Appendix A
`
`Supplemental Disclosures Regarding § 103 Combinations
`
`And Motivations To Combine References
`
`1. Use Of Two Identical Earphones
`
`To the extent that a reference discloses a single wireless earphone, or discloses a system
`
`of wireless earphones, but does not disclose that both have the same form factor; or, to the extent
`
`that a reference discloses a system of wireless earphones, and one of which includes a
`
`transceiver, processor, antenna, speaker or transducer, microphone, and battery, but does not
`
`disclose explicitly that both include all such elements, it would have been obvious to a person of
`
`ordinary skill in the art to utilize a system of two earphones, identical in form factor, and each
`
`including a transceiver, processor, antenna, speaker or transducer, and microphone. As set forth
`
`below, multiple references taught (and multiple products available for sale and in public use
`
`comprised) a system of two wireless earphones identical in form factor and in internal
`
`components. A person of skill would have been motivated to apply this teaching in references
`
`that did not already embody it, because a person of skill would have recognized the advantages
`
`in a two-earphones system, including the ability to listen to music in stereo. A person of skill
`
`would further have known that a system in which both earphones used the same form factor and
`
`included the same essential components would have avoided the need to design and manufacture
`
`different earphones configurations within a single product, and would have allowed a user who
`
`forgets or misplaces either of the set of earphones to use the remaining earphone as a fully
`
`functional unit. A person of skill would have also found it obvious to try including the same
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`components in a second earphone that are already disclosed as included in a first earphone in a
`
`two-earphone system, and would have considered such an approach to be a natural starting point
`
`of their design in view of the disclosures already provided.
`
`Recognizing these advantages, a person of ordinary skill would have been motivated to
`
`combine the reference in question with the below references, which teach of earphone systems
`
`including two earphones of an identical form factor, or two earphones that each include a
`
`transceiver, processor, antenna, speaker or transducer, microphone, and battery include:
`
`• Rosener (U.S. Patent Publication No. 2008/0076489)
`
`Each of the first and second wireless earphones 502, 504 comprises a housing containing a
`speaker, an RF receiver or transceiver and a battery. The speaker may comprise, for example, a
`magnetic element attached to a voice-coil-actuated diaphragm, an electrostatically charged
`diaphragm, a balanced armature driver, or a combination of one or more of these transducer
`elements. As explained in detail below, the receiver or transceiver of each of the first and second
`earphones 502, 504 is operable to communicate with one or more external data or audio data
`devices (e.g., a cellular telephone, PDA, MP3 player, CD player, radio, personal computer,
`game console, etc.) over one or more wireless links. Each of the first and second
`earphones 502, 504 may be in the form of an earbud designed to fit into the concha of the pinna
`of the user's ear; a canalphone, which can be fitted within the ear canal of the user's ear; an
`over-the-ear circum-aural type headphone; or any other suitable configuration that may be
`attached to, worn on, or fitted within the user's ear. Each of the first and second
`earphone 502, 504 may further include a clip, earloop, or other suitable securing mechanism to
`help maintain the earphone 502 or 504 on the ear of the user. Either or both of the first and
`second earphones 502, 504 may further be coupled to a second data or audio data source such
`as, for example, a sensor or a microphone for capturing sound waves generated by the
`user's 500 voice.
`
`[0030.]
`
`
`• Chiloyan (U.S. Patent Publication No. 2007/0147629)
`
`Phone 901 may include an antenna 902 for a wireless communication link between the phone
`901 and a headset 903 during monaural use, and which may communicate with a second headset
`904 for binaural use. Second headset may be the earpiece described above, or it may be a
`separate, duplicate version of earpiece 903. Headsets 903, 904 may each wirelessly
`communicate with phone 901 to obtain necessary data and signals for separate audio channels. .
`.. When two headsets 903, 904 are used in a telephone call, the microphones on each headset
`
`2
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`may be used as dual directional microphones, to help reduce noise encountered in a telephone
`call.
`
`[0038, 0039; see FIGS. 9, 11.]
