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`EXHIBIT E
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`Trials@uspto.gov
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` Paper 13
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` Entered: July 19, 2016
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`TOYOTA MOTOR CORPORATION,
`Petitioner
`
`v.
`
`BLITZSAFE TEXAS, LLC,
`Patent Owner.
`____________
`
`Case IPR2016-00419
`Patent 8,155,342 B2
`____________
`
`
`
`Before JAMESON LEE, THOMAS L. GIANNETTI, and HUNG H. BUI,
`Administrative Patent Judges.
`
`BUI, Administrative Patent Judge.
`
`
`
`DECISION
`Denying Institution of Inter Partes Review
`37 C.F.R. § 42.108
`
`
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`INTRODUCTION
`I.
`On December 30, 2015, Petitioner, Toyota Motor Corporation, filed a
`Petition requesting an inter partes review of claims 49–57, 62–64, 66, 68,
`70, 71, 73–80, 94, 95, 97, 99–103, 106, 109–111, 113, 115, and 120 of
`U.S. Patent No. 8,155,342 B2 (Ex. 1101, “the ’342 patent”). Paper 1
`(“Pet.”). Patent Owner, Blitzsafe Texas, LLC, filed a Preliminary Response
`on April 22, 2016. Paper 9 (“Prelim. Resp.”).
`To institute an inter partes review, we must determine that “the
`information presented in the petition . . . shows that there is a reasonable
`likelihood that the petitioner would prevail with respect to at least 1 of the
`claims challenged in the petition.” 35 U.S.C. § 314(a). Having considered
`both the Petition and the Preliminary Response, we are not persuaded that
`Petitioner has demonstrated a reasonable likelihood that it would prevail in
`showing the unpatentability of any one of 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 based on the prior art cited in the Petition. For reasons discussed
`below, we deny the Petition as to all challenges.
`
`A. Related Matters
`The ’342 patent is involved in the following litigations: (1) Blitzsafe
`Texas, LLC v. Nissan Motor Co., Ltd., 2-15-cv-01276 (E.D. Tex. July 16,
`2015), (2) Blitzsafe Texas, LLC v. Toyota Motor Corp. et al., 2-15-cv-01277
`(E.D. Tex. July 16, 2015), (3) Blitzsafe Texas, LLC v. Volkswagen Group of
`Am., Inc., 2-15-cv-01278 (E.D. Tex. July 16, 2015), (4) Blitzsafe Texas, LLC
`v. Hyundai Motor Co., 2-15-cv-01275 (E.D. Tex. July 16, 2015), (5)
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`2
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`Blitzsafe Texas, LLC v. Honda Motor Co., Ltd., 2-15-cv-01274 (E.D. Tex.
`July 16, 2015), (6) Marlowe Patent Holdings LLC v. Dice Elects., LLC., 3-
`10-cv-01199 (D.N.J.), and (7) Marlowe Patent Holdings LLC v. Ford Motor
`Company, 3-10-cv-07044 (D.N.J.). Pet. 2–3. The ’342 patent is also
`involved in IPR2016-00118 and IPR2016-00418. Related Patent 7,489,786
`B2 is involved in IPR2016-00421 and IPR2016-00422.
`
`B. The ’342 Patent
`The ’342 patent relates to a multimedia device integration system that
`allows a plurality of “after-market” portable devices to be integrated into an
`existing car audio/video (stereo) system, via an “integration subsystem,”
`while allowing information to be displayed on, and control to be provided
`from, the car audio/video system. See Ex. 1101, 2:44–54; Abstract.
`Examples of these portable devices include CD players, CD changers, digital
`media devices (e.g., MP3 players, Apple iPod, WMV players, portable
`media centers, and other devices), satellite receivers, DAB receivers,
`auxiliary input sources, video devices (e.g., DVD players), cellular
`telephones, or any combination thereof. Id.
`The ’342 patent claims are directed to certain embodiments where
`wireless integration is provided between a car audio/video system and a
`portable device, via an integration subsystem. Ex. 1101, 33:43–46. For
`example, Figure 18 shows an integration subsystem positioned within a
`portable device, and Figure 19 shows an integration subsystem positioned
`within a car audio/video system. Figures 18–19 are reproduced below.
`
`3
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`Figures 18 and 19 of the ’342 patent show integration subsystems 932 and
`1032 positioned, respectively, within portable device 924 or within car
`audio/video system 1010.
`
`As shown in Figure 18, integration subsystem 932 positioned within
`portable device 924 allows information (data and control signals) to be
`exchanged between portable device 924 and car audio/video system 910, and
`processes and formats data accordingly so that instructions and data from car
`audio/video system 910 are processed by portable device 924, and vice
`versa. See id. at 33:43–35:62, Fig. 18. Similarly, as shown in Figure 19,
`integration subsystem 1032 positioned within car audio/video system 1010
`allows information (data and control signals) to be exchanged between
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`portable device 1024 and car audio/video system 1010, and processes and
`formats data accordingly so that instructions and data from car audio/video
`system 1010 are processed by portable device 1024, and vice versa. See id.
`at 33:43–35:62, Fig. 19.
