................................................................... 51
`5.
`Claims 66 and 70...................................................................... 51
`VI. Mandatory Notices Pursuant to 37 C.F.R. § 42.8(a)(1) ............................... 52
`A.
`C.F.R. § 42.8(b)(a): Real Parties-In-Interest ..................................... 52
`B.
`C.F.R. § 42.8(b)(2): Related Matters ................................................ 53
`C.
`C.F.R. § 42.8(b)(3) and (4): Lead and Back-up Counsel and
`Service Information ............................................................................ 53
`VII. Conclusion .................................................................................................... 54
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`LIST OF EXHIBITS
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`Exhibit 1001: U.S. Patent No. 8,155,342 (“the ‘342 patent”)
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`Exhibit 1002: File History of the ‘342 patent (“‘342 file history”) (part 1 of 2)
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`Exhibit 1003: File History of the ‘342 patent (“‘342 file history”) (part 2 of 2)
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`Exhibit 1004: File History for U.S. Application Serial No. 11/071,667 (“the ‘667
`application”) (part 1 of 2)
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`Exhibit 1005: File History for U.S. Application Serial No. 11/071,667 (“the ‘667
`application”) (part 2 of 2)
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`Exhibit 1006: U.S. Patent No. 7,489,786 (“the ‘786 patent”)
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`Exhibit 1007: Declaration of James T. Geier (“Geier Decl.”)
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`Exhibit 1008: Plaintiff’s Disclosure of Asserted Claims and Infringement
`Contentions
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`Exhibit 1009: U.S. Patent Application Publication No. 2003/0215102 ("Marlowe")
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`Exhibit 1010: German Patent Application Publication No. 10101802 A1
`(“Plagge”)
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`Exhibit 1011: German Patent Application Publication No. 10101802 A1 –
`Translated (“Plagge”)
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`Exhibit 1012: U.S. Patent Application Publication No. US 2003/007649 A1
`(“Riggs”)
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`Exhibit 1013: U.S. Patent No. 6,629,197 (“Bhogal”)
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`Exhibit 1014: U.S. Patent Application Publication No. US 2003/0171834 A1
`(“Silvester”)
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`Exhibit 1015: U.S. Patent Application Publication No. US 2005/0281414 A1
`(“Simon”)
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`Exhibit 1016: Canadian Patent Application Publication No. CA 2347648
`(“Kandler”)
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`Exhibit 1017: Excerpt from JENNIFER BRAY & CHARLES F. STURMAN, BLUETOOTH
`1.1 CONNECT WITHOUT CABLES, 2nd ed. 2002
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`
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`Exhibit 1018: File History for U.S. Application Serial No. 10/732,909 (“the ‘909
`application”) (part 1 of 3)
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`Exhibit 1019: File History for U.S. Application Serial No. 10/732,909 (“the ‘909
`application”) (part 2 of 3)
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`Exhibit 1020: File History for U.S. Application Serial No. 10/732,909 (“the ‘909
`application”) (part 3 of 3)
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`Exhibit 1021: File History for U.S. Application Serial No. 10/316,961 (“the ‘961
`application”) (part 1 of 3)
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`Exhibit 1022: File History for U.S. Application Serial No. 10/316,961 (“the ‘961
`application”) (part 2 of 3)
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`Exhibit 1023: File History for U.S. Application Serial No. 10/316,961 (“the ‘961
`application”) (part 3 of 3)
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`-iv-
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`American Honda Motor Co., Inc. (“Honda” or “Petitioner”) respectfully
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`requests inter partes review under 35 U.S.C. §§ 311-319 and 37 C.F.R. § 42 of
`
`claims 49, 53, 54, 56, 57, 62, 66, 70, 73, 77, and 78 of U.S. Patent No. 8,155,342
`
`(Ex. 1001, "the '342 patent"), attached hereto as Exhibit 1001.
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`The undersigned representative of Petitioner authorizes the Patent Office to
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`charge the Petition Fee, along with any additional fees, to Deposit Account
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`503013, ref: 651377-600009.
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`I.