`
`2. Elongated Body Portion
`
`To the extent that a reference discloses a wireless earphone system, but does not disclose
`
`that the earphones may be implemented in a form factor that includes an elongated portion
`
`extending downwards when the earphone is worn, the implementation of the disclosed earphones
`
`in such a form factor would have been obvious to a person of ordinary skill in the art. A person
`
`of skill would have known that many different commercially available earphone systems utilized
`
`an elongated form factor, including earphones or headpieces to allow users to wirelessly
`
`participate in telephone calls or video conferences, or to speak over a radio link. A person of skill
`
`would have recognized advantages in using such a form factor in a system of earphones that
`
`were designed to allow the wearer to listen to music from a digital audio player. For instance, a
`
`person of skill would have recognized that the elongated form factor allowed for an easier and
`
`more effective layout of the relevant electrical components, including by providing a larger space
`
`in which to locate a power source, such as a battery, and by providing an elongated axis for an
`
`antenna to extend along, thus improving the performance of the antenna. Further still, if the
`
`reference disclosed that the earphones included a microphone, as was known to be advantageous
`
`to allow the earphones to be used with a cellular phone to place voice calls, and to allow the
`
`earphones to transmit voice commands, the person of skill would have understood that the
`
`elongated portion allowed for an advantageous placement of the microphone by allowing it to be
`
`placed in front of the ear and oriented towards the user’s mouth. A person of skill would have
`
`also recognized that the elongated form factor would make it easier for a user to insert and
`
`remove the earphones or headpieces by providing her with an element that could be readily
`
`3
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`grasped. A person of skill would have also considered it obvious to try an elongated body portion
`
`because it was one of a finite number of possible configurations already known in the art.
`
`Recognizing these, and other, advantages, a person of skill would have been motivated to
`
`combine the reference in question with one or more of the following, each of which teach
`
`earphones with an elongated form factor:
`
`•
`
` Rosener (U.S. Patent Publication No. 2008/0076489)
`
`[FIG. 5.]
`
`
`[FIG. 9.]
`
`
`• Chiloyan (U.S. Patent Publication No. 2007/0147629)
`
`
`
`
`
`4
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`• Huddart (U.S. Patent Publication No. 2008/0076489)
`
`[FIG. 6.]
`
`
`
`
`• Hupkes (U.S. Patent Publication No. 2008/0279409)
`
`[FIG. 5.]
`
`3. Ear Canal Portion
`
`
`
`
`
`To the extent that a reference discloses a wireless earphone system, in which a speaker is
`
`placed in proximity to a user’s ear, but does not disclose that the earphones may include a
`
`portion that is inserted into the user’s ear canal, including such an element in the earphone
`
`system would have been obvious to a person of ordinary skill the art. A person of skill would
`
`have known that, as taught by multiple references and evidenced by commercially-available
`
`products, earphones typically utilized one of a small number of form factors, including over-ear,
`
`next-to-ear, and in-ear, the latter of which was known to extend into the user’s ear canal. A
`
`person of skill would have known that the next-to-ear and in-ear form factors could be chosen
`
`5
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`between without need to significantly modify the nature, size, or arrangements of the earphone’s
`
`internal components. Further still, a person of skill in the art would have understood that an in-
`
`ear design, which extended into the user’s ear canal, provided certain design advantages,
`
`including using friction between the in-ear portion and the ear to hold the earphone in place
`
`without the need for mechanical restraints or hooks, and enabling a snug fit that more easily
`
`excluded ambient noise. Given these advantages, and the limited number of general form factors
`
`available, a person of skill presented with teachings about an earphone system that used next-to-
`
`ear speaker elements would have found it obvious to try an in-ear design, in which a portion of
`
`the earphone extends into the ear canal, and would have been able to do so with a minimum of
`
`experimentation and re-design.
`
`Recognizing these, and other, advantages, a person of skill would have been motivated to
`
`combine the reference in question with one or more of the following, each of which teach
`
`earphones with a portion that extends into the user’s ear canal when worn:
`
`• Rosener (U.S. Patent Publication No. 2008/0076489)
`
`The first and second data sinks in exemplary embodiments described herein comprise audio data
`sinks, e.g., left-ear and right-ear earphones (e.g., earbuds or canal-phones), left-ear and right-
`ear circum-aural over-the-ear headphones, stereo speakers, speakers for a surround sound
`system, etc.
`
`[0011.]
`
`Each of the first and second earphones 502, 504 may be in the form of an earbud designed to fit
`into the concha of the pinna of the user’s ear; a canalphone, which can be fitted within the ear
`canal of the user’s ear; an over-the-ear circum-aural type headphone; or any other suitable
`configuration that may be attached to, worn on, or fitted within the user’s ear.
