Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”). Filed December 1, 2006 and published July 19, 2007.
`
`Rezvani-875 qualifies as prior art under at least pre-AIA 35 U.S.C. § 102(e). Claims 1–4, 6–9, and 11–14 of the ’155 Patent are invalid as (a)
`obvious over Rezvani-875 itself or Rezvani-875 in view of the background knowledge and ordinary creativity of a person having ordinary skill
`in the art at the time the ’155 Patent was invented; and (b) obvious over Rezvani-875 in view of one or more of the references listed in Appendix
`A, combined as set forth herein.
`
`In addition to the disclosures listed below, Defendants incorporate by reference the teachings and disclosures described in Appendix A.
`
`Claim
`[1(a)] A wireless headphone
`assembly comprising:
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`Rezvani-875 discloses a wireless headphone assembly as demonstrated in the following exemplary
`disclosures:
`
`“High fidelity multimedia wireless headset.”
`
`Title.
`
`“The invention provides a multiple-antenna wireless multimedia headset with high fidelity sound,
`peer-to-peer networking capability, seamless handoff between multiple wireless interfaces,
`multimedia storage with advanced search capability, and ultra low power such that the device is
`capable of operation without recharging. The headset supports multiple wireless systems such as
`Wifi (802.11a/b/g/n), Wimax, 3G cellular, 2G cellular, GSM-EDGE, radio (e.g. AM/FM/XM),
`802.15 (Bluetooth, UWB, and Zigbee) and GPS. The headset also provides a platform such that
`applications can access the high fidelity sound system, the speech recognition engine, the
`microprocessor, and the wireless systems on the device.”
`Abstract
`
`“The present disclosure is generally directed to a wireless multimedia headset that can include
`multiple features and support multiple wireless systems. These features can include any combination
`of a multimedia storage with advanced search capability; a high fidelity sound system; peer-to-peer
`
`1
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`[0017]
`
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`networking capability; and an ultra low power consumption, such that the device is capable of
`operation without recharging. The headset can also provide a platform for both existing and new
`headset applications (such as “push-to-talk” between headsets) to enable access to the device
`features.”
`
`FIG. 1 provides a functional block diagram showing the features of the headset according to some
`embodiments. In these embodiments, the headset 100 comprises a user interface 105 having query
`110 and command 115 functionality for voice recognition. The headset 100 includes a peer-to-peer
`networking 120 functionality that will allow any headset within range of other wireless devices to
`self-configure with them into a multihop network.
`
`[1(b)] first and second earphones,
`wherein each of the first and
`second earphones comprises an
`acoustic transducer;
`
`[0018]
`Rezvani-875 discloses a headphone assembly comprising first and second earphones, wherein each of the
`first and second earphones comprises an acoustic transducer.
`
`For example, Rezvani discloses an audio interface 227 with an output 229 as part of a high fidelity sound
`system. A POSA would have understood the “output 229” to be a speaker, which is an acoustic
`transducer. See U.S. 5,889,870, 2:6-9 (“A speaker is a transducer…”). Moreover, a POSA would have
`understood that Rezvani-875’s “headset” includes “a pair of [i.e., first and second] transducers…to convert
`the signal into audible sound waves” (i.e., acoustic transducers). See, e.g., U.S. Patent Appl. Publ. No.
`2008/0031475 (“Goldstein”), [0048] (explaining: “‘Headphones’ (also known as … headsets …) are a pair
`of transducers that receive an electrical signal from a media player, communication receivers and
`transceivers, and use speakers placed in close proximity to the ears (hence the name earphone) to convert
`the signal into audible sound waves.”). See also:
`
`
`Wireless headsets are common devices used for hands-free operation in conjunction with cell
`phones and VoIP phones, as well as with portable music players such as digital MP3 players. Such
`headsets typically include radio technology to access a given wireless system. For example, cell
`
`2
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`[0004]
`
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`phone headsets use wireless technology to communication with the cell phone handset such that the
`voice signals received by the handset over the cell phone system can be transferred to the headset.
`Similarly, wireless headsets for MP3 players use wireless technology to transfer music files from
`the player to the headset.
