`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`VOLKSWAGEN GROUP OF AMERICA, INC., SUBARU OF AMERICA, INC.,
`and VOLVO CAR USA, LLC
`Petitioner
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`v.
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`STRATOSAUDIO, INC.,
`Patent Owner
`____________________
`IPR2021-007211
`U.S. Patent No. 8,166,081
`____________________
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`PETITIONER VOLKSWAGEN GROUP OF AMERICA, INC.’S
`SUPPLEMENTAL BRIEFING
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`1 Subaru of America, Inc. and Volvo Car USA, LLC (IPR2022-00203) have
`been joined as petitioners in this proceeding.
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`Case IPR2021-00721
`U.S. Pat. No. 8,166,081
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`I.
`II.
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`TABLE OF CONTENTS
`Introduction ...................................................................................................... 1
`Responses to the Board’s Questions ................................................................ 3
`A. Question 1 .............................................................................................. 3
`B.
`Question 2 .............................................................................................. 4
`C.
`Question 3 .............................................................................................. 4
`D. Question 4 .............................................................................................. 5
`E.
`Question 5 .............................................................................................. 6
`F.
`Question 6 .............................................................................................. 8
`G. Question 7 .............................................................................................. 9
`H. Question 8 ............................................................................................11
`I.
`Question 9 ............................................................................................12
`J.
`Question 10 ..........................................................................................14
`III. Conclusion .....................................................................................................14
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`I.
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`Case IPR2021-00721
`U.S. Pat. No. 8,166,081
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`INTRODUCTION
`Petitioner thanks the Board for the opportunity to clarify the scope of claim
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`9 and the dispute regarding the first and second receiver modules and their
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`relationship to the output system. At the outset, Petitioner reiterates three important
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`points from its earlier papers that serve as the foundation for Petitioner’s responses
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`to all ten questions posed in the Board’s August 15 Order.
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`First, there is no dispute that the term “module” in claim 9 refers to “logical
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`modules,” and that such logical modules “may be combined with other modules or
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`divided into sub-modules.” EX1001, 6:47-7:8; Pet. Reply, Paper 31, 6-10; Sur-
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`Reply, Paper 36, 2. The ’081 patent also explains that its modules may include
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`logic embodied in “a collection of software instructions, possibly having entry
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`and/or exit points.” Pet. Reply, 6-10 citing EX1001, 6:47-7:8. Accordingly, the
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`“first receiver module” and “second receiver module” of claim 9 can reside within
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`a single device and can include separate or overlapping “logical modules.” Id., 6-
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`10.
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`Second, the phrase “an output of the first receiver module or the second
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`receiver module” in claim 9 merely refers to a logical association between the
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`output and the first or second receiver module. Id., 6-7, 11-12; Pet., Paper 1, 4-6.
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`Such a conclusion is the natural result of the first and second receiver modules
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`being logical modules, potentially including combined modules or sub-modules.
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`Pet. Reply, 6-7 citing EX1001, 6:47-7:8. Therefore, for an output to be “of the first
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`receiver module or the second receiver module,” the output simply needs to have a
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`logical association with the first or second receiver module, an example of which
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`would be the output receiving media content via one or more “exit points” of the
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`logical module(s) making up the first or second receiver module. Id.; Pet., 4-6.
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`Third, the claimed “output system configured to present concurrently the
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`first media content and the second media content on an output of the first receiver
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`module or the second receiver module” can be satisfied in any one of three
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`different ways. Pet. Reply, 11-12, 16, 25. The use of “or” in this phrase indicates
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`that claim 9 is satisfied under any of the following scenarios: (1) an output
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`associated with the first receiver module concurrently outputs both the first and
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`second media content; (2) an output associated with the second receiver module
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`concurrently outputs both the first and second media content; or (3) an output
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`associated with the first receiver module outputs the first media content
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`concurrently with an output associated with the second receiver module outputting
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`the second media content. Id. To be clear, “the claimed ‘output system’ need only
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`output the first and second media content on a single output to be satisfied.” Id.,
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`11.2 Contrary to Patent Owner’s arguments, claim 9 does not require “a first
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`‘output’ of the ‘first receiver module’ and a second ‘output’ of the ‘second receiver
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`module.’” Order, Paper 47, 5 citing POR, Paper 27, 31.
