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`Exhibit 5
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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. 7,489,786
`Issue Date: February 10, 2009
`Title: AUDIO DEVICE INTEGRATION SYSTEM
`__________________________________________________________________
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,489,786
`PURSUANT TO 35 U.S.C. § 312 and 37 C.F.R. § 42.104
`
`Case No. IPR2016-01448
`__________________________________________________________________
`
`
`
`
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`

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`Case 2:15-cv-01274-JRG-RSP Document 133-6 Filed 08/15/16 Page 3 of 76 PageID #:
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`TABLE OF CONTENTS
`
`I.
`II.
`III.
`
`B.
`C.
`D.
`
`B.
`
`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)) .............................................................. 2
`A.
`Background of the ’786 Patent ............................................................. 3
`1.
`The ’786 Patent .......................................................................... 3
`2.
`Prosecution History of the ’786 Patent ...................................... 4
`Patents and Printed Publications Relied On ......................................... 7
`Statutory Grounds for Challenge (37 C.F.R. § 42.104(b)(1)–(2)) ....... 7
`Claim Construction (37 C.F.R. § 42.104(b)(3)) ................................... 8
`1.
`“Integration” and “Integrated” ................................................... 8
`2.
`“Car Stereo” and “Car Radio” ................................................... 8
`3. Means-Plus-Function Limitations .............................................. 9
`IV. How Challenged Claims Are Unpatentable (37 C.F.R. § 42.104(b)(4)–
`(5)) ................................................................................................................ 10
`A.
`Claims 1, 2, 13, 14, 23, 24, 44 and 47 of the ’786 Patent are
`Obvious Under 35 U.S.C. § 103(a) in View of Owens, Beckert,
`and Cooper ......................................................................................... 11
`1.
`Claims 1, 2, 13, 14, 23, 24, 44 and 47 ..................................... 14
`2.
`Obviousness in View of Owens, Beckert, and Cooper ............ 23
`3.
`Claim Charts ............................................................................ 24
`Claims 7 and 8 of the ’786 Patent are Obvious Under 35 U.S.C.
`§ 103(a) in View of Owens, Beckert, Cooper, and Ohmura .............. 42
`1.
`Claims 7 and 8 .......................................................................... 42
`2.
`Obviousness in View of Owens, Beckert, Cooper, and
`Ohmura ..................................................................................... 43
`Claim Charts ............................................................................ 44
`
`3.
`
`i
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`

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`C.
`
`Claims 4-6, 57, 58, 60, 63-65, 86, 88-92, 94 and 97 of the ’786
`Patent are Obvious Under 35 U.S.C. § 103(a) in View of
`Owens, Beckert, Cooper, and Berry ................................................... 45
`1.
`Claims 4-6, 57, 58, 60, 63-65, 86, 88-92, 94 and 97 ............... 46
`2.
`Obviousness in View of Owens, Beckert, Cooper, and
`Berry ......................................................................................... 56
`Claim Charts ............................................................................ 57
`3.
`Claims 61 and 62 of the ’786 Patent are Obvious Under 35
`U.S.C. § 103(a) in View of Owens, Beckert, Cooper, Berry, and
`Ohmura ............................................................................................... 68
`1.
`Claims 61 and 62...................................................................... 68
`2.
`Obviousness in View of Owens, Beckert, Cooper, Berry,
`and Ohmura .............................................................................. 68
`Claim Charts ............................................................................ 69
`3.
`Conclusion .................................................................................................... 69
`
`D.
`
`
`
`ii
`
`V.
`
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`

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`LISTING OF EXHIBITS
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`U.S. Patent No. 7,489,786 to Marlowe
`
`Declaration of Scott Andrews
`
`U.S. Patent Application Publication No. 2002/0084910 to
`Owens et al.
`
`U.S. Patent No. 6,175,789 to Beckert et al.
`
`U.S. Patent No. 5,774,793 to Cooper et al.
`
`U.S. Patent Application Publication No. 2001/0028717 to
`Ohmura et al.