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`Introduction
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`The '342 patent is directed to a multimedia device integration system that
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`integrates a portable device with a car audio/video system such that control
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`commands issued at the car audio/video system can control the portable device,
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`and information about an audio file on the portable device can be displayed on
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`the car audio/video system. See Ex. 1001 at Abstract. The '342 patent claims
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`are directed to multimedia integration subsystems comprising an integration
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`subsystem and wireless interfaces that permit the portable device and car
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`audio/video system to be integrated wirelessly. See id.
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`The systems and methods claimed in the ‘342 patent were neither new nor
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`non-obvious when the ‘342 patent was filed. This petition sets forth grounds that
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`each independently render the claims of the ‘342 patent invalid. Each of these
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`grounds are based upon patents or printed publications that were publicly available
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`prior to the priority date of the ‘342 patent. Further, none of these grounds are
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`redundant with any other ground set forth in this Petition. Accordingly, in this
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`Petition, Petitioner challenges the validity of claims 49, 53, 54, 56, 57, 62, 66, 70,
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`73, 77, and 78.
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`II. Grounds for Standing Pursuant to 37 C.F.R. § 42.104(a)
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`Honda certifies that the ‘342 patent is available for inter partes review. This
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`Petition is being submitted within one year of Blitzsafe’s service of the complaint in
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`Blitzsafe Texas, LLC v. Honda Motor Co., Ltd., et al., Case No. 2:15-CV-1274-JRG-
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`RSP (E.D. Tex.). Petitioner is not barred or estopped from requesting inter partes
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`review, nor is Petitioner in privity with any party who is barred or estopped from
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`challenging the patent claims on the grounds identified herein.
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`III. The ‘342 Patent
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`Prosecution History of the ‘342 Patent
`
`A.
`U.S. Application Serial No. 11/475,847 (“the ‘847 application”) was filed on
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`June 27, 2006 with 91 claims. ‘342 file history, Ex. 1002 at pp. 1-199.
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`In response to the first Non-Final Office Action issued on May 28, 2009, the
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`Applicant cancelled original claims 1- 91 and added new claims 92-212, noting
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`that "[n]ew claims 92-212 are directed to a multimedia device integration system
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`which allows for wireless integration of a portable device with a car audio/video
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`system." ‘342 file history, Ex. 1003 at p. 732; see id. at 702-37. With this
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`Amendment, the Applicant argued that the primary reference cited, Coon (U.S.
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`Patent No. 6,539,358), disclosed a voice-interactive docking station for a portable
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`computer device, and failed to disclose an integration subsystem that obtains
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`information about an audio/visual file. See id. at p. 734.
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`In a later Office Action issued on February 15, 2011, the Examiner rejected
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`all the claims primarily in view of Tranchina (US 7,493,645). See id. at pp. 882-
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`909. In response, the Applicant argued that Tranchina failed to disclose a system
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`which instructs a portable device to play an audio file in response to a user
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`selecting the audio file from controls of the car audio/visual system. See id. at p.
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`937. After a second Final Office Action in which the Examiner rejected the claims
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`again based on Tranchina, the Applicant further attempted to distinguish Tranchina
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`by arguing that the claimed integration subsystem is wirelessly connected to a car
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`audio/video system, whereas the system in Tranchina was not wireless. Id. at
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`1039-42. On February 16, 2012, the Examiner issued a Notice of Allowance,
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`without an indication of a reason for allowance. See id. at pp. 1079-1083. The
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`‘342 Patent issued on April 10, 2012.
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`Priority Date of the ‘342 Patent
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`B.
`The ‘342 patent was filed on June 27, 2006, and issued on April 10, 2012. The
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`‘847 application was a continuation-in-part of application No. 11/071,667 (“the ‘667
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`application”) which was filed on March 3, 2005. The ‘667 application was a
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`continuation-in-part of application No. 10/732,909 (“the ‘909 application”) which was
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`filed on December 10, 2003. The ‘909 application was a continuation-in-part of
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`application No. 10/316,961 (“the ‘961 application”) which was filed on December 11,
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`2002 which is now U.S. patent no. 7,489,786 (“the ‘786 patent”). Claims 49 and 73
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`(including dependent claims 53, 54, 56, 57, 62, 66, 70, 77, and 78) each require an
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`integration subsystem in communication with a car audio system and first wireless
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`interface in 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. These claimed features do not appear in any
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`one of the applications above that were filed before the filing of the ‘847 application.
