IPR2021-01267
`U.S. Patent No. 8,166,081
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`HYUNDAI MOTOR AMERICA
`Petitioner
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`v.
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`STRATOSAUDIO, INC.,
`Patent Owner
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`IPR2021-01267
`U.S. Patent No. 8,166,081
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`DECLARATION OF DR. TODD K. MOON
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`StratosAudio Exhibit 2016
`Hyundai v. StratosAudio
`IPR2021-01267
`Page 1 of 88
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`U.S. Patent No. 8,166,081
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`HYUNDAI MOTOR AMERICA
`Petitioner
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`v.
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`STRATOSAUDIO, INC.,
`Patent Owner
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`IPR2021-01267
`U.S. Patent No. 8,166,081
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`DECLARATION OF DR. TODD K. MOON
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`StratosAudio Exhibit 2016
`Hyundai v. StratosAudio
`IPR2021-01267
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`TABLE OF CONTENTS
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`IPR2021-01267
`U.S. Patent No. 8,166,081
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`INTRODUCTION ........................................................................................... 5
`A. Background And Qualifications ............................................................ 5
`SUMMARY OF OPINIONS ........................................................................... 7
` LEGAL STANDARDS ................................................................................... 9
`A. Claim Construction ................................................................................ 9
`B. Obviousness ......................................................................................... 10
` THE ’081 PATENT AND THE CHALLENGED CLAIMS ........................ 12
`LEVEL OF ORDINARY SKILL IN THE ART ........................................... 20
` CLAIM CONSTRUCTION .......................................................................... 22
` THE PRIOR ART .......................................................................................... 22
`A. Noreen (EX1005) ................................................................................. 22
`B. Crosby (EX1006) ................................................................................. 25
`C.
`Ellis-2002 (EX1007) ............................................................................ 26
`D. Ellis-2005 (EX1008) ............................................................................ 27
` CLAIMS 9, 15, AND 23 ARE NOT OBVIOUS OVER NOREEN
`(GROUND 1) ................................................................................................. 28
`A. Noreen Fails To Render Obvious Claim 9 .......................................... 29
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`Noreen Fails to Teach “data enabling identification of a specific
`instance of the first media content” – Element 9[a] ................. 29
`Noreen Fails to Teach Element 9[b] ......................................... 35
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`Noreen Fails to Teach Two Receiver Module Outputs (“output
`system configured to present concurrently the first media
`content and the second media content on an output of the first
`receiver module or the second receiver module”) – Element
`9[c] ............................................................................................ 39
`Noreen Fails to Teach “a response message having at least the
`uniquely identifying data specific to the second media content”
`– Element 9[e] ........................................................................... 48
`B. Noreen Alone Does Not Render Claim 15 Obvious ............................ 49
`C. Noreen Alone Does Not Render Claim 23 Obvious ............................ 50
` CLAIMS 9, 15, AND 23 ARE NOT OBVIOUS OVER NOREEN IN VIEW
`OF CROSBY (GROUND 2) ......................................................................... 50
`A. Noreen In View of Crosby Does Not Render Claim 9 Obvious ......... 50
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`Noreen In View Of Crosby Fails to Teach “uniquely identifying
`data specific to at least the second media content” – Element
`9[b] ............................................................................................ 51
`Noreen in View of Crosby Fails to Teach “a response message
`having at least the uniquely identifying data specific to the
`second media content” – Element 9[e] ..................................... 52
`B. Noreen In View Of Crosby Does Not Render Claims 15 And 23
`Obvious ................................................................................................ 52
`CLAIMS 10 AND 11 ARE NOT OBVIOUS OVER NOREEN IN VIEW
`OF CROSBY AND ELLIS-2002 (GROUND 3) .......................................... 52
` CLAIMS 9-11, 15, AND 23 ARE NOT OBVIOUS OVER ELLIS-2005
`ALONE (GROUND 4) .................................................................................. 53
`A. Ellis-2005 Alone Does Not Render Claim 9 Obvious ......................... 53
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`Ellis-2005 Fails to Teach “data enabling the identification of a
`specific instance of the first media content” – Element 9[a] .... 53
`Ellis-2005 Alone Does Not Render Claim 15 Obvious ....................... 55
`B.