`
`U.S. Patent No. 6,559,773 to Berry
`
`Exhibit 1001
`
`Exhibit 1002
`
`Exhibit 1003
`
`
`Exhibit 1004
`
`Exhibit 1005
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`Exhibit 1006
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`
`Exhibit 1007
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`iii
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`

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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 Company 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, IPR2016-01445 and IPR2016-01449
`
`(both filed by VWGoA simultaneously with this petition), U.S. Pat. App. Ser. Nos.
`
`1
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`

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`60/523,714; 10/732,909; 11/071,667; 11/475,847; 11/805,799; 11/928,408;
`
`11/928,474; 11/928,534; 11/929,757; and 11/928,503.
`
`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 and 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. Patent No. 7,489,786 (“the ’786 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.
`
`III.
`
`Identification of Challenge (37 C.F.R. § 42.104(b)(1)-(3)) and Relief
`Requested (37 C.F.R. § 42.22(a)(1))
`
`
`
`VWGoA challenges claims 1, 2, 4-8, 13, 14, 23, 24, 44, 47, 57, 58, 60-65,
`
`86, 88-92, 94, 97, and 98 of the ’786 patent under 35 U.S.C. § 103, and requests
`
`cancellation of these claims.
`
`2
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`A. Background of the ’786 Patent
`The ’786 Patent
`1.
`The ’786 patent describes a system for integrating after-market components
`
`
`
`such as satellite receivers, CD players, CD changers, MP3 players, Digital Audio
`
`Broadcast (DAB) receivers, and auxiliary audio sources, with factory-installed
`
`(OEM) or after-market car stereo systems. Ex. 1001, 1:7-12. The integration
`
`system is described as an “interface system.” See id. at 5:14-15 and Fig. 1,
`
`reproduced below; Ex. 1002, ¶ 3.
`
`
`As shown in Fig. 1, the interface can be connected to a plurality of devices
`
`
`
`and auxiliary inputs and integrated with a car stereo. The interface converts control
`
`signals from the car stereo into a format compatible with an after-market external
`
`device, and vice versa, allowing commands input at the car stereo to control the
`
`external device and display of external device information on the car’s display.
`
`Information from the audio device (e.g., track, disc, song, station, an time) is
`
`received, processed, converted into a format recognizable by the car stereo, and
`
`3
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`dispatched to the car stereo for display thereon. See Ex. 1001, Abstract, 4:27-46,
`
`5:15-8:15. Auxiliary input sources can be integrated with the car stereo, and
`
`selected by using the controls of the car stereo. See id., Abstract, 4:43-46. See Ex.
`
`1002, ¶ 4.
`
`
`
`The interface includes a microcontroller performing these functions. See Ex.
`
`1001, 8:46-64, 9:45-67, 10:49-62, 11:30-46, 12:4-14; Ex. 1002, ¶ 5.
`
`2.
`
`Prosecution History of the ’786 Patent
`
`
`
`During prosecution, the claims of the ’786 patent were repeatedly rejected in
`
`view of the prior art, and were allowed only after the Applicant amended the
`
`independent claims to reflect that the microcontroller included in the interface is
`
`“pre-programmed” to execute “pre-programmed” code.
`
`
`
`The ’786 patent issued from U.S. Pat. App. Ser. No. 10/316,961 (“the ’961
`
`application”), which was filed on December 11, 2002. During the years 2006 and
`
`2007, the Examiner rejected the claims four times in view of various prior art
`
`references. The Applicant made claim amendments in response to each of those
`
`four Office Actions, and further added new claims twice.
`
`
`
`In an Office Action dated February 29, 2008, the Examiner again rejected
`
`the then-pending claims as obvious, most of them over U.S. Pat. App. Publ. No.
`
`2002/0084910 (“Owens,” Ex 1003) in view of U.S. Patent No. 6,175,789
`
`(“Beckert,” Ex. 1004). For example, the Examiner reasoned that Owens discloses
`
`4
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`an audio device integration system as described in then-pending claim 1, with the
`
`exception of a microcontroller programmed to execute code portions to process
`
`control commands into compatible formats between the car stereo and after-market
`
`devices, and that it would have been obvious to include the “compatibility
`
`processing” described in Beckert in the interface of Owens. See February 29, 2008
`
`Office Action at 4-5.
