IPR2016-01472
`
`Patent 7,489,786 B2
`
`2.
`
`Independent Claims 1 and 57
`
`For reasons discussed below, Petitioner has not shown a reasonable
`
`likelihood that it would prevail in establishing unpatentability of either
`
`claim 1 or claim 57 on any ground of obviousness relying in part on Bhogal.
`
`a)
`
`pre-programmed code portion for remotely
`controlling an audio device or MP3 player
`(claims 1 and 57)
`
`Claim 1 requires a microcontroller within the interface to execute a
`
`pre-programmed code portion that is:
`
`for remotely controlling the after-market audio device using the
`car stereo by receiving a control command from the car stereo
`through said first electrical connector in a format incompatible
`with the afier-market audio device, processing the received
`control command into a formatted command compatible with the
`after-market device, and transmitting the formatted command to
`the after—market device through said second connector for
`execution by the afier-market audio device.
`
`Ex. 1001, 21 :45—54. Claim 57 includes a similar limitation that differs from
`
`the above-quoted limitation of claim 1 by reciting a portable MP3 player
`
`instead of an after-market audio device. Id. at 22:28—37. Thus, claim 1
`
`pertains to a car stereo remotely controlling an after-market audio device,
`
`and claim 57 pertains to a car stereo remotely controlling a portable MP3
`
`player.
`
`For this rcmotc control aspect of claims 1 and 57, and aside from the
`
`specific requirement of a portable MP3 player of claim 57, Petitioner relies
`
`on Bhogal’s disclosure. Bhogal pertains to an actual CD-changer and an
`
`emulator unit that emulates CD-changers, as discussed above.
`
`According to Petitioner, Bhogal discloses the above-noted limitation
`
`for remotely controlling the audio device that is connected to the interface.
`
`Page 1381 of 1457
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`Daimler Exhibit 1002
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`18
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`Daimler Exhibit 1002
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`

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`IPR2016-01472
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`Patent 7,489,786 B2
`
`Pet. 19. Petitioner’s argument is as follows:
`
`typically, car stereos are designed to
`Bhogal explains that
`communicate only with CD-changers made by the same
`manufacturer. Ex. 1004, at 4:57—62. The emulator unit in
`Bhogal contains a “CD-changer unit specification database 312”
`which “contains operational information about various models of
`CD-changer units and the manner in which emulator unit 302 can
`interface with a particular type of CD-changer unit.” Id. at 7: 1—
`4, FIG. 3. A signal/command interpreter unit 314 inside the
`emulator unit monitors for signals and commands from the car
`stereo intended for the selected type of CD-changer. Id. at 7: 12—
`24. For example, when a user of the car stereo presses controls
`on the car stereo for changing CDs or for obtaining information
`about CDs,
`the emulator unit captures the commands and
`“performs appropriate processing.” Id. at 8:21—26.
`In doing so,
`the emulator unit “operates in a particular manner that
`is
`compatible with the CD-changer to which the emulator unit is
`connected.” Id. at 7:7—11. See Geier Decl., Ex. 1014, W 53—55.
`
`Id.
`
`The argument is unpersuasive. None of the cited disclosure and
`
`explanations, as presented by Petitioner, pertains to remotely controlling an
`
`audio device that is connected to Bhogal’s emulator unit. The operations
`
`identified by Petitioner support the emulator unit’s role as an emulator,
`
`where the emulator interprets commands from the car stereo intended for an
`
`actual CD-changer, and uses the interpreted commands to access audio data
`
`files within the emulator itself that. are organized as virtual CD-RONIS.
`
`The claim limitation requires receiving a control command from the
`
`car stereo in a format incompatible with the connected audio device,
`
`processing it into a formatted control command that is compatible with the
`
`audio device, and transmitting the formatted command to the audio device.
`
`Petitioner has not identified any disclosure in Bhogal that describes
`
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`IPR2016-01472
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`Patent 7,489,786 B2
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`transmitting such a converted command to the connected audio device to
`
`control the audio device remotely.
