`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
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`
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`TCL Electronics Holdings Ltd. (f/k/a TCL Multimedia Technology Holdings, Ltd.)
`TCL Industries Holdings Co., Ltd.
`TCL Industries Holdings (H.K.) Limited
`TTE Technology, Inc. (d/b/a TCL North America)
`TTE Corporation
`TCL Moka International Limited
`TCL Moka Manufacturing S.A. de C.V.
`TCL King Electrical Appliances (Huizhou) Co. Ltd.
`Manufacturas Avanzadas S.A. de C.V.
`TCL Smart Device (Vietnam) Co., Ltd
`Shenzhen TCL New Technology Co., Ltd.
`TCL Optoelectronics Technology (Huizhou) Co., Ltd.
`TCL Overseas Marketing Ltd.
`TCL Technology Group Corporation (f/k/a TCL Corp.),
`Petitioners,
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`v.
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`LG Electronics Inc.,
`Patent Owner.
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`
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`Case No. IPR2023-00240
`Patent No. 7,982,803
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`PATENT OWNER’S PRELIMINARY RESPONSE
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`IPR2023-00240
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`Patent Owner’s Preliminary Response
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`I.
`II.
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`TABLE OF CONTENTS
`INTRODUCTION ........................................................................................... 1
`BACKGROUND ............................................................................................. 2
`A. Overview of the ’803 Patent .................................................................. 2
`B.
`Challenged Claims ................................................................................ 4
`III. LEVEL OF SKILL IN THE ART ................................................................... 7
`IV. CLAIM CONSTRUCTION ............................................................................ 8
`V.
`SUMMARY OF THE PRIOR ART REFERENCE (BOUDREAU) ............ 10
`VI. THE PETITION DOES NOT ESTABLISH A REASONABLE
`LIKELIHOOD OF SUCCESS ...................................................................... 13
`A.
`Legal Standard ..................................................................................... 13
`B.
`Petitioner fails to establish that all elements of the challenged
`claims can be found in Boudreau ........................................................ 14
`1.
`Petitioner’s reliance on Boudreau’s “related content”
`(e.g., audio for the doll) is incorrect ......................................... 14
`Petitioner fails to establish a reasonable likelihood that
`Boudreau discloses “a switching unit selecting paths for
`the video signal that is input to the video signal
`processing unit.” ........................................................................ 17
`VII. CONCLUSION .............................................................................................. 18
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`2.
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`TABLE OF AUTHORITIES
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`Page(s)
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`CASES
`Personal Web Technologies, LLC v. Apple, Inc.,
`848 F.3d 987 (Fed. Cir. 2017) ............................................................................ 14
`STATUTES
`35 U.S.C. § 102 .................................................................................................. 13, 14
`35 U.S.C. § 103 .............................................................................................. 4, 13, 14
`35 U.S.C. § 314(a) ................................................................................................... 13
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`I.
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`Patent Owner’s Preliminary Response
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`INTRODUCTION
`The inventions disclosed in the ’803 Patent are not at all like the cited prior
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`art (U.S. Patent Publication 2004/00117858, “Boudreau”) (EX1003), and Petitioner
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`fails to establish otherwise. While the ’803 Patent is directed to the synchronization
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`of the audio and video for content being displayed on a television, Boudreau’s
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`disclosure relates to manipulation of an entirely separate audio signal. More
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`specifically, Boudreau describes its invention as a multi-device system involving a
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`television and a separate device (a doll), which can be used to supplement a
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`television program by coordinating the television’s audio and video with the doll’s
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`audio. EX1003, ¶0016. Controlling the processing for the main television audio (as
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`in the ’803 Patent) is not equivalent to processing separate audio for a doll.
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`Petitioner muddles this distinction and builds its arguments on top of an
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`unsupported assumption that the doll’s audio and the television’s audio in Boudreau
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`can be relied upon interchangeably. Petitioner’s attempt to map these two distinct
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`and separate audio signals (the doll’s audio and the television’s audio) to the single
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`audio signal claimed in the ’803 Patent should be rejected. Further, because the
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`audio signal that Petitioner maps in Boudreau is handled separately from the
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`television video, Petitioner has failed to show that Boudreau discloses the claimed
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`“switching unit,” which selects a path for both the video signal and the audio signal.
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`Patent Owner therefore respectfully requests that the Board deny institution of the
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`Petition.
