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`Exhibit 6
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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. IPR2016-01449
`__________________________________________________________________
`
`
`
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`

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`Case 2:15-cv-01274-JRG-RSP Document 133-7 Filed 08/15/16 Page 3 of 81 PageID #:
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`TABLE OF CONTENTS
`I. 
`Mandatory Notices (37 C.F.R. § 42.8) ........................................................... 1 
`Real-Party-in Interest: ............................................................................................... 1 
`Related Matters: ........................................................................................................ 1 
`II. 
`Grounds for Standing (37 C.F.R. § 42.104(a)) ............................................... 2 
`III. 
`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 49-52, 55, 57, 62-64, 66, 68, 71, 73-76, 79, 80, 94, and
`95 are Obvious in View of Tranchina and Silvester .......................... 10 
`1. 
`Independent Claims 49 and 73 ................................................. 11 
`2. 
`Dependent Claims 50-52, 55, 57, 62-64, 66, 68, 71, 74-
`76, 79, 80, 94, and 95 ............................................................... 15 
`Obviousness in View of Tranchina and Silvester .................... 19 
`3. 
`Claims 53, 54, 56, 70, 77, 78, 97, 99-103, 106, 109-111, 113,
`115, and 120 are Obvious in View of Tranchina, Silvester, and
`Berry ................................................................................................... 21 
`1. 
`The Additional Limitations of Claims 53, 54, 56, 70, 77,
`78, 97, 99-103, 106, 109-111, 113, 115, and 120 .................... 21 
`Obviousness in View of Tranchina, Silvester, and Berry ........ 25 
`2. 
`Claims 49-52, 55, 57, 62-64, 66, 68, 71, 73-76, 79, 80, 94, and
`95 are Obvious in View of Tranchina and Shibasaki ......................... 26 
`1. 
`Independent Claims 49 and 73 ................................................. 27 
`
`C. 
`
`B. 
`
`i
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`2. 
`
`D. 
`
`Dependent Claims 50-52, 55, 57, 62-64, 66, 68, 71, 74-
`76, 79, 80, 94, and 95 ............................................................... 30 
`Obviousness in View of Tranchina and Shibasaki .................. 31 
`3. 
`Claims 53, 54, 56, 70, 77, 78, 97, 99-103, 106, 109-111, 113,
`115, and 120 are Obvious in View of Tranchina, Shibasaki, and
`Berry ................................................................................................... 33 
`1. 
`The Additional Limitations of Claims 53, 54, 56, 70, 77,
`78, 97, 99-103, 106, 109-111, 113, 115, and 120 .................... 33 
`Obviousness in View of Tranchina, Shibasaki, and Berry ...... 35 
`2. 
`Claim Charts ....................................................................................... 36 
`E. 
`The Proposed Grounds of Unpatentability are not Redundant .................... 73 
`V. 
`VI.  Conclusion .................................................................................................... 74 
`
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`ii
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`LISTING OF EXHIBITS
`
`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 No. 7,493,645 to Tranchina
`
`U.S. Patent Application Publication No. 2003/0171834 to
`Silvester
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`U.S. Patent Application Publication No. 2003/0032419 to
`Shibasaki
`
`U.S. Patent No. 6,559,773 to Berry
`
`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
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`Exhibit 1005
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`Exhibit 1006
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`
`Exhibit 1007
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`
`Exhibit 1008
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`Exhibit 1009
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`iii
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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 IPR2016-01448
`
`(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 (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 wired interfaces, and so fail to enable the
`
`subject matter claimed in the challenged claims and fail to provide adequate
`
`written description of the subject matter of the challenged claims.
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`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
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`commands from the car audio/video system into a format compatible with the
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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 correspond to patent claims 49, 73, and 97.
`
`In an Office Action dated March 5, 2010, the claims were rejected for
`
`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
`
`5
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`terminal disclaimer over the earlier 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 corresponds to patent claim 97. Application
`
`claim 213 corresponds to 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,” Ex. 1005). The Applicant
`
`responded on August 15, 2011, arguing against the rejection. The claims were
`
`again rejected, based on Tranchina, on November 29, 2011. The Applicant
`
`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 (corresponding to 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 33-35. As to application
`
`claim 188 (patent claim 97), the Applicant argued that Tranchina does not describe
`
`an integration system that “receives a control command issued by a user through
`
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`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 claims on
`
`February 16, 2012.