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`Geier Decl., Ex. 1007 at 24-29. The ‘909 application discloses a wireless
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`communication link, but only between an integration subsystem and a car stereo. Geier
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`Decl., Ex. 1007 at 27. The ‘667 application contains no such disclosure of a first
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`wireless interface, second wireless interface, and integration subsystem in the
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`configuration required by claims 49 and 73. Id. at 28. No application filed prior to the
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`‘847 application reasonably conveys to a person of ordinary skill in the art that the
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`inventor of the ‘342 patent was in possession of the subject matter claimed in
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`independent claims 49 and 73, or dependent claims 53, 54, 56, 57, 62, 66, 70, 77 and 78
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`of the ‘342 patent. Id. at 29. Accordingly, the applicable priority date for claims of the
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`‘342 patent challenged by this petition is its filing date of June 27, 2006. Blitzsafe
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`confirmed this priority date in the litigation referenced in Section II. Ex. 1008 at 6.
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`IV.
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`Identification of Challenge Pursuant to 37 C.F.R. § 42.104(b)
`A.
`Requested
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`37 C.F.R. § 42.104(b)(1): Claims For Which Inter Partes Review Is
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`Inter partes review is requested for claims 49, 53, 54, 56, 57, 62, 66, 70, 73,
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`77, and 78 of the ‘342 patent.
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`37 C.F.R. § 42.104(b)(2): The Prior Art and Specific Grounds On
`B.
`Which The Challenge to the Claims Is Based
`Inter partes review is requested in view of the following prior art references:
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`• U.S. Patent Application Publication No. 2003/0215102 ("Marlowe") (Ex.
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`1009). Marlowe was published on November 20, 2003. Thus, it is prior art under
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`35 U.S.C. § 102(b).
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`• German Patent Application Publication No. 10101802 A1 (“Plagge”) (Ex. 1010
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`& Ex. 1011) was published on July 18, 2002. Thus, it is prior art under § 102(b).
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`• U.S. Patent Application Publication No. US 2003/007649 A1 (“Riggs”) (Ex.
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`1012) was published on January 9, 2003. Thus, it is prior art under § 102(b).
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`• U.S. Patent No. 6,629,197 (“Bhogal”) (Ex. 1013) was filed on November 3,
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`2000, and issued on September 30, 2003, and is prior art under § 102(b).
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`• U.S. Patent Application Publication No. US 2003/0171834 A1 (“Silvester”)
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`(Ex. 1014) was published on September 11, 2003. Thus, it is prior art under §
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`102(b).
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`• U.S. Patent Application Publication No. US 2005/0281414 A1 (“Simon”) (Ex.
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`1015) was published on December 22, 2005. Thus, it is prior art under § 102(e).
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`• Canadian Patent Application Publication No. CA 2347648 ("Kandler") (Ex.
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`1016) was published on December 1, 2001. Thus, it is prior art under § 102(b).
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`The specific statutory grounds on which the challenge to the claims is based
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`and the patents or printed publications relied upon for each ground are as follows:
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`Claims Rendered Unpatentable
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`Combination
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`1. Claims 49, 53, 54, 56, 62, 66, 70, 73,
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`Marlowe and Plagge (§ 103(a))
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`77, and 78
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`2. Claim 57
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`Marlowe, Plagge, and Riggs (§ 103(a))
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`3. Claims 49, 53, 54, 56, 62, 66, 70, 73,
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`Marlowe, Plagge, and Bhogal (§ 103(a))
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`77, and 78
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`4. Claims 49, 53, 62, 66, 70, 73, and 77 Silvester (§ 102(b))
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`5. Claim 54, 56, and 78
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`Silvester and Simon (§ 103(a))
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`6. Claim 57
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`Silvester and Kandler (§ 103(a))
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`7. Claims 49, 53, 54, 56, 62, 66, 70, 73,
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`Simon and Bhogal (§ 103(a))
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`77, and 78
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`37 C.F.R. § 42.104(b)(3): Claim Construction
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`C.