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`Patent Owner’s Preliminary Response
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`II. BACKGROUND
`A. Overview of the ’803 Patent
`The ’803 Patent is directed to an apparatus and methods for synchronizing
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`audio and video signals that are input to a digital television, particularly in scenarios
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`where one or both of the audio and video signals are subsequently routed out of the
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`television to an external device. EX1001, 1:12-23, FIG. 4 (annotated and reproduced
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`below) (illustrating audio input and video input in red boxes and audio output and
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`video output in a yellow box).
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`At the time of the invention in 2005, most digital televisions were equipped
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`with an image processor capable of providing high-definition images, however, such
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`televisions often lacked an audio processor capable of providing high-quality audio.
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`Id. at 1:36-2:3. And thus, with respect to prior art systems, it was a common practice
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`to output the audio signal from the television to an external audio system equipped
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`with superior audio processing capabilities. Id. This practice, however, presented
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`synchronization issues between the audio and video. Id. at 2:4-34. When both the
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`audio signal and the video signal are processed internally by the television, the
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`television was able to determine the timing difference between the audio processing
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`and video processing and delay one of the signals to synchronize the signals. Id.
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`However, when the audio is outputted to and processed by an external device, the
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`television was no longer able to determine the timing difference between the audio
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`and video processing for synchronization purposes. Id.
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`To solve these problems in the prior art, the ’803 Patent teaches that the
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`decision whether to route the audio signal through the television’s internal
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`processing can be made based on a type or kind of the external device. Id. at 2:38-
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`3:36; see also id. at 8:16-19 (explaining that in some embodiments “an output path
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`is automatically controlled for the synchronization of an audio signal according to
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`the result of detecting the kinds of external devices”). Controlling the processing
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`based on the external device further avoids issues with prior art synchronization
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`techniques that manually delayed signals because there are many variations that
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`impact the potential delay required. Id. at 2:4-34.
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`B. Challenged Claims
`The Petition challenges Claims 1-18 of the ’803 Patent as unpatentable under
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`35 U.S.C. § 103 in view of U.S. Patent Publication No. 2004/0117858 (“Boudreau”).
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`The challenged claims include five (5) independent claims that are directed to
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`apparatuses and two (2) independent claims that are directed to methods. Petitioner
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`does not substantially differentiate between the different independent claims, and
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`thus the arguments below about Claim 1 apply equally to the other independent
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`claims. See, e.g., Petition, pp. 29-51 (challenging the independent claims with
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`references back to its arguments for Claim 1).
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`Independent Claim 1 recites1:
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`1. An audio and video synchronizing apparatus comprising:
`a video signal processing unit processing a video signal that is
`provided to a display device of video processing equipment;
`an audio signal processing unit processing an audio signal that
`is provided to an audio device of the video processing equipment, the
`audio signal synchronized with the video signal;
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`1 Herein, all emphasis is added, unless noted otherwise.
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`a switching unit selecting paths for the video signal that is input
`to the video signal processing unit and the audio signal that is input to
`the audio signal processing unit, and selecting at least an audio signal
`for output to an external device that is not part of the video processing
`equipment;
`an outputting unit outputting the selected at least an audio signal
`to the external device; and
`an output selecting unit controlling the switching unit according
`to a kind of the external device,
`wherein the switching unit is controlled to select a first audio
`signal that bypasses the audio signal that is input to the audio signal
`processing unit as the at least an audio signal for output to the
`external device or to select a second audio signal output from the
`audio signal processing unit as the at least an audio signal for output
`to the outputting unit.
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`Like Claim 1, all of the independent claims include claim language requiring
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`that “the audio signal” could be played directly from the speakers of the television,
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`but if the audio signal is instead output to an external device then the signal is either
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`processed by, or bypasses the processing of, the television’s internal audio processor
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`unit.
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` Independent Claim 6 recites, “an audio signal processing unit processing an
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`audio signal that is provided to an audio device of the video processing
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`equipment,” and an “output selecting unit” that selects either a first or second
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`audio signal “as the audio signal that is output to the external device.”
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` Independent Claim 7 recites, “an audio signal processing unit outputting an audio
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`signal,” and an “audio output selecting unit” that selects “as the audio signal that
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`is output to the external device” either “an audio signal that bypasses the audio
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`signal that is input to the audio signal processing unit” or “an audio signal output
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`from the audio signal processing unit.”