`Ellis-2005 Alone Does Not Render Claims 10, 11, And 23 Obvious . 58
`C.
` CLAIMS 9-11, 15, AND 23 ARE NOT OBVIOUS OVER ELLIS-2005 IN
`VIEW OF CROSBY (GROUND 5) .............................................................. 58
`A. Ellis-2005 In View Of Crosby Fails to Teach “data enabling the
`identification of a specific instance of the first media content” –
`Element 9[a] ......................................................................................... 59
` DECLARATION ........................................................................................... 64
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`IPR2021-01267
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`INTRODUCTION
`1.
`I, Todd K. Moon, Ph.D., have been retained by Patent Owner
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`StratosAudio, Inc. (“Patent Owner”) as an independent expert witness in the above
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`referenced inter partes review (“IPR”) of United States Patent No. 8,166,081 (“the
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`’081 patent”) (EX1001). I understand that Hyundai Motor America (“Petitioner”)
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`has petitioned for inter partes review of the ’081 patent and requests that the
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`United States Patent and Trademark Office (“PTO”) cancel as unpatentable certain
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`claims of the ’081 patent.
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`2.
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`This declaration sets forth my analyses and opinions based on the
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`materials I have considered thus far and the bases for my opinions. I understand
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`that this declaration will be used in the above mentioned IPR2021-01267.
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`A. Background And Qualifications
`3. My qualifications are set forth in my curriculum vitae, a copy of
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`which is attached as Appendix A. As set forth in my curriculum vitae, I received
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`my B.S. in Electrical Engineering and Mathematics (dual major) and M.S. in
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`Electrical Engineering from Brigham Young University in 1988. I received my
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`Ph.D. in Electrical Engineering from the University of Utah in 1991.
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`4.
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`In 1991, I began teaching electrical and computer engineering at the
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`Utah State University (“USU”). From 1991 to 1996, I was an Assistant Professor
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`of Electrical Engineering, and from 1996 to 2002, I was an Associate Professor of
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`Electrical Engineering. I currently serve as a Professor of Electrical and Computer
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`Engineering and served as the department head from 2007 through 2016.
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`5.
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`As further described in my CV, I have over thirty years of experience
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`in electrical engineering, including extensive experience in signal processing and
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`digital communications. I have taught numerous classes in the field of signals and
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`systems. Some of the courses I have taught include digital communications, digital
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`signal processing, circuits and signals/signals and systems, digital control systems,
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`and digital systems design. I am a member of the IEEE Signal Processing Theory
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`and Methods (SPTM) Committee and was the General Conference Chair of the
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`IEEE Signal Processing/SP Education Workshop in 2015.
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`6.
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`I have authored or co-authored four books: Error Correction Coding:
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`Mathematical Methods and Algorithms, 1st Ed., Wiley, 2005, Error Correction
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`Coding: Mathematical Methods and Algorithms, 2nd Ed., Wiley, 2021,
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`Mathematical Methods and Algorithms for Signal Processing, Prentice-Hall, 2000,
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`and Advanced Signal Processing: A Concise Guide, McGraw-Hill, 2020. I have
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`authored or coauthored more than 50 journal papers and over 140 conference
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`papers on topics including geolocation, remote sensing, signal processing,
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`communication, filter design, and error correction coding.
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`7.
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`I have been involved in a variety of technologies related to
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`communications. My dissertation was about spread spectrum communications. I
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`have done work on co-channel interference, and using communications signals to
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`locate the transmitter source.
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`8.
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`9.
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`Additional qualifications are detailed in my CV.
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`I have been asked to provide certain opinions related to the validity of
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`the ’081 Patent. In doing so, I have considered my own education and work
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`experience that I believe render me well-qualified to opine on the level of ordinary
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`skill in the art and the non-obviousness of certain claims in view of prior art
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`presented in the petition.