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`II. RESPONSES TO THE BOARD’S QUESTIONS
`A. Question 1
`Would a single device housing the recited “first receiver module” and
`“second receiver module” fall within the scope of claim 9?
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`Yes. It is undisputed that a single device housing the first and second
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`receiver module would fall within the scope of claim 9. Pet. Reply, 6-10 citing
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`EX1015, 95:16-18; Sur-Reply, 2. As explained in the Petitioner Reply, the ’081
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`patent’s specification recites several instances of a single device housing the first
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`and second receiver modules. Pet. Reply, 6-10, 12 citing EX1001, FIGS. 1B, 1C,
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`3, 4A, 4:50-63, 14:40-46; 14:63-15:3, 22:45-23:35. Additionally, the first and
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`second receiver modules can be implemented within a single device housing in the
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`2 Patent Owner contends that Petitioner “conceded at oral argument, claim 9
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`requires outputs of both the first and second receiver modules.” Supplemental
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`Brief, Paper 49, 5, 12. Petitioner makes no such concession. Instead, as evidenced
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`by Petitioner’s papers, the prior art applied in this proceeding, and the statements
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`reiterated herein, claim 9 is satisfied when the first and second media content are
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`output “on a single output.”
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`form of separate or overlapping “logical modules” and fall within the scope of
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`claim 9. Id., 7.
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`B. Question 2
`Would a “first receiver module” or a “second receiver module” having
`more than one output fall within the scope of claim 9?
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`Yes. Claim 9 broadly encompasses, but is not limited to, the scenario of
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`either the first or second receiver module having more than one output. Pet. Reply,
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`6-7, 11-12, 16, 25. As previously explained, the claimed receiver modules are
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`separate or overlapping “logical modules.” Id. And for a receiver module to
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`“hav[e] more than one output” as provided in Question 2, the receiver module
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`merely needs to be logically associated with—e.g., provide received media content
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`to—more than one output. Id. So, in the scenario posed in Question 2, the first (or
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`second) receiver module may receive first media content (or second media content)
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`having both an audio and visual component, which it may then provide to an audio
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`output (e.g., speakers) and a visual output (e.g., display), respectively. Id., 11-12.
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`Such a scenario falls within the scope of claim 9. Id.
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`C. Question 3
`Would an output system configured to present a “first media content”
`on a first output of a “first receiver module” while concurrently
`presenting a “second media content” on a second output of the “first
`receiver module” fall within the scope of claim 9?
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`Yes. As previously explained, claim 9 broadly encompasses a first receiver
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`module being logically associated with—e.g., providing received media content
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`to—more than one output. Pet. Reply, 6-7, 11-12, 16, 25. For example, a first
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`receiver module may be logically associated with both an audio output (e.g.,
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`speakers) and a visual output (e.g., display). Id., 11-12. In the scenario of Question
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`3, audio content (“first media content”) received by the “first receiver module”
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`may be provided to the audio output, and visual content (“second media content”)
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`received by a “second receiver module” may be provided to the visual output. In
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`this case, the first and second receiver modules may share overlapping logical
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`components and outputs. Id., 6-7, 11-12, 16, 25. The visual output would therefore
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`be logically associated with—capable of receiving media content from—the first
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`receiver module and second receiver module. Id., 11-12. Such a scenario falls
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`within the scope of claim 9. Id.
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`D. Question 4
`Assume primary device 4 depicted in Figure 3 of the ’081 Patent
`contains a “first receiver module” and a “second receiver module.”
`Also assume the “first receiver module” and the “second receiver
`module” of primary device 4 each have two outputs. Would such a
`device fall within the scope of claim 9 if its output system was
`configured to present a “first media content” on the first output of the
`“first receiver module” while concurrently presenting a “second media
`content” on the second output of the “first receiver module”?
