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 obviousnessrelying in part on Bhogal.
`
`a)
`
`pre-programmedcodeportion 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-programmedcode portion that is:
`
`for remotely controlling the after-market audio device using the
`car stereo by receiving a control commandfrom the car stereo
`through said first electrical connector in a format incompatible
`with the after-market audio device, processing the received
`control commandinto 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.
`Ex. 1001, 21:45—54. Claim 57 includesa similar limitation that differs from
`
`the above-quoted limitation of claim | by reciting a portable MP3 player
`
`instead of an after-market audio device. /d. 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 remote control aspect of claims 1 and 57, and aside from the
`
`specific requirement of a portable MP3player 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
`
`Daimler Exhibit 1002
`
`18
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`Daimler Exhibit 1002
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`

`

`IPR2016-01472
`Patent 7,489,786 B2
`
`Pet. 19. Petitioner’s argumentis 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-changerunit specification database 312”
`which “contains operational information about various models of
`CD-changerunits and the mannerin which emulator unit 302 can
`interface with a particular type of CD-changer unit.” Jd. 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 intendedfor 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 CDsor for obtaining information
`about CDs,
`the emulator unit captures the commands and
`“performs appropriate processing.” Jd. at 8:21—26.
`In doingso,
`the emulator unit “operates in a particular manner that
`is
`compatible with the CD-changer to which the emulator unit is
`connected.” Jd. at 7:7-11. See Geier Decl., Ex. 1014, 99] 53-55.
`
`Id.
`
`The argumentis unpersuasive. Noneof 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 commandsto access audio data
`
`files within the emulatoritself that are organized as virtual CD-ROMs.
`
`The claim limitation requires receiving a control command from the
`
`car stereo in a format incompatible with the connected audio device,
`
`processingit into a formatted control commandthat is compatible with the
`
`audio device, and transmitting the formatted commandto the audio device.
`
`Petitioner has not identified any disclosure in Bhogalthat describes
`
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`IPR2016-01472
`Patent 7,489,786 B2
`
`transmitting such a converted commandto 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 commandfrom a
`
`format that is incompatible with the connected audio device to a format that
`
`is compatible with the connected audio device. Jd.
`
`In Bhogal, the car stereo
`
`and the actual CD-changeralready.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
`
`emulatoris not in the docking station, the car stereo and the actual CD-
`
`exchanger may operate together. Jd. at 5:65—-67.
`
`In addition, there is an operation mode of the emulatorcalled
`
`“end-unit” mode, in which the emulator replaces the CD-changerentirely
`
`and itself emulates the presence of the CD-changer. Jd. at 7:47-49. Nothing
`
`in that modeof operation involves conversion of any commandto besent to
`
`the CD-changerto control the CD-changer remotely.
`
`Therealso is an operation mode of the emulator called “combination
`
`mode,” in which the emulator also reads tracks and track information from
`
`(he actual CD-changer unit connectedto it, “to create virtual CDs with tracks
`
`from both sources.” Jd. at 8:4—-20. Petitioner identifies no disclosure in
`
`Bhogal that any conversion is performed on car stereo commandsthat are
`
`incompatible with the actual CD-changer to make them compatible with the
`
`CD-changer, muchless transmitting such converted commandsto the
`
`CD-changerto effect remote control of the CD-changerbythe car stereo.
`
`Page 1383 of 1457
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`

`IPR2016-01472
`Patent 7,489,786 B2
`
`As noted above, the car stereo and the actual CD-changeralready
`
`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 Bhogaldiscloses the
`
`required conversion.
`
`The foregoing reason aloneconstitutes sufficient basis to conclude
`
`that Petitioner has not shown reasonable likelihoodthat it would prevail in
`
`establishing unpatentability of any challenged claim on any ground based in
`
`part on Bhogal. Wediscuss below an additional deficiency with respectto
`
`claim 1 and claims dependentthereon, 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 pre-programmedcode portion thatis:
`
`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-changerunit 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 sentto the car stereo.” Pet. 22. Petitioner’s argumentis
`
`unpersuasive.
`
`Page 1384 of 1457
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`