`
`
`
`On April 2, 2008, the Examiner and the Applicant discussed possible claim
`
`amendments to overcome Owens and Beckert, and in a Response dated April 21,
`
`2008, the Applicant amended the claims to recite that the microcontroller of the
`
`interface is “pre-programmed” to execute “pre-programmed” code, stating:
`
`In the interview, it was agreed that independent Claim 1 and its
`associated dependent Claims 2-13 and 15-23 would overcome the
`references cited in the Office Action if amended to recite that the
`microcontroller of the interface of the present invention is “pre-
`programmed to execute a first pre-programmed code portion for
`remotely controlling an after-market audio device... ; a second pre-
`programmed code portion for receiving data from an after-market
`audio device...; and a third pre-programmed code portion for
`switching between one or more auxiliary input sources....” In
`particular, at the interview, it was discussed that neither of the primary
`references (i.e., Owens, et al. and Beckert, et al.), nor any of the
`remaining references, taken alone or in combination, teach or suggest
`providing an interface having a pre-programmed microcontroller
`
`5
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`which executes pre-programmed code portions for integrating an
`after-market device for use with a car stereo.
`
`April 21, 2008 Response at 30 (emphasis in original). The Applicant explained that
`
`he amended (what became issued) independent claims 25, 33, 44, 57, 66, 76, and
`
`92 in a similar fashion, and (what became issued) independent claims 49, 86, and
`
`99 “to recite that the microcontroller is pre-programmed to execute a first pre-
`
`programmed code portion for generating a device presence signal ... to maintain a
`
`car stereo in a responsive state.” Id. at 30-31 (emphasis in original).
`
`
`
`On July 31, 2008, the claims were allowed, with the Examiner stating the
`
`following reasons for allowance:
`
`The general concept of interfacing auxiliary after-market devices with
`a car stereo was known in the art at the time of the invention as
`evidenced by Owens et al (US 2002/0084910 A1) and Beckert et al
`(US 6,175,789 B1). However, the Examiner has not found prior art
`that
`teaches or suggests an
`interface unit containing a pre-
`programmed microcontroller that allows for the communication of
`incompatible audio devices as presented in the independent claims 1,
`24, 30, 42, 55, 63 and 72. The Examiner has not found prior art that
`teaches or suggests an interface unit that includes a microcontroller
`pre-programmed to execute a code portion for generating and
`transmitting a device presence signal to a car stereo to maintain the
`stereo in an operational state responsive to signals from an after-
`market device as presented in the independent claims 47, 81, 83, 104.
`
`6
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`July 31, 2008 Notice of Allowability at 2.
`
`B.
`
`Patents and Printed Publications Relied On
`
`1.
`
`U.S. Patent Application Publication No. 2002/0084910 (“Owens,” Ex.
`
`1003), published July 4, 2002, constitutes prior art against the ’786 patent under 35
`
`U.S.C. §§ 102(a) and (e).
`
`2.
`
`U.S. Patent No. 6,175,789 (“Beckert,” Ex. 1004), issued January 16, 2001,
`
`constitutes prior art against the ’786 patent under 35 U.S.C. § 102(b).
`
`3.
`
`U.S. Patent No. 5,774,793 (“Cooper,” Ex. 1005), issued June 30, 1998,
`
`constitutes prior art against the ’786 patent under 35 U.S.C. § 102(b).
`
`4.
`
`U.S. Patent Application Publication No. 2001/0028717 (“Ohmura,” Ex.
`
`1006), published October 11, 2001, constitutes prior art against the ’786 patent
`
`under 35 U.S.C. § 102(b).
`
`5.
`
`U.S. Patent No. 6,559,773 (“Berry,” Ex. 1007), issued May 6, 2003, from
`
`U.S. Patent Application Serial No. 09/468,170, filed December 21, 1999,
`
`constitutes prior art against the ’786 patent under 35 U.S.C. § 102(e).
`
`C.
`
`Statutory Grounds for Challenge (37 C.F.R. § 42.104(b)(1)–(2))
`
`1.