`
`[0030.]
`
`6
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`• Hupkes (U.S. Patent Publication No. 2008/0279409)
`
`
`
`[FIG. 5.]
`
`Turning now to FIGS. 4 and 5, the earpiece speaker system 40 is shown equipped with an in-ear
`speaker module 80. The in-ear speaker module 80, when properly worn, extends at least
`partially into an ear canal of a user.
`
`[0034.]
`
`As will be appreciated, the speaker module 80 includes an ear canal insert tip 88 (e.g., ear
`rubber) that is insertable at least partially into an ear canal of a user. The ear canal tip 88 is
`typically made of a soft and/or flexible material, such [as] silicone or rubber, to provide a snug
`yet comfortable fit when the time is inserted into the ear canal.
`
`[0037.]
`
`
`• Zellner (U.S. Patent No. 8,180,078)
`
`FIG. 3A shows one example of an earbud 302. This earbud 302 has a form factor similar to a
`hearing aid, where the earbud 302 may rest partially within the ear canal.
`
`(4:31-33.)
`
`4. Earphones Containing A Baseband Processor
`
`
`To the extent that a reference discloses a set of wireless earphones, but does not disclose
`
`that each earphone includes a baseband processor, the presence of such a baseband within the
`
`earphones would have been obvious to a person of ordinary skill in the art. Further, to the extent
`
`a reference also discloses that the earphone is capable for transmitting signals wirelessly, a
`
`person of ordinary skill would have understood such a reference to necessarily disclose a
`
`7
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`baseband processor as Koss has interpreted the term, as such a processor would be needed to
`
`modulate the wireless signals that the earphone would need to transmit.
`
`As a person of skill would have recognized, baseband processors were an ordinary and
`
`conventional part of wireless communications circuits and were used to manage the transmission
`
`and receipt of data over the radio interface provided by the wireless communication circuit. A
`
`person of skill would thus have found it obvious that the wireless communication circuits
`
`included in a set of earphones would include a baseband processor. To the extent that a
`
`motivation to come to such an understanding would have been necessary, the person of skill
`
`would have recognized that wireless communications processors require the ability to process the
`
`data being sent to and from their RF interfaces in order to function and would, thus, have been
`
`motivated to include a baseband processor as such processors were the known and conventional
`
`means of controlling the processing of such data.
`
`Recognizing these, and other, advantages, a person of skill would have been motivated to
`
`combine the reference in question with one or more of the following, which teach the use of
`
`baseband processors within the wireless communications circuits of earphones:
`
`• Rosener (U.S. Patent Publication No. 2008/0076489)
`
`FIG. 6 is a diagram showing a wireless system 600 that may be used to wirelessly transmit data
`signals to first and second data sinks 602, 606, in accordance with an embodiment of the present
`invention. According to this and other exemplary embodiments of the invention, the data signals
`may comprise audio data signals, and the first and second data sinks may correspond to the first
`and second earphones 502, 504 in FIG. 5. The first data sink 602 is electrically coupled to a
`first radio frequency (RF) receiver 604 and the second data sink 606 is electrically coupled to a
`second RF receiver 608.
`. . .
`According to an aspect of the invention, the baseband portion of the first and second RF
`transmitters 610,614 in the embodiment of the invention shown in FIG. 4, as well as in other
`embodiments in this disclosure, process and configure the incoming data from the data source
`618 into data packets compliant with the Bluetooth radio standard. [0032, 0034]
`
`
`8
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`[FIG. 7A.]
`
`
`• Rahman (U.S. Patent Publication No. 2010/0151788)
`
`
`
`FIG. 7 is a block diagram of an architecture 700 including software components for a headset
`that may be used as part of the inventive headset and gateway system, in accordance with some
`embodiments of the present invention. As shown in the figure, a radio 702, a Baseband and Link
`Controller 704, a Link Manager Protocol 706, and an MMU 708 are run by chipset 604 of FIG.
`6. Radio 602, and Baseband and Link Controller 604 receive incoming audio signals 730.
`
`[0087.]
`
`
`
`[FIG. 7.]
`
`
`
`
`9
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`5. Earphones Containing A Rechargeable Battery or Power Source
`
`
`To the extent that a reference discloses a set of wireless earphones, but does not disclose
`
`that each earphone includes a rechargeable power source, such as a battery, the use of such
`
`batteries within the earphones would have been obvious to a person of ordinary skill in the art.