`
`D. Patents and Printed Publications Relied On
`
`1. U.S. Patent No. 7,493,645 (“Tranchina,” Ex. 1005), which is prior art
`
`against the ’342 patent under 35 U.S.C. § 102(e).
`
`2. U.S. Patent Appl. Pub. No. 2003/0171834 (“Silvester,” Ex. 1006), which
`
`is prior art against the ’342 patent under 35 U.S.C. § 102(b).
`
`3. U.S. Patent Appl. Pub. No. 2003/0032419 (“Shibasaki,” Ex. 1007),
`
`which is prior art against the ’342 patent under 35 U.S.C. § 102(b).
`
`4. U.S. Patent No. 6,559,773 (“Berry,” Ex. 1008), which prior art against
`
`the ’342 patent under 35 U.S.C. § 102(b).
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`7
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`E. Statutory Grounds for Challenge (37 C.F.R. § 42.104(b)(1)–(2))
`
`1. Claims 49-52, 55, 57, 62-64, 66, 68, 71, 73-76, 79, 80, 94, and 95 are
`
`obvious under 35 U.S.C. § 103(a) in view of Tranchina and Silvester.
`
`2. Claims 53, 54, 56, 70, 77, 78, 97, 99-103, 106, 109-111, 113, 115, and
`
`120 are obvious under 35 U.S.C. § 103(a) in view of Tranchina, Silvester, and
`
`Berry.
`
`3. Claims 49-52, 55, 57, 62-64, 66, 68, 71, 73-76, 79, 80, 94, and 95 are
`
`obvious under 35 U.S.C. § 103(a) in view of Tranchina and Shibasaki.
`
`4. Claims 53, 54, 56, 70, 77, 78, 97, 99-103, 106, 109-111, 113, 115, and
`
`120 are obvious under 35 U.S.C. § 103(a) in view of Tranchina, Shibasaki, and
`
`Berry.
`
`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. 1009, 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
`42.104(b)(4)–(5))
`
`(37 C.F.R. §
`
`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
`
`9
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`system, or an integration subsystem … receives audio generated by the portable
`
`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 Tranchina and Silvester, and the
`
`disclosures of Tranchina and Shibasaki, disclose 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 49-52, 55, 57, 62-64, 66, 68, 71, 73-76, 79, 80, 94, and 95
`are Obvious in View of Tranchina and Silvester
`
`Tranchina was relied upon during prosecution to reject the claims, as
`
`discussed above. Silvester was not cited during the prosecution of the ’342 patent.
`
`Tranchina and Silvester describe systems for integrating electronic devices
`
`with a vehicle audio system. Tranchina describes wirelessly integrating external
`
`media devices for playback of media stored on those devices from the console of
`
`the vehicle audio/visual system. The vehicle console includes a wireless receiver
`
`for communicating with local input devices 106 located in the vehicle, such as
`
`video cassette players, televisions, CD players, DVD players, personal computers,
`
`pagers, and video game players, so that the content of the local input devices may
`
`be played over the vehicle console. 4:56-67, 5:27-51, 8:13-23. Tranchina further
`
`describes portable devices, such as PDAs, hand held personal computers, laptop
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`computers, and smart phones as additional examples of local input devices 106.
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`9:12-18. Tranchina describes that the wireless receiver 102 and wireless transmitter
`
`199 of the vehicle console can control the local input devices 106, and that the
`
`“wireless signals can be any type of wireless signal.” 4:40-46, 7:21-30, 8:12-50.
`
`Silvester describes, in greater detail, the communication between the car
`
`audio/video system and the portable audio/video devices, including controlling the
`
`playback of the portable audio/video devices over the car audio/video system.
`
`According to Silvester, an automobile entertainment system connects wirelessly to
`
`portable media players, receiving playback information, such as albums and song
`
`titles, from the portable media player, issuing control commands to the portable
`
`media device based on user input, receiving playback from the portable media
`
`player, and outputting the audio from loudspeakers in the automobile. ¶¶ 20, 22-24.
`
`Ex. 1002, ¶ 8.
`
`1. Independent Claims 49 and 73
`Claims 49 and 73 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
`
`11
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`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.