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`10.
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`I am being compensated for my time spent in connection with this
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`matter at my usual rate of $450 per hour. My compensation is not contingent on
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`the outcome of this case.
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`SUMMARY OF OPINIONS
`11.
`I have reviewed the Declaration of Kevin C. Almeroth, Ph.D.
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`(EX1002) (the “Almeroth Declaration”), the Petition, the specification, claims, and
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`prosecution history of the ’081 patent, and the PTAB’s Institution Decision. In
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`forming my opinions, I considered the ’081 patent, the Petition, Petitioner’s
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`Exhibits, the Institution Decision, and additional exhibits cited herein. I also relied
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`on my education, training, and experience as a skilled artisan in the field.
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`12. The opinions that I express in this declaration are based on the
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`information and evidence currently available to me. It is my opinion that the
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`challenged claims of the ’081 patent are not obvious in light of the combinations of
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`references put forth in the Petition.
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`13.
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`In my opinion, the challenges presented by Petitioner and Dr.
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`Almeroth in Grounds 1-5 all fail. In particular, I have formed the following
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`opinions with respect to the challenges against claims 9-11, 15, and 23 of the ’081
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`patent:
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` Noreen does not render obvious claims 9, 15, and 23 (Ground 1);
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` Noreen in view of Crosby does not render obvious claims 9, 15, and
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`23 (Ground 2);
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` Noreen in view of Crosby and Ellis-2002 does not render obvious
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`clams 10 and 11 (Ground 3);
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` Ellis-2005 does not render obvious clams 9-11, 15, and 23 (Ground
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`4); and
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` Ellis-2005 in view of Crosby does not render obvious clams 9-11, 15,
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`and 23 (Ground 4).
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`14. The bases for my opinions are set forth in this declaration.
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` LEGAL STANDARDS
`15.
`I am not an attorney, and therefore, my understanding of patent law
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`and the legal standards set forth in this report is based on explanations provided by
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`counsel.
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`16.
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`I have been informed by counsel and I understand that the ’081 Patent
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`was filed on February 5, 2009, but that it claims priority to U.S. Provisional
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`Application No. 61/026,449 filed on February 5, 2008. Therefore, I have been
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`instructed by counsel that the invention date of the ’081 Patent is February 5, 2008,
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`for the purposes of this Petition. I take no position on whether an earlier invention
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`date should be afforded to the ’081 Patent.
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`A. Claim Construction
`17.
`I understand that the United States Patent and Trademark Office
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`interprets claim terms in an inter partes review proceeding under the same claim
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`construction standard that is used in a United States federal court. I understand
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`that, under this standard, the meaning of claim terms is considered from the
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`viewpoint of a person of ordinary skill in the art (“POSITA”) at the time of the
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`alleged invention.
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`18.
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`I understand that claim terms are generally given their plain and
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`ordinary meaning as understood by a POSITA, in light of the specification and the
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`prosecution history pertaining to the patent. I further understand that claim terms
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`are generally not to be imported from the embodiments described in the
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`specification unless the patentee has demonstrated a clear intention to limit the
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`claim scope.
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`19.
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`I understand that in addition to the claims, specification, and
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`prosecution history, other evidence may be considered to ascertain the meaning of
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`claim terms, including textbooks, encyclopedias, articles, and dictionaries. I have
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`been informed and understand that this other evidence is often less significant and
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`less reliable than the claims, specification, and prosecution history.
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`B. Obviousness
`20.
`I understand that even if an alleged claimed invention is not
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`identically disclosed or described in a single piece of prior art, the patent claim
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`may still be unpatentable if the differences between the claimed invention and the
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`prior art (alone or in combination) are such that the claimed invention as a whole
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`would have been obvious to a person having ordinary skill in the art at the time the
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`invention was made. I understand that the level of ordinary skill in the pertinent
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`art is evaluated as of the time of the invention, here the effective filing date of the
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`’081 patent.
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`21.