`IPR2016-01472
`Patent 7,489,786 B2
`
`Petitioner cites no disclosure in Bhogalto the effect that data from the
`
`actual CD-changeris 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 Bhogalto 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 Bhogalthat indicates
`
`the car stereo and the audio device do not already share the same format
`
`without involvement of the emulator.
`
`Asdiscussed above, Bhogal describes that when the emulatoris 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 doesnot involve any conversion of
`
`data from a formatthat is incompatible with the car stereo to a formatthatis
`
`compatible with the car stereo. Jd. 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 ofsignals.
`
`c)
`
`generating and transmitting a device presence
`signal (claim 57)
`Claim 57 further requires the microcontroller within the interface to
`
`have a pre-programmed codeportionthat is “for generating a device
`
`presencesignal and transmitting the signal to the car stereo to maintain the
`
`car stereo in an operationalstate.” Ex. 1001, 26:22-26. According to
`
`Petitioner, neither Bhogal nor Berry disclosesthis 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
`
`22
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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. Jd.
`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.
`Jd. 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. Jd. at [0082].
`In another method, the AUX input
`terminal 55 contains a voltage detector. Jd. at [0083]. Based on
`the voltage detection, the system controller 60 determines if an
`AUX device is present.
`Jd) 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. Jd. 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 operationalstate.
`
`Id. at 19-20 (emphasis added).
`
`Petitioner’s explanation is misdirected and unpersuasive. The term
`
`“device presence signal” has been construed as a signalindicating that an
`
`audio device, other than the car stereo, is connected to the interface. The
`
`construction is the sameas 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
`
`23
`
`Page 1386 of 1457
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`

`

`IPR2016-01472
`Patent 7,489,786 B2
`
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`5;
`
`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
`
`presencesignal, but by itself detecting the presence of an auxiliary device.
`
`Merepresenceof data on an inputline does notsatisfy 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
`
`presencesignal and to transmit that device presence signal to the car stereo.
`
`Page 1387 of 1457
`
`24
`
`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 sendsto an internal source
`
`selector, atter it already has recognized that an auxiliary deviceis present,
`
`in order to select that auxiliary device as input. Id. { 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 madea 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 presencesignal.
`
`3.
`
`Dependent Claims 5-8, 10, 14, 60-62, 64, and 65
`
`Each of claims 5-8, 10, 14, 60-62, 64, and 65 dependsdirectly 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 obviousnessrelying 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
`
`Tor reasous discussed below, we determinethat Petitioner has not
`
`showna 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
`
`25
`
`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:
`
`Wheninstalling 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. | 2. JP 954 describes its objective as: “to make it possible to add a CD
`
`changer made by companyB 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.” Jd. 93. JP ’954 achieves that objective by providing an
`
`interface unit as noted helow:
`
`(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 companyB.
`
`Ex. 1012, Abstr. JP ’?954 summarizesits interface unit as follows:
`
`Page 1389 of 1457
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`

`IPR2016-01472
`Patent 7,489,786 B2
`
`(MEANSFOR SOLVING) The[interface] unit is constituted
`by splitting signals into three systems, namely a control system,
`audio system and powersystem, and providing a conversion
`circuit for each of these systems.
`Id. Figure 1 of JP ’954 is reproduced below:
`
`(Fig. 1)
`
`
`
`Figure 1 illustrates a block diagram ofthe structure ofthe audio system
`according to JP 954. Id. 46. Interface unit 1 “converts the format of the
`
`signal that links the CD changer 2 and the main unit 3, etc.” Jd. Interface
`
`unit 1 links main unit 3 and CD changer2, and is provided with control
`
`system conversion portion 4, audio system conversion portion 5, and power
`
`conversion portion 6. Jd. at Abstr. Control conversion portion 4 is for the
`
`busline, clock control signal, etc.; audio conversion portion 5 is for the
`
`audio signal; and power conversion portion 6 is for the power supply. Id.
`
`6.
`
`Page 1390 of 1457
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`

