Petition for Inter Partes Review of USP 8,155,342
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re Inter Partes Review of:
`U.S. Patent No. 8,155,342
`Issued: April 10, 2012
`Application No.: 11/475,847
`Filing Date: June 27, 2006
`
`)
`)
`)
`)
`)
`
`For: Multimedia Device Integration System
`FILED VIA E2E
`
`DECLARATION OF DR. JOHN M. STRAWN IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 8,155,342
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`Strawn Declaration in Support of
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`Jaguar Land Rover
`Exhibit 1003
`Page 001
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`Petition for Inter Partes Review of USP 8,155,342
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`TABLE OF CONTENTS
`Table of Contents ....................................................................................................... i
`INTRODUCTION........................................................................................... 6
`I.
`QUALIFICATIONS ....................................................................................... 6
`II.
`III.
`SUMMARY OF MATERIALS REVIEWED AND CONSIDERED .......... 10
`IV. SUMMARY OF MY OPINIONS ................................................................. 12
`V. UNDERSTANDING OF LEGAL PRINCIPLES RELEVANT TO
`OBVIOUSNESS ........................................................................................... 13
`VI. LEVEL OF SKILL IN THE ART AND PERSPECTIVE APPLIED
`IN THIS DECLARATION ........................................................................... 15
`VII. THE ’342 PATENT ...................................................................................... 16
`A. Overview ............................................................................................. 16
`B.
`Prosecution History Of The ʼ342 Patent............................................. 17
`C.
`Date When Wireless Communication With A Portable Device
`Added .................................................................................................. 17
`VIII. CLAIM CONSTRUCTION .......................................................................... 19
`A.
`“integration subsystem” ...................................................................... 19
`
`“car audio/video system” .................................................................... 20
`B.
`
`C.
`“device presence signal” ..................................................................... 20
`
`IX. THE PRIOR ART AND BACKGROUND EVIDENCE ............................. 21
`A.
`Prior Art Relied Upon For Obviousness Combinations ..................... 21
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`1.
`Simonds (Ex. 1005) .................................................................. 21
`
`Ekstrom (Ex. 1006) .................................................................. 24
`2.
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` MOST Specification (Ex. 1007) ............................................... 29
`3.
`THE CHALLENGED CLAIMS OF THE ’342 PATENT ARE
`OBVIOUS ..................................................................................................... 35
`
` Overview of Challenged Claims ......................................................... 35 A.
`Overview of the Combination ............................................................ 39
`B.
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`X.
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`i
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`Petition for Inter Partes Review of USP 8,155,342
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`1.
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`2.
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` Motivation to Combine ....................................................................... 44 C.
`
`The MOST Specification describes obtaining and
`transmitting information for display and instructing and
`sending commands to a portable device. .................................. 39
`Ekstrom describes formatting data and commands for
`wireless transmission and receiving audio generated by
`the portable device for playing on the car audio/video
`system. ...................................................................................... 42
`
`1.
`Reasons for implementing the display of information
`and control of the portable device by the car
`audio/video system as described by the MOST
`Specification ............................................................................. 50
`Reasons for implementing the formatting of commands
`and data and playing of audio generated on the portable
`device on the car audio/video system as described by
`Ekstrom ..................................................................................... 54
`Independent Claims 49 and 73 ........................................................... 57
`1.
`49[a] and 73[a] Preamble: “A multimedia device
`integration system, comprising” ............................................... 57
`49[b] and 73[b]: “an integration subsystem in
`communication with a car audio/video system” ...................... 61
`49[b(i)] and 73[b(i)] “an integration subsystem”:
`connecting one or more portable devices or inputs to
`the car audio/video system via an interface ............................. 64
`49[b(ii)] and 73[b(ii)] “an integration subsystem”:
`processing and handling signals, audio, and/or video
`information ............................................................................... 67
`49[b(iii)] and 73[b(iii)] “an integration subsystem”:
`allowing a user to control the one or more portable
`devices via the car audio/video system .................................... 69
`49[b(iv)] and 73[b(iv)] “an integration subsystem”:
`displaying data from the one or more portable devices
`on the car audio/video system .................................................. 71
`49[c] and 73[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” ........................................................... 74
`
`D.
`
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`2.
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`2.
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`a.
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`b.
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`c.
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`d.
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`3.
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`ii
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`4.
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`5.
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`6.
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`7.
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`E.