`Pursuant to 37 C.F.R. § 42.100(b), and solely for the purposes of this
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`review, Petitioner construes the claim language such that the claims are given their
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`broadest reasonable interpretation in light of the specification of the ‘342 patent.
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`For terms not specifically listed and construed below, Petitioner interprets them for
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`purposes of this review in accordance with their plain and ordinary meaning under
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`the required broadest reasonable interpretation.
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` “integration subsystem” — In its Decision Denying Institution in Case No.
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`IPR2016-00118, the Board construed the term “integration subsystem” of the ‘342
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`patent to mean:
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`A subsystem to perform at least: (1) connecting one or more portable
`devices or inputs to the car audio/video system via an interface, (2)
`processing and handling signals, audio, and/or video information, (3)
`allowing a user to control the one or more portable devices via the car
`audio/video system, and (4) displaying data from the one or more
`portable devices on the car audio/video system.
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`Therefore, solely for the purposes of this petition, Petitioner adopts
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`the same construction.
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`“car audio/video system” – In its Institution of Inter Partes Review in Case
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`No. IPR2016-00418, the Board construed the term “car audio/video system” of the
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`‘342 patent to mean “a car audio system, a car video system, or a car audio and
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`video system.” Therefore, solely for the purposes of this petition, Petitioner adopts
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`the same construction.
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`“device presence signal” – In its Institution of Inter Partes Review in Case
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`No. IPR2016-00418, the Board construed the term “device presence signal” of the
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`‘342 patent to mean “a signal indicating that a portable device is connected to the
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`car audio/video system through the integration subsystem.” Therefore, solely for
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`the purposes of this petition, Petitioner adopts the same construction.
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`Beyond these terms, there is no indication in the ‘342 patent that the
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`broadest reasonable interpretation of any other term in the challenged claims
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`should be afforded anything other than its plain and ordinary meaning. Because
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`the broadest reasonable interpretation standard for claim construction in inter
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`partes review proceedings is different than that used during a U.S. district court
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`litigation, see Cuozzo Speed Techs. v. Lee, __ S. Ct. __, 2016 WL 3369425, at *12-
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`14 (June 20, 2016), Petitioner expressly reserves the right to argue a different claim
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`construction in litigation for any term of the ‘342 patent as appropriate in that
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`proceeding.
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`D.
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`37 C.F.R. § 42.104(b)(4): How the Construed Claims are
`Unpatentable
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`An explanation of how claims 49, 53, 54, 56, 57, 62, 66, 70, 73, 77, and 78 are
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`unpatentable is set forth below at Section V.
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`37 C.F.R. § 42.104(b)(5): Supporting Evidence
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`E.
`This Petition is supported by the evidence included in the Exhibits submitted
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`contemporaneously with this Petition including, without limitation, the Declaration of
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`Jim Geier under 37 C.F.R. § 1.68 included at Exhibit 1007. A list of all Exhibits is
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`included with this Petition. Unless otherwise noted, citations to page numbers in this
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`Petition are to the page numbers appended to each page of the exhibits and not to any
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`page numbers present in the original document.
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`V.
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`There Is a Reasonable Likelihood That at Least One Claim of the ‘342
`Patent Is Unpatentable
`A. Ground 1: Claims 49, 53, 54, 56, 62, 66, 70, 73, 77, and 78 are
`unpatentable under 35 U.S.C. § 103(a) by Marlowe in view of Plagge
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`The combination of Marlowe and Plagge discloses all of the limitations
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`described in claims 49, 53, 54, 56, 62, 66, 70, 73, 77, and 78 and renders those claims
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`obvious. Marlowe is directed to an “audio device integration system” for integrating
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`one or more after-market audio devices with an existing OEM or after-market car stereo
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`systems. Marlowe, Ex. 1009, at Abstract. Once integrated, “control commands can be
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`issued at the car stereo and responsive data from the audio device can be displayed on
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`the car stereo.” Id. Examples of after-market audio devices that may be integrated via
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`the system described in Marlowe include CD players, CD changers, MP3 players,
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`satellite receivers, and DAB receivers. Id.