`
`FIG. 2 illustrates the subsystems that support the various functionalities according to some
`embodiments. In these embodiments, the signals 205 received from the antenna 210, or array of
`antennas 215, through antenna interface 217 are processed by a MIMO RF system 220 and a
`baseband processor 225. The subsystems include an audio interface 227 having a microphone array
`27 having an input 228 and an output 229.
`
`[0020]
`
`If Koss argues that a POSA would not have interpreted Rezvani-875 to expressly disclose a second
`earphone, then implementing the headset of Rezvani-875 to include a first and second earphone would
`have been obvious as a POSA had several reasons to make such an implementation. For example, a
`POSA would have wanted to offer stereo sound and Rezvani-875suggested by disclosing a “high fidelity”
`sound system for listening to music, which many consumers prefer to listen to in stereo. Second, it would
`have been applying a known technique (using two earphones and transducers) to improve similar devices
`(wireless headsets) in the same way (to provide stereo sound). Third, two earphones and transducers
`would have been obvious to try because it was one of a finite number (two) of predictable configurations
`for a headphone assembly (either one or two earphones and transducers). At least the following prior art
`references disclose the use of two earphone for headsets/headphones were common and conventional prior
`to the alleged invention of the ’155 Patent:
`
`
`“There are two types of commercial headsets available, namely mono headsets and stereo headsets.
`The former can be applied in hands free cell phones. When the headsets are connected to bluetooth
`modules, users can answer phone calls through the headsets directly. In general, for purposes of
`
`3
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`convenience, mono headsets are designed to be small and delicate. Mono headsets, however, are not
`suitable for listening to stereo music, not only because they comprise only one earphone but also
`because the sound is limited to the vocal frequency range of (300 Hz˜3 KHz).
`
`Stereo headsets are mostly used when users wish to listen to music as they have two earphones for
`creating stereo sound. There are three types of stereo headsets: head-wear headsets, neck-wear
`headsets, and ear-wear headsets.”
`U.S. 2007/0253579, [0004]-[0005]
`
`
`“FIG. 4 illustrates a perspective view of the wireless headset 4 shown in FIG. 1. The wireless headset
`4 includes a headband 30, speaker 18, speaker 20, and a wireless communication module installed
`within the housing of the headset. The term “module” is used interchangeably with “circuitry” herein.
`In an example of the invention, speaker 18 and speaker 20 are flexibly coupled to headband 30 using
`a yoke 21 and yoke 23, respectively. Referring to FIG. 5, yoke 21 includes a yoke stem 22 coupled to
`headband 30 via a pivot pin 27. In a similar manner, referring to FIG. 4, yoke 23 includes a yoke stem
`24 coupled to headband 4 via a pivot pin 25. An electrical interface 26 is disposed within yoke stem
`22.”
`U.S. 7,457,649B1 (“Wilson”), 4:4-15
`
`4
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`
`
`Wilson, FIG. 4 (showing headband 30 connected between two earphones).
`
`
`“Headsets, which can incorporate one or two earphones for monaural or stereo listening, can be
`classified into three general types in accordance with the type of ear-phone that they employ: 1)
`“In-the-ear” type earphones, sometimes referred to as “ear buds,” which fit into the concha, or
`entrance to a wearer's middle ear, such as that described in U.S. Pat. No. 5,761,298 to M. Davis, et al.;
`2) “On-the-ear” types that couple against a lateral face of the auricle, or external ear, of the wearer,
`such as that described in U.S. Pat. No. 5,960,094 to W. Jensen, et al.; and, 3) “Over-the-ear” types
`
`5
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`

`

`Claim
`
`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`that surround and form a closed chamber over the auricle of the listener, such as that described in U.S.
`Pat. No. 6,295,366 to L. Haller, et al.”
`U.S. 6,856,690, 1:21-34
`
`
`“However, there are certain usage scenarios in which the user of a wireless communication headset
`may wish to listen to a stereo signal using both ears. Such usage scenarios are expected to increase
`with the availability of a variety of electronic devices and multi-function devices. Such devices
`include cellular telephones, digital music players, personal digital assistants, and devices combining
`one or more of these devices into a single integrated device.”