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`
`49[d(i)] and 73[d(i)] “wherein said integration
`subsystem obtains, using said wireless communication
`link, information about an audio file [stored on /
`received by] the portable device” ............................................. 83
`49[d(ii)] and 73[d(ii)] “[said integration subsystem]
`transmits the information to the car audio/video system
`for subsequent display of the information on a display
`of the car audio/video system” ................................................. 86
`49[d(iii)] and 73[d(iii)] “[said integration subsystem]
`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” ................................................. 89
`49[d(iv)] and 73[d(iv)] “[said integration subsystem]
`receives audio generated by the portable device over
`said wireless communication link for playing on the car
`audio/video system.” ................................................................ 94
`Independent Claim 97 ......................................................................... 97
`1.
`97[a] “A multimedia device integration system,
`comprising:” ............................................................................. 97
`97[b] “first and second wireless interfaces establishing
`a wireless communication link between a car
`audio/video system and a portable device external to the
`car audio/video system;” .......................................................... 97
`97[c] “an integration subsystem in communication with
`said wireless communication link,” ......................................... 98
`97[d] “wherein said integration subsystem channels
`audio generated by the portable device to the car
`audio/video system using the wireless communication
`link for subsequent playing of the audio on the car
`audio/video system, the audio corresponding to an
`audio file played by the portable device, and” ......................... 99
`97[e(i)] “wherein said integration subsystem receives a
`control command issued by a user through one or more
`controls of the car audio/video system in a format
`incompatible with the portable device,” ................................. 100
`97[e(ii)] “processes the control command into a
`formatted command compatible with the portable
`device, and” ............................................................................ 106
`97[e(iii)] “dispatches the formatted command to the
`portable device for execution thereby.” ................................. 108
`
`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`Petition for Inter Partes Review of USP 8,155,342
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`F.
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`
`G.
`
`
`J.
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`
`
`Independent Claim 120 ..................................................................... 110
`1.
`120[a] “A multimedia device integration system,
`comprising:” ........................................................................... 111
`120[b] “first and second wireless interfaces establishing
`a wireless communication link between a car
`audio/video system and a portable device external to the
`car audio/video system;” ........................................................ 111
`120[c] “an integration subsystem in communication
`with said wireless communication link,” ............................... 111
`120[d] “wherein said integration subsystem instructs
`the portable device to play an audio file in response to a
`user selecting the audio file using controls of the car
`audio/video system,” .............................................................. 111
`120[e] “wherein said integration subsystem channels
`audio generated by the portable device to the car
`audio/video system using the wireless communication
`link for subsequent playing of the audio on the car
`audio/video system, the audio corresponding to an
`audio file played by the portable device, and” ....................... 112
`120[f(i)] “wherein said integration subsystem receives
`data generated by the portable device in a format
`incompatible with the car audio/video system,” .................... 112
`120[f(ii)] “processes the data into formatted data
`compatible with the car audio/video system, and” ................. 115
`120[f(iii)] “transmits the processed data to the car
`audio/video system for subsequent display of the
`processed data on a display of the car audio/video
`system.” .................................................................................. 116
`Integration Subsystem Dependent Claims ........................................ 116
`Claims 53 and 77 .................................................................... 116
`1.
`
`Claims 54, 70, and 78 ............................................................. 117
`2.
`
`Claims 66 and 94 .................................................................... 119
`3.
`
`Claim 113 ............................................................................... 121
`4.
`
`
` Device Presence Signal Dependent Claims (56, 83, and 106) ......... 123 H.
`After-Market Device Dependent Claims .......................................... 130
`I.
`
`1.
`Claims 62, 86, and 109 ........................................................... 130
`Claims 63, 87, and 110 ........................................................... 130
`2.
`3.
`Claims 64, 88, and 111 ........................................................... 131
`File Type Dependent Claims ............................................................ 131
`1.
`Claims 71 and 95 .................................................................... 131
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`2.
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`3.
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`4.
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`5.
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`6.
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`7.
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`8.
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`L.
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` Voice Recognition Dependent Claims ............................................. 132 K.
`
`Claims 68 and 115 .................................................................. 131
`2.
`
`1.
`Claims 55, 79, and 102 ........................................................... 132
`2.
`Claims 57, 80, and 103 ........................................................... 135
`Location Dependent Claims ............................................................. 138
`1.
`Claims 50, 74, and 99 ............................................................. 138
`2.
`Claims 100 and 101 ................................................................ 138
`3.
`Claims 51 and 75 .................................................................... 139
`4.
`Claims 52 and 76 .................................................................... 139
`XI. CONCLUSION ........................................................................................... 140
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`I.