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`Yes. As previously explained, claim 9 is satisfied when a single receiver
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`module is associated with two outputs capable of concurrently presenting the first
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`and second media content. Pet. Reply, 6-7, 11-12, 16, 25. Therefore, the same
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`would hold true for the scenario of Question 4 where two receiver modules are
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`each associated with two outputs capable of concurrently presenting the first and
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`second media. Importantly, however, while the scenario of Question 4 would fall
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`within the scope of claim 9, such a scenario is not disclosed anywhere in the ’081
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`patent. That is, the ’081 patent does not disclose, in FIG. 3 or anywhere else, any
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`device (including primary device 4) having four outputs. Id., 6-12. Such a scenario
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`would therefore lack written description support. As such, claim 9 should in no
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`way be limited to the scenario of Question 4.
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`E. Question 5
`Please identify where in the substantive papers you argued that
`Mackintosh does, or does not, disclose a “first receiver module” and a
`“second receiver module,” and provide a brief summary of the
`evidence of record you cited in support of those arguments.
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`Petitioner has provided two instances of the first and second receiver
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`modules in its papers. First, as explained in the Petition, Mackintosh’s computer
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`702 discloses the claimed “first receiver module.” Pet., 23-25 citing EX1004, FIG.
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`7, FIG. 12, 12:18-22, 21:56-67. Specifically, Mackintosh’s computer 702 is
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`“configured to receive (i) ‘broadcast material’ (audio data), which corresponds to
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`the claimed ‘first media content,’ and (ii) ‘program data,’ which corresponds to the
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`claimed ‘data enabling the identification of a specific instance of the first media
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`content from a first broadcast medium.’” Id., 25. The Petition also explains that
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`Mackintosh’s communications interface 724 corresponds to the “second receiver
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`module.” Id., 32; see also id., 23-25 citing EX1004, 24:55-25:4. Specifically,
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`communication interface 724 “allows software and data to be transferred between
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`computer system 702 and external devices,” including “the relevant supplemental
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`materials.” Pet., 24 citing EX1004, 24:55-58; see also id., 25-26 citing EX1004,
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`3:19-26; 5:36-42; 5:50-54; 5:59-6:2; 7:16-20; 8:40-55; 9:7-59; 10:4-16; 21:13-25 .
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`Additionally, in response to the erroneous claim constructions raised in
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`Patent Owner’s Response requiring the first and second receiver modules to be
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`“separate and distinct,” Petitioner also explained that Mackintosh depicts separate
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`and distinct receiver modules in the form of received broadcast module 404 and
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`get-data module 414. Pet. Reply, 14-15. Specifically, received broadcast module
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`404 is “configured to receive a broadcast,” and get-data module 414 “retrieves
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`information pertaining to supplemental materials.” Id., 15 citing EX1004, 20:3-22.
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`Therefore, Mackintosh’s received broadcast module 404 discloses the “first
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`receiver module” while get-data module 414 discloses the “second receiver
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`module.” Id. Patent Owner has also acknowledged that these modules are
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`“separate” from each other. Sur-Reply, 11.
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`F. Question 6
`Please identify where in the substantive papers you argued that
`Mackintosh does, or does not, disclose an output system configured to
`present concurrently a “first media content” and a “second media
`content” on an output of a “first receiver module,” and provide a brief
`summary of the evidence of record you cited in support of those
`arguments.
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`Again, Petitioner has provided two instances in its papers of an output
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`system presenting concurrently a “first media content” and a “second media
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`content” on an output of a “first receiver module.” First, as explained in the
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`Petition and above, Mackintosh’s computer 702 discloses the claimed “first
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`receiver module.” Pet., 23-25 citing EX1004, FIG. 7, FIG. 12, 12:18-22, 21:56-67.