`
`There is an operation mode of the emulator called “pass-thru mode” in
`
`which the emulator passes commands from the car stereo to the audio device
`
`that is connected. Ex. 1004, 7:36—46. However, as described in Bhogal, the
`
`“pass-thru mode” does not involve any conversion of a command from a
`
`format that is incompatible with the connected audio device to a format that
`
`is compatible with the connected audio device. Id.
`
`In Bhogal, the car stereo
`
`and the actual CD-changer already. communicate with each other
`
`compatibly, without the need for an intermediate interface to do any
`
`conversion of signals. As discussed above, Bhogal describes that when the
`
`emulator is not in the docking station, the car stereo and the actual CD-
`
`exchanger may operate together. Id. at 5 :65—67.
`
`In addition, there is an operation mode of the emulator called
`
`“end-unit” mode, in which the emulator replaces the CD-changer entirely
`
`and itself emulates the presence of the CD-changer. Id. at 7:47—49. Nothing
`
`in that mode of operation involves conversion of any command to be sent to
`
`the CD-changer to control the CD-changer remotely.
`
`There also is an operation mode of the emulator called “combination
`
`mode,” in which the emulator also reads tracks and track information from
`
`the actual CD-changer unit connected to it, “to create Virtual CDs with tracks
`
`from both sources.” Id. at 8:4—20. Petitioner identifies no disclosure in
`
`Bhogal that any conversion is performed on car stereo commands that are
`
`incompatible with the actual CD-changer to make them compatible with the
`
`CD-changer, much less transmitting such converted commands to the
`
`CD-changer to effect remote control of the CD-changer by the car stereo.
`
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`IPR2016-01472
`
`Patent 7,489,786 B2
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`As noted above, the car stereo and the actual CD-changer already
`
`communicate with each other compatibly without need for an intermediate
`
`interface to do any conversion. Petitioner’s reference to Bhogal’s
`
`“processing” alone is insufficient to persuade us that Bhogal discloses the
`
`required conversion.
`
`The foregoing reason alone constitutes sufficient basis to conclude
`
`that Petitioner has not shown reasonable likelihood that it would prevail in
`
`establishing unpatentability of any challenged claim on any ground based in
`
`part on Bhogal. We discuss below an additional deficiency with respect to
`
`claim 1 and claims dependent thereon, and an additional deficiency with
`
`respect to claim 57 and claims dependent thereon.
`
`b)
`
`receiving, processing, transmitting data, and
`converting data from incompatible format to
`compatible format (claim 1)
`
`Claim 1 further requires the microcontroller within the interface to
`
`have a pie-programmed code portion that is:
`
`for receiving data from the after-market audio device through
`said second connector in a format incompatible with the car
`stereo, processing the received data into formatted data
`compatible with the car stereo, and transmitting the formatted
`data to the car stereo through said first connector for display by
`the car stereo.
`
`Ex. 1001, 21:55—61. According to Petitioner, Bhogal discloses format
`
`conversion of the display data from the CD-changer unit for display on the
`
`car stereo. Pet. 22, 32. Specifically, Petitioner argues: “Because the car
`
`stereo [of Bhogal] is designed to communicate using proprietary formats, see
`
`[Ex. 1004,] 4:57—62, the emulator unit generates data ‘in the necessary
`
`format’ to be sent to the car stereo.” Pet. 22. Petitioner’s argument is
`
`unpersuasive.
`
`Page 1384 of 1457
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`IPR2016—01472
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`Patent 7,489,786 B2
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`Petitioner cites no disclosure in Bhogal to the effect that data from the
`
`actual CD—changer is originally incompatible with the car stereo and requires
`
`a conversion in format to be compatible with and thus understood by the car
`
`stereo. Petitioner also cites no disclosure in Bhogal to the effect that any
`
`such data conversion is performed by the emulator unit of Bhogal. Although
`
`there is a necessary format for data from the audio device to be understood
`
`by the car stereo, Petitioner identifies no disclosure in Bhogal that indicates
`
`the car stereo and the audio device do not already share the same format
`
`without involvement of the emulator.
