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`Exhibit 4
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`VOLKSWAGEN GROUP OF AMERICA, INC.
`
`Petitioner
`
`
`Patent No. 8,155,342
`Issue Date: April 10, 2012
`Title: MULTIMEDIA DEVICE INTEGRATION SYSTEM
`__________________________________________________________________
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 8,155,342
`PURSUANT TO 35 U.S.C. § 312 and 37 C.F.R. § 42.104
`
`Case No. IPR2016-01445
`__________________________________________________________________
`
`
`
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`

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`Case 2:15-cv-01274-JRG-RSP Document 133-5 Filed 08/15/16 Page 3 of 75 PageID #:
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`I. 
`II. 
`III. 
`
`TABLE OF CONTENTS
`Mandatory Notices (37 C.F.R. § 42.8) ........................................................... 1 
`Grounds for Standing (37 C.F.R. § 42.104(a)) ............................................... 2 
`Identification of Challenge (37 C.F.R. § 42.104(b)(1)-(3)) and Relief
`Requested (37 C.F.R. § 42.22(a)(1)) .............................................................. 3 
`A. 
`The Challenged Claims of the ’342 Patent Are Not Entitled to
`a Filing Date Earlier than June 27 2006 ............................................... 3 
`The ’342 Patent .................................................................................... 4 
`B. 
`Prosecution History of the ’342 Patent ................................................ 4 
`C. 
`Patents and Printed Publications Relied On ......................................... 7 
`D. 
`Statutory Grounds for Challenge (37 C.F.R. § 42.104(b)(1)–(2)) ....... 8 
`E. 
`Claim Construction (37 C.F.R. § 42.104(b)(3)) ................................... 8 
`F. 
`IV.  How Challenged Claims Are Unpatentable (37 C.F.R. § 42.104(b)(4)–
`(5)) .................................................................................................................. 9 
`A. 
`Claims 49-57, 62-64, 66, 68, 70, 71, 73-80, 94, 95, 97, 99-103,
`106, 109-111, 113, 115, and 120 are Obvious in View of
`Marlowe and Clayton ......................................................................... 10 
`1. 
`Independent Claims 49, 73, 97, and 120 .................................. 12 
`2. 
`Dependent Claims 50-57, 62-64, 66, 68, 70, 71, 74-80,
`94, 95, 99-103, 106, 109-111, 113, and 115 ............................ 19 
`Obviousness in View of Marlowe and Clayton ....................... 22 
`3. 
`Claims 49-57, 62-64, 66, 68, 70, 71, 73-80, 94, 95, 97, 99-103,
`106, 109-111, 113, 115, and 120 are Obvious in View of
`Marlowe and Silvester ........................................................................ 24 
`1. 
`Independent Claims 49, 73, 97, and 120 .................................. 25 
`2. 
`Dependent Claims 50-57, 62-64, 66, 68, 70, 71, 74-80,
`94, 95, 99-103, 106, 109-111, 113, and 115 ............................ 27 
`Obviousness in View of Marlowe and Silvester ...................... 29 
`3. 
`Claim Charts ....................................................................................... 30 
`C. 
`The Proposed Grounds of Unpatentability are not Redundant .................... 68 
`V. 
`VI.  Conclusion .................................................................................................... 69 
`
` 
`
`B. 
`
`i
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`LISTING OF EXHIBITS
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`U.S. Patent No. 8,155,342 to Marlowe
`
`Declaration of Scott Andrews
`
`and
`of Asserted Claims
`Plaintiff’s Disclosure
`Infringement Contentions, served in Blitzsafe Texas, LLC
`v. Honda Motor Co., Ltd. et al., Case No. 2:15-cv-1274
`(E.D. Tex)
`
`U.S. Patent No. 7,489,786 to Marlowe
`
`U.S. Patent Application Publication No. 2003/0215102 to
`Marlowe
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`U.S. Patent Application Publication No. 2006/0181963 to
`Clayton
`
`U.S. Patent Application Publication No. 2003/0171834 to
`Silvester
`
`Plaintiff Blitzsafe Texas LLC’s Opening Claim
`Construction Brief, D.I. 98, filed May 13, 2016 in
`Blitzsafe Texas, LLC v. Honda Motor Co., Ltd. et al.,
`Case No. 2:15-cv-1274 (E.D. Tex.)