`U.S. 7,627,289, 1:7-15
`
`
`“Headphones: "Headphones" (also known as earphones, earbuds, stereophones, headsets Canal
`phones, or the slang term "cans") are a pair of transducers that receive an electrical signal from a
`media player, communication receivers and transceivers, and use speakers placed in close proximity
`to the ears (hence the name earphone) to convert the signal into audible sound waves.”
`Goldstein, [0048]
`
`
`“FIG. 3 illustrates an example of various elements that can be part of an earpiece device in
`accordance with at least one exemplary embodiment. The earpiece can include all or some of the
`elements illustrated in FIG. 3. For example the logic circuit 570 or the operatively connected memory
`storage device 585, can include spatial enhancement software 329, a DSP code 330, a speech
`synthesis and recognition system 311, and a digital timer 312. Additional elements can be connected
`to the logic circuit 570 as needed, for example a software communication interface 307 (e.g., wireless
`module 515), data port interface 306, audio input buffers 300 connected to digital audio input 302
`and/or analog audio input converted to digital via an ADC 301, environmental audio input acoustic
`transducer(s) 321 converted to digital via an ADC 316, user control 324, digital audio output 328,
`output acoustic transducers 319, display systems 318, communication buffers 325 as well as other
`electronic devices as known by one of ordinary skill in the relevant arts.”
`
`6
`
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`
`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`
`Goldstein, [0067]
`
`
`
`Goldstein, Fig. 3 (showing Amp 309 outputting to Output Acoustical Transducers 319):
`
`
`In at least one embodiment, a wireless headset 108 is utilized to facilitate the transmission of audio
`information and other information (e.g., video information) between the communications device 102
`
`7
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`

`

`Claim
`
`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`and a user 110. As discussed below with reference to FIGS. 2A-2C, the headset 108 may be
`implemented as an earbud-type or ear-clip type headset which may utilize a relatively small headset
`body 112 operably connected to an earbud speaker (not shown) for outputting audio information
`and a microphone assembly 114 for inputting audio information (such as the vocalizations of the user
`110). As depicted in the illustrated embodiment, the microphone assembly 114 may be operably
`connected to the headset body 112 via a boom 116. Alternatively, the microphone assembly 114 may
`be implemented on a wire connected to the headset body 112 which may be clipped to the clothing of
`the user 110, for example. The microphone assembly 114 may include any of a variety of
`microphones, including, but not limited to, throat microphones, boom microphones, bone induction
`microphones (i.e., microphones placed in the ear canal which pick up audio signals via vibrations in
`the ear canal), and the like.
`U.S. Application Publication No. 2009/0029743 (“Lair”), [0028]
`
`
`As illustrated in greater detail with reference to FIGS. 2D-2G, the headset 108 alternately may be
`implemented as a headband-type headset having one or two ear pads or cups connected via one or
`more bands that encircle at least part of the head or neck of the user 110.
`Lair, [0029]
`
`
`Packetized audio information transmitted from the wireless adapter 118 (FIGS. 1A and 1B) or
`directly from the communications device 102 is received via the antenna or transducer 310 and
`transceiver 308, depacketized by the processor 306 and provided to a decoder 314 for conversion to
`an analog signal representative of the audio information. The analog signal then may be used to drive
`a speaker 316 to output the audio information as sound for detection by the user 110. As discussed
`above, the speaker 316 may be implemented in a earbud or ear insert placed in or near to an
`ear canal of the user 110, in an earpiece of the headset which covers at least a portion of the ear,
`and the like.
`Lair, [0046]
`
`8
`
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`
`Lair, FIG. 3 (speaker 316)
`
`
`
`
`
`FIG. 1A is a block diagram illustrating functional components that may be found in a wireless
`telecommunications headset 101. Headset 101 may be wearable by a user. For example, headset 101
`may be formed so as to affix to the head of a user by wrapping around an ear or inserting at least
`partially within the ear canal, or the headset may include a speaker for one or both ears and
`extend over or around the head as with conventional headphones. Headset 101 may also be separated
`into multiple physical components attached to each other using wired and/or wireless schemes (e.g.
`separate microphone or battery attached by a wire). Although represented here by distinct blocks for
`clarity, functional components of headset 101 may be combined into a single component (e.g.