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` Independent Claim 8 recites, “an audio signal processing unit processing an
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`audio signal that is provided to an audio device of the video processing
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`equipment,” and an “output selecting unit [that] controls the outputting unit to”
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`select the outputting audio signal as either “a first audio signal that bypasses the
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`audio signal that is input to the audio signal processing unit” or “a second audio
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`signal output from the audio signal processing unit.”
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` Independent Claim 9 recites, “an audio signal processing unit processing an
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`audio signal that is provided to an audio device of the video processing
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`equipment,” and an “output selecting unit [that] controls the outputting unit to”
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`select “the outputting audio signal as either “a first audio signal that bypasses the
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`audio signal that is input to the audio signal processing unit” or “a second audio
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`signal output from the audio signal processing unit.”
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` Independent Claim 10 recites, “determining a kind of an external device that is
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`not part of the video processing equipment and is connected to an output port of
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`video processing equipment,” and “selecting an audio signal according to a result
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`of the determination … wherein the selected audio signal is either a first audio
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`signal that bypasses an audio signal that is input to an audio signal processing
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`unit… or a second audio signal output from the audio signal processing unit.”
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` Independent Claim 16 recites “selecting an output mode of video processing
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`equipment,” “selecting an audio signal according to the selected output mode for
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`output to an external audio device,” “outputting the selected audio signal to the
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`external audio device, wherein the selected audio signal is either a first audio
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`signal that bypasses an audio signal that is input to an audio device of the video
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`processing equipment that synchronizes the audio signal with a video signal that
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`is provided to a display device of the video processing equipment or a second
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`audio signal output from the audio device.”
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`III. LEVEL OF SKILL IN THE ART
`For the limited purpose of this Preliminary Response, Patent Owner does not
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`contest Petitioner’s definition of a person of ordinary skill in the art (“POSA”), but
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`reserves the right to do so in the event that trial is instituted.
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`IV. CLAIM CONSTRUCTION
`Petitioner submitted that the terms in the challenged claims of the ’803 Patent
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`should be given their plain and ordinary meaning. Petition at 4. For purposes of
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`evaluating this preliminary response, Patent Owner’s position is that the Board need
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`not construe any claim terms in the ’803 Patent.
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`However, as explained above in Section II.B, Patent Owner submits that the
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`plain claim language requires that the audio signal recited in each independent claim
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`is the audio for the video content, and this audio could be provided to the television’s
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`audio device (speaker). This is also confirmed by the ’803 Patent’s specification:
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`FIG. 3 illustrates the configuration of an audio and video signal
`processing unit 40 of a digital TV, a video processing equipment
`employing the present invention. Referring to FIG. 3, the digital TV
`includes an AV switch 41 switching inputted a video signal (Vin) and
`an audio signal (Ain) … an audio decoder/amplifier 45 decoding and
`amplifying the audio signal inputted through the AV switch 41, and a
`TV speaker 46 outputting the decoded and amplified audio signal.
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`See, e.g., EX1001, 4:3-15.
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`See, e.g., EX1001, FIG. 3 (illustrating that the audio input (annotated red) can
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`be output to the TV speaker (annotated blue) or external to the TV as audio
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`output (annotated green)).
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`[T]he AV switch 41 controls the audio and video signal processing
`paths, thereby allowing the audio and video output using the speaker
`46 and the display 44 of the video processing equipment, or allowing
`the audio and video output to an external device connected to an output
`port.
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`See, e.g., id. at 5:40-45; see also id. at 6:4-17.
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`See, e.g., id. at FIG. 4 (illustrating that the audio input (annotated red) can be output
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`to the TV speaker (annotated blue) or external to the TV as audio output (annotated
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`green)).
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`V.
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`SUMMARY OF THE PRIOR ART REFERENCE (BOUDREAU)
`Boudreau is directed to a multi-device system that is designed to enhance the
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`viewing experience of a television show with separate audio content emitted from
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`an external doll or action figure. EX1003, ¶¶ 0016, 0023, 0092; FIG. 2A
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`(reproduced below). The doll can be used to “increase the level of interest in the
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`show” by outputting its own audio content on top of the content presented on the
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`television. Id. at ¶¶ 0016, 0023. Examples provided by Boudreau include a child
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`workout show where the doll is configured to output phrases like “let’s work out”
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`and an educational show where the doll is configured to output phrases like “stay
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`fit.” Id. at ¶¶ 0024-25.
