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`Exhibit 3
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`Trials@uspto.gov
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`Paper No. 13
`571-272-7822
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`Filed: July 7, 2016
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`TOYOTA MOTOR CORPORATION,
`Petitioner,
`
`v.
`
`BLITZSAFE TEXAS, LLC,
`Patent Owner.
`____________
`
`Case IPR2015-00421
`Patent 7,489,786 B2
`____________
`
`
`
`Before JAMESON LEE, THOMAS L. GIANNETTI, and HUNG H. BUI,
`Administrative Patent Judges.
`
`LEE, Administrative Patent Judge.
`
`DECISION
`Institution of Inter Partes Review
`37 C.F.R. § 42.108
`
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`I. INTRODUCTION
`
`Background
`A.
`On December 30, 2015, Petitioner filed a Corrected Petition (Paper 3,
`“Pet.”) to institute inter partes review of claims 1, 2, 4–8, 10, 13, 14, 23, 24,
`44, 47, 57, 58, 60–65, 86, 88–92, 94, 97, and 98 of U.S. Patent
`No. 7,489,786 (Ex. 1101, “the ’786 patent”). On April 22, 2016, Patent
`Owner filed a Preliminary Response (Paper 10, “Prelim. Resp.”).
`To institute an inter partes review, we must determine that the
`information presented in the Petition shows “that there is a reasonable
`likelihood that the petitioner would prevail with respect to at least 1 of the
`claims challenged in the petition.” 35 U.S.C. § 314(a). Having considered
`both the Petition and the Preliminary Response, we determine that Petitioner
`has demonstrated a reasonable likelihood that it would prevail in
`establishing the unpatentability of claims 44 and 47. Petitioner has not,
`however, shown a reasonable likelihood that it would prevail in establishing
`the unpatentability any other claim. We institute an inter partes review of
`claims 44 and 47 of the ’786 patent.
`Related Matters
`B.
`The parties indicate that the ’786 patent was asserted in five
`infringement actions before the United States District Court of the Eastern
`District of Texas and two infringement actions before the United States
`District Court for the District of New Jersey. Pet. 1–2, Paper 5, 1–2. The
`’786 patent also is involved in IPR2016-00422. Related Patent 8,155,342
`B2 is involved in IPR2016-00118, IPR2016-00418, and IPR2016-00419.
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`The ’786 Patent
`C.
`The ’786 patent is titled “Audio Device Integration System.” Ex.
`1001 (54). “One or more after-market audio devices, such as a CD player,
`CD changer, MP3 player, satellite receiver, DAB receiver, or the like, is
`integrated for use with an existing OEM or after-market car stereo system,
`wherein control commands can be issued at the car stereo and responsive
`data from the audio device can be displayed on the stereo.” Id. at Abstr.
`The ’786 patent describes:
`Control commands generated at the car stereo are received,
`processed, converted into a format recognizable by the audio
`device, and dispatched to the audio device for execution.
`Information from the audio device, including track, disc, song,
`station, time, and other information, is received, processed,
`converted into a format recognizable by the car stereo, and
`dispatched to the car stereo for display thereon.
`Id. Additional auxiliary sources also may be integrated together, and “a user
`can select between the [audio] device or the one or more auxiliary input
`sources by issuing selection commands through the car stereo.” Id. A
`docking station for docking a portable audio or video device for integration
`with the car stereo. Id. Figures 2A–2C are reproduced below:
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`Figure 2A illustrates an embodiment integrating a CD player with the car
`stereo; Figure 2B illustrates an embodiment integrating a MP3 player with a
`car stereo; and Figure 2C illustrates an embodiment integrating a satellite or
`DAB receiver with a car stereo. Id. at 3:14–23. A more versatile
`embodiment is shown in Figure 1:
`
`
`Figure 1 illustrates an embodiment integrating a CD player, a MP3 player, a
`satellite radio or DAB receiver, and a number of auxiliary input sources with
`a car stereo. Id. at 3:12–13. As shown in the above Figures, central to the
`’786 patent is an “interface” positioned between the car stereo and the audio
`device(s) and auxiliary input(s) being integrated.