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`I also understand that, in addressing obviousness, the following
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`factors must be considered from the perspective of a hypothetical person of
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`ordinary skill in the relevant art: (1) the scope and content of the prior art; (2) the
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`differences between the claimed invention and the prior art; (3) the level of
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`ordinary skill in the art; and (4) any other indications (“objective indicia”) of non-
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`obviousness, such as commercial success, long-felt but unsolved needs, failure of
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`others, industry acclaim, and unexpected results.
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`22.
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`I understand that prior art references may be combined to render a
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`claim obvious if a person of ordinary skill in the art would have been motivated to
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`combine those teachings to derive the claimed subject matter with a reasonable
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`expectation of success. I also understand that the use of hindsight to select or
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`combine prior art references is improper for purposes of an obviousness analysis.
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`23.
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`I understand that in considering obviousness, it is relevant to consider
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`whether the art includes references that “teach away” from the claimed invention.
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`I have been informed that a reference teaches away from the claimed invention if a
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`person of ordinary skill, reading the reference, would be discouraged from
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`following the path of the claimed invention or would be led in a divergent
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`direction.
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` THE ’081 PATENT AND THE CHALLENGED CLAIMS
`24. The ’081 patent relates to media advertising and combining an
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`advertising media signal with another media signal. Specifically, the ’081 patent
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`describes a novel system for combining multiple media content after discretely
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`identifying each instance of the first media content (e.g., content such as a radio
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`program) and the second media content (e.g., target advertisements). EX1001,
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`1:18-20. In advertising, it is desirable to associate products with specific
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`characteristics and such associations may increase the chance that a potential
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`customer will decide to purchase a product when the product is associated with a
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`favorable characteristic. EX1001, 1:22-30. In view of this, the ’081 Patent states
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`that an advertisement may be more effective if it is associated with an image of a
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`celebrity or another media element that exhibits favorable characteristics.
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`EX1001, 1:30-34.
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`25. The ’081 patent achieves the objective of associating ads with other
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`media content by, for example, the steps of challenged claims 9-11, 15, and 23.
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`Claim 9 is set forth below:
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`9[pre] A system for combining multiple media comprising:
`9[a]
`a first receiver module configured to receive at least a first
`media content and data enabling the identification of a
`specific instance of the first media content from a first
`broadcast medium;
`9[b] a second receiver module configured to receive at least a
`second media content and uniquely identifying data specific to
`at least the second media content, the second media content
`received discretely from the first media content;
`9[c] an output system configured to present concurrently the first
`media content and the second media content on an output of
`the first receiver module or the second receiver module;
`9[d] an input module configured to receive at least a response input
`responsive to the second media content; and
`9[e] a transmitting module configured to transmit a response
`message having at least the uniquely identifying data specific
`to the second media content to a computer server.
`26. The subject matter of challenged claims 9-11, 15, and 23 is set forth
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`throughout the specification of the ’081 patent.
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`27. The Summary of the invention contemplates several embodiments of
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`“associating multiple media signals” and “combining multiple media signals”
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`which provide support for the claimed system. See EX1001, 1:38-2:30. The
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`Detailed Description also discloses several embodiments for a media enhancement
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`system configured to associate/combine a secondary media signal (for example, an
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`advertisement) to a primary media signal (for example, a radio broadcast).
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`EX1001, 3:8-5:21.
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`28. The claimed system is implemented, for example, by the system
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`shown in Figures 1 and 1A (reproduced below):
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`29. The system comprises a first transmitter 3, primary device 4, ancillary
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`device(s) 5, media association system 2, advertisement entity 6, and control
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`management system 100. EX1001, FIG. 1, 8:11-16.