`
`Exhibit 1001
`
`Exhibit 1002
`
`Exhibit 1003
`
`
`Exhibit 1004
`
`Exhibit 1005
`
`
`Exhibit 1006
`
`
`Exhibit 1007
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`
`Exhibit 1008
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`
`
`ii
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`I. Mandatory Notices (37 C.F.R. § 42.8)
`
`
`
`Real-Party-in Interest:
`
`Volkswagen Group of America, Inc. (“VWGoA”), which is a subsidiary of
`
`Volkswagen AG.
`
`Related Matters:
`
`The following judicial matters may affect, or be affected by, a decision in
`
`this inter partes review: Blitzsafe Texas, LLC v. Honda Motor Co., Ltd. et al., 2:15-
`
`cv-01274 (E.D. Tex.); Blitzsafe Texas, LLC v. Hyundai Motor Co. et al., 2:15-cv-
`
`01275 (E.D. Tex.); Blitzsafe Texas, LLC v. Nissan Motor Co., Ltd. et al., 2:15-cv-
`
`01276 (E.D. Tex.); Blitzsafe Texas, LLC v. Toyota Motor Corporation et al., 2:15-
`
`cv-01277 (E.D. Tex.); Blitzsafe Texas, LLC v. Volkswagen Group of America, Inc.
`
`et al., 2:15-cv-01278 (E.D. Tex.), in which VWGoA and Volkswagen Group of
`
`America Chattanooga Operations, LLC, which is a subsidiary of VWGoA, are
`
`defendants; Marlowe Patent Holdings LLC v. Ford Motor Company, 3:11-cv-
`
`07044 (D.N.J.); and Marlowe Patent Holdings LLC v. Dice Electronics, LLC, et
`
`al., 3:10-cv-01199 (D.N.J.).
`
`The following administrative matters may affect, or be affected by, a
`
`decision in this inter partes review: IPR2016-00418, IPR2016-00419, IPR2016-
`
`00421, IPR2016-00422, IPR2016-00118, IPR2016-01448 and IPR2016-01449
`
`(both filed by VWGoA simultaneously with this petition), U.S. Pat. App. Ser. Nos.
`1
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`60/523,714, 10/732,909, 11/071,667, 11/805,799, 11/928,408, 11/928,474,
`
`11/928,534, 11/929,757, 11/928,503, and 10/316,961 (which issued as U.S. Pat.
`
`No. 7,489,786).
`
`Lead Counsel:
`
`Michael J. Lennon (Reg. No. 26,562)
`
`Backup Counsel:
`
`Clifford A. Ulrich (Reg. No. 42,194)
`
`Service:
`
`VWGoA agrees to electronic service at the following email addresses:
`
`mlennon@kenyon.com
`culrich@kenyon.com
`
`Service may be made at the following address:
`
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`Telephone: 212-425-7200
`Facsimile: 212-425-5288
`
`II. Grounds for Standing (37 C.F.R. § 42.104(a))
`
`VWGoA certifies that U.S. Pat. No. 8,155,342 (“the ’342 patent,” Ex. 1001)
`
`is available for inter partes review and that VWGoA is not barred or estopped
`
`from requesting an inter partes review challenging the patent claims on the
`
`grounds identified in this petition.
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`2
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`III. Identification of Challenge (37 C.F.R. § 42.104(b)(1)-(3)) and
`Relief Requested (37 C.F.R. § 42.22(a)(1))
`
`Claims 49-57, 62-64, 66, 68, 70, 71, 73-80, 94, 95, 97, 99-103, 106, 109-
`
`111, 113, 115, and 120 of the ’342 patent are invalid under 35 U.S.C. § 103, and
`
`cancelation of these claims is requested.
`
`A. The Challenged Claims of the ’342 Patent Are Not
`Entitled to a Filing Date Earlier than June 27 2006
`
`The challenged claims of the ’342 patent are not entitled to a filing date
`
`earlier than the June 27, 2006 filing date of U.S. Pat. App. Ser. No. 11/475,847
`
`(“the ’847 application”).
`
`The ’342 patent issued from the ’847 application, which was filed as a CIP
`
`of U.S. Pat. App. Ser. No. 11/071,667, filed Mar. 3, 2005, which is a CIP of U.S.
`
`Pat. App. Ser. No. 10/732,909, filed Dec. 10, 2003, which is a CIP of U.S. Pat.
`
`App. Ser. No. 10/316,961, filed Dec. 11, 2002 (now U.S. Pat. No. 7,489,786).
