Independent
`Claim 1
`1. A method of securing a display to a headrest
`of a vehicle seat, comprising:
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`Prior Art
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`The HVM500 Guide discloses “a headrest video monitor.” The HVM500
`Guide, on page 13, discloses instructions for installing the HVM500 into the
`headrest of a vehicle seat. The HVM500 Guide discloses a method of securing a
`display to a headrest of a vehicle seat.
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`attaching the display having a back to a frame The HVM500 Guide discloses that the “Directed HVM 500 5” monitor comes
`with a mounting bezel designed for headrest installations.” Exhibit 1004, pg. 13.
`As used in the HVM500 Guide, one skilled in the art would understand the
`mounting bezel to be a frame. The display is attached to the frame.
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`Voxx International Corp. Exhibit 1015
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`Claim 1
`1. A method of securing a display to a headrest
`of a vehicle seat, comprising:
`
`Prior Art
`
`The HVM500 Guide discloses “a headrest video monitor.” The HVM500
`Guide, on page 13, discloses instructions for installing the HVM500 into the
`headrest of a vehicle seat. The HVM500 Guide discloses a method of securing a
`display to a headrest of a vehicle seat.
`
`
`attaching the display having a back to a frame The HVM500 Guide discloses that the “Directed HVM 500 5” monitor comes
`with a mounting bezel designed for headrest installations.” Exhibit 1004, pg. 13.
`As used in the HVM500 Guide, one skilled in the art would understand the
`mounting bezel to be a frame. The display is attached to the frame.
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`Voxx International Corp. Exhibit 1015
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`Exhibit 1004, Pg. 1. (Text added for illustrative purposes.)
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`The display disclosed in the HVM500 Guide discloses a display that includes a
`back. A person of ordinary skill in the art would readily understand that the
`display would include a back to keep the electronic components of the display
`from being exposed. If not expressly disclosed, the display including a back
`would be inherent to one skilled in the art.
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`The actual Directed Video HVM500 headrest video monitor described in the
`HVM500 Guide demonstrates that the display has a back.
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`Voxx International Corp. Exhibit 1015
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`The photograph above is being submitted to more clearly disclose the headrest
`video unit depicted in the HVM500 Guide as it represents the actual unit
`depicted in the HVM500 Guide.
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`The HVM500 Guide discloses a frame that has a floor with at least one
`mounting hole in an upper half of the floor and at least one mounting hole in a
`lower half of the floor.
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`[a frame] having a floor with at least one
`mounting hole in an upper half of the floor and
`at least one mounting hole in a lower half of
`the floor,
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`Voxx International Corp. Exhibit 1015
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`and a top wall, a bottom wall, and two side
`walls which extend from the floor,
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`Exhibit 1004, pg. 14 (text added for illustrative purposes).
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`The HVM500 Guide discloses that the frame has top wall, a bottom wall, and
`two side walls which extend from the floor.
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`the floor, top wall, bottom wall, and side walls
`cooperating to define a cavity,
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`Exhibit 1004, pg. 14 (text added for illustrative purposes).
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`The HVM500 Guide instructs the installer to “[i]nstall the monitor into the
`mounting bezel and adjust to the proper angle.” Exhibit 1004, pg. 13. Thus, the
`floor, top wall, bottom wall, and side walls cooperate to define a cavity.
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`Voxx International Corp. Exhibit 1015
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`Exhibit 1004, pg. 14 (text added for illustrative purposes).
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`Voxx International Corp. Exhibit 1015
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`wherein the display is attached to the frame
`such that the display can be pivoted relative to
`the frame
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`Exhibit 1004, Cover Page (text added for illustrative purposes). The display
`disclosed in the HVM500 Guide snaps into hinges on opposing sides of the
`frame and pivots within the cavity of the frame.
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`The HVM500 Guide states “the picture viewing angle can be easily adjusted by
`pressing against the top or bottom of the monitor bezel.” Exhibit 1002, pg. 7.
`Therefore, the HVM500 Guide discloses that the display is attached to the frame
`such that the display can be pivoted relative to the frame.