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`30. The first transmitter 3 (e.g., a radio broadcaster) may transmit the first
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`media content to the primary device, or any other devices, systems, or entities in
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`the multimedia system, including the ancillary device. EX1001, 10:56-58 (“the
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`first transmitter 3 can send a first media signal 111 to the primary device 4 and/or
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`ancillary device 5”), 12:30-35 (“it is clear that the first media signal 111 could
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`further be transmitted to any number of devices or entities, as well as the ancillary
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`devices 5”). The media association system can provide a related media signal 114
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`to the primary and/or ancillary devices. EX1001, 9:43-48. Similarly, “the media
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`association system 2 and the advertisement entity 6 can provide an advertisement
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`media signal 113 to the primary and/or ancillary devices 4, 5.” EX1001, 12:37-40;
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`see also id., 21:49-51 (“The ancillary device 5 can receive the first media signal
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`111 and the advertisement signal 113 directly from the first transmitter 3 and/or the
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`media association system 2.”).
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`31. The ’081 patent describes three ways of transmitting the first media
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`signal and the second media signal to the devices: (1) the second media signal is
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`integrated with the first media signal; (2) “the first media signal and the second
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`media signal are separate and discrete;” and (3) the first media signal is
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`intercepted during transmission and the second media signal is added to the
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`transmission. EX1001, 4:64-5:3 (emphasis added), 10:63-11:1, 11:14-20. In my
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`opinion, a POSITA would understand that claim 9 is directed to those
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`embodiments where the first media content is transmitted separately and discretely
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`from the second media content. EX1001, cl. 9, 35:30-31.
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`32. The ’081 patent explains that when the first and second media signals
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`are sent separately, a “unique identifier 115” can be assigned to each signal.
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`EX1001, 11:24-28, 12:66-13:13, FIG. 1D (reproduced below).
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`33. A unique identifier may be used to identify each media signal from
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`other media signals and “each instance of each signal or content media segment.”
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`EX1001, 12:61-13:4. “As illustrated in FIG. 1D, the unique identifier 115 is
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`database-linked thereby allowing a user (for example, a user of the control
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`management system 100, media association system 2 and/or advertisement entity
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`6) to conduct a search or lookup of the information identified by the unique
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`identifier 115 to determine the location, the user device, the time of transmittal, the
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`program and/or media content in the first media signal, the available options for
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`response to the user of the device, and/or other identifying characteristic
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`information.” EX1001, 11:38-46.
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`34. The ’081 patent shows that data enabling the identification of a
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`specific instance (in other words, occurrence) is determined in real time while the
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`broadcast stream is broadcasted. In particular, the ’081 patent states, “the
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`broadcast scanning system 160 is configured to: analyze the broadcast streams
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`received by a plurality of broadcast sources 120 to obtain or identify the media
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`content transmitted in the broadcast streams” and “assign a unique event identifier
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`115 specific to the broadcast of each specific broadcast stream.” EX1001, 32:5-11.
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`The ’081 patent incorporates by reference a co-pending application (which issued
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`as U.S. Patent No. 8,875,188 (EX2014)) for its disclosure regarding how the
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`broadcast scanning system 160 determines the unique event identifier. See
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`EX1001, 32:14-20. The incorporated-by-reference application confirms that the
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`broadcast scanning system analyzes the broadcast stream and determines the
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`unique event identifier enabling identification of the specific instance of the media
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`content in real time while each broadcast occurs. See, e.g., EX2014, 10:4-42,
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`12:32-38, 14:31-34.
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`35. The ’081 patent “assign[s] a unique identifier that is specific to the
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`transmission of the selected second media signal, wherein at least the unique
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`identifier is stored in a database.” EX1001 2:15-18. The unique event identifier
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`data is “preferably implemented as a part of a database that allows for the storage
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`and/or retrieval of the identifier and/or data associated with the identifier.”
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`EX1001, 7:65-8:1. The patent states “[b]y means of the unique event identifier
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`and/or identifiers, reports can be generated on the performance of various aspects
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`of the system such as who, what, when, where, why, which, and/or how an event
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`within the system occurred, including the number of times an event within the
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`system occurred; locations for events; what prompted an event; devices, signals
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`and/or users associated with events and/or means associated with the events.”
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`EX1001, 8:1-9.