`
`As discussed above, Bhogal describes that when the emulator is not in
`
`the docking station, the car stereo and the actual CD-exchanger may operate
`
`together. Ex. 1004, 5:65—67. Also, although the emulator has a “pass-thru
`
`mode,” operation in the pass-thru mode does not involve any conversion of
`
`data from a format that is incompatible with the car stereo to a format that is
`
`compatible with the car stereo. Id. at 7:36—46. As noted above, in the
`
`context of Bhogal, the car stereo and the audio device already communicate
`
`with each other compatibly without need for an interface to do any
`
`conversion of signals.
`
`0)
`
`generating and transmitting a device presence
`signal (claim 57)
`'
`
`Claim 57 further requires the microcontroller within the interface to
`
`have a pre-programmed code portion. that is “for generating a device
`
`presence signal and transmitting the signal to the car stereo to maintain the
`
`car stereo in an operational state.” Ex. 1001, 26:22—76. According to
`
`Petitioner, neither Bhogal nor Berry discloses this limitation regarding the
`
`generation and transmission of a device presence signal, but Onishi does.
`
`Pet. 19—21. Specifically, Petitioner explains as follows:
`
`Page 1385 of 1457
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`IPR2016-01472
`
`Patent 7,489,786 B2
`
`Onishi discloses an on—vehicle audio device 50 (a car stereo) that
`includes a source selector 63. Ex. 1007, at [0060], [0063],
`FIG. 5. Source selector 63 accepts audio signals input from the
`on-vehicle device’s tuner and CD player, as well as audio signals
`received by the on-vehicle device’s AUX input terminal 55. Id
`at [0064], FIG. 5. A system controller 60 in the on-vehicle
`device controls which of these audio signals is selected by the
`source selector and output through speakers.
`Id. at [0065].
`Onishi describes
`at
`least
`two methods
`for
`the
`system
`controller 60 to detect that an AUX device is present.
`In one
`method, the system controller recognizes display information
`DD received from the AUX device through AUX input
`terminal 55.
`Id. at [0082].
`In another method, the AUX input
`terminal 55 contains a voltage detector. Id. at [0083]. Based on
`the voltage detection, the system controller 60 determines if an
`AUX device is present.
`Id. When the AUX device has been
`detected, “a control is performed ” (i. e., a device presence signal
`is sent) to the source selector 63 to select the AUX input as the
`audio source. Id. at [0084], FIG. 6 (S105). Consequently, analog
`audio signals from the MD player/recorder are output as sound
`from the vehicle speakers, id. at [0085], FIG. 6 (S106), and the
`car stereo is maintained in an operational state.
`
`Id. at 19—20 (emphasis added).
`
`Petitioner’s explanation is misdirected and unpersuasive. The term
`
`“device presence signal” has been construed as a signal indicating that an
`
`audio device, other than the car stereo, is connected to the interface. The
`
`construction is the same as that urged by Petitioner. Pet. 9. Petitioner’s
`
`above—quoted explanation does not support its assertion that Onishi
`
`discloses the generation of a device presence signal and transmitting that
`
`signal to the car stereo. Figure 5 of Onishi, as referenced by Petitioner, is
`
`reproduced below:
`
`Page 1386 of 1457
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`IPR2016-01472
`
`Patent 7,489,786 B2
`
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`
`Figure 5 is a block diagram illustrating an internal configuration of an
`
`embodiment of the on-vehicle audio device of Onishi. Ex. 1007, 14.
`
`As explained by Petitioner, the on-vehicle audio device, e.g., car
`
`stereo, detects the presence of an auxiliary device not by receiving a device
`
`presence signal, but by itself detecting the presence of an auxiliary device.