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`Petition for Inter Partes Review of USP 8,155,342
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`INTRODUCTION
`
`I have been retained by Jaguar Land Rover North America, LLC and
`1.
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`Jaguar Land Rover Ltd. (“Jaguar Land Rover”) to provide my opinion concerning
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`the validity of certain claims of U.S. Patent No. 8,155,342 (attached to the
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`accompanying Petition as Ex. 1001 and referred to herein as “the ’342 patent”).
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`2.
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`
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`In particular, I have been asked to review and provide my opinion on
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`the validity of claims 49-57, 62-64, 66, 68, 70, 71, 73-80, 83, 86-88, 94, 95, 97,
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`99-103, 106, 109-111, 113, 115, and 120.
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`3.
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`
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`I am being compensated at my standard consulting rate of $450 per
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`hour for my services. My compensation does not depend on the outcome of this
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`review proceeding or of any pending litigation.
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`II. QUALIFICATIONS
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`I am currently an independent consultant working under the aegis of
`4.
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`my corporation S Systems Inc. My curriculum vitae, which includes a more
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`detailed summary of my background, experience, and publications, is attached
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`to the accompanying Petition as Ex. 1004.
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`5.
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` My formal education includes a Bachelor's degree from Oberlin
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`College in 1973. As a Fulbright scholar in Berlin, I attended lectures and
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`seminars in German at the Free University and Technical University Berlin from
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`1973-1975. I earned a Ph.D. degree from Stanford in 1985, with my doctoral
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`6
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`dissertation focusing on signal processing for analyzing digital audio. As part of
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`Petition for Inter Partes Review of USP 8,155,342
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`that work, I implemented audio recording and playback in real time on networked
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`mainframe computers using, for example, specially formatted hard disks that
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`operated in a drive the size of a washing machine, long before the compact disc
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`was invented.
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`6.
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` With regard to the subject matter of this proceeding, I have
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`extensive experience relating to audio and media reproduction. I have studied and
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`worked with analog and digital audio hardware, television technology, computer
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`architecture, processor architecture, high-level language programming, assembly
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`language programming, digital signal processing, compression (especially audio
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`but also data, image, and video), networking, digital buses, user interface design,
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`and user interface implementation.
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`7.
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`
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`In addition, I have over 45 years involvement in software, digital
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`media, digital signal processing, networking, and processor architecture. Working
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`in those areas, I have been an employee, a manager of a team of other Ph.D.s, and
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`an independent software consultant in signal processing specializing in high-level
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`languages and assembly language. My specialties have included compression and
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`decompression of media, streaming media, the Fourier transform, and the discrete
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`cosine transform used in audio compression, JPEG, and MPEG video.
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`Implementing real-time streaming media has been the backbone of many of my
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`Petition for Inter Partes Review of USP 8,155,342
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`consulting projects, such as for DTS or Verance.
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`8.
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`
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`Throughout my career, I have received a variety of awards including
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`the Fulbright scholarship mentioned above and a grant from the IBM Thomas
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`Watson Foundation to work in Europe and Japan. I was named Fellow of the
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`Audio Engineering Society.
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`9.
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`
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`In the Audio Engineering Society, I have held various positions
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`including chair of international conventions [Ex. 1004, p. 16] in the years 2004,
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`2006, and 2008; and technical papers chair in 1992 and again 2002. I ensured
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`that automotive audio played a role at such conventions, with technical papers in
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`the program, and demonstration automobiles on the exhibit floor. For example,
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`the 2004 Audio Engineering Society convention1 which I chaired featured a
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`papers session on Automotive Audio2 and a workshop on subjective evaluation
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`methods for multichannel automotive sound systems3 with participants from
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`Harman/Becker Automotive Systems, Volvo, Panasonic, and THX/Lucasfilm.
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`The AES maintains a Technical Committee on Automotive Audio which met at
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`1 http://www.aes.org/events/117/
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`2 http://www.aes.org/events/117/papers/Q.cfm
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`3 http://www.aes.org/events/117/workshops/
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`8
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`the convention and discussed, among other topics, MOST2 and voice
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`Petition for Inter Partes Review of USP 8,155,342
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`recognition.4 Exhibitors5 included Harman / Becker Automotive Systems.
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` During the time period 2002-2006, I was active not only as a
`10.
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`convention chair but also as an audio and signal processing consultant. The
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`signal processing chip which I helped Analog Devices redesign in 2002 [Ex.