`
`As a person of skill would have recognized, numerous references disclosed, and numerous
`
`commercially available headsets used, such rechargeable power sources. A person of skill would
`
`have recognized that the use of rechargeable batteries included numerous advantages, including
`
`eliminating hassle, cost, and environmental impact from discarding and replacing non-
`
`rechargeable batteries, and the need to design the earphones to conform to the form factors of
`
`standard, commercially-available non-rechargeable batteries. A person of skill in the art would
`
`have also recognized that rechargeable batteries were commonly used and routinely preferred for
`
`the devices that communicate with the earphones, such as mobile phones and MP3 players,
`
`which would further motivate a person of skill to use rechargeable batteries for the earphones.
`
`Recognizing these, and other, advantages, a person of skill would have been motivated to
`
`combine the reference in question with one or more of the following, which teach the use of
`
`rechargeable batteries in a set of earphones:
`
`• Huddart (U.S. Patent No. 7,627,289)
`
`Headset 4 also includes typical components found in a communication headset. For example,
`headset 4 includes a speaker 36, a microphone 34, a user interface, and status indicator. . .. The
`headset 4 further includes a power source such as a rechargeable battery installed within the
`housing to provide power to the various components of the receiver.
`
`(4:62-5:12.)
`
`Wireless earbud 6 also includes a power source such as a rechargeable battery and a controller
`comprising a processor, memory and software to implement functionality as described herein.
`
`(5:26-29.)
`
`
`10
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`• Rutschman (U.S. Patent Publication No. 2008/0226094)
`
`The battery 70 can be a replaceable, rechargeable battery for powering the primary earpiece 12.
`The battery charger circuit 72 may be a commercially-available battery charger circuit having
`an external jack that permits the battery 70 to be recharged using an AC wall adapter.
`
`[0051.]
`
`The battery 116 can be a replaceable, rechargeable battery for powering the secondary earpiece
`14. The battery charger circuit 118 may be a commercially-available battery charger circuit
`having an external jack that permits the battery 116 to be recharged using an AC wall adapter.
`
`[0059.]
`
`6. Earphones Containing A “Passively” Rechargeable Battery or Power Source
`
`To the extent that a reference discloses a set of wireless earphones, but does not disclose
`
`that each earphone includes a power source that is “passive” and is rechargeable wirelessly, the
`
`use of such a source would have been obvious to a person of skill in the art. As set forth above, a
`
`person of skill would have found it obvious to include a rechargeable power source in each
`
`earphone in a system of earphones. It is unclear precisely what meaning Koss attaches to the
`
`term “passive, wirelessly rechargeable power source,” and Koss has not served infringement
`
`contentions that map this element to anything in the accused product. Nevertheless, to the extent
`
`that Koss interprets this limitation to require that the power source be recharged without forming
`
`a direct electrical connection between the power source in the earphones and the external power
`
`supply, it would have been obvious to a person of ordinary skill in the art to use such a
`
`configuration. The use of induction chargers was known in the art, and such chargers were one
`
`of a finite number of known ways to recharge power sources located within electronic devices.
`
`A person of skill in the art would thus have been motivated to try the use of a “passive” charger
`
`in such a system, and would have recognized that the use of such passive charging would have
`
`avoided the need to design electrical charging contacts into the exterior of the earphones, thus
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`allowing for greater flexibility in design, an elimination of contacts that could become degraded
`
`or corroded, which would impair the ability of the user to recharge her earphones, and the ability
`
`of the user to recharge her earphones without placing them in a particular configuration.
`
`Recognizing these, and other, advantages, a person of skill would have been motivated to
`
`combine the reference in question with one or more of the following, which teach the use of
`
`passively chargeable power sources under Koss’ apparent construction:
`
`• Huddart (U.S. Patent No. 7,627,289)
`
`In a further example, the charger/carrier utilizes a charging coil to provide charging current to
`the wireless earbud battery 84 via receive aerial 52 shown in FIG. 4. The earbud
`advantageously does not require charging contacts on its small exterior surface when charging
`is performed with inductive charging. In this example, the single receive aerial 52 functions
`multiply to receive charging power for battery 84, generate a wake up signal 82, or receive an
`audio signal carrier. An on/off user interface and charging contacts are therefore not required
`on the wireless earbud. In a further example, the charging coil of the charger/carrier is used to
`charge the battery of the headset as well. Inductive charging systems are discussed in the patent
`application “Inductive Charging System”, application Ser. No. 10/882,961, filed Jul. 1, 2004
`and assigned to the present applicant Plantronics, Inc., which is hereby incorporated by
`reference.