`
`The challenged claims describe a wireless interface for integrating an after-
`
`market device with a car stereo. While the ’847 application describes wireless
`
`interfaces, none of the earlier applications describe wireless interfaces. Instead, all
`
`of the earlier applications describe only wired interfaces, such that the earlier
`
`applications fail to enable the subject matter claimed in the challenged claims and
`
`fail to provide an adequate written description of the subject matter claimed in the
`
`challenged claims. The challenged claims therefore are not entitled to a filing date
`
`3
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`earlier than the June 27, 2006 filing date of the ’847 patent.
`
`This conclusion is confirmed by Patent Owner’s statements in the pending
`
`litigation in which Petitioner is a defendant. Plaintiff’s Disclosure of Asserted
`
`Claims and Infringement Contentions, Ex. 1003, at 6 (“Each of the asserted claims
`
`of the ’342 patent is entitled to the priority date of U.S. Patent Application No.
`
`11/475/847 [sic], filed June 27, 2006.”).
`
`B. The ’342 Patent
`
`The ’342 patent describes a multimedia integration system that wirelessly
`
`integrates portable audio and/or video devices with a car audio and/or video
`
`system, using a wireless interface and an integration subsystem. Ex. 1001, 5:7-30;
`
`Ex. 1002, ¶¶ 3-5. Of the challenged claims, claims 1, 25, 49, 73, 97 and 120 are
`
`independent claims.
`
`C. Prosecution History of the ’342 Patent
`
`As described below, during prosecution, the claims of the ’342 patent were
`
`repeatedly rejected in view of the prior art, and were allowed only after the
`
`Applicant argued that the prior art does not describe an integration subsystem that
`
`instructs the portable device to play an audio file in response to a user operating the
`
`controls of a car audio/video system, that receives or channels audio from the
`
`portable device for playing on the car audio/video system, or that processes control
`
`commands from the car audio/video system into a format compatible with the
`
`4
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`portable device.
`
`The ’847 application initially included claims 1-91, which were canceled in
`
`favor of application claims 92-212, in a Response of November 30, 2009.
`
`Application claims 140, 164, and 188 would issue as patent claims 49, 73, and 97.
`
`In an Office Action dated March 5, 2010, all pending claims were rejected
`
`for obviousness-type double patenting over claims 1-99 of U.S. Patent No.
`
`7,489,786 (Ex. 1004), a parent to the ’342 patent. According to the Examiner, the
`
`claims from the earlier Marlowe ’786 patent were similar to the pending claims,
`
`and the differences in the claims would have been obvious: replacing a wired
`
`connection with a wireless connection was well-known in the art, and the
`
`placement of the integration subsystem in the portable device or in the car
`
`audio/video system would be a mere design choice. March 5, 2010 Office Action,
`
`at 2-3 (“[I]t is well known in the art that direct electrical communication lines may
`
`be replaced by wireless
`
`interfaces
`
`that achieve
`
`the same functions of
`
`communicating data…. [I]t would have been obvious to mount the integration
`
`subsystem in either the portable device or the car AV system.”). The Examiner
`
`stated that dependent claims 193 (for processing control commands into a format
`
`compatible with the portable device) and 194 (for processing data into a format
`
`compatible with the car audio/video) included allowable subject matter. The
`
`Applicant responded on April 30, 2010, filing a terminal disclaimer over the earlier
`
`5
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`Marlowe ’786 patent, amending application claim 188 to include the subject matter
`
`of dependent claim 193, and adding new application claim 213 to include the
`
`subject matter of dependent claim 194. As noted above, application claim 188
`
`would eventually issue as patent claim 97. Application claim 213 would eventually
`
`issue as patent claim 120.
`
`In an Office Action dated February 15, 2011, the claims were rejected in
`
`view of U.S. Patent No. 7,493,643 (“Tranchina”). The Applicant responded on
`
`August 15, 2011, arguing against the rejection, and held an interview with the
`
`Examiner on November 8, 2011, to discuss the rejection based on Tranchina, but
`
`no agreement was reached. The claims were again rejected, based on Tranchina, on
`
`November 29, 2011.