`
`With regard to Figure 2B, the ’786 patent describes:
`The interface 20 allows data and audio signals to be exchanged
`between the MP3 player 30 and the car radio 10, and processes
`and formats signals accordingly so that instructions and data
`from the radio 10 are processable by the MP3 player 30, and vice
`versa. Operational commands, such as track selection, pause,
`play, stop, fast forward, rewind, and other commands, are entered
`via the control panel buttons 14 of car radio 10, processed by the
`interface 20, and formatted for execution by the MP3 player 30.
`Data from the MP3 player, such as track, time, and song
`information, is received by the interface 20, processed thereby,
`and sent to the radio 10 for display on display 13. Audio from
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`MP3 player 30 is selectively forwarded by the interface 20 to the
`radio 10 for playing.
`Id. at 6:11–24. Similar description is provided with respect to Figures 2A
`and 2C. Id. at 5:49–55, 6:35–43.
`Claims 1, 44, 57, 86, and 92 are independent. Claim 1 is directed to a
`system that connects an after-market audio device as well as one or more
`auxiliary input sources to a car stereo. In particular, claim 1 recites a first
`connector electrically connectable to a car stereo, a second connector
`electrically connectable to an after-market device, and a third connector
`electrically connectable to one or more auxiliary input sources. Id. at 21:33–
`38. Claim 1 also recites an interface connected between the first and second
`electrical connectors, and that the interface includes a microcontroller pre-
`programmed to execute:
`a first pre-programmed code portion for remotely controlling the
`after-market audio device using the car stereo by receiving a
`control command from the car stereo through said first
`connector in a format incompatible with the after-market
`audio device, processing the received control command into
`a formatted command compatible with the after-market audio
`device, and transmitting the formatted command to the after-
`market audio device through said second connector for
`execution by the after-market audio device;
`a second pre-programmed code portion for receiving data from
`the after-market audio device through said second connector
`in a format incompatible with the car stereo, processing the
`received data into formatted data compatible with the car
`stereo, and transmitting the formatted data to the car stereo
`through said first connector for display by the car stereo; and
`a third pre-programmed code portion for switching to one or
`more auxiliary input sources connected to said third electrical
`connector.
`Id. at 21:44–64.
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`Claim 57 is directed to a system including an interface that connects a
`portable MP3 player to a car stereo. Claim 86 is directed to a system
`including an interface that connects an after-market video device to a car
`stereo. Claim 92 is directed to a system including an interface that connects
`a portable audio device with a car stereo. Claims 57, 86, and 92 each require
`the generation, within an interface, of a device presence signal that is
`transmitted to the car stereo to maintain the car stereo in an operational state.
`Claims 57, 86, and 92 are reproduced below:
`57. An audio device integration system comprising:
`a first electrical connector connectable to a car stereo;
`a second electrical connector connectable to a portable MP3
`player external to the car stereo
`an interface connected between said first and second electrical
`connectors for transmitting audio from a portable MP3 player
`to a car stereo, said interface including a microcontroller in
`electrical communication with said first and second electrical
`connectors,
`said microcontroller pre-programmed to execute:
`a first pre-programmed code portion for generating a
`device presence signal and transmitting the signal to
`the car stereo to maintain the car stereo in an
`operational state; and
`a second pre-programmed code portion for remotely
`controlling the MP3 player using the car stereo by
`receiving a control command from the car stereo
`through said first electrical connector in a format
`incompatible with the MP3 player, processing the
`control command into a formatted control command
`compatible with the MP3 player, and transmitting
`the formatted control command to the MP3 player
`through said second electrical connector for
`execution by the MP3 player.
`
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`Id. at 26:13–37.
`86. A device for integrating video information for use with a car
`stereo, comprising:
`a first electrical connector connectable to a car stereo;
`a second electrical connector connectable to an after-market
`video device external to the car stereo;
`an interface connected between said first and second electrical
`connectors for transmitting video information from the after-
`market video device to the car stereo, the interface including
`a microcontroller in electrical communication with said first
`and second electrical connectors, said microcontroller pre-
`programmed to execute:
`a first pre-programmed code portion for generating a
`device presence signal and transmitting the signal to
`the car stereo through said first electrical connector
`to maintain the car stereo in an operational state
`responsive to signals generated by the after-market
`video device.