`
`i. Tranchina and Silvester 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)
`
`Tranchina describes a console for a vehicle that includes a wireless receiver
`
`receiving wireless signals from portable input sources (e.g., audio and video
`
`devices, such as televisions, CD players, DVD players, PDAs, hand-held PCs,
`
`laptop PCs, smartphones, etc.) having a wireless transmitter from which the
`
`wireless signals are transmitted. Abstract, 4:58-67, 5:27-32, 5:48-51. The console
`
`includes a processer (CPU) that is in communication with the car audio visual
`
`system. 4:58-67. Ex. 1002, ¶ 9.
`
`Silvester, like Tranchina, describes the claimed wireless communication
`
`link: a wireless communications interface 130 as part of an automobile
`
`entertainment system 100, in communication with controller 122 (¶ 18), and a
`
`wireless interface 214 as part of the portable media player 200 (¶ 19). Using the
`
`wireless interfaces 130, 214, the automobile entertainment system 100 establishes
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`a wireless communications link with a portable media player 200, for example, via
`
`Bluetooth or IEEE 802.11 protocols. ¶¶ 18-20. Ex. 1002, ¶ 10.
`
`ii. Tranchina and Silvester 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)
`
`Tranchina describes that the wireless receiver 102 receives wireless signals
`
`from local and remote wireless devices 106 and 108, each having its own wireless
`
`transmitter 150 for communicating with the console 100. Local input devices (e.g.,
`
`CD players, DVD players, PDAs, hand-held PCs, laptop PCs, smartphones, etc.)
`
`transmit audio and video channels to the console for playing and displaying. 5:48-
`
`51, 6:16-28. Remote input devices include a satellite network that provides
`
`streaming multimedia content (including video), or any other remote wireless
`
`device or network. Tranchina’s console streams “varying types of media to a
`
`vehicle.” 5:33-48. Tranchina states that the wireless receiver 102 may be used to
`
`control the local or remote input device 106 and 108 (7:22-24) and that wireless
`
`transmitter 199, having a processor storing programs for controlling different types
`
`of devices including, e.g., a cellular telephone (8:25-50). Ex. 1002, ¶ 11. The
`
`components of console 100 therefore perform the connecting (via wireless
`
`transmitter
`
`and
`
`receiver
`
`118,
`
`signal
`
`processing
`
`(by
`
`signal
`
`102),
`13
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`processing/conversion facilities 110 and CPU 112), device control (wireless
`
`receiver 102 controlling local input device 106), and data display (by display
`
`device 104) of the integration subsystem.
`
`As noted above, the claims of the ’342 patent were only allowed after the
`
`Applicant argued that Tranchina failed to 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 receives audio
`
`generated by the portable device over said wireless communication link for playing
`
`on the car audio/video system.” Silvester describes this limitation.
`
`Silvester describes that the portable media player 200 transmits, via the
`
`wireless link, album or song titles to the automobile entertainment system 100 for
`
`display. ¶¶ 22, 24. The system 100 sends, via the wireless link, control signals to
`
`the media player 200 based on a user’s input at a faceplate of the system 100, such
`
`as stop, play, rewind, etc. ¶¶ 20-22. The portable media player disables its own
`
`loudspeakers and enters a “playback state” to play the selected media by wirelessly
`
`transmitting a playback signal to the system 100, which is played over the
`
`loudspeakers of the system 100. ¶¶ 22, 24. Ex. 1002, ¶ 12. The components of
`
`system 100 therefore perform the connecting (via wireless communications
`
`interface 130), signal processing (by signal converter 128 and decoder 126), device
`
`control (via wireless communications interface 130), and data display (by prompt
`
`14
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`generation and playback unit 124, and video display 118) of the integration
`
`subsystem, and integrate an external device with a car audio/video system.
`
`2. Dependent Claims 50-52, 55, 57, 62-64, 66, 68, 71, 74-76, 79, 80,
`94, and 95
`i. Claims 50, 74
`
`Tranchina describes that the vehicle console 100 is installed in a vehicle, and
`
`includes a processor (CPU) 112. 4:58-67. The elements of the system “may be
`
`included within the console.” 5:1-2. Silvester describes a controller 122, within the
`
`automobile entertainment system 100, controlling operation of the system. ¶ 18;
`
`Fig. 1 (reproduced below). Ex. 1002, ¶ 13.
`
`15
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`

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`
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`ii. Claims 51, 75
`
`Tranchina describes console 100 including wireless receiver 102. 4:58-67,
`
`5:1-2. Silvester describes an automobile entertainment system 100 including a
`
`wireless communication interface 130. ¶ 18; Fig. 1. Ex. 1002, ¶ 14.