`processor with on-board memory) and/or split
`into multiple components (e.g. multiple
`co-processors).
`U.S. Application Publication No. 2008/0113689 (“Bailey”), [0017]
`
`Rezvani-875 discloses a headphone assembly comprising an antenna for receiving wireless signals. For
`example, Rezvani-875 discloses antenna 210 and array of antennas 215 for receiving wireless signals.
`
`
`9
`
`[1(c)] an antenna for receiving
`wireless signals;
`
`Page 9 of 59
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`

`

`Claim
`
`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`[0020]
`
`
`[0040]
`
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`FIG. 2 illustrates the subsystems that support the various functionalities according to some
`embodiments. In these embodiments, the signals 205 received from the antenna 210, or array of
`antennas 215, through antenna interface 217 are processed by a MIMO RF system 220 and a
`baseband processor 225. The subsystems include an audio interface 227 having a microphone array
`227 having an input 228 and an output 229. The subsystems include control buttons 230 for the user
`interface 105 as well as voice recognition 155. And, a microprocessor 235 having a USB interface
`237 is present to perform the arithmetic, logic, and control operations for the various functionalities
`through the assistance of an internal memory 240.
`
`The headset may advantageously support simultaneous operation on the different wireless
`interfaces, such as for example simultaneous operation on at least two systems that may include
`Wifi (802.11a/b/g/n), Wimax, 3G cellular, 2G cellular, GSM-EDGE, radio (e.g. AM/FM/XM),
`802.15 (Bluetooth, UWB, and Zigbee) and GPS. These systems often operate at different
`frequencies and may require different antenna characteristics. The simultaneous operation over
`different frequencies can be done, for example, by using some set of antennas for one system and
`using another set of antennas for another system.
`
`FIG. 8 illustrates simultaneous operation over a cellular system and a Wifi system according to
`some embodiments. In these embodiments, a headset 805 having a plurality of antennas 810-1,
`810-2, 810-3, and 810-4 is able to connect to a wi-fi access point 820 via its one or more antennas
`830, 835 and to a cellular base station 840 via one or more base station antennas 850, 855. A voice
`over IP call handoff between a wi-fi and cellular connection may advantageously be implemented.
`Another mechanism to support this simultaneous multifrequency operation is time division. In
`addition to simultaneous operation, the handset can support seamless handoff between two systems.
`For example, the handset could switch a VoIP call from a wide-area wireless network such as
`Wimax or 3G to a local area network such as Wifi. FIG. 8 also illustrates the seamless handoff of a
`
`10
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`[1(d)] a wireless communication
`circuit connected to the antenna,
`wherein the wireless
`communication circuit is for
`receiving and transmitting wireless
`signals to and from the wireless
`headphone assembly;
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`VoIP call between a cellular and Wifi system.
`
`[0041]
`Rezvani-875 discloses a headphone assembly comprising a wireless communication circuit connected to
`the antenna, wherein the wireless communication circuit is for receiving and transmitting wireless signals
`to and from the wireless headphone assembly. For example, Rezvani-875 discloses antenna interface 217
`connected to the antenna 210 or array of antennas 215 and the MIMO RF system 220.
`
`
`[0020]
`
`[0038]
`
`FIG. 2 illustrates the subsystems that support the various functionalities according to some
`embodiments. In these embodiments, the signals 205 received from the antenna 210, or array of
`antennas 215, through antenna interface 217 are processed by a MIMO RF system 220 and a
`baseband processor 225. The subsystems include an audio interface 227 having a microphone array
`227 having an input 228 and an output 229. The subsystems include control buttons 230 for the user
`interface 105 as well as voice recognition 155. And, a microprocessor 235 having a USB interface
`237 is present to perform the arithmetic, logic, and control operations for the various functionalities
`through the assistance of an internal memory 240.
`
`“As shown in FIG. 2, the headset may have an optional power management algorithm that
`minimizes power consumption based on the usage of the handset…. For example these may be
`accomplished by utilizing multiple antennas (MIMO) in the most efficient way to minimize the
`power consumption required for wireless transmission….”
`
`11
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`
`
`FIG. 2 (showing antenna interface 217 connected to antenna 210 and array of antennas 215 and to MIMO
`RF system 220).