`
`Mere presence of data on an input line does not satisfy the requirements of a
`
`device presence signal as we have construed the term. For instance, the
`
`data could be received directly from an auxiliary device and not through an
`
`interface to which the auxiliary device is connected. According to claim 57,
`
`it is the microcontroller within the interface that has to generate the device
`
`presence signal and to transmit that device presence signal to the car stereo.
`
`Page 1387 of 1457
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`IPR2016-01472
`
`Patent 7,489,786 B2
`
`Also, what Petitioner identifies as a device presence signal actually is a
`
`control signal the on-vehicle audio device sends to an internal source
`
`selector, after it already has recognized that an auxiliary device is present,
`
`in order to select that auxiliary device as input. Id. 11 84.
`
`Thus, Petitioner has not made a sufficient showing that Onishi
`
`discloses the generation of a device presence signal from outside of the car
`
`stereo and transmission of that signal to the car stereo. It follows, also, that
`
`Petitioner has not made a sufficient showing that Onishi’s alleged teaching
`
`regarding the generation of a device presence signal and transmission of
`
`that signal to the car stereo, when applied to JP ’954, results in satisfaction
`
`of claim 57’s limitation directed to a device presence signal.
`
`3.
`
`Dependent Claims 5—8, 10, 14, 60—62, 64, and 65
`
`Each of claims 5—8, 10, 14, 60—62, 64, and 65 depends directly or
`
`indirectly from either claim 1 or 57. The deficiencies noted above with
`
`regard to claims 1 and 57 carry through to the claims depending therefrom.
`
`Accordingly, Petitioner has not shown a reasonable likelihood that it would
`
`prevail in establishing unpatentability of any of claims 5-8, 10, 14, 60—62,
`
`64, and 65 on any alleged ground of obviousness relying in part on Bhogal.
`
`C.
`
`Alleged Obviousness of Claims 1, 6, 7, 10, 14, 57,
`60, and 61 as Obvious over JP ’954, Onishi, and Owens
`
`For reasons discussed below, we determine that Petitioner has not
`
`shown a reasonable likelihood that it would prevail in establishing
`
`unpatentability of any of claims 1, 6, 7, 10, 14, 57, 60, and 61 as obvious
`
`over JP’954, Onishi, and Owens.
`
`Page 1388 of 1457
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`IPR2016-01472
`
`Patent 7,489,786 B2
`
`1.
`
`JP ’954
`
`JP ’954 is directed to solving the problem of equipment
`
`incompatibility, in the environment of automotive audio equipment, between
`
`a main unit made by one company and a CD changer made by another
`
`company. Ex. 1012, Abstr. Specifically, JP ’954 describes the
`
`disadvantages associated with prior art systems as follows:
`
`When installing an audio device in a vehicle on the
`occasion of a vehicle purchase,
`it is common for a so-called
`“basic” main unit to be installed. If one were to subsequently
`attempt to add a CD changer capable of automatically changing
`and playing a plurality of loaded CDs, prior to now it would have
`been necessary to purchase and install a model produced by the ‘
`same manufacturer as the “basic” main unit, as the format of
`signals
`connecting
`the
`respective
`devices
`vary
`from
`manufacturer to manufacturer.
`Furthermore,
`if a user had
`installed both of
`these devices produced by the
`same
`manufacturer, and at a later point wished to upgrade the main
`unit to, for example, a model produced by company A, it would
`have been necessary for the same reason to also purchase a new
`CD changer made by company A.
`
`Id. 11 2. JP ’954 describes its objective as: “to make it possible to add a CD
`
`changer made by company B to a main unit made by company A, as well as
`
`to add a CD changer made by company A to a main unit made by
`
`company B.” Id. 1] 3. JP ’954 achieves that objective by providing an
`
`interface unit as noted below:
`
`(PROBLEM) Provide an interface unit for automotive audio
`equipment that renders possible the addition of a CD changer
`made by company B to a main unit made by company A as well
`as the addition of a CD changer made by company A to a main
`unit made by company B.