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`Exhibit 1004, Cover Page (text added for illustrative purposes).
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`The HVM500 Guide discloses that the display can be pivotably removed from
`the frame during installation. Step (9) instructs the installer to “[i]nstall the
`monitor into the mounting bezel and adjust to the proper angle.” See Exhibit
`6
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`Voxx International Corp. Exhibit 1015
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`between a first orientation that permits access
`to the at least one mounting hole in the upper
`half of the floor and to the at least one
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`mounting hole in the lower half of the floor of
`the frame,
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`1004, Pg. 13. The HVM500 display is capable of being pivoted relative to the
`frame between a first orientation that permits access to the at least one mounting
`hole in the upper half of the floor and to the at least one mounting hole in the
`lower half of the floor of the frame.
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`Tada discloses a “television fixture for vehicles”. Exhibit 1008, Title, English
`Translation. This television fixture is “affixed in the seat backs of vehicles to
`allow viewing…in vehicles as well.” Exhibit 1008, English Translation, pg.
`357. As is illustrated below in Figs. 1 and 3, the display of Tada includes hinges
`13, 14 at an upper portion of the display. These hinges permit the “television
`monitor 7 can be opened and closed (rotation) for example in a range of 80
`degrees.” Exhibit 1008, English Translation, pg. 358. The Tada display pivots
`from a stored position where a floor under the display is not accessible or
`exposed to an open position where the floor under the display is accessible or
`exposed. Exhibit 1008, Figs. 1 and 3.
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`Voxx International Corp. Exhibit 1015
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`Tada discloses that the “television monitor can be opened and closed (rotation)
`for example in a range of 80 degrees.” Exhibit 1008, Page 358. Tada discloses
`a display that is attached to the frame such that the display can be pivoted
`relative to the frame between a first orientation (i.e. – open) that permits access
`to the floor of the frame and a second orientation (i.e. – closed) that would
`conceal the floor of the frame.
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`Moving the hinge location to the upper edge as taught by Tada would permit
`access to the mounting holes in the floor of the frame when the display is rotated
`to the open position. Therefore, the combination of the HVM500 Guide in light
`of Tada discloses that the display can be pivoted between a first orientation
`(open) that permits access to the at least one mounting hole in the upper half of
`the floor and to the at least one mounting hole in the lower half of the floor of
`the frame. Tada allows the display to be pivoted to a second orientation as well,
`thereby allowing the display to be pivoted between first and second orientations
`as recited in claim 1.
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`Voxx International Corp. Exhibit 1015
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` and a second orientation that is suitable for
`viewing a front face of the display and inhibits
`access to the at least one mounting hole in the
`upper half of the floor and to the at least one
`mounting hole in the lower half of the floor,
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`The HVM500 Guide discloses that “[t]he picture viewing angle can be easily
`adjusted by pressing against the top or bottom of the monitor bezel.” Exhibit
`1004, Pg. 7.
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`Exhibit 1004, Cover Page. When the display is not disconnected from the
`hinges in the first orientation, it is positioned in a second orientation that is
`suitable for viewing a front face of the display and inhibits access to the at least
`one mounting hole in the upper half of the floor and to the at least one mounting
`hole in the lower half of the floor. The installation instructions state the display
`can be positioned in a second orientation suitable for viewing the front face of
`the display. The instructions instruct the owner to “[i]nstall the monitor into the
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`Voxx International Corp. Exhibit 1015
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`mounting bezel and adjust to the proper angle.” Exhibit 1004, Pg. 13. The
`HVM500 Guide discloses that the display can be rotated relative to the frame
`between first and second orientations.
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`-------------------------------------------------------------------------------------
`Modifying the location of the hinges on the HVM500 video headrest unit
`disclosed in the HVM500 Guide as taught by Tada, which would have been an
`obvious design choice to one skilled in the art, would allow the display to be
`positioned in a second orientation that is suitable for viewing a front face of the
`display and inhibit access to the at least one mounting hole in the upper half of
`the floor and to the at least one mounting hole in the lower half of the floor.