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`Marlowe discloses a known problem in using after-market devices with car
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`stereos: original equipment manufacturers often produce car stereos having CD players
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`or CD changers that use proprietary buses and protocols, which made the car stereos
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`inoperable with after-market audio devices not made by the same manufacturer. Id. at
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`[0005]. Marlowe teaches an “interface” to address this problem. Id. at [0042]. In the
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`context of Figure 2A, Marlowe discloses an interface 20 being electrically connected to
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`an after-market CD player/changer 15 as well as a car radio 10. Id. at [0042] and FIG.
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`2A. The interface 20 “allows the CD player 15 to be controlled by the control buttons
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`14 of 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 formatted by
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`the interface 20, [and] sent to the display 13 of the radio 10.” Id. The interface can
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`receive commands generated at the car stereo and convert them into a format
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`recognizable by the after-market audio device, as well as receive information from the
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`audio device and convert it into a format recognizable by the car stereo. Id. at [0010].
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`Plagge discloses an interface emulator for integrating an after-market MP3
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`player with a motor vehicle radio. Plagge, Ex. 1011 at [0005], [0006], [0008].
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`Plagge identifies that MP3 players are frequently inoperable with motor vehicle
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`radios and Plagge thus describes retrofitting a motor vehicle radio already present
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`in the motor vehicle to include an interface emulator. Id. Plagge at Figure 1
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`describes a motor vehicle audio device 1 having an interface 2 for a CD changer
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`and an audio input 3 for CD data. Id. at [0015], FIG. 1. Interface emulator 4
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`connects to the motor vehicle audio device 1 via interface 2. Id. Plagge also
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`teaches that interface emulator 4 has a wireless interface 5 which allows it to
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`communicate wirelessly with an MP3 player 7. Id. The interface emulator 4
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`converts control and status signals coming from the motor vehicle audio device 1
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`into a format compatible with the MP3 player and converts status signals coming
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`from the MP3 player into a format that emulates a CD changer that motor vehicle
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`device 1 is accustomed to communicating with. Id.
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`Claims 49 and 73
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`1.
`Marlowe in view of Plagge discloses all of the limitations of claims 49 and
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`73. Geier Decl., Ex. 1007 at 42. Claim 49 is directed to “an integration subsystem
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`in communication with a car audio/video system.” Marlowe describes an interface
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`system containing a Microcontroller U1 subsystem. See Marlowe, Ex. 1009 at
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`[0055]. Marlowe teaches each of the elements of an integration subsystem, which
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`is a subsystem that (1) connects one or more external devices or inputs to an
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`existing car stereo or video system via an interface, (2) processes and handles
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`signals, audio, and/or video information, (3) allows a user to control the external
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`devices via the car stereo or video system, and (4) displays data from the devices
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`on the car stereo or video system. Geier Decl., Ex. 1007 at 43. Marlowe describes
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`an 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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`Marlowe also describes processing and handling signals, audio, and/or video
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`information. See id. at [0075], [0089], and [0090]. For example, Marlowe
`
`discloses “converting command signals issued from an after-market or OEM car
`
`stereo into a format compatible with one or more external audio devices connected
`
`
`
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`-11-
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`

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`
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`to the present invention.” Id. at [0089]. Marlowe further describes allowing a user
`
`
`
`to control the external devices via the car stereo or video system. For example,
`
`Marlowe discloses “monitor[ing] the control panel buttons of the car stereo for
`
`MP3 operational commands. . . . [I]f 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.” Id. at [0075]. In addition,
`
`Marlowe also describes displaying data from the devices on the car stereo or video
`
`system. For example, Marlowe discloses retrieving data “from the MP3 player,
`
`including track, time, title, and song information, formatted, and transmitt[ing] to
`
`the car stereo for display by the car stereo.” Id. at [0074].