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`Additionally, Mackintosh’s “broadcast material, including audio and program
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`data” corresponds to the “first media content,” and Mackintosh’s “supplemental
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`materials” correspond to the claimed “second media content.” Id., 22-23 citing
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`EX1004, 8:40-49, 9:48-50, 12:18-22, 21:56-67; see also id., 25, 29-31 citing
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`EX1004, 23:26-24:4. Mackintosh’s computer 702 also includes “player” software
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`“configured to receive the [broadcast] stream … and play the audio component
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`thereof through speakers or the like …,” and “displays the supplemental materials
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`to the user.” Pet., 36 citing EX1004, 21:56-67, 22:13-23:6; EX1003, ¶91.
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`Mackintosh’s speakers and display are output(s) of an “output system” that are
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`logically associated with—e.g., output media content
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`received
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`from—
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`Mackintosh’s computer 702 (“first receiver module”). Id., 23 citing EX1004,
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`12:18-22, 21:56-67; see also id., 29 citing EX1004, 23:26-24:4.
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`The player software on Mackintosh’s computer 702 also provides the
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`supplemental materials (“second media content”) “in conjunction with the
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`broadcast materials” (“first media content”). Id., 17, 26 citing EX1004, 2:57-62,
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`10:32-33, 22:55-60. Specifically, the computer’s speakers present the audio
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`broadcast while the computer’s display concurrently presents the supplemental
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`materials visually. Id., 36-38 citing EX1004, FIG. 12, 21:56-67, 22:13-23:6.
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`Additionally, in response to the erroneous claim constructions raised in
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`Patent Owner’s Response, Petitioner explained that Mackintosh’s received
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`broadcast module 404 also discloses the claimed “first receiver module.” Pet.
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`Reply, 14-15 citing EX1004, FIG. 8, 19:59-20:22. Petitioner also explained that
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`received broadcast module 404 is logically associated with—e.g., provides
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`received media content to—Mackintosh’s speakers and display. Id., 16-17 citing
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`EX1004, 20:10-13 (“In one embodiment, the broadcast material [from received
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`module 404] can be provided to a display screen 410, a speaker 412, as well as
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`other peripheral devices”).
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`G. Question 7
`Please identify where in the substantive papers you argued that
`Mackintosh does, or does not, disclose an output system configured to
`present concurrently a “first media content” and a “second media
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`content” on an output of a “second receiver module,” and provide a
`brief summary of the evidence of record you cited in support of those
`arguments.
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`Petitioner has again provided two instances in its papers of an output system
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`presenting concurrently a “first media content” and a “second media content” on
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`an output of a “second receiver module.” First, as explained in the Petition and
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`above, Mackintosh’s communication interface 724 discloses the claimed “second
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`receiver module.” Pet., 32; see also id., 23-25 citing EX1004, 24:55-25:4.
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`Communication interface 724 “allows the user’s computer to receive the audio
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`broadcast (and program data) sent over the Internet by the broadcaster,” as well as
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`receive “the relevant supplemental materials.” Id., 25-26 citing EX1004, 3:19-26;
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`5:36-42; 5:50-54; 5:59-6:2; 7:16-20; 8:40-55; 9:7-59; 10:4-16; 21:13-25. And as
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`explained above, the received audio broadcast and supplemental materials are then
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`concurrently played through speakers and displayed to the user. Id., 36 citing
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`EX1004, 21:56-67, 22:13-23:6; EX1003, ¶91. Mackintosh’s speakers and display
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`are output(s) of an “output system” that are also logically associated with—e.g.,
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`output media content received via—Mackintosh’s communication interface 724
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`(“second receiver module”). Id., 32; Pet. Reply, 6-7, 11-12.
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`Additionally, in response to the erroneous claim constructions raised in
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`Patent Owner’s Response, Petitioner explained that Mackintosh’s get-data module
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`414 also discloses the claimed “second receiver module.” Pet. Reply, 15 citing
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`EX1004, 20:3-22. Petitioner also explained that get-data module 414 is logically
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`associated with—e.g., provides received media content to—at least Mackintosh’s
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`display. Pet., 36-37
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`(“Mackintosh’s display concurrently presents
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`the
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`‘supplemental materials’”) citing EX1004, 22:13-23:6; Pet. Reply, 16-17 citing
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`EX1004, 20:23-31 (“… these supplemental materials [from get-data module 404]
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`can be displayed or otherwise played along with the broadcast material …”).