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`1004, p. 12] is used extensively by one of the major manufacturers of automobile
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`audio equipment.
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`11.
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`I have been asked to provide my technical opinions regarding the
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`understanding of a person of ordinary skill in the art (discussed below) as it
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`relates to the ’342 patent and other reference documents.
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`12.
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`I have also been asked to provide my technical opinions on concepts
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`discussed in the ’342 patent and other reference documents, as well as my
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`technical opinions on how these concepts relate to certain claims of the ’342
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`patent in the context of the specification.
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`13.
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`In reaching the opinions stated herein, I have considered the ’342
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`patent, its prosecution history, and the references listed in Section III (Summary
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`of Materials Reviewed and Considered), and have also drawn as appropriate upon
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`4 http://www.aes.org/technical/documentDownloads.cfm?docID=205
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`5 http://www.aes.org/events/117/exhibitors.cfm
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`my own education, training, research, knowledge, and personal and professional
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`Petition for Inter Partes Review of USP 8,155,342
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`experience.
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`III. SUMMARY OF MATERIALS REVIEWED AND CONSIDERED
` All of the opinions contained in this declaration are based on the
`14.
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`documents I reviewed and my knowledge and professional judgment. In forming
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`the opinions expressed in this declaration, while drawing on my experience in the
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`field of electrical engineering and signal processing, I reviewed the following
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`documents:
`
`Ex. No. Description
`
`1001 U.S. Patent No. 8,155,342 (“’342 patent”)
`
`1002
`
`File History for U.S. Patent No. 8,155,342
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`1004 Curriculum Vitae of Dr. John M. Strawn
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`1005 U.S. Patent Application Publication 2004/0093155 (“Simonds”)
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`1006
`
`Peter Ekstrom and Fredrik Hoel, “Audio over Bluetooth and
`MOST,” Department of Science and Technology, Linkoping
`University, March 7, 2002 (“Ekstrom”)
`
`1007 Media Oriented System Transport (MOST) Specification, Version
`2.2-00, November 2002 (“MOST Specification”)
`
`1008 Media Oriented System Transport (MOST) Specification
`Framework, Version 1.1-07 (“MOST Framework”)
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`1010 Affidavit of Christopher Butler regarding the MOST Specification
`from the Internet Archive
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`1011 Affidavit of Christopher Butler regarding Ekstrom from the Internet
`Archive
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`10
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`1012 Declaration of Alex Planidin regarding the translation of Swedish
`text in Ekstrom
`
`1013 Copy of the U.S. Patent No. 8,155,342 with highlighting material
`added to the original application in the chain
`
`1014 Murray, Charles J., “Automakers pick MOST as high-speed in-car
`bus,” EE Times (November 13, 2000)
`1015 Mufid6, “Future Automotive Multimedia Subsystem Interconnect
`Technologies” 2000-01-C028
`
`1016 Bruess, “Open Systems and Open Mindsets: Entertainment,
`Information and Communication Systems for the Automotive
`Future” 2000-01-C085
`
`1017 Hasse Johansson and Anders Ellasson, “Mobile Information Systems
`Overview: The End to End Solution” 2000-01-C028
`
`1018 OS8104 Preliminary Product Data Sheet, September 2000
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`1019
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`Parnell, “Put the Right Bus in Your Car” (XCell Journal, Winter
`2004)
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`1020 Convergence 2000 (October 16 - 18, 2000) in Detroit, Michigan,
`https://web.archive.org/web/20000615131506/
`http://www.convergence2000.org:80/
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`1021 Convergence 2000 technical sessions, https://web.archive.org/
`web/20000818231705/http://www.convergence2000.org:80/
`techsessions.html
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`
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`6 For the author’s name, see the information regarding this paper in Exhibit 1005,
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`Page 019, third entry from the bottom.
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`In addition, I reviewed Institution Decision, IPR2016-01473; Institution
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`Petition for Inter Partes Review of USP 8,155,342
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`Decision, IPR2016-00418; Application 10/732,909; and Application 11/071,667.
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`I have also reviewed every document mentioned in this declaration.
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` My opinions are additionally guided by my appreciation of how a
`15.
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`person of ordinary skill in the art would have understood the claims of the ’342
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`patent at the time of the alleged invention. I have been asked to assume that the
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`relevant time is the 2005-2006 timeframe. For purposes of whether the teachings
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`render obvious the ’342 patent’s claims, I have been asked to assume the earliest
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`priority date to be March 3, 2005. Accordingly, I will use the term “date of
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`invention” or “relevant timeframe,” with this understanding.