`
`Claims 1, 2, 13, 14, 23, 24, 44, and 47 are obvious under 35 U.S.C. § 103(a)
`
`in view of Owens, Beckert, and Cooper.
`
`2.
`
`Claims 7 and 8 are obvious under 35 U.S.C. § 103(a) in view of Owens,
`
`Beckert, Cooper, and Ohmura.
`
`7
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`3.
`
`Claims 4-6, 57, 58, 60, 63-65, 86, 88-92, 94, 97, and 98 are obvious under
`
`35 U.S.C. § 103(a) in view of Owens, Beckert, Cooper, and Berry.
`
`4.
`
`Claims 61 and 62 are obvious under 35 U.S.C. § 103(a) in view of Owens,
`
`Beckert, Cooper, Berry, and Ohmura.
`
`D. Claim Construction (37 C.F.R. § 42.104(b)(3))
`
`
`
`Except for the terms “integration/integrated” and “car stereo/car radio,”
`
`neither the specification nor the original prosecution history of the ’786 patent
`
`presents a definition for any claim terms, such that all other terms should be given
`
`their broadest reasonable construction. 37 C.F.R. § 42.100(b).
`
`1.
`
`“Integration” and “Integrated”
`
`
`
`The ’786 patent states that “the term ‘integration’ or ‘integrated’ is intended
`
`to mean connecting one or more external devices or inputs to an existing car radio
`
`or stereo via an interface, processing and handling signals and audio channels,
`
`allowing a user to control the devices via the car stereo, and displaying data from
`
`the devices on the radio.” Ex. 1001 at 4:47-52.
`
`2.
`
`“Car Stereo” and “Car Radio”
`
`
`
`The ’786 patent states that “the terms ‘car stereo’ and ‘car radio’ are used
`
`interchangeably and are intended to include all presently existing car stereos and
`
`radios, such as physical devices that are present at any location within a vehicle, in
`
`addition to software and/or graphically-or display-driven receivers.” Id. at 5:1-5.
`
`8
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`3. Means-Plus-Function Limitations
`
`
`
`In Blitzsafe Texas, LLC v. Volkswagen Group of America, Inc. et al., 2:15-
`
`cv-01278 (E.D. Tex.) (and the other E.D. Tex. cases listed on page 1), the parties
`
`agreed that claim 92 of the ’786 patent contains various means-plus-function
`
`limitations with the following corresponding structures:
`
`i.
`
`“First pre-programmed means for generating a
`device presence signal”
`
`“ports J2A1, X2, RCH, and LCH, connected to a power source (i.e.
`battery) that are provided for allowing connection between the
`interface system of the present invention and an after-market device,
`or an auxiliary input source” and “a microcontroller (U1) with
`hardware components such as resistors, diodes, capacitors, and
`oscillators.”
`
`ii.
`
`“First pre-programmed means for … transmitting
`the signal to the car stereo to maintain the car
`stereo in an operational state”
`
`“the ‘resistors, diodes, capacitors, transistors, transformers, amplifiers,
`oscillator’ of FIG. 3B.”
`“Means for remotely controlling the portable
`iii.
`audio device using the car stereo by receiving a
`control command from the car stereo in a format
`incompatible with the portable audio device”
`
`“a microcontroller, which is comprised of a 16F873 microcontroller
`manufactured by MICROCHIP, Inc.; and a plurality of resistors (R1-
`R7), capacitors (C1-C2), and amplifier (A1).”
`
`9
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`iv.
`
`“Means for remotely controlling the portable
`audio device using the car stereo by … processing
`the control command into a formatted control
`command compatible with the portable audio
`device”
`
`“the code or algorithm illustrated in Tables 1 and 2 of ’786 Patent.”
`“Means for remotely controlling the portable
`v.
`audio device using the car stereo by …
`transmitting the formatted control command to
`the portable audio device for execution thereby”
`
`“circuit in Figure 3B … having a plurality of resistors, diodes,
`capacitors, transistors, transformers, amplifiers, oscillator, among
`other structural components that provide the hardware framework, for
`the microcontroller to act as an interface in integrating an after-market
`device with a car stereo.”