`
`The Applicant then responded, on January 29, 2012, without amendment,
`
`arguing that Tranchina does not describe an integration subsystem that “instructs
`
`the portable device to play the audio file in response to a user selecting the audio
`
`file using controls of the car audio/video system, and transmits audio generated by
`
`the portable device over said wireless communication link to the car audio/video
`
`system for playing on the car audio/video system,” according to application claim
`
`92. The Applicant argued that application claims 140, 164, and 213 (to be patent
`
`claims 49, 73, and 120) include “identical or analogous” limitations, and were
`
`therefore allowable for the same reasons. Jan. 29, 2012 Reply to Office Action, at
`
`6
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`33-35. As to application claim 188 (to be patent claim 97), the Applicant argued
`
`that Tranchina does not describe an integration system that “receives a control
`
`command issued by a user through one or more controls of the car audio/video
`
`system in a format incompatible with the portable device, processes the control
`
`command into a formatted command compatible with the portable device, and
`
`dispatches the formatted command to the portable device for execution thereby.”
`
`Id. at 36 (“The claim therefore requires (paraphrasing) the subsystem to receive a
`
`user command issued through the controls of the car audio/video system, and
`
`convert the command into a format acceptable to the portable device.”).
`
`In response to these arguments, the Examiner allowed the pending claims on
`
`February 16, 2012.
`
`D. Patents and Printed Publications Relied On
`
`1. U.S. Patent Appl. Pub. No. 2003/0215102 (“Marlowe,” Ex. 1005),
`
`published November 20, 2003, from U.S. Patent Appl. No. 10/316,961, filed
`
`December 11, 2002, constitutes prior art against the ’342 patent under 35 U.S.C. §
`
`102(b).
`
`2. U.S. Patent Appl. Pub. No. 2006/0181963 (“Clayton,” Ex. 1006),
`
`published August 17, 2006, from U.S. Patent Appl. No. 11/296,975, filed
`
`December 8, 2005, constitutes prior art against the ’342 patent under 35 U.S.C. §§
`
`102(a), (e).
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`3. U.S. Patent Appl. Pub. No. 2003/0171834 (“Silvester,” Ex. 1007),
`
`published September 11, 2003, from U.S. Patent Appl. No. 10/094,220, filed
`
`March 7, 2002, constitutes prior art against the ’342 patent under 35 U.S.C. §
`
`102(b).
`
`E. Statutory Grounds for Challenge (37 C.F.R. § 42.104(b)(1)–(2))
`
`1. Claims 49-57, 62-64, 66, 68, 70, 71, 73-80, 94, 95, 97, 99-103, 106, 109-
`
`111, 113, 115, and 120 are obvious under 35 U.S.C. § 103(a) in view Marlowe and
`
`Clayton.
`
`2. Claims 49-57, 62-64, 66, 68, 70, 71, 73-80, 94, 95, 97, 99-103, 106, 109-
`
`111, 113, 115, and 120 are obvious under 35 U.S.C. § 103(a) in view of Marlowe
`
`and Silvester.
`
`F. Claim Construction (37 C.F.R. § 42.104(b)(3))
`
`The claim terms in an unexpired patent should be given their broadest
`
`reasonable construction in view of the specification. 37 C.F.R. § 42.100(b). Except
`
`the following terms, the specification of the ’342 patent does not present special
`
`definitions for any claim term, and the original prosecution history of the ’342
`
`patent does not include any claim construction arguments, so that claim terms other
`
`than those outlined below should be given their broadest reasonable construction.
`
`Integration Subsystem: The ’342 patent describes “integration” as
`
`“connecting one or more external devices or inputs to an existing car stereo or
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`video system via an interface, processing and handling signals, audio, and/or video
`
`information, allowing a user to control the devices via the car stereo or video
`
`system, and displaying data from the devices on the car stereo or video system.”
`
`8:64-9:3. For the purposes of this review, the “integration subsystem” should be
`
`construed to mean a subsystem that performs the connecting, signal processing,
`
`device control, and data display described by the ’342 patent.
`
`Patent Owner asserted, in the pending litigation in which Petitioner is a
`
`defendant, that “integration subsystem” should be construed as “one or more
`
`components of a system or device configured to integrate an external device with a
`
`car audio/video system.” Plaintiff Blitzsafe Texas LLC’s Opening Claim
`
`Construction Brief, Ex. 1008, at 9. Patent Owner’s construction does not affect the
`
`below analysis or conclusion that the challenged claims are invalid as obvious, as
`
`the prior art referred to below describes one or more components of a system or
`
`device configured to integrate an external device with a car audio/video system.