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`IV. SUMMARY OF MY OPINIONS
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`It is my opinion that claims 49-57, 62-64, 66, 68, 70, 71, 73-80, 83,
`16.
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`86-88, 94, 95, 97, 99-103, 106, 109-111, 113, 115, and 120 of the ’342 patent are
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`invalid based on at least the following grounds:
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`Ground 1: Claims 49-57, 62-64, 66, 68, 70, 71, 73-80, 83, 86-88, 94, 95,
`97, 99-103, 106, 109-111, 113, 115, and 120 are obvious under 35 U.S.C.
`§103(a) by Simonds (Ex. 1005) in view of Ekstrom (Ex. 1006) and the
`MOST Specification (Ex. 1007).
`
`
`17.
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`In this declaration, I provide the basis and support for my opinions
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`that each of these challenged claims are invalid based on these grounds.
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`V. UNDERSTANDING OF LEGAL PRINCIPLES RELEVANT TO
`OBVIOUSNESS
`
`18.
`I am not an attorney. My analysis and opinions are based on my
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`expertise in this technical field, as well as the instructions for the legal standards
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`relating to validity provided by counsel.
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`19.
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`I understand that a prior art reference can render a patent claim
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`obvious to one of ordinary skill in the art if the differences between the subject
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`matter set forth in the patent claim and the prior art are such that the subject
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`matter of the claim would have been obvious at the time the claimed invention
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`was made. In analyzing obviousness, I understand that it is important to consider
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`the scope of the claims, the level of skill in the relevant art, the scope and content
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`of the prior art, the differences between the prior art and the claims, and any
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`secondary considerations.
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`20.
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`I understand that when the claimed subject matter involves
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`combining pre-existing elements to yield no more than one would expect from
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`such an arrangement, the combination is obvious. I also understand that in
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`assessing whether a claim is obvious one must consider whether the claimed
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`improvement is more than the predictable use of prior art elements according to
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`their established functions. I understand that there need not be a precise teaching
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`in the prior art directed to the specific subject matter of a claim because one can
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`take account of the inferences and creative steps that a person of ordinary skill in
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`the art would employ. I further understand that a person of ordinary skill is a
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`person of ordinary creativity, not an automaton.
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`21.
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`I understand that obviousness cannot be based on the hindsight
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`combination of components selectively culled from the prior art. I understand
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`that in an obviousness analysis, neither the motivation nor the avowed purpose of
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`the inventors controls the inquiry. Any need or problem known in the field at the
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`time of the invention and addressed by the patent can provide a reason for
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`combining elements. For example, I understand that it is important to consider
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`whether there existed at the time of the invention a known problem for which
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`there was an obvious solution encompassed by the patent’s claims. I understand
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`that known techniques can have obvious uses beyond their primary purposes, and
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`that in many cases a person of ordinary skill can fit the teachings of multiple
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`pieces of prior art together like pieces of a puzzle.
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`22.
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`I understand that, when there is a reason to solve a problem and
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`there are a finite number of identified, predictable solutions, a person of ordinary
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`skill has good reason to pursue the known options within his or her technical
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`grasp. I further understand that, if this leads to the anticipated success, it is likely
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`the product not of innovation but of ordinary skill and common sense, which
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`bears on whether the claim would have been obvious.
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`23.
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`I understand that secondary considerations can include, for example,
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`evidence of commercial success of the invention, evidence of a long-felt need
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`that was solved by an invention, evidence that others copied an invention, or
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`evidence that an invention achieved a surprising result. I further understand that
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`such evidence must have a nexus, or causal relationship to the elements of a
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`claim, in order to be relevant. I am unaware of any such secondary
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`considerations for the ’342 patent.
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`VI. LEVEL OF SKILL IN THE ART AND PERSPECTIVE APPLIED IN
`THIS DECLARATION
` The invention of the ’342 patent relates to a multimedia device
`24.
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`integration system to allow a portable device to communicate wirelessly with the
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`audio/video system of a vehicle. At the date of invention, a person of ordinary
`
`skill in the art would have had at least a bachelor’s degree in electrical
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`engineering, or equivalent degree and at least two years of experience in signal
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`processing and/or electronic system design. More education can supplement
`
`relevant experience and vice versa.
`
`
`25.
`
`I would have qualified as a person of at least ordinary skill in the art
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`as of the relevant timeframe. I have a sufficient level of knowledge, experience,
`
`and education to provide an expert opinion in the field of the ’342 patent.