`“Means for transmitting audio from the portable
`vi.
`audio device to the car stereo”
`
`“circuit in Figure 3B … having a plurality of resistors, diodes,
`capacitors, transistors, transformers, amplifiers, oscillator, among
`other structural components that provide the hardware framework, for
`the microcontroller to act as an interface in integrating an after-market
`device with a car stereo.”
`IV. How Challenged Claims Are Unpatentable (37 C.F.R. § 42.104(b)(4)–
`(5))
`
`
`
`As described above, the claims of the ’786 patent were allowed only after
`
`the Applicant amended the independent claims to reflect that the microcontroller
`
`included in the interface is “a pre-programmed microcontroller that allows for the
`
`communication of incompatible audio devices” or is “a microcontroller pre-
`10
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`programmed to execute a code portion for generating and transmitting a device
`
`presence signal to a car stereo to maintain the stereo in an operational state
`
`responsive to signals from an after-market device.” As discussed below, Cooper
`
`describes the compatibility features and Berry describes the device presence signal
`
`features that were the reasons for allowance. The prior art relied upon by the
`
`Examiner, Owens and Beckert, in combination with Cooper—and for some claims,
`
`with Ohmura and/or Berry in addition—discloses all of the limitations of the
`
`challenged claims, such that the challenged claims would have been obvious to one
`
`of ordinary skill in the art.
`
`A. Claims 1, 2, 13, 14, 23, 24, 44 and 47 of the ’786 Patent are
`Obvious Under 35 U.S.C. § 103(a) in View of Owens, Beckert,
`and Cooper
`
`
`
`Owens, Beckert, and Cooper describe systems and methods for integrating
`
`electronic devices with vehicle audio systems. Ex. 1002, ¶ 6.
`
`
`
`Owens describes an expandable automotive multimedia system having a bus
`
`for integrating, e.g., MP3 players, CD players, TV monitors, VCRs, or game
`
`stations, to the vehicle’s OEM head unit and speaker system, subject to control at
`
`the head unit, which “offers enormous versatility for a traveling family.” Ex. 1003,
`
`¶¶ [0006]–[0010], [0025]–[0026]; Ex. 1002, ¶ 7. The bus carries “control
`
`commands from the head unit to the modules, and commands from the modules to
`
`11
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`the head unit.” Ex. 1003, ¶ [0027]; Ex. 1002, ¶ 7. See also Ex. 1003, e.g., Fig. 1,
`
`reproduced below.
`
`
`Beckert describes a vehicle computer system designed to integrate and
`
`
`
`control, e.g., audio, navigation, and communication systems, which “allows for
`
`easy expandability.” Ex. 1004, 2:8-30; Ex. 1002, ¶ 8. The system includes three
`
`modules: a support module, a faceplate module and computer module. The support
`
`module includes a logic unit, “which is responsible for facilitating communication
`
`among peripheral devices,” and which can be implemented as a microprocessor or
`
`other processing device. Ex. 1004, 5:40-55; Ex. 1002, ¶ 8. See also Ex. 1004, e.g.,
`
`Fig. 2, reproduced below.
`
`12
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`
`
`
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`Cooper, which was not cited during prosecution of the ’786 patent, describes
`
`a docking system for interfacing a variety of devices having different control and
`
`command formats to a bus having a known universal signal format, providing
`
`“ease of manufacture and updating the system to accommodate new models and
`
`makes of cellular telephones, as well as changes to command signal structure of
`
`existing cellular telephones and devices.” Ex. 1005, 1:19-23; 2:16-20; Ex. 1002, ¶
`
`9. An interface device includes a microcontroller “which contains, in its non-
`
`volatile memory, a data control program having a plurality of firmware drivers;”
`
`these drivers “have the operating circuitry and commands necessary for controlling
`
`the selected cellular telephone.” Ex. 1005, 3:12-22; 4:34-39; Ex. 1002, ¶ 9. See
`
`also Ex. 1005, e.g., Fig. 2, reproduced below.
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`1.