`
`IV. How Challenged Claims Are Unpatentable (37 C.F.R. §
`42.104(b)(4)–(5))
`
`As described above, the claims of the ’342 patent were allowed during
`
`prosecution only after the Applicant argued that the prior art does not describe that
`
`“an integration subsystem … instructs the portable device to play the audio file in
`
`response to a user selecting the audio file using controls of the car audio/video
`
`system, or an integration subsystem … receives audio generated by the portable
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`device over said wireless communication link for playing on the car audio/video
`
`system.” During prosecution, it was undisputed that the prior art cited by the
`
`Examiner disclosed the remaining features of the claims.
`
`As discussed below, the disclosures of Marlowe and Clayton, and the
`
`disclosures of Marlowe and Silvester, describe these claim features and all of the
`
`other claim features of the challenged claims. Further, the claims would have been
`
`obvious to one of ordinary skill in the art.
`
`A. Claims 49-57, 62-64, 66, 68, 70, 71, 73-80, 94, 95, 97, 99-103, 106, 109-
`111, 113, 115, and 120 are Obvious in View of Marlowe and Clayton
`
`Marlowe is the publication of the application that led to the ’786 Marlowe
`
`patent. Marlowe was cited by the Applicant during prosecution of the ’342 patent,
`
`but was not relied upon by the Examiner in rejecting the claims. Instead, the
`
`Examiner relied on the ’786 Marlowe patent in rejecting the claims for
`
`nonstatutory obviousness-type double patenting. The Examiner determined that the
`
`Marlowe ’786 patent and the ’342 patent describe similar integration systems,
`
`except that the earlier ’786 Marlowe patent describes a wired interface, located
`
`between the car stereo and after-market device.
`
`Clayton was not cited during the prosecution of the ’342 patent.
`
`Marlowe and Clayton describe systems for integrating electronic devices
`
`with a vehicle audio system. Marlowe includes the same Figures 1-7b and
`
`associated description as the ’342 patent, and therefore, like the ’342 patent,
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`describes a device integration system for integrating after-market audio devices,
`
`such as CD players, CD changers, MP3 players, satellite receivers, and DAB
`
`receivers, with car stereo systems, so that control commands can be issued from
`
`the car stereo and responsive data can be displayed on the car stereo. Also like the
`
`’342 patent, Marlowe emphasizes the desirability of allowing devices of any
`
`manufacture to be integrated with any OEM or after-market car stereo. Abstract, ¶
`
`[0007]. Marlowe describes a hard-wired interface device, situated between the
`
`after-market device and the car stereo system. Fig. 1 (reproduced below).
`
`Clayton describes the wireless integration (e.g., Bluetooth) of portable
`
`devices, such as cellular telephones, MP3 players, portable video players, etc., with
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`a car audio system, so that the portable device may be played and controlled in a
`
`natural and intuitive manner with familiar user interfaces. ¶¶ [0018], [0053],
`
`[0066]; Ex. 1002, ¶ 13.
`
`1. Independent Claims 49, 73, 97, and 120
`
`Claims 49, 73, 97, and 120 describe multimedia device integration systems
`
`including an integration subsystem, first and second wireless interfaces, and a
`
`wireless communication link between the first and second wireless interfaces,
`
`bringing a portable device into communication with a car audio/video system.
`
`Claims 49 and 73 describe the interaction between the car audio/video
`
`system and the portable device as follows: the integration subsystem obtains
`
`information about an audio file from the portable device, transmits the information
`
`to the car audio/video system for display, instructs the portable device to play the
`
`audio file in response to a user selecting the audio file using the controls of the car
`
`audio/video system, and receives audio generated by the portable device.
`
`Like claims 49 and 73, claims 97 and 120 describe that the integration
`
`subsystem sends audio generated by the portable device to the car audio/video
`
`system for playing. In addition, claims 97 and 120 describe processing of
`
`incompatible information between the car audio/video system and the portable
`
`device: claim 97 describes that the integration subsystem receives a control
`
`command from the car audio/video system in a format incompatible with the
`
`12
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`portable device, and processes the command into a format compatible with the
`
`portable device before dispatching the formatted command to the portable device;
`
`claim 120 describes a similar formatting step, but instead of processing control
`
`commands from the car audio/video system, claim 120 describes that the
`
`integration subsystem receives data generated by the portable device in a format
`
`incompatible with the car audio/video system, and processes the data into a format
`
`compatible with the car audio/video system before transmitting the processed data
`
`to the car audio/video system.