`
`iii. Claims 52, 76
`
`Tranchina describes that the local input device includes an optical
`
`transmitting device and an antenna. 5:53-62, 9:12-18. Silvester describes a portable
`
`16
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`media player 200 including a wireless communication interface 214. ¶ 19; Fig. 2
`
`(reproduced below). Ex. 1002, ¶ 15.
`
`
`
`iv. Claims 55, 57, 79, 80
`
`Tranchina describes a voice recognition system used to control the console
`
`and corresponding functions. 8:51-60. Silvester describes user input by an audio
`
`prompt; a voice command is deciphered using voice recognition algorithms. ¶ 20.
`
`A user inputs commands “such as play, stop, rewind, etc.” to change the state of
`
`the portable media player. ¶ 21. Ex. 1002, ¶ 16.
`
`17
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`

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`v. Claims 62, 63, 64
`
`Tranchina describes that a local input source may for example be a digital
`
`video disk, a DVD player, etc. 6:17-19. Silvester describes the portable media
`
`player as a portable DVD player, MP3 player, a notebook computer, or a cellular
`
`telephone. ¶¶ 20, 23, 25. Ex. 1002, ¶ 17.
`
`vi. Claims 66, 94
`
`As discussed above for claims 49 and 73, these limitations are described by
`
`Tranchina (5:33-51, 6:16-28), and by Silvester (¶¶ 20-25). Ex. 1002, ¶ 18.
`
`vii. Claim 68
`
`Tranchina describes that the wireless receiver receives wireless signals from,
`
`e.g., a video cassette player, television, and DVD player (5:27-32) and further
`
`describes the wireless transmission of video from DVD players (6:17-28). Silvester
`
`describes that a DVD player may be wirelessly integrated with the car audio
`
`system, and video signal from the DVD player may be transmitted to the system.
`
`¶¶ 20, 23. Ex. 1002, ¶ 19.
`
`viii. Claims 71, 95
`
`Silvester describes a portable media player playing back songs, as shown by
`
`the album and song titles associated with the stored media. ¶ 22, 24. Ex. 1002, ¶
`
`20.
`
`18
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`3. Obviousness in View of Tranchina and Silvester
`According to the framework set forth in KSR Int’l Co. v. Teleflex Inc., 550
`
`U.S. 398 (2007), “[o]ften, it will be necessary … to look to interrelated teachings
`
`of [the prior art]; the demand known to the design community or present in the
`
`marketplace; and the background knowledge possessed by a person having
`
`ordinary skill in the art, all in order to determine whether there was an apparent
`
`reason to combine the known elements in the fashion claimed by the patent at
`
`issue.” KSR, 550 U.S. at 1740-41. And, “[u]nder the correct analysis, any need or
`
`problem known in the field of endeavor at the time of invention and addressed by
`
`the patent can provide a reason for combining the elements in the manner
`
`claimed.” KSR, 550 U.S. at 1742.
`
`It would have been obvious to include, in the vehicle console of Tranchina,
`
`the functionality of the automobile entertainment system described in Silvester,
`
`that is capable of instructing the portable device to play an audio file in response to
`
`user input at the controls of the car/audio video system, and that receives audio
`
`generated by device wirelessly through the wireless communication link. The
`
`control, over a wireless link, of portable media devices for playing back
`
`multimedia were well-known at the time the ’847 application was filed in June
`
`2006 (as the Examiner stated during the original prosecution of the ’342 patent, see
`
`March 5, 2010 Office Action, at 2-3), and it would have been mere routine
`
`19
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`adaptation of the vehicle console of Tranchina to provide wireless integration of
`
`portable devices as described by Silvester. Tranchina already briefly describes a
`
`wireless link used to control integrated devices (see, e.g., 4:40-46, 4:56-67, 5:27-
`
`51, 7:21-30, 8:12-50); Silvester describes these aspects of the integration of a
`
`wirelessly connected portable device in greater detail (see, e.g., ¶¶ 20, 22-24). Ex.
`
`1002, ¶ 21.
`
`Moreover, a person of ordinary skill in the art would have found this
`
`modification obvious, at least in view of the recognized demand to access the
`
`information from portable media players in an automobile environment, and
`
`recognized solutions to that