`IPR2016-01472
`Patent 7,489,786 B2
`
`Figure 2 of JP ’954 is reproduced below:
`
`(Fig. 2)
`
`-
`
`bus input
`
`ToH, U
`
`Figure 2 illustrates control system conversion portion 4. Id. § 7.
`
`Microcomputer4a is provided to convert and unify different signal formats
`
`between the CD changer and the main unit. Jd.
`
`Figure 4 is reproduced below:
`
`(Fig. 4)
`
`
`
`Figure4 illustrates audio system conversion portion 5. Jd. 411. It includes
`
`differential amplifiers Sa and 5b and amplifiers Sc and 5d. Jd.
`
`JP 954 states: “[a]lthough one embodiment example was described
`
`above, to expand the range ofavailable 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. ¥ 10.
`
`Page 1391 of 1457
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`

`IPR2016-01472
`Patent 7,489,786 B2
`
`2.
`
`Claims 57, 60, and 61
`
`Asnoted above, claim 57 requires the microcontroller within the
`
`interface to have a pre-programmed codeportion that is “for generating a
`
`device presence signal and transmitting the signalto the car stereo to
`
`maintain the car stereo in an operational state.” Ex. 1001, 26:22-26.
`
`Accordingto Petitioner, Onishi disclosesthis limitation. Pet. 52-53.
`
`Specifically, Petitioner refers back to and incorporates its discussion of this
`
`limitation of claim 57 in the contextof its assertion that claim 57 is
`
`unpatentable as obvious over Bhogal, Berry, and Onishi. Jd. at 52.
`
`For the samereasons discussed above,in the alleged obviousness of
`
`claim 57 over Bhogal, Berry, and Onishi, Petitioner has not made an
`
`adequate showingthat 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 dependsfrom claim 60.
`
`Accordingly, Petitioner has not shown a reasonablelikelihoodthatit
`
`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 codeportion thatis:
`
`Page 1392 of 1457
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`IPR2016-01472
`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-programmedcodeportionthatis:
`
`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 commandinto a formatted command compatible with the
`after-market device, and transmitting the formatted commandto
`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 ’954is
`
`again reproduced below:
`
`
`
`Figure 2 illustrates control system conversion portion 4. Ex. 1012 4 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
`Patent 7,489,786 B2
`
`4g, which are converted and forwarded to the CD changer via
`‘Data out” line 2c.
`Jd. at FIG. 2; Geier Decl., Ex. 1004, at
`qj 133-34. The control conversion portion 4 also converts
`“operational status” data such as “PLAY, FWD, BWD,etc.”
`received from the CD changervia “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 makeit 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 ff 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.” Jd. at [0086].
`
`Pet. 45.
`
`As shown by Onishi, it was a knowntechniqueto 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 aboutstatus of playback.
`See Onishi, Ex. 1007,at [0030], [0073], [0086]; Geier Decl., Ex.
`1014, ff 147-49. JP ’954 recognized the need to inform the car
`stereo of “operational status”data ofthe after-market device. See
`Ex. 1012, at (0009). It would have been obviousfor a person of
`ordinary skill in the art at the time ofthe filing of the ’786 patent
`to modify the interface unit ofJP ’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, § 149. Such modification would have resulted in the
`
`Page 1394 of 1457
`
`3]
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`