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`H. Question 8
`Please identify where in the substantive papers you argued that
`DeWeese does, or does not, disclose a “first receiver module” and a
`“second receiver module,” and provide a brief summary of the
`evidence of record you cited in support of those arguments.
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`As explained in the Petition, DeWeese’s set-top box 26 discloses the
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`claimed “first receiver module.” Pet., 57-58 citing EX1005, FIG. 1A, ¶¶55-56.
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`Specifically, set-top box 26 “is both configured
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`to receive ‘television
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`programming,’ which corresponds to the claimed ‘first media content … from a
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`broadcast medium,’ and configured to receive ‘program guide data,’ which
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`corresponds to the claimed “data enabling the identification of a specific instance
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`of the first media content from a first broadcast medium.” Id., 58-59. The Petition
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`further explains that DeWeese’s DOCSIS modem discloses the claimed “second
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`receiver module.” Id., 59, 63 citing EX1005, FIG. 9, ¶¶56, 58-59. Specifically,
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`DeWeese’s DOCSIS modem “is configured to receive ‘real-time communications
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`and chat requests,’ which correspond to the claimed ‘second media content,’” and
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`also receive a “‘unique user identification code’ [that] corresponds to the claimed
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`‘uniquely identifying data specific to at least the second media content.’” Id., 63-64
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`citing EX1005, FIG. 9, ¶¶58-59.
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`Question 9
`I.
`Please identify where in the substantive papers you argued that
`DeWeese does, or does not, disclose an output system configured to
`present concurrently a “first media content” and a “second media
`content” on an output of a “first receiver module,” and provide a brief
`summary of the evidence of record you cited in support of those
`arguments.
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`As explained in the Petition and above, DeWeese’s set-top box 26 discloses
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`the claimed “first receiver module.” As also explained in the Petition, DeWeese’s
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`television program 202 corresponds to the “first media content,” and DeWeese’s
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`chat room messages 208 and 210 correspond to the “second media content.” Pet.,
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`58; see also id., 54, 56-57 citing EX1005, FIG. 9, ¶¶55-56. DeWeese’s user
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`television equipment 20 corresponds to the claimed “output system,” and display
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`screen 200 corresponds to the “output of a first receiver module.” Id., 66-68 citing
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`EX1005, FIG. 9, ¶¶93, 97. As shown in FIG. 9 below, “[t]elevision program 202
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`may be displayed in region 203 of display screen 200, while [chat room messages
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`208 and 210 in] chat room region 206 may be displayed simultaneously in the
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`lower portion of display screen 200.” Id.
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`EX1005, FIG. 9.
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`Therefore, DeWeese’s television equipment 20 having display screen 200 discloses
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`the claimed “output system configured to present concurrently the first media
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`content and the second media content on an output.” DeWeese’s display screen
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`200 is also logically associated with—e.g., outputs media content received from—
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`set-top box 26 (“first receiver module”). Pet., 57-58 (“set-top box 26 is “configured
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`to receive ‘television programming.’”), 66 (“[t]elevision program 202 may be
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`displayed in region 203 of display screen 200”); EX1005, FIG. 1A, ¶¶51, 53, 56
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`93.
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` Question 10
`J.
`Please identify where in the substantive papers you argued that
`DeWeese does, or does not, disclose an output system configured to
`present concurrently a “first media content” and a “second media
`content” on an output of a “second receiver module,” and provide a
`brief summary of the evidence of record you cited in support of those
`arguments.
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`As also explained in the Petition and above, DeWeese’s “DOCSIS modem”
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`discloses the claimed “second receiver module.” Pet., 59, 63 citing EX1005, FIG.