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`In Boudreau, the content presented on the external device (e.g., doll’s audio)
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`is specifically defined as “related content” that can be presented in coordination with
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`a television show: “Herein such content that is related (e.g., relatedness as to subject
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`matter, message, theme, etc.) to programming presented on a television and is for
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`download (or transmittal) to an external device will be referred to as related
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`content.” Id. at ¶ 0015 (emphasis added). Consistent with industry standards at the
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`time, Boudreau explains “related content” (e.g., doll’s audio) would be separated
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`into a different elementary data stream from the television program’s main audio
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`and video:
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`An MPEG encoder such as the encoder 520 receives content such as
`video and audio signals and converts the content into digitized streams
`of content known as elementary streams. The encoder produces
`separate elementary streams for the video content and the audio content.
`In many instances, an MPEG program, such as a movie, includes a
`video elementary stream, audio elementary streams in multiple
`different languages, and associated elementary streams, which
`include things such as the director's comments, out takes, etc., or
`whatever the producer or distributor or others desire to associate with
`the movie, such as related content to download to an external
`device.
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`Id. at ¶ 0035 (emphasis added).
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`Boudreau teaches that “related content” is transmitted to the doll through an
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`“XPORT buffer” and with a software program referred to as the “XPORT
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`application.” Id. at ¶ 0069. The “XPORT application” in Boudreau “includes
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`functionality for effecting the retrieval of related content from a data stream,
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`routing related content to an appropriate buffer or buffers, and interpreting time
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`stamps for the related content designated for transmittal and/or download[.]” Id. at
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`¶ 0072. However, nothing in Boudreau indicates that the XPORT application has
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`any involvement with processing the main audio or video for presentation on the
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`television’s display and through the television’s speakers.
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`VI. THE PETITION DOES NOT ESTABLISH A REASONABLE
`LIKELIHOOD OF SUCCESS
`The Board should deny institution because Petitioner fails to show that there
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`is a reasonable likelihood that it would prevail with respect to at least one of the
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`challenged claims. 35 U.S.C. § 314(a).
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`For brevity, the Patent Owner addresses only those arguments that are
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`necessary for the Board to determine whether to institute trial at this stage and makes
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`no admission or waiver with respect to arguments not addressed herein. Further, to
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`avoid confusion and facilitate the Board’s review, the Patent Owner adopts the
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`Petition’s labeling of claim elements of the ’803 Patent for this Response without
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`accepting the substance of the Petition’s arguments or any substantive implications
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`of such labeling.
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`A. Legal Standard
`Petitioner asserts a single obviousness ground for unpatentability in view of a
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`single prior art reference, Boudreau. However, while framed as an “obviousness”
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`challenge under Section 103, the arguments are more akin to an anticipation
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`argument under Section 102. Petitioner never identifies any potential modification
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`to Boudreau. In any case—whether considered as an “obviousness” argument or an
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`“anticipation” argument—Petitioner must show that all claim elements are present
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`in the cited art. See Personal Web Technologies, LLC v. Apple, Inc., 848 F.3d 987,
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`993 (Fed. Cir. 2017) (reversing obviousness determination for failing to explain how
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`the cited art “disclose all of the elements recited in the challenged claims”).
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`B.
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`Petitioner fails to establish that all elements of the challenged
`claims can be found in Boudreau
`The ’803 Patent is fundamentally different from that of Boudreau. The ’803
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`Patent is directed to synchronizing the audio and video signals input to a digital
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`television (EX1001, 1:12-23), whereas Boudreau is directed to an audio signal that
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`is entirely separate from the audio and video designated for the television, see supra
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`§ V, pp.10–13. Petitioner muddles this distinction and simply assumes—without
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`providing any explanation or citation—that Boudreau’s disclosure of a doll’s audio
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`can be mapped to the audio inputted into a television. This flawed analysis should
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`be rejected.
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`1.
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`Petitioner’s reliance on Boudreau’s “related content” (e.g.,
`audio for the doll) is incorrect
`The claims require a scheme for selectively processing, or bypassing the
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`processing of, the main audio for the video content displayed on the television. As
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`discussed in Section II.B, the independent claims require the audio signal outputted
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`to an external device to be an audio signal that the processing unit could alternatively
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`provide to the television’s speakers. See also, e.g., EX1001 at 4:3-5, 5:40-45, FIG.