`
`Ex. 1012, Abstr. JP ’954 summarizes its interface unit as follows:
`
`Page 1389 of 1457
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`IPR2016-01472
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`Patent 7,489,786 B2
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`(MEANS FOR SOLVING) The [interface] unit is constituted
`by splitting signals into three systems, namely a control system,
`audio system and power system, and providing a conversion
`circuit for each of these systems.
`
`Id. Figure l of JP ’954 is reproduced below:
`
`(Fig. 1)
`
`
`
`Figure 1 illustrates a block diagram of the structure of the audio system
`
`according to JP ’954. Id. 11 6. Interface unit 1 “converts the format of the
`
`signal that links the CD changer 2 and the main unit 3, etc.” Id. Interface
`
`unit 1 links main unit 3 and CD changer 2, and is provided with control
`
`system conversion portion 4, audio system conversion portion 5, and power
`
`conversion portion 6. Id. at Abstr. Control conversion portion 4 is for the
`
`bus line, clock control signal, etc.; audio conversion portion 5 is for the
`
`audio signal; and power conversion portion 6 is for the power supply. Id.
`
`116.
`
`Page 1390 of 1457
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`IPR2016-01472
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`Patent 7,489,786 B2
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`Figure 2 of JP ’954 is reproduced below:
`
`(Fig. 2)
`
`>
`
`_-m .
`
` —|,,c
`
`Figure 2 illustrates control system conversion portion 4. Id. 1] 7.
`
`Microcomputer 4a is provided to convert and unify different signal formats
`
`between the CD changer and the main unit. Id.
`
`Figure 4 is reproduced below:
`
`(Fig. 4)
`
`
`
`Figure 4 illustrates audio system conversion portion 5. Id. 1[ 11. It includes
`
`differential amplifiers 5a and 5b and amplifiers 5c and 5d. Id.
`
`JP ’954 states: “[a]1though one embodiment example was described
`
`above, to expand the range of available inter-company format conversions, a
`
`switch can be provided on the microcomputer 4a to enable application to
`
`various models using a connection adapter between the CD changer and
`
`main unit. Id. 1] 10.
`
`Page 1391 of 1457
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`IPR2016-01472
`
`Patent 7,489,786 B2
`
`2.
`
`Claims 57, 60, and 61
`
`As noted above, claim 57 requires the microcontroller within the
`
`interface to have a pre-programmed code portion that is “for generating a
`
`device presence signal and transmitting the signal to the car stereo to
`
`maintain the car stereo in an operational state.” Ex. 1001, 26:22—26.
`
`According to Petitioner, Onishi discloses this limitation. Pet. 52—53.
`
`Specifically, Petitioner refers back to and incorporates its discussion of this
`
`limitation of claim 57 in the context of its assertion that claim 57 is
`
`unpatentable as obvious over Bhogal, Berry, and Onishi. Id. at 52.
`
`For the same reasons discussed above, in the alleged obviousness of
`
`claim 57 over Bhogal, Berry, and Onishi, Petitioner has not made an
`
`adequate showing that Onishi discloses the generation of a device presence
`
`signal and transmitting that signal to the car stereo. The same deficiency
`
`carries through to claim 60 which depends from claim 57, and to claim 61
`
`which depends from claim 60.
`
`Accordingly, Petitioner has not shown a reasonable likelihood that it
`
`would prevail in establishing unpatentability of any of claims 57, 60, and 61
`
`as obvious over JP ’954, Onishi, and Owens.
`
`3.
`
`Claim 1
`
`For reasons discussed below, Petitioner has not shown a reasonable
`
`likelihood that it would prevail in establishing unpatentability of claim 1 as
`
`obvious over JP ’954, Onishi, and Owens.