`
`i. Marlowe and Clayton describe a multimedia device
`integration
`system
`including
`an
`integration
`subsystem, first and second wireless interfaces, and a
`wireless communication link between the first and
`second wireless interfaces (Claims 49, 73, 97, 120)
`
`Marlowe describes a multimedia device integration system for integrating an
`
`external audio devices (CD player, CD changer, MP3 player, satellite receiver,
`
`DAB receiver, etc.) and external video devices with car stereo systems. Abstract; ¶
`
`[0100]. Marlowe describes a wired interface for integrating an after-market device
`
`with a car stereo. ¶ [0010]. As noted above, during the original prosecution of the
`
`’342 patent, the Examiner determined that the use of a wireless connection was
`
`well known in the art, and not a patentable distinction. March 5, 2010 Office
`
`Action, at 2 (“[I]t is well known in the art that direct electrical communication
`
`lines may be replaced by wireless interfaces that achieve the same functions of
`
`13
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`communicating data.”). Bluetooth is such a wireless connection, which was well-
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`known at the time of the filing of the ’342 patent. Ex. 1002, ¶¶ 6-9, 14. The
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`claimed first and second wireless interfaces establishing a wireless communication
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`link are therefore obvious in view of Marlowe.
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`In addition to the obviousness, in view of Marlowe, of replacing electrical
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`communication lines with wireless interfaces, Clayton describes the claimed
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`wireless communications link: a wireless adaptor 173 for wirelessly integrating a
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`cellular telephone 142 (which may include an MP3 player) with a car audio system
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`143, connecting via Bluetooth. Abstract; ¶¶ [0048], [0052]-[0054]; Fig. 4
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`(reproduced below). The wireless adaptor 173 connects one or more external
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`devices (cellular telephone 142) or inputs to an existing car stereo or video system
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`(car audio system 143) via an interface (wireless link between wireless adapter 173
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`and wireless interfaces 148, 150), processing and handling signals, audio, and/or
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`video information, allowing a user to control the devices via the car stereo or video
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`system, and displaying data from the devices on the car stereo or video system. Ex.
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`1002, ¶ 13.
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`14
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`ii. Marlowe and Clayton describe an
`integration
`subsystem that obtains information about an audio
`file
`from
`the portable device,
`transmits
`the
`information to the car audio/video system for display,
`instructs the portable device to play the audio file in
`response to a user selecting the audio file using the
`controls of the car audio/video system, and receives
`audio generated by the portable device (Claims 49, 73,
`97, 120)
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`As noted above, the claims of the ’342 patent were only allowed after the
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`Applicant argued that the prior art failed to describe an integration subsystem that
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`“instructs the portable device to play the audio file in response to a user selecting
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`the audio file using controls of the car audio/video system, and receives audio
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`generated by the portable device over said wireless communication link for playing
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`15
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`on the car audio/video system.” Marlowe and Clayton describe this limitation.
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`Marlowe describes receiving information from an audio device (track,
`
`channel, song, or artist information), and forwarding that information to the car
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`stereo for display, allowing the user to control playback of, e.g., music, from the
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`audio device. Audio played by the audio device is forwarded to the car stereo for
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`playing. ¶¶ [0010], [0038], [0044] (“Audio from the MP3 player 30 is selectively
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`forwarded by the interface 20 to the radio 10 for playing.”), [0100]; Ex. 1002, ¶ 15.
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`As noted above, the use of a wireless connection, e.g., Bluetooth, was already well
`
`known at the time the ’847 application was filed in June 2006. The interface 20
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`therefore performs the connecting, signal processing, device control, and data
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`display described by the ’342 patent.
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`In addition to the obviousness, in view of Marlowe, of replacing wired
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`communication lines with wireless interfaces, Clayton describes a similar system,
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`operating over a wireless link. Clayton describes car audio system 143 receiving
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`content from a portable device 142, including metadata (song titles, artist names,
`
`playlists) to be displayed on the car audio system. ¶¶ [0052], [0056]; Fig. 3
`
`(reproduced below). The playback of audio by portable device 142 is controlled by
`
`(e.g., receives instructions from) the car audio system 143. ¶ [0063] (“[T]he SPP or
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`AVRCP enables the car audio system 143 to act as a controller that sends audio
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`command/control signals to the cellular telephone 142 for playback of the audio
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`16
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`stream.”); Fig. 3. The portable device plays the audio as instructed, and streams the
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`audio over the wireless communications link to the car audio system for playing.