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`3, FIG. 4, 7:21-27.
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`Petitioner ignores this requirement and argues that the claims can be satisfied
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`based on a piecemeal mapping of Boudreau’s doll audio and television audio. With
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`respect to limitation 1[b], Petitioner argues that Boudreau discloses “an audio signal
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`processing unit processing an audio signal that is provided to an audio device of the
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`video processing equipment” by citing to Boudreau’s disclosure of a digital home
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`communication terminal (DHCT) and the DHCT’s capability of processing the
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`television’s audio. Petition at 31-32. Petitioner even specifically cites to the use of
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`“an audio elementary stream” for an MPEG picture in Boudreau—something that is
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`expressly distinct from “related content” in Boudreau. Compare Petition at 32
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`(citing EX1003 at ¶ 0043), with EX1003 at ¶ 0035. Nonetheless when addressing
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`the same “audio signal” in limitation 1[c], Petitioner cites to “XPORT application”
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`in Boudreau, which is used exclusively for the doll’s audio (“related content”) and
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`not the television’s audio signal. Petition at 32-33; EX1003 at ¶ 0072 (the XPORT
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`application is used “for effecting the retrieval of related content … routing related
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`content … and interpreting time stamps for the related content designated for
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`transmittal and/or download to the external device.”). The same audio signal is also
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`recited in limitation 1[e], and Petitioner again cites to the XPORT application,
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`improperly conflating the doll’s audio with the television’s audio. Petition at 35-36.
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`Similar to its mistake with the “audio signal,” Petitioner also disregards the
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`fact that the same “audio processing unit” is recited in both limitations 1[b] and 1[e].
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`Petitioner has not shown that the XPORT application (the alleged “switching unit”
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`for 1[e]) has any ability to control the DHCT’s audio processing for the main
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`television audio, which is what Petitioner cites for 1[b]. Compare id. at 31-32 with
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`34-35. The sleight-of-hand in Petitioner’s approach is also highlighted by Petitioner
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`ignoring the claimed “audio device of the video processing equipment,” recited in
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`limitation 1[b], which is further disconnected from the XPORT application.2
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`Petitioner’s disregard for common claim terms (e.g., audio signal, audio
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`processing unit) is fatal to the Petition. Petitioner cannot change the meaning of the
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`claimed “audio signal” and “audio processing unit” in order to stitch together
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`different, incompatible aspects of Boudreau’s disclosure in a way that allegedly
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`satisfies the Challenged Claims. Petitioner does not provide any justifiable basis
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`that could support treating the claimed “audio signal” or “audio processing unit”
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`2 Independent Claims 6, 8, 9, and 16 also recite “an audio device of the video
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`processing equipment,” and Petitioner’s failure to address this element is an
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`independent basis to deny institution.
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`differently in the various instances recited in the claims. Nor does Petitioner provide
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`any obviousness argument that a POSA would modify Boudreau such that the
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`XPORT application and external doll would use the same “audio signal” as the
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`television. Thus, because all of the claims similarly require an audio signal that may
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`be provided to the television’s speakers (supra § II.B), Petitioner has failed to
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`present a prima facie obviousness case against any challenged claims.
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`2.
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`Petitioner fails to establish a reasonable likelihood that
`Boudreau discloses “a switching unit selecting paths for the
`video signal that is input to the video signal processing unit.”
`In addition to the deficiencies noted above, Petitioner also fails to establish
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`that Boudreau discloses the claimed “switching unit” that “select[s] for the video
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`signal that is input to the video signal processing unit,” as required by claim
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`limitation 1[c]. See, e.g., EX1001 at 5:40-45 (“the AV switch 41 controls the audio
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`and video signal processing paths, thereby allowing the audio and video output
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`using the speaker 46 and the display 44 of the video processing equipment, or
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`allowing the audio and video output to an external device connected to an output
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`port”). Petitioner contends that the claimed “switching unit” is disclosed by the
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`Boudreau’s disclosure of the “XPORT application.” Petition at 32-36. However,
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`as discussed above, Petitioner fails to show that the XPORT application is capable
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`of controlling anything beyond the doll’s audio, let alone selecting paths for the
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`video signal that is input to the video signal processing unit. For this additional
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`IPR2023-00240
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`reason, Petitioner fails to establish a reasonable likelihood that Boudreau renders
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`Patent Owner’s Preliminary Response
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`Claim 1 obvious.