`
`At least the following prior art references further demonstrate that a POSA would have understood that
`MIMO RF system 220 disclosed in Rezvani-875 contains at least one MIMO RF transceiver, which is a
`wireless communication circuit for receiving and transmitting wireless (RF) signals to and from the
`wireless assembly.
`
`
`“[R]adio frequency (RF) block of a MIMO RF transceiver,”
`U.S. Patent Appl. Publ. No. 2006/0141950, [0003].
`
`
`“A conventional MIMO RF system includes a plurality of RF blocks respectively corresponding to
`pairs of input and output ports. Each of the RF blocks includes a serial programming interface (SPI)
`
`12
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`[1(e)] a processor in
`communication with the wireless
`communication circuit; and
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`and thus is controllable by an external central processing unit (CPU) or a controller using the SPI.”
`U.S. Patent Appl. Publ. No. 2006/0141950, [0006].
`Rezvani-875 discloses a headphone assembly comprising a processor in communication with the wireless
`communication circuit. For example, Rezvani-875 discloses microprocessor 235 and baseband processor
`225 in communication with the MIMO RF system.
`
`
`FIG. 2 illustrates the subsystems that support the various functionalities according to some
`embodiments. In these embodiments, the signals 205 received from the antenna 210, or array of
`antennas 215, through antenna interface 217 are processed by a MIMO RF system 220 and a
`baseband processor 225. The subsystems include an audio interface 227 having a microphone array
`227 having an input 228 and an output 229. The subsystems include control buttons 230 for the user
`interface 105 as well as voice recognition 155. And, a microprocessor 235 having a USB interface
`237 is present to perform the arithmetic, logic, and control operations for the various functionalities
`through the assistance of an internal memory 240.
`
`[0020]
`
`
`13
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`
`[1(f)] a rechargeable battery for
`powering the wireless headphone
`assembly,
`
`
`
`
`FIG. 2 (showing microprocessor 235 and baseband processor 225 in communication with the MIMO RF
`system).
`
`Rezvani-875 discloses a headphone assembly comprising a rechargeable battery for powering the wireless
`headphone assembly. For example, Rezvani-875 discloses a battery 270 for powering the wireless
`headphone assembly. It is rechargeable via solar cells 265 or charger 275.
`
`
`“The powers subsystems 250 include advanced power management 255 functionality to control
`energy use through power supplies 260. Solar cells 265 are also available to assist in sustaining the
`supply of power. The solar cells 265 can charge the battery 270 from ambient light as well as solar
`light. A battery charger 275 is included and can charge the battery, for example, through the input
`of a DC current 280.”
`
`14
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`[0021]
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`
`[1(g)] wherein the headphone
`assembly is configured, with the
`processor, to transition
`automatically from playing digital
`audio content received wirelessly
`by the headphone assembly via a
`first wireless network to playing
`digital audio content received
`wirelessly by the headphone
`
`
`FIG. 2 (showing battery 270 and battery charger 275).
`Rezvani-875 discloses a headphone assembly that is configured, with the processor, to transition
`automatically from playing digital audio content received wirelessly by the headphone assembly via a first
`wireless network to playing digital audio content received wirelessly by the headphone assembly via a
`second wireless network.
`
`For example, Rezvani-875 discloses a “seamless handoff” (i.e., automatic transition) where “the handset
`could switch [i.e., transition] a VoIP call [digital audio content] from a wide-area wireless network [a first
`wireless network] such as Wimax or 3G to a local area network [a second wireless network] such as Wifi.
`FIG. 8 also illustrates the seamless handoff of a VoIP call between a cellular and Wifi system.” [0041].
`Because “the handset” switches, a POSA would have understood the switching (transitioning) is done
`“automatically” because the handset executes the transition without user intervention. This is consistent
`
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`assembly via a second wireless
`network.
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`with the 155 patent’s disclosure that an example of automatic and seamless transitioning is “without user
`intervention.” 155 patent, 5:20-22 (“The earphone 10 and the data source 20 (e.g., the wireless network
`adapter 22) may include firmware, as described further below, that cause the components to make the
`transition to a common infrastructure wireless network 30 automatically and seamlessly, e.g., without user
`intervention.”).