`
`(8:35-50.)
`
`7. Use Of Docking Station To Charge Earphones
`
`
`To the extent that a reference discloses a set of earphones that are internally powered, and
`
`either discloses or renders obvious that the power source used therein is rechargeable, but does
`
`not disclose that the earphones in question would be charged using a docking station that is
`
`connected to an external power source using a wire, the use of such a docking station would have
`
`been obvious to a person of ordinary skill in the art. As a person of skill would have appreciated,
`
`the use of docking stations to charge small electronic devices, including headsets and earphones,
`
`was well-known and described in numerous references and used in numerous commercial
`
`products at the relevant time. A person of skill would have known that there were only a limited
`
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`set of ways through which the power supply of a set of earphones could be replaced, including
`
`through the use of a docking station-based charge, and would thus be motivated to try a docking
`
`station for charging purposes in any earphone system that required a charging mechanism. A
`
`person of skill would have been motivated to apply teachings regarding the use of a docking
`
`station-based charger to reference that teaches wireless earphones to allow for a way to recharge
`
`the headphones’ power source using conventional techniques. Further still, the use of a docking
`
`station to hold the earphones while charging was known to provide advantages including holding
`
`the earphones in the proper configuration to ensure that they properly contacted the charging
`
`configuration, and avoiding the user losing or mislaying the headphones when they were not in
`
`use.
`
`Recognizing these, and other, advantages, a person of skill would have been motivated to
`
`combine the reference in question with one or more of the following, which teach the use of
`
`docking stations (with power wires) to recharge a set of earphones:
`
`• Huddart (U.S. Patent No. 7,627,289)
`
`The headset system may further include a charger/carrier, such as a pocket charger, including a
`small plastic storage case for storing the headset 4 and wireless earbud 6 for protection and
`charging. The pocket charger includes a battery and charger circuit for charging both the
`headset battery and wireless earbud battery when inserted into the pocket charger/carrier.
`. . .
`The headset system may further include a primary charger to which the pocket charger may be
`removably attached. The primary charger may be a cable or docking facility connecting the
`pocket charger/carrier to a wall outlet or primary batter such as a car battery, allowing the
`headset battery, wireless earbud battery, and the storage case battery to be charged using the
`wall outlet or primary battery. (8:25-31, 8:51-57.)
`
`8. Transitioning Between Audio Sources
`
`
`To the extent that a reference discloses a set of wireless earphones that can connect to
`
`different wireless sources, such as MP3 players, telephones, computers, or other devices, but
`
`does not explicitly disclose that the earphones can transition their audio connection between
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`devices, such a transition would have been obvious to a person of ordinary skill in the art. As set
`
`forth below, multiple references taught earphones that switched between sources in this way. A
`
`person of skill would have understood that allowing earphones to switch between audio sources
`
`would have been beneficial in that it would allow a user to seamlessly continue to use her
`
`earphones if she was interrupted during a listening session, for instance if she was listening to
`
`music and a telephone call came in. As a person of skill would appreciate, this type of transition
`
`would increase the convenience to the user by allowing her to switch between audio sessions
`
`without removing her earphones and switching to a different pair. Additional information
`
`regarding transitioning of earphones between audio sources may be found in Section 12, below.
`
`Recognizing these, and other, advantages, a person of skill would have been motivated to
`
`combine the reference in question with one or more of the following, which teach earphones that
`
`are capable of switching between audio sources:
`
`• Chiloyan (U.S. Patent Publication No. 2007/0147629)
`
`The user could use phone 901 and headset 903 for a monaural call and when finished, the user
`could bring in second headset 904, and an MP3 player 905 as a separate device, and headsets
`903, 904 would transition their communications from phone 901 to the MP3 player.
`
`[0038, 0039; see FIGS. 9, 11.]