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`VII. CONCLUSION
`For at least these reasons, Petitioner fails to establish a reasonable likelihood
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`that it would prevail with respect to at least one of the challenged claims, and thus
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`the Petition for inter partes review should be denied.
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`IPR2023-00240
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`Date: March 20, 2023
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`Patent Owner’s Preliminary Response
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`/Eliot D. Williams/
`Eliot D. Williams (Reg. No. 50,822)
`BAKER BOTTS L.L.P.
`700 K Street, N.W.
`Washington, D.C. 20001-5692
`T: (202) 639-1334
`F: (202) 639-1167
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`Peter H. Kang (Reg. No. 40,350)
`Brianna L. Potter (Reg. No. 76,748)
`BAKER BOTTS L.L.P.
`1001 Page Mill Road,
`Building One, Suite 200
`Palo Alto, CA 94304
`T: (650) 739-7500
`F: (650) 739-7699
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`Theodore W. Chandler (Reg. No.
`50,319)
`BAKER BOTTS L.L.P.
`1801 Century Park East
`Suite 2400
`Los Angeles, CA 90067
`T: (213) 202-5702
`F: (213) 202-5732
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`Ferenc Pazmandi (Reg. No. 66,216)
`Lute Yang (Reg. No. 79,253)
`BAKER BOTTS L.L.P.
`101 California Street
`Suite 3200
`San Francisco, CA 94111
`T: (415) 291-6200
`F: (415) 291-6300
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`Mark A. Speegle (Reg. No. 77,512)
`Sean Lee (Reg. No. 77,322)
`BAKER BOTTS L.L.P.
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`Patent Owner’s Preliminary Response
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`401 South First Street
`Suite 1300
`Austin, TX 78704
`T: (512) 322-2500
`F: (512) 322-2501
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`Counsel for Patent Owner
`LG Electronics Inc.
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`Patent Owner’s Preliminary Response
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`CERTIFICATE OF COMPLIANCE
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`Pursuant to 37 C.F.R. § 42.24(d), the undersigned certifies that the foregoing
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`Patent Owner Preliminary Response, exclusive of the exempted portions as provided
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`in 37 C.F.R. § 42.24(a), contains no more than 3,369 words and therefore complies
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`with the type-volume limitations of 37 C.F.R. § 42.24(b).
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`Date: March 20, 2023
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`/Eliot D. Williams/
`Eliot D. Williams (Reg. No. 50,822)
`BAKER BOTTS L.L.P.
`700 K Street, N.W.
`Washington, D.C. 20001-5692
`United States
`T: (202) 639-1334
`F: (202) 639-1167
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`Counsel for Patent Owner
`LG Electronics Inc.
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`Patent Owner’s Preliminary Response
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`CERTIFICATE OF SERVICE
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`In accordance with 37 C.F.R. § 42.6(e), the undersigned certifies that on the
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`20th day of March, 2023, a complete and entire copy of the foregoing PATENT
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`OWNER’S PRELIMINARY RESPONSE was served by email on the following
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`counsel for Petitioners:
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`Jeremy D. Peterson (Reg. No. 52,115)
`PV Law LLP
`5335 Wisconsin Avenue, N.W., Suite
`440
`Washington, DC 20015-2052
`Phone: 202.871.0140
`Fax: 202.888.3163
`Email: jeremy.peterson@pvuslaw.com
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`LGE-IPRs@pvuslaw.com
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`Date: March 20, 2023
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`Bradford A. Cangro (Reg. No. 58,478)
`PV Law LLP
`5335 Wisconsin Avenue, N.W., Suite
`440
`Washington, DC 20015-2052
`Phone: 202.871.0140
`Fax: 202.888.3163
`Email: bradford.cangro@pvuslaw.com
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`/Eliot D. Williams/
`Eliot D. Williams (Reg. No. 50,822)
`BAKER BOTTS L.L.P.
`700 K Street, N.W.
`Washington, D.C. 20001-5692
`United States
`T: (202) 639-1334
`F: (202) 639-1167
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`Counsel for Patent Owner
`LG Electronics Inc.
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