`
`Claims 1, 2, 13, 14, 23, 24, 44 and 47
`i.
`
`Claim 1: “An audio device integration system
`comprising a first connector electrically
`connectable to a car stereo”
`
`
`
`Owens describes “an expandable system” for “serial additional of modules”
`
`such as A/V sources, and further describes a “bus cable” connecting the head unit
`
`to the modules, including to an A/V interface module. Ex. 1003, Abstract, ¶¶
`
`[0006], [0025]; Ex. 1002, ¶ 10. Beckert describes a vehicle computer system that is
`
`capable of integrating diverse and separate systems and can serve as, e.g., a
`
`multimedia entertainment system. Ex. 1004, 2:8-11, 5:3-6; Ex. 1002, ¶ 10. Cooper
`
`describes a system for connecting a plurality of cellular telephones to an
`
`automotive electronics and communications system; a cable (no. 44 in Fig. 2)
`
`connects
`
`the
`
`interface unit
`
`to a bus connector of
`
`the electronics and
`
`communications system. Ex. 1005, Abstract, 3:42-45, Figs. 1, 2; Ex. 1002, ¶ 10.
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`ii.
`
`Claim 1: “a second connector electrically
`connectable to an after-market audio device
`external to the car stereo”
`
`
`
`Owens describes that A/V devices (e.g., after-market audio devices), such as
`
`TV monitors, VCRs, tuners, game stations, etc., may be connected to a “source
`
`selector” which is connected to the A/V interface module. Ex. 1003, ¶ [0026]; Ex.
`
`1002, ¶ 11. Beckert describes that the “support module” is connected to a USB
`
`hub, which provides connections to peripheral devices, such as CD-ROM
`
`changers, TV tuners, etc. Ex 1004, 5:28-38; Ex. 1002, ¶ 11. Cooper describes a
`
`cable (no. 40 in Fig. 2) connecting the interface unit with a cellular phone. Ex.
`
`1005, 3:29-41, Fig. 2; Ex. 1002, ¶ 11.
`
`iii. Claim 1: “a third connector electrically
`connectable to one or more auxiliary input sources
`external to the car stereo and the after-market
`audio device”
`
`
`
`Owens describes “auxiliary plugs” (no. 12 in Fig. 1) for connection of an
`
`auxiliary audio source (no. 13 in Fig. 1), such as a cassette tape deck or an MP3
`
`player, to the head unit. Ex. 1003, ¶ [0025], Fig. 1; Ex. 1002, ¶ 12. Beckert’s
`
`system is connectable to multiple external devices. For example, Beckert describes
`
`that “[t]he USB hub 70 provides connections to many peripheral devices (e.g., 128
`
`devices).” Ex. 1004, 5:28-38; Ex. 1002, ¶ 12. Cooper describes that multiple cell
`
`phones may be separately connected to the interface unit through multiple “cradle
`
`members.” Ex. 1005, claim 4, Fig. 1; Ex. 1002, ¶ 12.
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`iv. Claim 1: “an interface connected between said first
`and second electrical connectors for channeling
`audio signals to the car stereo from the after-
`market audio device, said interface including a
`microcontroller in electrical communication with
`said first and second electrical connectors”
`
`
`
`Owens describes an A/V interface module connected between the bus and
`
`the “source selector,” which in turn is connected to A/V sources; Owens further
`
`describes a “master microprocessor” that performs all of the system selection
`
`functions (such as choosing between different A/V sources). Ex. 1003, ¶¶ [0009]-
`
`[0010], [0034]; Ex. 1002, ¶ 13.
`
`
`
`Beckert describes a support module (the interface) connected to a computer
`
`module (first electrical connection) and a USB hub (second electrical connection),
`
`for connection to peripheral devices such as a CD-ROM changer; the support
`
`module contains a logic unit that can be implemented as a microprocessor, and “is
`
`responsible for facilitation communication among the peripheral devices … and
`
`coordinating the functionality of the entertainment system.” Ex. 1004, 5:28-38,
`
`5:40-55; Fig. 2; Ex. 1002, ¶ 13.