`Id. 28:40–56.
`92. An audio device integration system comprising:
`a car stereo;
`a portable audio device external to the car stereo;
`an interface connected between the car stereo and the portable audio
`device, the interface including a microcontroller pre-programmed
`to execute:
`first pre-programmed means for generating a device presence
`signal and transmitting the signal to the car stereo to
`maintain the car stereo in an operational state;
`second pre-programmed means for remotely controlling the
`portable audio device using the car stereo by receiving a
`control command from the car stereo in a format
`incompatible with the portable audio device, processing
`the control command into a formatted control command
`compatible with
`the portable audio device, and
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`transmitting the formatted control command to the
`portable audio device for execution thereby; and
`means for transmitting audio from the portable audio device
`to the car stereo.
`Id. at 29:11–31.
`Claim 44 is directed to an apparatus for docking a portable device for
`integration with a car stereo. We reproduce claim 44 in the portion of our
`analysis below specifically discussing claim 44.
`Evidence Relied Upon
`D.
`Petitioner relies on the following references:1
`
`
`
`Reference
`
`Lau
`
`International Pub. No. WO
`01/67266 A1
`
`Date
`
`Exhibit
`
`Sept. 13, 2001 Ex. 1103
`
`JP ’9542
`
`Jap. Pub. App. No. H7–6954
`
`Jan. 31, 1995
`
`Ex. 1106
`
`XR-C5120
`
`XA-C30
`
`SONY® 3-865-814-11(1)
`Operating Instructions, Model
`No. XR-C5120 /4890
`
`SONY® 9-923-535-11
`Source Selector
`Service Manual XA-C30
`
`1999
`
`Ex. 1108
`
`March, 1996
`
`Ex. 1109
`
`Bhogal
`
`U.S. Patent No. 6,629,197 B1
`
`Sept. 30, 2003 Ex. 1110
`
`
`1 For certain alleged grounds of unpatentability, Petitioner also relies on
`what it refers to as “known bus technology.” Hereinafter, we refer to that
`material as “KBT.” We understand Petitioner to have presented KBT as
`common knowledge and routine skill within the level of ordinary skill in the
`art that does not require citation of any particular reference.
`2 All citations to specific content of JP’954 refer to its English Translation
`(Ex. 1107).
`
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`Petitioner also relies on the Declaration of Thomas G. Matheson,
`Ph.D. Ex. 1115.
`The Asserted Grounds
`E.
`Petitioner asserts the following grounds of unpatentability:
`Claim(s) Challenged
`Basis
`References
`57, 58, 60, 64, 86, 88, 90, 91,
`92, 94, and 97
`61, 62, and 63
`
`§ 103(a)
`
`§ 103(a)
`
`JP ’954 and Lau
`JP ’954, Lau, and XR-
`C5120
`JP ’954, Lau, and KBT
`JP ’954, XR-C5120, and
`XA-C30
`JP ’954, XR-C5120, XA-
`C30, and KBT
`JP ’954, XR-C5120, XA-
`C30, and Lau
`JP ’954, Lau, and Bhogal
`
`65, 89, and 98
`
`§ 103(a)
`
`1, 2, 4, 7, 8, 13, 14, and 23
`
`§ 103(a)
`
`5 and 24
`
`6 and 10
`
`44 and 47
`
`§ 103(a)
`
`§ 103(a)
`
`§ 103(a)
`
`57, 86, and 92
`
`§ 103(a)
`
`II. ANALYSIS
`The question of obviousness is resolved on the basis of underlying
`factual determinations including: (1) the scope and content of the prior art;
`
`JP ’954, Lau, and Bhogal3
`
`
`3 Petitioner identifies this alleged ground of unpatentability simply as
`“obvious in view of Bhogal.” Pet. 57. However, a plain reading of
`Petitioner’s analysis on pages 57–59 of the Petition reveals that the alleged
`ground actually is that of obviousness over JP ’954, Lau, and Bhogal. Also,
`although Petitioner labels this ground as directed to claims 57 and 86, a plain
`reading of the Petitioner’s analysis reveals that it is intended to apply to
`claims 57 and 92. We have restated the applicable claims as 57, 86, and 92.