`
`9. Transmission Of Communications Based On User Utterances
`
`To the extent that a reference discloses a set of wireless earphones that includes a
`
`microphone, but does not disclose that that microphone can be used for transmitting a
`
`communication based on user speech, including that capability would have been obvious to a
`
`person of ordinary skill in the art. To the extent it is the communication (rather than the
`
`transmission) that is based on user speech, a person of skill in the art would have found it
`
`obvious to enable such communication. A person of skill would have known that “walkie-talkie”
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`functionality was very well-known in the art as a means to broadcast voice messages to other
`
`nearby listening devices.
`
`To the extent it is the transmission (rather than the communication) that is based on user
`
`speech, such functionality would have been obvious to include. As persons of skill knew, voice-
`
`response systems were well-known in the field, and were typically used to allow individuals to
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`issue basic commands to a system, such as to turn a device on or off, start or stop playback of
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`sound, and the like. A person of skill would have realized that a set of wireless earphones would
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`include the essential hardware needed to support detecting user utterances, including a
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`microphone and processor, and that the earphones would be well positioned to use their
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`microphone to detect user speech, as they would be positioned proximate to the user’s head when
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`in use. A person of skill would have been motivated to include the ability to recognize or
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`process utterances of a user in a set of earphones so that the user of the earphones could control
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`features without having to physically manipulate the earphones or an attached device. This
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`would allow the user to control her audio playback session even when her hands were occupied
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`with other tasks, and would also avoid the need to build user-interface controls onto the earbuds
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`themselves, simplifying their design. Further still, a person of ordinary skill in the art would
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`have recognized that it would have been advantageous for the system to be able to initiate
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`communications over a Bluetooth link to an associated device because certain features, such as
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`stopping and starting playback, rewinding, etc., may be controlled only by that device.
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`Recognizing these, and other, advantages, a person of skill would have been motivated to
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`combine the reference in question with one or more of the following, which teach earphones that
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`process utterances of the user and transmit a communication wirelessly as a result:
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`Koss v. Apple; Case No. 6:20-cv-00665-ADA; Appendix A to Apple’s Invalidity Contentions
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`• Rahman (U.S. Patent Publication No. 2010/0151788)
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`Thus, in some embodiments, the headset is configured to have a voice based interface to the
`audio or voice gateway to enable the headset to control the access of data from the gateway or a
`connected device, and to translate that data into an audio stream that is sent to the headset and
`heard by the user. In such an embodiment, a physical interface (such as a keypad or control
`buttons) would not be required to issue commands and receive a response. Instead, voice
`commands are used to control and navigate the functions or operations of an application
`installed on the gateway or on a server coupled to the gateway by means of a communications
`network.
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`[0031.]
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`As shown at path 1, a voice command may be issued from a headset 906 through a voice or
`audio gateway (which will be described in greater detail with reference to the other figures) to a
`communications network 908. . .. An example is a request for streaming music from a back-end
`library, a music library located in the home, etc.
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`[0051.]
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`
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`10. Initiating Transmission Of Requests To Server And Receipt Of Response
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`To the extent that a reference discloses a set of wireless earphones that includes a
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`wireless communication unit, but does not disclose that that unit can be used for initiating
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`requests to, and receiving responses from, a server, including that capability would have been
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`obvious to a person of ordinary skill in the art. A person of skill would have been motivated to
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`Koss v. Apple; Case No. 6:20-cv-00665-ADA; Appendix A to Apple’s Invalidity Contentions
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`include this functionality for multiple reasons. First, the presence of streaming media servers,
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`from which audio content could be accessed, was well-known, and permitting a set of
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`headphones to initiate commands to such a server would have allowed a user of the headphones
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`to access functionality related to such streaming audio, such as stopping playback, skipping to a
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`new song, or the like, without having to actuate controls on a different device. Second, as set
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`forth above, voice-recognition and voice-command systems were well-known, and including
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`within a set of earphones the ability to issue commands that could initiate transmission of a
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`request to a server would greatly broaden the set of services that could be accessed through such
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`voice recognition, to include web services such as searches and the like. Third, a person of skill
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`would recognize that earphones that are capable of communicating wirelessly via Wi-Fi would
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`already possess the hardware needed to communicate with a streaming media server via IP
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`protocols. Further, a person of skill in the art would recognize that such earphones that are
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`already disclosed as capable of communicating via the Internet could be readily programmed to
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`communicate with a streaming server over the Internet. Finally, a person of skill would have
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`recognized that allowing a headset to initiate the transmission of requests to a remote server
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`would allow it to operate as a telephony headse