`
`
`
`Cooper describes an interface unit (no. 36 in Fig. 2) connected via cables
`
`(nos. 40 and 44 in Fig. 2) to the audio and communications system of the vehicle
`
`and one or more cell phones; the system enables audio output of the connected
`
`cellular phones to be output on the audio/communication system of the vehicle. Ex.
`
`1005, 3:29-45, 4:11-20, Figs. 1, 2; Ex. 1002, ¶ 13. The interface device includes a
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`microcontroller that “contains, in its non-volatile memory, a data control program
`
`having a plurality of firmware drivers;” these drivers “have the operating circuitry
`
`and commands necessary for controlling the selected cellular telephone.” Ex. 1005,
`
`3:12-22; 4:34-39; Ex. 1002, ¶ 13.
`
`v.
`
`Claim 1: “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”
`
`
`
`Owens describes that the head unit has controls which allow the vehicle
`
`driver control over the entire system; the bus carries “control commands from the
`
`head unit to the modules, and commands from the modules to the head unit.” Ex.
`
`1003, ¶ [0006], [0027], Fig. 2; Ex. 1002, ¶ 14. Beckert describes that the computer
`
`has a voice recognition device that permits the user to verbally enter commands,
`
`which “can be used for controlling most operating modes of the vehicle computing
`
`platform,” and the connection of “many peripheral devices” to the computing
`
`platform. Ex. 1004, 4:23-27, 5:28-36; Ex. 1002, ¶ 14. Beckert describes that its
`
`system runs on an open platform operating system, which enables the addition of
`
`new systems to the vehicle by installing new programs. Ex. 1004, 2:8-30. Once the
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`appropriate software for a new peripheral device is installed, the system in Beckert
`
`integrates the device and transforms commands to or from the peripheral device
`
`into the right format. Ex. 1002, ¶ 14.
`
`
`
`Cooper describes “pre-programmed” compatibility processing. As discussed
`
`above, Cooper describes an interface device that includes a microcontroller that
`
`“contains, in its non-volatile memory, a data control program having a plurality of
`
`firmware drivers;” these drivers “have the operating circuitry and commands
`
`necessary for controlling the selected cellular telephone,” each of which has
`
`“individual special command signal requirements specific to the unit’s operation.”
`
`Ex. 1005, 3:12-22; 4:11-20, 4:34-39, 4:65-5:4; 5:33-38, 5:53-64; Ex. 1002, ¶ 14.
`
`The after-market cell phones can be controlled through commands from the
`
`automotive head unit. Ex. 1005, 3:29-41, 3:42-45, 4:65-5:4, Fig. 2; Ex. 1002, ¶ 14.
`
`vi. Claim 1: “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”
`
`
`
`Beckert describes that the support module, which can be implemented as a
`
`microprocessor, includes circuitry that can receive data from the serial devices and
`
`convert the data into a “parallel format.” Ex. 1004, 5:53-55, 8:16-23; Ex. 1002, ¶
`
`15. As discussed above, Beckert describes format conversion between the
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`computing platform and the peripheral devices. Further, the system may display
`
`information on the faceplate display. Ex. 1004, 4:17-22, Fig. 1; Ex. 1002, ¶ 15.
`
`
`
`As discussed above, Cooper describes that the microcontroller in the
`
`interface unit can select the proper hardware and/or firmware to interface with a
`
`particular cell phone; the system further has the capability “for passing the audio
`
`output signal of the cellular telephone to the bus connector and thus to the
`
`automotive electronics and communications system.” Ex. 1005, 5:53-64; 4:11-20;
`
`Ex. 1002, ¶ 15. Cooper also describes that an LCD screen may be provided in a
`
`convenient location in the car to “display information normally shown on the
`
`display screen of a cellular telephone.” Ex. 1005, 4:4-10; Ex. 1002, ¶ 15.
`
`vii. Claim 1: “a third pre-programmed code portion
`for switching to one or more auxiliary input
`sources connected to said third electrical
`connector”
`
`
`
`Owens describes that the A/V interface module is “connected to an A/V
`
`source selector module which serves as a switching unit between various A/V
`
`inputs and a monitor, sub