`
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`(2) any differences between the claimed subject matter and the prior art;
`(3) the level of ordinary skill in the art; and (4) objective evidence of
`nonobviousness. Graham v. John Deere Co., 383 U.S. 1, 17–18 (1966).
`One seeking to establish obviousness based on more than one reference also
`must articulate sufficient reasoning with rational underpinnings to combine
`teachings. See KSR Int’l Co. v. Teleflex, Inc., 550 U.S. 398, 418 (2007).
`With regard to the level of ordinary skill in the art, we determine that
`no express finding is necessary, on this record, and that the level of ordinary
`skill in the art is reflected by the prior art of record. See Okajima v.
`Bourdeau, 261 F.3d 1350, 1355 (Fed. Cir. 2001); In re GPAC Inc., 57 F.3d
`1573, 1579 (Fed. Cir. 1995); In re Oelrich, 579 F.2d 86, 91 (CCPA 1978).
`Claim Construction
`A.
`In an inter partes review, claim terms in an unexpired patent are
`interpreted according to their broadest reasonable construction in light of the
`specification of the patent in which they appear. See 37 C.F.R. § 42.100(b);
`Cuozzo Speed Techs., LLC v. Lee, No. 15–446, 2016 WL 3369425, at *12
`(U.S. June 20, 2016) (upholding the use of the broadest reasonable
`interpretation standard as the claim construction standard to be applied in an
`inter partes review proceeding). Consistent with the rule of broadest
`reasonable interpretation, claim terms also are given their ordinary and
`customary meaning, as would be understood by one of ordinary skill in the
`art in the context of the entire disclosure. See In re Translogic Tech., Inc.,
`504 F.3d 1249, 1257 (Fed. Cir. 2007).
`“Claims are not interpreted in a vacuum, but are part of and are read
`in light of the specification.” Slimfold Mfg. Co. v. Kinkead Indus., Inc.,
`810 F.2d 1113, 1116 (Fed. Cir. 1987). Although it is improper to read a
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`limitation from the specification into the claims, In re Van Geuns, 988 F.2d
`1181, 1184 (Fed. Cir. 1993), the claims still must be read in view of the
`specification of which they are a part. Microsoft Corp. v. Multi-Tech Sys.,
`Inc., 357 F.3d 1340, 1347 (Fed. Cir. 2004).
`If a limitation of an embodiment described in the specification is not
`necessary to give meaning to a claim term, it would be “extraneous” and
`should not be read into the claim. See Hoganas AB v. Dresser Indus., Inc.,
`9 F.3d 948, 950 (Fed. Cir. 1993); E.I. du Pont de Nemours & Co. v. Phillips
`Petroleum Co., 849 F.2d 1430, 1433 (Fed. Cir. 1988). If the applicants for a
`patent desire to be their own lexicographer, the purported definition must be
`set forth in either the specification or prosecution history. See CCS Fitness,
`Inc. v. Brunswick Corp., 288 F.3d 1359, 1366 (Fed. Cir. 2002). Such a
`definition must be set forth with reasonable clarity, deliberateness, and
`precision. See Renishaw PLC v. Marposs Societa’ per Azioni, 158 F.3d
`1243, 1249 (Fed. Cir. 1998); In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir.
`1994). However, only terms which are in controversy need to be construed,
`and only to the extent necessary to resolve the controversy. See Wellman,
`Inc. v. Eastman Chem. Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011); Vivid
`Techs., Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999).
`“portable”
`1.
`Independent claim 44 recites a portable device. Independent claim 57
`recites a portable MP3 player. Independent claim 92 recites a portable audio
`device. Petitioner proposes that the term “portable” be construed the way it
`has been construed by the district court in related actions involving the ’786
`patent, i.e., “capable of being moved about.” Pet. 13–14 (citing Ex. 1112).