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`9, ¶¶56, 58-59. DeWeese’s DOCSIS modem “is configured to receive ‘real-time
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`communications and chat requests,’” (“second media content”) which are then
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`“displayed simultaneously in the lower portion of display screen 200” along with
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`television program 202 (“first media content”). Id., 66-68 citing EX1005, FIG. 9,
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`¶¶93, 97. Therefore, DeWeese’s display screen 200 is also logically associated
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`with—e.g., outputs media content received from—the DOCSIS modem, and is also
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`an output of the “second receiver module.” Id.; Pet. Reply, 11-12 25-27.
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`III. CONCLUSION
`As demonstrated above, Petitioner has shown that Mackintosh and DeWeese
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`disclose the claimed first and second receiver modules. These modules are logical
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`modules that may both be logically associated with—e.g., provide received media
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`content to—a single output, or each module may be logically associated with a
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`separate output. With this understanding, both Mackintosh and DeWeese disclose
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`“present[ing] concurrently the first media content and the second media content on
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`an output of the first receiver module or the second receiver module,” as recited in
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`claim 9. Thus, Petitioner requests that the challenged claims of the ’081 patent be
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`found unpatentable for these reasons as well as those presented in Petitioner’s
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`substantive papers and at Oral Hearing.
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`Respectfully submitted,
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`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/Ryan C. Richardson, Reg. No, 67,254/
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`Ryan C. Richardson (Reg. No. 67,254)
`Attorney for Petitioner
`Volkswagen Group of America, Inc.
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`Date: August 29, 2022
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
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`CERTIFICATE OF COMPLIANCE WITH TYPE-VOLUME
`LIMITATION, TYPEFACE REQUIREMENTS, AND TYPE STYLE
`REQUIREMENTS
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`This Supplemental Briefing submitted by Petitioner complies with the 15-
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`page limit specified by the Board’s August 15 Request for Supplemental Brief
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`Order (37 C.F.R. § 42.5).
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`This Supplemental Briefing complies with the general format requirements
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`of 37 C.F.R. § 42.6(a) and has been prepared using Microsoft® Word 2010 in 14
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`point Times New Roman.
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`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
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`/Ryan C. Richardson, Reg. No, 67,254/
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`Ryan C. Richardson (Reg. No. 67,254)
`Attorney for Petitioner
`Volkswagen Group of America, Inc.
`
`
`
`
`
`Date: August 29, 2022
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case IPR2021-00721
`U.S. Pat. No. 8,166,081
`CERTIFICATION OF SERVICE (37 C.F.R. § 42.6(e))
`
`The undersigned hereby certifies that on August 29, 2022, true and correct
`
`copies of
`
`the foregoing PETITIONER VOLKSWAGEN GROUP OF
`
`AMERICA, INC.’S SUPPLEMENTAL BRIEFING was served electronically
`
`via e-mail in its entirety on the following parties:
`
`Counsel for Patent Owner StratosAudio, Inc.
`John Scheibeler (Lead Counsel) jscheibeler@whitecase.com
`Jonathan Lamberson (Back-up Counsel)
`jonathan.lamberson@whitecase.com
`Hallie Kiernan (Back-up Counsel)
` hallie.kiernan@whitecase.com
`WCStratosAudioIPR@whitecase.com
`
`Counsel for Petitioners Subaru of America, Inc. and Volvo Car USA, LLC
`Matthew D. Satchwell (Lead Counsel)
` matthew.satchwell@dlapiper.com
`Paul R. Steadman (Back-up Counsel)
` paul.steadman@dlapiper.com
`Lewis E. Hudnell, III (Back-up Counsel)
` lewis@hudnelllaw.com
`Nicolas S. Gikkas (Back-up Counsel)
` nick@hudnelllaw.com
`DLA-StratosAudio@us.dlapiper.com
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`
`/Ryan C. Richardson, Reg. No, 67,254/
`
`Ryan C. Richardson (Reg. No. 67,254)
`Attorney for Petitioner
`Volkswagen Group of America, Inc.
`
`Date: August 29, 2022
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600
`
`
`
`
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