`
` My opinions in this declaration are based on the perspective of a
`26.
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`person of ordinary skill in the art as of the relevant timeframe.
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`Jaguar Land Rover
`Exhibit 1003
`Page 016
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`Petition for Inter Partes Review of USP 8,155,342
`
`
`VII. THE ’342 PATENT
`A. Overview
` The ’342 patent is directed to a multimedia device integration
`27.
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`system that provides wireless integration between a car audio/video system and a
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`portable device (for example, an MP3 player or cellular phone). [’342 patent,
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`Abstract.] The integration subsystem allows a car audio/video system and a
`
`portable device to communicate with each other and to use each other’s services.
`
` The ’342 patent addresses a common engineering problem of
`28.
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`integrating two proprietary systems. In particular, the ’342 patent addresses
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`“integrating after-market audio and video systems with existing car stereo and
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`video systems.” [ibid., 1:54-56.]. “[S]ignals generated by both systems are in
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`proprietary formats, and are not capable of being processed by” each other.
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`[ibid., 1:54-58.]. The ’342 patent applies a conventional solution to address this
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`problem: providing a subsystem in between “to convert signals between such
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`systems.” [ibid., 1:57-60.].
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` This signal conversion “allows for information to be exchanged
`29.
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`between the after-market device and car stereo or video system,” information to
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`be “transmitted and displayed on both hardwired car stereo and video systems,”
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`and for “full remote control of the portable device . . . at the controls of the car
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`system.” [ibid., 2:21-43.].
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`Jaguar Land Rover
`Exhibit 1003
`Page 017
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`
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`Petition for Inter Partes Review of USP 8,155,342
`
`B.
`Prosecution History Of The ʼ342 Patent
` Although I am not a patent attorney, I have briefly reviewed the
`30.
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`prosecution history of the ’342 patent [Ex. 1002].
`
`
`31.
`
`I have been provided with the family tree below. I understand that
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`the ’342 patent issued from an application that was fourth in a chain claiming
`
`priority to the application that issued as U.S. Patent No. 7,489,786.
`
`
`C. Date When Wireless Communication With A Portable
`Device Added
`I have been provided with Ex. 1013, a copy of the ’342 patent
`
`
`32.
`
`highlighting certain portions of the specification. I understand that portions
`
`17
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`Jaguar Land Rover
`Exhibit 1003
`Page 018
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`highlighted in pink were added on December 10, 2003, portions in turquiose were
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`Petition for Inter Partes Review of USP 8,155,342
`
`added on March 3, 2005, and portions in green were added on June 27, 2008.
`
`
`33.
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`I have been asked to provide my opinion of the earliest date portions
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`of
`
`the specification were added disclosing
`
`the
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`limitations “wireless
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`communication link . . . with a portable device” (claims 49, 73) and “wireless
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`communication link between a car audio/video system and a portable device”
`
`(claims 97, 120).
`
` The earliest date for the portions of the specification disclosing these
`34.
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`limitations is March 3, 2005. Each reference to wireless communications in the
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`specification is highlighted in green (added June 27, 2006) with two exceptions:
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`27:39-40 and 28:3-6.
`
` At column 27,
`35.
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`lines 39
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`to 40,
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`the specification states,
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`“[a]lternatively, the integration system could wirelessly communicate with the
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`car stereo.” This passage does not disclose wireless communication with a
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`portable device. Instead, this passage discloses wireless communication between
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`the integration system and the car stereo. Immediately before this passage, the
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`specification explains in addition that the portable device is connected to the
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`integration system not with any wireless link but through a cable 555. [’342
`
`patent, 27:30-39] There is no disclosure that a portable device could be
`
`18
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`
`Jaguar Land Rover
`Exhibit 1003
`Page 019
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`integrated to the system using anything other than a wired connection. This
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`Petition for Inter Partes Review of USP 8,155,342
`
`passage is highlighted in pink in Ex. 1013 (i.e., added December 10, 2003).
`
` At column 28, lines 3 to 6, the specification states, “[f]urther, in all
`36.
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`embodiments of the present invention, communication between the after-market
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`device and a car stereo or video system can be accomplished using known
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`wireless technologies, such as Bluetooth.” This passage discloses that a wireless
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`communication link, such as Bluetooth, can be established between the portable
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`device and car audio/video system. This passage is highlighted in turquoise in
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`Ex. 1013 (i.e., added March 3, 2005).
`
`VIII. CLAIM CONSTRUCTION
`
`I understand