`Patent Owner argues that Petitioner’s proposed construction is unreasonably
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`broad because it “improperly broadens the plain meaning of the term to
`include anything which can be moved, no matter how large or unwieldy.”
`Prelim. Resp. 9. Patent Owner asserts that one with ordinary skill in the art
`could readily understand the plain meaning of the term “portable,” and that
`no further construction is necessary. Id.
`We agree with Patent Owner that Petitioner’s proposed construction is
`unreasonably broad. In the Specification of the ’786 patent, the term
`“portable” is used to modify devices that can be integrated with a car stereo
`through an interface. In that context, not every device that is capable of
`being moved is reasonably deemed portable. Few items, if any, simply
`cannot be moved, given appropriate tools and persistent effort. Thus, the
`term must be read in context within its application environment. In that
`regard, we note that certain objects, although heavy and large, may be
`deemed portable, such as freight containers and emergency generators.
`It may be that the term requires no express construction, and simply
`would be understood by one with ordinary skill in the art. We note that even
`the ’786 patent itself and Bhogal, both using the term “portable” in their
`written description, do not provide a definition therefor. Nevertheless, an
`express construction is helpful to this proceeding. We construe “portable,”
`in the context of the ’786 patent, as meaning capable of being carried by a
`user.
`
`“interface”
`2.
`Of all challenged claims, claims 1, 44, 57, 86, and 92 are independent,
`
`and each recites an “interface.”
`Claims 1, 57, and 86 require the interface to be connected between a
`first electrical connector and a second electrical connector, where the first
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`connector is connectable to a car stereo and the second connector is
`connectable to an after-market audio device (claim 1), a portable MP3 player
`(claim 57), or an after-market video device (claim 86). Claim 92 requires
`the interface to be connected between the car stereo and a portable audio
`device. Claim 44 recites a docking portion that mates with a portable
`device, and an interface that is connected to the car stereo as well as to a data
`port that communicates with the docking portion.
`Also, claim 57 recites that the interface is “for transmitting audio from
`a portable MP3 player to a car stereo”; claim 86 recites that the interface is
`“for transmitting video information from the after-market video device to the
`car stereo”; claim 1 recites that the interface is “for channeling audio signals
`to the car stereo from the after-market audio device”; claim 44 recites an
`interface for “channeling audio from the portable device to the car stereo”;
`and claim 92 recites that the interface includes a microcontroller pre-
`programmed to execute “means for transmitting audio from the portable
`audio device to the car stereo.”
`Petitioner proposes the proper construction of “interface” is “a
`microcontroller that is functionally and structurally separate component
`from the car stereo, which integrates an after-market device with a car
`stereo,” and notes that that is the construction determined by the district
`court in related actions involving the ’786 patent. Pet. 12–14. For several
`reasons, the proposal is unpersuasive. First, as is noted by Patent Owner,
`even if the interface is deemed “functionally and structurally separate” from
`the car stereo, the proposed construction is incomplete in that it omits any
`requirement of separation or distinctness of the interface from the portable or
`after-market device connected thereto. Prelim. Resp. 8–9. Second, the
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`proposed construction is too narrow by specifying that the interface
`“integrates an after-market device with a car stereo.” We note that the
`Specification of the ’786 patent provides a special definition for
`“integration” or “integrated.” Ex. 1101, 4:47–52. We discern no reason to
`import limitations into a claim if they are unnecessary to accord meaning to
`the claim.
`Third, the proposed construction is too narrow by requiring the
`interface to be a microcontroller. In the Specification of the ’786 patent, the
`term “interface” is described as including not only a microcontroller but also
`several discrete components, such as resistors, diodes, capacitors, transistors,
`oscillators, amplifiers, and multiplexers, shown in various embodiments of
`Figures 3A, 3B1–3B2, 3C1–3C2, and 3D. Ex. 1101, 9:8–20, 10:19–33,
`11:4–18, 11:59–67. Thus, the term “interface” itself is not limited to a
`microcontroller. In that regard, we note that if the interface itself is
`construed as a microcontroller, as Petitioner proposes, then the additional
`claim language reciting that the interface includes a microcontroller would
`serve no meaningful purpose.