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`36. Once the system receives the first media content, the second media
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`content, and their respective identifying data, either the primary device 4 and/or the
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`ancillary device 5 present concurrently both media content. EX1001, 14:5-13
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`(“then have either the primary device 4 and/or ancillary device 5 to present the
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`advertisement signal 113 at the same time or substantially the same time as the first
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`media signal 111 is presented to the user of either the primary device 4 and/or
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`ancillary device 5”), 14:27-31 (“Next the primary device 4 and/or ancillary device
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`5 present the advertisement signal media signal 113 at the same time or nearly the
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`same time as the first media signal 111 is presented to the user of primary device 4
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`and/or ancillary device 5.”). When discussing presentation of the first and second
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`media content on an output, the use of “and/or” in the specification versus “or” in
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`claim element 9[c] of the challenged claims has meaning. While the specification
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`contemplates that the first and second media content may be presented separately
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`or together on the primary device and/or the ancillary device, claim element 9[c]
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`requires concurrently presenting the “first media content” and “second media
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`content” together on “an output of the first receiver module or the second receive
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`module.” EX1001, 35:34-35.
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`37. The ’081 patent explains that “[t]he ancillary device 5 can comprise
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`superior bandwidth, storage capacity, and/or processing power relative to the
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`primary device 4, allowing the ancillary device 5 to transmit more complex data to
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`the media association system 2.” EX1001, 15:43-47. “For example, if a media
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`signal 114 and/or an advertisement media signal 113 cannot be viewed, then a user
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`can view the media signal 113 on an ancillary device 5.” EX1001, 21:32-36; see
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`also id., 25:26-29 (“Such steps can reduce bandwidth requirements, restrict access
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`to the related media signal 114, and allow it to be viewed on the primary and/or an
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`ancillary devices 4, 5 capable of viewing media in a certain set of formats.”).
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`38. The ’081 patent further explains the system includes a means of
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`allowing a user to input or respond to the media content being presented. EX1001,
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`15:9-12. The user responses can include responses to interactive media content,
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`such as polls, voting, or games. EX1001, 12:54-57, 15:12-14.
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` LEVEL OF ORDINARY SKILL IN THE ART
`39.
`I understand that Dr. Almeroth asserts that a person of skill in the art
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`(“POSITA”) in the context of the ’081 Patent as of February 5, 2008 would have
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`had “at least a bachelor’s degree in electrical engineering, computer engineering,
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`computer science, or a related field, and at least two years of experience in the
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`communications or Internet-related industries, or the equivalent, with additional
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`education substituting for experience and vice versa.” EX1002, ¶40.
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`40. For the purpose of these proceedings, I do not object to the level of
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`skill proposed by Dr. Almeroth.
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`41.
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`I am qualified to testify as to this level of skill because, as noted
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`above, I have B.S., M.S., and Ph.D. degree in electrical engineering and have over
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`thirty-years’ experience teaching and working in the electrical engineering
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`industry. Specifically, I have taught electrical and computer engineering at USU
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`since 1991. From 1991 to 1996, I was an Assistant Professor of Electrical
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`Engineering, and from 1996 to 2002, I was an Associate Professor of Electrical
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`Engineering. I currently serve as a Professor of Electrical and Computer
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`Engineering and served as the department head from 2007 through 2016.
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`42. Within the electrical engineering field, I have extensive experience in
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`signal processing and digital communications, and I have taught numerous classes
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`in the field of signals and systems. I am also a member of the IEEE Signal
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`Processing Theory and Methods (SPTM) Committee and was the General
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`Conference Chair of the IEEE Signal Processing/SP Education Workshop in
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`2015. Further, I have authored or co-authored four books: Error Correction
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`Coding: Mathematical Methods and Algorithms, 1st Ed., Wiley, 2005, Error
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`Correction Coding: Mathematical Methods and Algorithms, 2nd Ed., Wiley, 2021,
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`Mathematical Methods and Algorithms for Signal Processing, Prentice-Hall, 2000,
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`and Advanced Signal Processing: A Concise Guide, McGraw-Hill, 2020. I have
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`authored or coauthored more than 50 journal papers and over 140 conference
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`papers on topics including geolocation, remote sensing, signal processing,
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`communication, filter design, and error correction coding.