`
`Claim 49 also requires “a first wireless interface in communication with said
`
`integration subsystem.” Marlowe does not disclose this limitation, but Plagge does.
`
`Plagge discloses that interface emulator 4 (the integration subsystem) includes a
`
`wireless interface 5. Plagge, Ex. 1011 at [0015], FIG. 1. Claim 49 further requires the
`
`“first wireless interface establishing a wireless communication link with a second
`
`wireless interface in communication with a portable device external to the car
`
`audio/video system.” Marlowe discloses integrating portable audio devices with a car
`
`stereo (car audio/video system), Marlowe, Ex. 1009 at [0101], but Marlowe does not
`
`disclose a wireless communication link. Plagge describes that MP3 player 7 (external
`
`portable device) includes a wireless interface 9 (second wireless interface). Plagge, Ex.
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`
`
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`-12-
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`
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`1011 at [0016], FIG. 1. Plagge describes that interface emulator 4 is able to
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`
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`communicate, via wireless interfaces 5 and 9, with an MP3 player 7. Id.
`
`Claim 49 additionally requires that the integration subsystem “obtains, using said
`
`wireless communication link, information about an audio file stored on the portable
`
`device, transmits the information to the car audio/video system for subsequent display
`
`of the information on a display of the car audio/video system, instructs the portable
`
`device to play the audio file in response to a user selecting the audio file using controls
`
`of the car audio/video system.” Marlowe teaches that interface 20 can receive
`
`commands generated at the car stereo and convert them into a format recognizable by
`
`the after-market audio device, as well as receive information from the audio device and
`
`convert it into a format recognizable by the car stereo. Marlowe, Ex. 1009 at [0010].
`
`The interface 20 “allows the CD player 15 to be controlled by the control buttons 14 of
`
`the radio 10” and also “allows information from the CD player 15, such as track, disc,
`
`time, and song information, to be retrieved therefrom, processed and formatted by the
`
`interface 20, [and] sent to the display 13 of the radio 10.” Id. Such information can
`
`come from CD tracks stored on discs in the CD player. Id. at [0043]. Marlowe teaches
`
`that the interface 20 can 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. Id. at [0044]; see [0075].
`
`Claim 49 further requires that the integration subsystem “receives audio
`
`
`
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`-13-
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`generated by the portable device over said wireless communication link for playing on
`
`
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`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].
`
`
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`The table below shows 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
`communication
`with a car
`audio/video
`system; and
`
`
`
`
`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]:
`“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]:
`“. . . 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. . . .”
`
`-14-
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`(c) a first wireless
`interface in
`communication
`with said
`integration
`subsystem, said
`first wireless
`interface
`establishing a
`wireless
`communication
`link with a second
`wireless interface
`in communication
`with a portable
`device external to
`the car
`audio/video
`system,
`
`(d) wherein said
`integration
`subsystem obtains,
`using said wireless
`communication
`link, information
`about an audio file
`stored on the
`portable device,
`(e) transmits the
`information to the
`car audio/video
`system for
`subsequent display
`
`
`
`
`
`
`Plagge at [0011]:
`“. . . 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]:
`“. . . 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]:
`“. . . MP3 player 7 is designed to have a wireless interface 9. .
`. .”
`
`Plagge at [0018]:
`“. . . 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 electrically connected with the car
`radio 10, and exchanges data and audio signals therewith. . . .
`[and] allows information from the CD player 15, such as
`track, disc, time, and song information, to be retrieved
`therefrom, processed and formatted by the interface 20, sent
`to the display 13 of the radio 10.”
`
`Marlowe at [0074]:
`“. . .In step 144, data is retrieved by the present invention
`from the MP3 player, including track, time, title, and song
`information, formatted, and transmitted to the car stereo for
`display by the car stereo. . . .”
`
`-15-
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`Marlowe at [0075]:
`“In steps 146, the present invention monitors the control panel
`buttons of the car stereo for MP3 operational commands. . . .
`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. . . .
`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. . . .”
`Marlowe at [0042], [0044], [0074], and [0075].
`
`
`
`of the information
`on a display of the
`car audio/video
`system,
`(f) instructs the
`portable device to
`play t