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`Tada discloses that that the display pivots to a second stored orientation for
`viewing as illustrated below. The “television monitor 7 can be opened and
`closed…” Exhibit 1008, English Translation, pg. 358.
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`Therefore, the display disclosed in the HVM500 Guide as modified by the
`teachings of Tada, disclose that the HVM500 display could be pivoted to a
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`Voxx International Corp. Exhibit 1015
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`second orientation (closed position) suitable for viewing a front face of the
`display and inhibits access to the at least one mounting hole in the upper half of
`the floor and to the at least one mounting hole in the lower half of the floor.
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`The HVM500 Guide discloses that when the display is in an orientation in which
`the display is positioned in the cavity of the frame the display is closer to the
`mounting holes in the upper and lower halves of the floor.
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`wherein the display in the second orientation is
`closer to the at least one mounting hole in the
`upper half of the floor and to the at least one
`mounting hole in the lower half of the floor
`than the display is in the first orientation;
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`Exhibit 1004, Cover Page. The display would be further away in the first
`orientation because it needs to be positioned away from the mounting holes so
`that screws can be used to mount the frame to the headrest.
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`If the HVM500 video headrest unit was modified to use the hinge locations
`taught by Tada (i.e. – moved to the upper edge of the frame and display), when
`the display is in the closed position (second orientation) it would be obvious to
`one skilled in the art that the display would be closer to the at least one mounting
`hole in the upper half of the floor and to the at least one mounting hole in the
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`Voxx International Corp. Exhibit 1015
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`lower half of the floor than the display would be in the open position (first
`orientation). As Tada et al states, the “television monitor 7 can be opened and
`closed…” Exhibit 1008, English Translation, pg. 358.
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`As the display of the HVM500 Guide, as modified by Tada, pivots inwardly
`toward the closed position, the display would inherently become closer to the
`mounting holes in the frame.
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`The HVM500 Guide discloses securing the frame to the headrest by passing at
`least one mounting fastener through the at least one mounting hole in the floor of
`the frame from within the cavity. Step (7) of the installation instructions instruct
`the installer to “[i]nstall the bezel. Some headrests have material that is strong
`enough to screw the bezel into.” Exhibit 1004, Pg. 13. Further, the HVM500
`Guide states that the kit includes “[s]crews and other mounting hardware.”
`Exhibit 1004, Pg. 6.
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`The HVM500 Guide discloses that one should “[r]emove the material to a depth
`sufficient for the lip of the mounting bezel to fit flush against the rear of the
`headrest once installed.” Exhibit 1004, Pg. 13.
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`Voxx International Corp. Exhibit 1015
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`securing the frame to the headrest by passing
`at least one mounting fastener through the at
`least one mounting hole in the floor of the
`frame from within the cavity,
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`the frame being secured to the headrest such
`that the front face of the display is
`substantially flush with a back surface of the
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`headrest when the display is in the second
`orientation; and
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`Exhibit 1004, Pg. 1. The frame is secured to the headrest such that the front face
`of the display is substantially flush with a back surface of the headrest when the
`display is in the second orientation. This structure is disclosed by the HVM500
`Guide instructing the person installing the headrest video monitor to “[r]emove
`the material to a depth sufficient for the lip of the mounting bezel to fit flush
`against the rear of the headrest once installed.” Exhibit 1004, Pg. 13.
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`Step (6) of the installation instructions in the HVM500 Guide tells the installer
`to “[r]oute the cable through the headrest access hole and the rear opening of the
`mounting bezel. Leave enough slack in the cable for monitor installation.”
`Exhibit 1004, Pg. 13. As illustrated below, the HVM500 Guide illustrates
`passing an electrical communication cable, which extends from the back of the
`display, through the floor of the frame.
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`passing an electrical communication cable,
`which extends from the back of the display,
`through the floor of the frame.
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`Voxx International Corp. Exhibit 1015
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`Exhibit 1004, Pg. 14. A hole is disclosed in the floor and bottom wall of the
`frame where the electrical cable is permitted to pass through.
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`Voxx International Corp. Exhibit 1015
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