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` CLAIM CONSTRUCTION
`43. Dr. Almeroth at ¶33 states that he does “not believe any term requires
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`explicit construction” in order “[t]o resolve the particular grounds presented in
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`[the] Petition.” For the purposes of this proceeding, I agree.
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` THE PRIOR ART
`A. Noreen (EX1005)
`44. Noreen describes an “Integrated Radio Satellite Response System and
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`Method.” EX1005, [54]. Noreen relates to a radio response system which
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`broadcasts program signals to mobile terminals. EX1005, 5:19-30, 5:53-55. In the
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`system, mobile users have mobile terminals that communicate with a satellite
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`capable of transmissions to mobile units. EX1005, 5:19-30, 5:53-55.
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`45. Noreen first describes a “Radio Satellite Network.” EX1005, 5:18. A
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`mobile terminal “may include: a radio satellite microchip (RSM); an optional audio
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`processor 217; an optional transmitter 211; satellite RF electronics 215; and L-
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`band antenna assembly 203.” EX1005, 5:55-58. The mobile terminal receives a
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`single signal with the combined contents of the TDM channel and assignable
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`channel and “[t]he satellite RF electronics 215 converts [the] received signal from
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`the L-band assembly 203, using satellite RF electronics 215, to an assignable-IF
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`signal and a TDM-IF signal.” EX1005, 6:43-46, 6:64-67 (“Broadly, the satellite
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`RF electronics 215 receives a signal from the L-band assembly 203 and converts
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`the received signal to two IF signals: an assignable-IF signal and a TDM-IF
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`signal.”). The RF electronics sends the assignable-IF signal to an assignable
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`demodulator 221 and the TDM-IF signal to TDM demodulator 222. EX1005,
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`6:67-7:1. The TDM channel is a low rate data channel with broadcasts such as
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`“alphanumeric pages, GPS differential corrections and integrity updates, stock
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`updates, sport reports, travel advisories and emergency alerts.” EX1005, 9:65-
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`10:1. The TDM demodulator and decoded demodulates and decodes the TDM-IF
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`signal and “provides paging, packet data” to the data processing and controller
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`223. EX1005, 7:10-13. The data processing controller 223 deinterleaves received
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`data streams and sends and receives the paging messages to the message display.
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`EX1005, 7:13-17. Messages with the data are then sent to and received from an
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`input panel and a message display. EX1005, 7:16-17.
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`46.
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`In contrast, the assignable-IF signal is sent from the assignable
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`demodulator to the assignable decompressor and audio to digital converter and
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`convers it to output analog signals such as analog program material or voice
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`messages. EX1005, 9:38-42. These analog signals are then sent to either a handset
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`or an audio amplifier to be output on speakers. EX1005, 9:36-42.
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`47. A separate “exemplary arrangement” of Noreen, Figure 4, is disclosed
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`with respect to a “Radio Response System and Method.” EX1005, 11:62. In
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`Figure 4, a mobile terminal receives a “program signal” at the broadcast receiver
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`that also demodulates the program signal. Ex1005, 12:21-42. The “mobile
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`terminal 401 has receiver means shown as broadcast receiver 402, data-transmitter
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`means as data transmitter 404, and controller means embodied by controller 403.”
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`EX1005, 12:5-8. “[T]he broadcast receiver 402 receives and demodulates the
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`program signal.” EX1005, 12:21-22. The demodulated signal is output to an
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`interface means. The interface means of the mobile terminal “uses the audio
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`and/or visual display 415 for means of communicating the program signal to a
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`user.” EX1005, 12:27-29. When the program signal includes audio information,
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`the interface means may include speakers and when the program signal includes
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`video information the interface means may include a visual display. EX1005,
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`12:27-32. The user inputs a response through the “input transducer 416,” and the
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`mobile terminal processes the user-input along with information identifying the
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`program signal and sends a combined response signal, “a user-data signal,” to a
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`processing center. Se
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