`
`
`“Provided are methods and systems for hands free communication with a wearable
`telecommunication device configured to recognize a command associated with the audio message
`and executing the command by communicating wirelessly with at least one communication device
`or a mobile telecommunication system. The wearable wireless telecommunications headset
`includes a casing containing a speaker for receiving an audio message, a microphone for sending an
`audio message, transceiver and a processor programmed for voice recognition. Methods are
`provided for direct communication with a telecommunication system and also communicating with
`a telecommunications system via an intermediary local device.”
`Abstract
`
`
`“The headset 100 is capable of several applications 125, in addition to power management 130 to
`enhance battery life. The headset 100 supports Voice over IP (VoIP) 135 directly through any of
`the interfaces that allow it to connect to the Internet, as well as an audio subsystem 140 that
`includes several functionalities such as, for example, noise cancellation 145 (and beamforming)
`through microphone array processing 150, in addition to voice recognition 155 and MP3 support
`160. Multiple wireless systems may be integrated into the headset 100, including, but not limited to,
`GPS and different radio systems (AM/FM/XM) 165, various cellular phone standards
`(3G/2G/GSM/Edge and/or Wimax) 170, different Wifi standards (802.11a/b/g/n) 175, and 802.15
`(Bluetooth, Zigbee, and/or UWB) 180. In most embodiments, an antenna, or array of antennas,
`having antenna algorithms 185 is used as part of the wireless system or subsystems disclosed
`herein.”
`
`[0019]
`
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`
`
`[0041]
`
`
`[0050]
`
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`
`“FIG. 8 illustrates simultaneous operation over a cellular system and a Wifi system according to
`some embodiments. In these embodiments, a headset 805 having a plurality of antennas 810-1,
`810-2, 810-3, and 810-4 is able to connect to a wi-fi access point 820 via its one or more antennas
`830, 835 and to a cellular base station 840 via one or more base station antennas 850, 855. A voice
`over IP call handoff between a wi-fi and cellular connection may advantageously be implemented.
`Another mechanism to support this simultaneous multifrequency operation is time division. In
`addition to simultaneous operation, the handset can support seamless handoff between two systems.
`For example, the handset could switch a VoIP call from a wide-area wireless network such as
`Wimax or 3G to a local area network such as Wifi. FIG. 8 also illustrates the seamless handoff of a
`VoIP call between a cellular and Wifi system.”
`
`“Another mechanism to support this simultaneous multifrequency operation is time division. In
`addition to simultaneous operation, the handset can support seamless handoff between two systems.
`For example, the handset could switch a VoIP call from a wide-area wireless network such as
`Wimax or 3G to a local area network such as Wifi. FIG. 8 also illustrates the seamless handoff of a
`VoIP call between a cellular and Wifi system.”
`
`
`The headset of claim 29, further including means supporting simultaneous operation over two or
`more different wireless systems at the same or different frequencies is supported.”
`Claim 32.
`
`
`“The headset of claim 32, further including means for seamless handoff of an application between
`the two systems is supported.”
`Claim 36.
`
`17
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`IPR2021-00297
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`

`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas, No. 6:20-cv-00663-ADA
`
`Exhibit B-7 - Invalidity of ’155 Patent in view of U.S. Patent Appl. Publ. No. 2007/0165875
`
`Claim
`
`U.S. Patent Appl. Publ. No. 2007/0165875 (“Rezvani-875”)
`
`
`Rezvani, Fig. 8 (showing VoIP call handoff from a first network connecting the headset and a Wi-Fi access
`point and a second network connecting the headset and a cellular base station).
`
`At least the following prior art references further demonstrate that a POSA would have understood that a
`“seamless handoff,” as disclosed in Rezvani-875, is an automatic transition between different networks
`(e.g., without user intervention).
`
`
`“[H]andoff is the feature where a mobile phone moves from one radio connection to the next
`[while] maintaining a voice call or data connection with as little interruption as possible. When
`this interruption is not noticeable to the user the handoff is deemed ‘seamless.’”
`U.S. Patent Appl. Publ. No. 2005/0286466, [0037].
`
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`

`Koss Corporation v. Plantronics, Inc. and Polycom, Inc.
`Western District of Texas,