`
`a)
`
`receiving, processing, transmitting data, and
`converting data from incompatible format to
`compatible format
`
`Claim 1 requires a microcontroller within the interface to execute a
`
`pre—programmed code portion that is:
`
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`IPR2016-01472
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`Patent 7,489,786 B2
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`for receiving data from the after-market audio device through
`said second connector in a format incompatible with the car
`stereo, processing the received data into formatted data
`compatible with the car stereo, and transmitting the formatted
`data to the car stereo through saidfirst connectorfor display by
`the car stereo.
`
`Ex. 1001, 21:55—61 (emphasis added). The same microcontroller also has to
`
`execute a pre-programmed code portion that is:
`
`for remotely controlling the after-market audio device using the
`car stereo by receiving a control command from the car stereo
`through said first electrical connector in a format incompatible
`with the after-market audio device, processing the received
`control command into a formatted command compatible with the
`after-market device, and transmitting the formatted command to
`the after-market device through said second connector for
`execution by the after-market audio device.
`
`Id. at 21:45—54.
`
`Petitioner first accounts for the control command conversion or
`
`remote control limitation of claim 1, by referring to control system
`
`conversion 4 of JP ’954. Pet. 44—45. In that regard, Figure 2 of JP ’954 is
`
`again reproduced below:
`
`
`
`Figure 2 illustrates control system conversion portion 4. Ex. 1012 1[ 7.
`
`Petitioner explains:
`
`The control signals converted by control conversion portion 4
`include incoming signals from the main unit on “Data in” line
`
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`IPR2016-01472
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`Patent 7,489,786 B2
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`4g, which are converted and forwarded to the CD changer via
`“Data out” line 20.
`1d. at FIG. 2; Geier Decl., Ex. 1004, at
`1]][133—34. The control conversion portion 4 also converts
`“operational status” data such as “PLAY, FWD, BWD, etc.”
`received from the CD changer via “Data in” line 2a and forward
`such data to the main unit via “Data out” line 4f.
`JP ’954,
`Ex. 1012, at (0008), (0009), FIG. 2. The ability of the interface
`unit to convert signal formats make it possible for a CD changer
`and a main unit made by different companies to communicate.
`Id. at (0005). See also Geier Decl., EX. 1014, at W 145—46.
`
`Pet. 44—45.
`
`Then, to satisfy the limitation about converting data and sending
`converted data for display in the car stereo, Petitioner cites to Onishi and
`
`interface unit 1 of JP ’954. Petitioner explains:
`
`Onishi teaches that once the MD recorder/player is connected to
`the on-vehicle audio device,
`information from the MD
`recorder/player can be transmitted to and displayed by display
`unit 53 on the on-vehicle audio device (car stereo). Ex. 1007, at
`[0030], [0073]. This information reflects the track being played
`back, such as “track number,” “track name,” and “playback
`progress time.” Id. at [0086].
`
`Pet. 45.
`
`As shown by Onishi, it was a known technique to display on the
`car stereo information relating to an audio track being played,
`including information on the playback progress time, so that the
`user of the car stereo could be informed about status of playback.
`See Onishi, Ex. 1007, at [0030], [0073], [0086]; Geier Decl., EX.
`1014, 1]] 147—49. JP ’954 recognized the need to inform the car
`stereo of “operational status” data ofthe alter-market device. See
`Ex. 1012, at (0009). It would have been obvious for a person of
`ordinary skill in the art at the time of the filing of the ’786 patent
`to modify the interface unit of JP ’954 to include the feature of
`processing and forwarding operational data such as time and
`track information to the car stereo to display. Geier Decl.,
`Ex. 1014, 1] 149. Such modification would have resulted in the
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`IPR2016-01472
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`Patent 7,489,786 B2
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`predictable improvement of allowing the interface unit to provide
`more information to the user. Id.
`
`Id. at 45—46 (emphasis added).