`With regard to an “interface,” the Specification states:
`Thus, as can be readily appreciated, the interface 20 of the
`present invention allows for the integration of a multitude of
`devices and inputs with an OEM or after-market car radio or
`stereo.
`Ex. 1101, 5:33–36.
`As mentioned earlier, the interface 20 of the present invention
`allows for a plurality of disparate audio devices to be integrated
`with an existing car radio for use therewith.
`Id. at 6:4–7.
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`Data from the MP3 player, such as track, time, and song
`information, is received by the interface 20, processed thereby,
`and sent to the radio 10 for displaying on display 13. Audio from
`the MP3 player 30 is selectively forwarded by the interface 20 to
`the radio 10 for playing.
`Id. at 6:19–24. Thus, the Specification refers to the interface receiving
`information from an audio device and forwarding information to the car
`stereo, and to the interface allowing integration of a plurality of disparate
`audio devices with a car radio.
`
`During prosecution, the Applicants of the ’786 patent distinguished
`U.S. Patent 6,993,615 B2 (“Falcon”),4 in part by arguing that the reference
`failed to disclose an interface connected between a car stereo and an external
`audio source. Ex. 1102, 0267. Specifically, in distinguishing the invention
`from Falcon, Applicants stated: “[Falcon’s graphical user interface] is an
`entirely different concept than the interface of the present invention, which
`includes a physical interface device connected between a car stereo system
`and an external audio source (e.g., a plurality of auxiliary input sources).”
`Id.
`Construing the term “interface” in light of the Specification, other
`
`language in the claims, as well as the prosecution history noted by
`Petitioner, we determine that—interface is a physical unit that connects one
`device to another and that has a functional and structural identity separate
`from that of both connected devices.
`
`
`4 Falcon discloses a portable computing device connectable to a car stereo
`through an interface configurable within the portable computing device.
`Ex. 3001, Abstr.
`
`15
`
`
`
`

`
`Case 2:15-cv-01274-JRG-RSP Document 133-4 Filed 08/15/16 Page 17 of 45 PageID #:
` 3488
`IPR2016-00421
`Patent 7,489,786 B2
`
`
`In the specific context of claims 1 and 86, the connected devices are
`the car stereo and an after-market device. In the specific context of claims
`44, 57, and 92, the connected devices are the car stereo and a portable
`device. Each of claims 1, 44, 57, 86, and 92 further requires the interface to
`include a microcontroller.
`“device presence signal”
`3.
`Each of claims 57 and 86 requires within the interface a
`
`microcontroller having a first pre-programmed code portion “for generating
`a device presence signal and transmitting the signal to the car stereo to
`maintain the car stereo in an operational state.” (Emphasis added). Claim
`92 requires within the interface a microcontroller pre-programmed to
`execute “first pre-programmed means for generating a device presence
`signal and transmitting the signal to the car stereo to maintain the car stereo
`in an operational state.” (Emphasis added). A description of “device
`presence signal” is contained in the Specification in the discussion of an
`embodiment that is for connecting a CD player to the car stereo:
`Beginning in step 110, a signal is generated by the present
`invention indicating that a CD player/changer is present, and the
`signal is continuously transmitted to the car stereo. Importantly,
`this signal prevents the car stereo from shutting off, entering a
`sleep mode, or otherwise being unresponsive to signals and/or
`data from an external source.
`Ex. 1001, 12:29–35. All other disclosed embodiments, whether they are for
`connecting an MP3 player or an auxiliary device to the car stereo, refer back
`to the above-quoted description of the device presence signal. Id. at 13:15–
`18, 13:62–65, 14:48–51, 15:35–38, 16:12–15, 16:57–60.
`Petitioner proposes that the term “device presence signal” be
`construed the way it has been construed by the district court in related
`
`16
`
`
`
`

`
`Case 2:15-cv-01274-JRG-RSP Document 133-4 Filed 08/15/16 Page 18 of 45 PageID #:
` 3489
`IPR2016-00421
`Patent 7,489,786 B2
`
`actions involving the ’786 patent, i.e., “transmission of a continuous signal
`indicating an audio device is present.” Pet. 13 (citing Ex. 1112). Patent
`Owner has not proposed a construction. For two reasons, we do not adopt
`Petitioner’s proposed construction.