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`¶¶ [0055], [0063] (“When the wireless adaptor 173 is in operation, the A2DP
`
`therein enables the wireless adaptor 173 to transfer the content stored in the
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`cellular telephone 142 to the car audio system 143 as streaming audio for stereo
`
`audio playback through the later [sic].”); Fig. 3.
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`
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`That is, the content stored on the portable device is played on the portable
`
`device, and streamed to the car audio system for outputting audio. ¶ [0066] (“[T]he
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`wireless adaptor 173 enables the cellular telephone 142 to be played and controlled
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`in a natural and intuitive manner.”). See also Ex. 1002, ¶¶ 17-18.
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`17
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`iii. Marlowe
`processing
`describe
`and Clayton
`incompatible information between the car audio/video
`system and the portable device (Claims 97, 120)
`
`Marlowe describes control commands generated at the car radio control
`
`panel are converted into a format recognizable by a portable device, and
`
`transmitted to the device. ¶¶ [0010], [0075] (“[A] command issued from a
`
`HONDA car radio is converted into a format recognizable by an MP3 player
`
`manufactured by PANASONIC, Inc.”). Further, “[i]nformation from the audio
`
`device is received by the present invention, converted into a format recognizable
`
`by the car stereo, and forwarded to the car stereo for display thereby.” ¶ [0010].
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`Ex. 1002, ¶ 18.
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`Clayton describes a command translation module programmed to translate
`
`command/control signals between the cellular telephone 142 and the car audio
`
`system 143, so that the wireless adaptor is operable with different car audio
`
`systems. ¶ [0058]. Clayton also describes car audio system 143 receiving content
`
`from a portable device 142, including metadata (song titles, artist names, playlists)
`
`to be displayed on the car audio system. ¶¶ [0052], [0056]. The wireless adaptor
`
`includes a decoder, which enables content and metadata received from the portable
`
`device to be processed into a “format understood” by the car audio system for
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`output. ¶¶ [0056]-[0057], [0063]. Ex. 1002, ¶ 19.
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`18
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`2. Dependent Claims 50-57, 62-64, 66, 68, 70, 71, 74-80, 94, 95,
`99-103, 106, 109-111, 113, and 115
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`i. Claims 50, 74, 99
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`Clayton describes that the wireless adaptor 173 may be integrated within the
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`car audio system 143. ¶¶ [0052], [0053]; Ex. 1002, ¶ 20.
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`ii. Claims 51, 75
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`Clayton describes that the “wireless adapter 173 may be a part of or separate
`
`from the car audio system 143.” ¶¶ [0052]; see also [0053] (describing the wireless
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`adaptor 173 as “integrated with the car audio system 143”); Ex. 1002, ¶ 21.
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`iii. Claims 52, 76
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`Clayton describes that a wireless interface 148/150 may be included within
`
`portable device 142. ¶ [0048]; Ex. 1002, ¶ 22.
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`iv. Claims 53, 77
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`As described above, Marlowe describes control commands generated at the
`
`control panel of the car radio are converted into a format recognizable by an after-
`
`market audio device, and are transmitted to the device (¶¶ [0010], [0075]), Clayton
`
`describes
`
`a
`
`command
`
`translation module
`
`programmed
`
`to
`
`translate
`
`command/control signals between the cellular telephone 142 and the car audio
`
`system 143, so that the wireless adaptor is operable with different car audio
`
`systems (¶ [0058]). Ex. 1002, ¶ 23.
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`19
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`v. Claims 54, 70, 78
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`As described above, Marlowe describes that “[i]nformation from the audio
`
`device is received by the present invention, converted into a format recognizable
`
`by the car stereo, and forwarded to the car stereo for display thereby” (¶ [0010]),
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`and that the system allows “video information generated by an external device to
`
`be integrated with the display of an existing OEM or after-market car stereo” (¶
`
`[0100]). Regarding video, Marlowe states that the system “accepts RGB input
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`signal from the external device, and converts same to composite signals” and that
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`“[t]he composite signals are then forwarded to the car stereo for display thereby,
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`such as on an LCD panel of the stereo.” ¶ [0100]. Clayton describes car audio
`
`system 143 receiving content from a portable device 142, including metadata (song
`
`titles, artist names, playlists) to be displayed on the car audio system. ¶¶ [0052],
`
`[0056]. The wireless adaptor includes a decoder, which enables content and
`
`metadata received from the portable device to be processed into a “format