`
`Patent Owner responds and argues as follows:
`
`Essentially Petitioner argues that because transmitting data from
`media players was known,
`it would have been obvious to
`implement it in JP ’954. This argument is woefiJlly short of a
`proper obviousness analysis. First, Petitioner does not address
`the analysis set forth by the Board [in IPR2016-00421 (Paper
`13)], particularly that “conversion portion 4 in interface unit 1 is
`for communicating and converting control signals, not any data
`for display on a car stereo, such as song title and artist
`information.” Petitioner does not identify which microprocessor
`should include the pre-programmed code portion, particularly in
`light of the fact that conversion portion 4 is not meant for sending
`data, such as title and artist information, to the head unit.
`
`PO Resp. 24—25.
`
`We find the above-quoted arguments of Petitioner to be deficient and
`
`the above-quoted arguments of Patent Owner to be persuasive. Petitioner
`
`fails to make a sufficient distinction between interface unit 1 of JP ’954
`
`and control system conversion portion 4 within interface unit 1 of JP ’954.
`
`Even assuming that, in light of Onishi, it would have been obvious to one
`
`with ordinary skill to send song and artist information back to the car
`
`stereo for display, Petitioner, in order to demonstrate that claim 1 would
`
`have been obvious, has to address why it would havc been obvious to one
`
`with ordinary skill in the art to use control system conversion portion 4,
`
`and in particular microcomputer 4a within control system conversion
`
`portion 4, in JP ’954 to perform that task. Interface unit 1 of JP ’054 is not
`
`just control system conversion portion 4. Rather, it also includes audio
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`system conversion portion 5 and power conversion portion 6, as is shown
`
`in its Figure l reproduced below:
`
`(Fig. 1)
`
`
`
`Figure 1 illustrates a block diagram of the structure of the audio system
`
`according to JP ’954. Ex. 1012 11 6.
`
`Petitioner fails to account for why one with ordinary skill in the art
`
`would have modified control system conversion portion 4, specifically, and
`
`not something else, to add the functionality of sending song and artist
`
`information back to the car stereo for display. The omission is significant
`
`because we understand that control system conversion portion 4 of JP ’954
`
`relates to operational control and status of the CD—changer, and time and
`
`track information of songs do not reflect the operational status of the CD—
`changer but the content of the music being played or to be played. We
`
`recognize that microcomputer 4a sends back to the car stereo operational
`
`status of the CD-changer. But operational status data relate to operational
`
`control of the CD-changer, and are not information about songs and artists.
`
`Also, JP ’954 does not describe that operational status data are for display at
`
`the car stereo. On this record, Petitioner has not provided reasoning with
`
`rational underpinning to support its conclusion that one with ordinary skill in
`
`the art would have selected microcomputer 4a in control system conversion
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`portion 4 of JP ’954 to perform data conversion of song and artist
`
`information to send back to the car stereo for display.
`
`b)
`
`switching to one or more auxiliary input sources
`
`Claim 1 further requires the microcontroller within the interface to
`
`execute a pre-programmed code portion that is “for switching to one or more
`
`auxiliary input source connected to said third electrical connector.”
`
`Petitioner acknowledges that neither JP ’954 nor Onishi discloses this
`
`limitation but asserts that Owens does. Pet. 46. Petitioner states:
`
`Owens discloses an auxiliary input source such as VCR 44,
`tuner 46, or game station 48, which is connectable to A/V source
`selector 40. Ex. 1010, at [0025], [0026], [0009], FIG. 7. Owens
`also discloses a microprocessor that performs switching to one
`or more auxiliary input sources as required in claim 1.
`Id.
`at [0034]; Geier Dec1., Ex. 1014,1[1] 151—152.
`
`Id. at 47. Figure 7 of Owens is reproduced below:
`
`» SOU‘RtE
`S F L FL‘MR
`
`j
`
`HEAD9HONES [
`MODULE
`
`FIG. /
`
`Figure 7 of Owens illustrates a schematic diagram of an embodiment
`
`according to Owens. Ex. 1010, Fig. 7. Petitioner regards the A/V interface
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`module and A/V source selector in Owens as an interface between the car
`
`stereo and multiple audio or video devices. Pet. 48.