`First, the proposed construction is too narrow because continuous
`transmission is not necessary to accord meaning to the term. The manner of
`transmission simply reflects how the signal is transmitted and does not
`change what the signal was generated and intended to accomplish and
`actually accomplishes. The Specification also does not put continuous
`transmission in the same category of importance as the requirements in the
`italicized portion of the above-quoted text.
`Second, in claims 57 and 86, the device presence signal is generated
`and transmitted by the interface that is connected between the first and
`second electrical connector, where the first electrical connector is
`connectable to a car stereo and the second electrical connector is connectable
`to a portable MP3 player (claim 57) or an after-market video device (claim
`86). Claim 57 recites that the interface is for transmitting audio from the
`portable MP3 player to the car stereo, and claim 86 recites that the interface
`is for transmitting video information from the after-market video device to
`the car stereo. In claim 92, the device presence signal is generated and
`transmitted by the interface that is connected between the car stereo and the
`portable audio device. Claim 92 further includes, within the interface, a
`means for transmitting audio from the portable audio device to the car
`stereo. In the context of these claims, the device the presence of which is
`signaled by the interface is that device which connects to the interface to
`
`17
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`

`
`Case 2:15-cv-01274-JRG-RSP Document 133-4 Filed 08/15/16 Page 19 of 45 PageID #:
` 3490
`IPR2016-00421
`Patent 7,489,786 B2
`
`communicate with the car stereo. Petitioner’s proposed construction does
`not make that clear.
`On the record before us, we construe “device presence signal,” as a
`signal indicating that an audio device (claim 57) or video device (claim 86)
`or portable audio device (claim 92), other than the car stereo, is connected
`to the interface.
`Alleged Obviousness of Claims 57, 58, 60, 64,
`B.
`86, 88, 90, 91, 92, 94, and 97 over JP ’954 and Lau
`We have reviewed the Petition and the Preliminary Response, and
`
`determine that Petitioner has not shown a reasonable likelihood that it would
`prevail in establishing unpatentability of claims 57, 58, 60, 64, 86, 88, 90,
`91, 92, 94, and 97 as obvious over JP ’954 and Lau.
`JP ’954
`1.
`JP ’954 is directed to solving the problem of equipment
`incompatibility, in the environment of automotive audio equipment, between
`a main unit made by one company and a CD changer made by another
`company. Ex. 1101, Abstr. Specifically, JP ’954 describes the
`disadvantages associated with prior art systems as follows:
`When installing an audio device in a vehicle on the occasion of
`a vehicle purchase, it is common for a so-called “basic” main unit
`to be installed. If one were to subsequently attempt to add a CD
`changer capable of automatically changing and playing a
`plurality of loaded CDs, prior to now it would have been
`necessary to purchase and install a model produced by the same
`manufacturer ass the “basic” main unit, as the format of signals
`connecting the respective devices vary from manufacturer to
`manufacturer. Furthermore, if a user had installed both of these
`devices produced by the same manufacturer, and at a later point
`wished to upgrade the main unit to, for example, a model
`produced by company A, it would have been necessary for the
`
`18
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`

`
`Case 2:15-cv-01274-JRG-RSP Document 133-4 Filed 08/15/16 Page 20 of 45 PageID #:
` 3491
`IPR2016-00421
`Patent 7,489,786 B2
`
`
`same reason to also purchase a new CD changer made by
`company A.
`Id. (0002). JP ’954 describes its objective as: “to make it possible to add a
`CD changer made by company B to a main unit made by company A, as
`well as to add a CD changer made by company A to a main unit made by
`company B.” Id. (0003). JP ’954 achieves that objective by providing an
`interface unit as noted below:
`(PROBLEM) Provide an interface unit for automotive audio
`equipment that renders possible the addition of a CD changer
`made by company B to a main unit made by company A as well
`as the addition of a CD cha

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