`IPR2016-01472
`Patent 7,489,786 B2
`
`predictable improvementofallowingthe interface unit to provide
`more information to the user. Jd.
`
`Id. at 45-46 (emphasis added).
`Patent Owner respondsandarguesas follows:
`
`Essentially Petitioner argues that because transmitting data from
`media players was known,
`it would have been obvious to
`implementit in JP °954. This argument is woefully 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-programmedcodeportion, particularly in
`light of the fact that conversion portion 4 is not meant for sending
`data, such astitle and artist information, to the head unit.
`
`PO Resp. 24-25.
`
`Wefind the above-quoted arguments of Petitioner to be deficient and
`
`the above-quoted arguments of Patent Ownerto 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 assumingthat, in light of Onishi, it would have been obvious to one
`
`with ordinary skill to send song andartist 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 have 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 performthat task. Interface unit 1 of JP ’054 is not
`
`just control system conversion portion 4. Rather, it also includes audio
`
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`IPR2016-01472
`Patent 7,489,786 B2
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`system conversion portion 5 and power conversion portion 6, as is shown
`
`in its Figure 1 reproduced below:
`
`(Fig. 1)
`
`
`
`Figure 1 illustrates a block diagram ofthe structure of the audio system
`
`according to JP 7954. Ex. 1012 4 6.
`
`Petitioner fails to account for why one with ordinary skill in the art
`
`would have modified contro! system conversion portion 4, specifically, and
`
`not something else, to add the functionality of sending song andartist
`
`information back to the car stereo for display. The omissionis 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 notreflect the operational status of the CD-
`changerbut the content ofthe music being played or to be played. We
`recognize that microcomputer 4a sends hack 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 songsandartists.
`
`Also, JP ’954 does not describe that operational status data are for display at
`
`the car stereo. Onthis 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
`
`Page 1396 of 1457
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`IPR2016-01472
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`portion 4 of JP °954 to perform data conversion of song andartist
`
`information to send backto 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-programmedcodeportionthat is “for switching to one or more
`
`auxiliary input source connectedto said third electrical connector.”
`
`Petitioner acknowledgesthat 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.
`Jd.
`at [0034]; Geier Decl., Ex. 1014, ff 151-152.
`
`Id. at 47. Figure 7 of Owensis reproduced below: GAME
`
`STATION
`
`FiG. f
`
`Figure 7 of Owensillustrates a schematic diagram of an embodiment
`
`according to Owens. Ex. 1010, Fig. 7. Petitioner regards the A/V interface
`
`Page 1397 of 1457
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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-knownin the art to use devices
`like the A/V interface module and A/V source selector of Owens
`to provide an interface to serially connect multiple audio or
`video devices to a car stereo. Geier Decl., Ex. 1014,154-57.
`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,
`4 157. 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 haveresulted in the predictable improvement of
`increasing the utility and versatility of the interface unit.
`Id. at
`q 158.
`
`Id. Petitioner’s argumentis 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 explanationalsois
`
`without rational underpinning. For instance, microcomputer 4a in JP ’954
`
`doesnotitself perform all of the communication betweenthe car stereo and
`
`the connected CD-changer. Someof 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 {{ 33-34, Fig. 9. Petitioner does not
`
`explain why that location would have been moved to within control system
`
`Page 1398 of 1457
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`IPR2016-01472
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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 teachingsto 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 abovein 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 presencesignal
`
`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
`
`whyPetitioner’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 reasonablelikelihood 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 furtherrecites: “wherein said
`
`interface further comprises a plug-and-play modefor automatically detecting
`
`device type ofthe after-market audio device connected to said second
`
`Page 1399 of 1457
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`IPR2016-01472
`Patent 7,489,786 B2
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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
`
`abovein the context of the alleged ground.of unpatentability of claim 1 over
`
`JP 954, Onishi, and Owens. Accordingly, Petitioner has not shown a
`
`reasonablelikelihood that it would prevail in establishing the unpatentability
`
`of claim 5 as obvious over JP °954, Onishi, Owens, and Berry.
`
`E.
`
`Alleged Obviousness of Claims 8 and 62
`over JP 954, Onishi, Owens, and Ohmura
`Claim 8 dependsdirectly from claim 1. Claim 62 dependsindirectly
`from claim 57. Petitioner’s addition of Ohmura doesnot cure the
`deficiencies discussed above in the context of the alleged ground of
`unpatentability of claims 1 and 57 over JP ’954,