`
`Petitioner argues:
`
`As shown in Owens, it was well-known in the art to use devices
`like the A/V interface module and NV source selector of Owens
`
`to provide an interface to serially connect multiple audio or
`video devices to a car stereo. Geier Decl., Ex. 1014, 111] 154—57.
`Such a configuration would allow consumers to obtain a car
`stereo without a large initial investment and gradually buy and
`add additional modules
`to accommodate additional
`input
`sources. See Owens, Ex. 1009, at [0008]; Geier Decl., Ex. 1014,
`fl 157. As such, modifying the interface unit taught by JP ’954,
`in View of Onishi, to permit one or more auxiliary audio or video
`sources, other than the after-market CD—changer unit, to be
`connected to a car stereo, and to configure the microprocessor
`inside JP ’954’s interface unit to be able to switch between
`
`(claim 1) and channel audio from (claim 14) those auxiliary
`sources, would have resulted in the predictable improvement of
`increasing the utility and versatility of the interface unit.
`Id. at
`11 158.
`
`Id. Petitioner’s argument is unpersuasive.
`
`It is not adequately explained by Petitioner why one with ordinary
`
`skill in the art would have chosen microcomputer 4a within control system
`
`conversion portion 4 of interface unit 1 within JP ’954 to perform source
`
`switching. Petitioner’s explanation is conclusory. The explanation also is
`
`without rational underpinning. For instance, microcomputer 4a in JP ’954
`
`does not itself perform all of the communication between the car stereo and
`
`the connected CD-changer. Some of the communication are conducted
`
`through audio system conversion portion 5. Ex. 1012, Abstr., Fig. 1. Also,
`
`in Owens, the processor that performs source selecting or switching is
`
`located within the car stereo. Ex. 1010 W 33—34, Fig. 9. Petitioner does not
`
`explain why that location would have been moved to within control system
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`conversion portion 4 in JP ’954, which is disposed in a link dedicated to a
`
`single audio or auxiliary device. For these reasons, Petitioner’s stated
`
`rationale to combine teachings to arrive at the claim limitation pertaining to
`
`source switching is conclusory, illogical, and lacks a rational underpinning.
`
`4.
`
`Claims 6, 7, 10, and 14
`
`Claims 6, 7, 10, and 14 each depend, directly or indirectly, from
`
`claim 1, and thus incorporate all of the limitations of claim 1. The
`
`deficiencies discussed above in the context of claim 1 carry through to each
`
`of dependent claims 6, 7, 10, and 14. In addition, we note that claim 6
`
`further recites: “wherein said interface generates a device presence signal
`
`for maintaining the car stereo in a state responsive to processed data and
`
`audio signals.” Petitioner’s arguments with regard to the limitation added by
`
`claim 6 are deficient for the same reasons discussed above, which explain
`
`Why Petitioner’s arguments are deficient with regard to the limitation in
`
`claim 57 that requires the microcontroller to execute a pre—programmed code
`
`portion “for generating a device presence signal and transmitting the signal
`
`to the car stereo to maintain the car stereo in an operational state.”
`
`Petitioner has not shown a reasonable likelihood that it would prevail
`
`in establishing unpatentability of any of claims 6, 7, 10, and 14 as obvious
`
`over JP ’954, Onishi, and Owens.
`
`D.
`
`Alleged Obviousness of Claim 5
`over JP ’954, Onishi, Owens, and Berry
`
`Claim 5 depends from claim 1 and further recites: “wherein said
`
`interface further comprises a plug-and-play mode for automatically detecting
`
`device type of the after-market audio device connected to said second
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`electrical connector and integrating the after—market audio device based
`
`upon the device type.”
`
`Petitioner’s addition of Berry does not cure the deficiencies discussed
`
`above in the context of the alleged groundof unpatentability of claim 1 over
`
`JP ’954, Onishi, and Owens. Accordingly, Petitioner has not shown a
`
`reasonable likelihood that it would prevail in establishing the unpatentability
`
`of claim 5 as obvious over JP ’954, Onishi, Owe