`
`C. Illustrative Claim
`
`Of the challenged claims, claims 49, 73, 97, and 120 are independent.
`Claims 50–57, 62–64, 66, 68, 70, and 71 depend, directly or indirectly, from
`claim 49.
`Claim 49, reproduced below, is illustrative.
`49. A multimedia device integration system, comprising:
`an integration subsystem in communication with a car
`audio/video system; and
`a first wireless interface in communication with said
`integration subsystem, said first wireless interface establishing a
`wireless communication link with a second wireless interface in
`communication with a portable device external to the car
`audio/video system,
`wherein said integration subsystem obtains, using said
`wireless communication link, information about an audio file
`stored on the portable device, transmits the information to the car
`audio/video system for subsequent display of the information on
`a display of the car audio/video system, 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.
`Ex. 1101, 42:29–47.
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`Claim 73 is substantially identical to claim 49, except that the audio
`
`file is “received by” instead of “stored on” the portable device. Id. at 44:4–
`23. Claim 97 is similar to claim 49, but further defines that the “audio
`generated by the portable device” corresponds to “an audio file played by
`the portable device” and adds that the car stereo control commands are in a
`format incompatible with the portable device, and are re-formatted for
`purposes of compatibility. Id. at 45:45–63. Likewise, claim 120 is similar
`to claim 49, but further defines that the “audio generated by the portable
`device” corresponds to “an audio file played by the portable device” and
`adds that the data from the portable device is in a format incompatible with
`the car audio/video device, and is then re-formatted for purposes of
`compatibility. Id. at 46:63–47:18.
`
`D. Prior Art Relied Upon
`Petitioner relies upon the following prior art references:
`Reference
`Date
`
`
`
`Exhibit
`
`Ohmura
`
`US 2001/0028717 A1
`
`Oct. 11, 2001 Ex. 1102
`
`Berry
`
`US 6,559,773 B1
`
`May 6, 2003
`
`Ex. 1103
`
`Marlowe
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`US 2003/0215102 A1
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`Nov. 20, 2003 Ex. 1104
`
`Kandler
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`Gioscia
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`Lau
`
`Myers
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`CA 2 347648 A1
`
`US 6,421,305 B1
`
`WO 01/67266 A1
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`US 6,486,889 B1
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`6
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`Dec. 1, 2001
`
`Ex. 1105
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`July 16, 2002 Ex. 1106
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`Sept. 13, 2001 Ex. 1107
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`Nov. 26, 2002 Ex. 1108
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`Petitioner also relies on the Declaration of Dr. Thomas Matheson. Ex.
`
`1120.
`
`E. Asserted Grounds of Unpatentability
`Petitioner challenges 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 on the
`following grounds:
`
`Basis
`
`References
`
`§ 103(a) Ohmura and Berry
`
`§ 103(a) Ohmura, Berry, and Marlowe
`
`Challenged Claims
`Claims 49–52, 55–57,
`62, 63, and 71
`Claims 49–57, 62, 63,
`66, 70, 71, 97, 99,
`100, 102, 103, 106,
`109, 110, 113, and 120
`Claims 64, 73–80, 94,
`95, 101, 111
`Claims 68 and 115
`Claims 49–57, 62–64,
`66, 68, 71, 73–80, 94,
`95, 97, 99, 100–103,
`106, 109, 110, 111,
`113, 115, and 120
`Claims 66, 68, 94,
`113, and 115
`Claim 70
`
`§ 103(a) Ohmura, Berry, Marlowe, and
`Kandler
`§ 103(a) Ohmura, Berry, Marlowe, and
`Gioscia
`
`
`
`Ohmura, Berry, Kandler, and Lau
`
`
`
`§ 103(a)
`
`§ 103(a) Ohmura, Berry, Kandler, Lau, and
`Gioscia
`§ 103(a) Ohmura, Berry, Kandler, Lau, and
`Myers
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`II. ANALYSIS
`A. Claim Construction
`In an inter partes review, claim terms in an unexpired patent are given
`their broadest reasonable construction in light of the specification of the
`patent in which they appear. 37 C.F.R. § 42.100(b); see also In re Cuozzo
`Speed Techs., LLC, 793 F.3d 1268, 1275–1279 (Fed. Cir. 2015), aff’d
`Cuozzo Speed Techs., LLC v. Lee, 2016 WL 3369425, at *12 (U.S. June 20,
`2016). Under the rule of broadest reasonable interpretation, claim terms are
`given their ordinary and customary meaning, as would be understood by one
`of ordinary skill in the art in the context of the entire disclosure. In re
`Translogic Tech., Inc., 504 F.3d 1249, 1257 (Fed. Cir. 2007).
`“Claims are not interpreted in a vacuum, but are part of and are read
`in light of the specification.” Slimfold Mfg. Co., Inc. v. Kinkead Indus., Inc.,
`810 F.2d 1113, 1116 (Fed. Cir. 1987). Although it is improper to read a
`limitation from the specification into the claims, In re Van Geuns, 988 F.2d
`1181, 1184 (Fed. Cir. 1993), the claims still must be read in view of the
`specification of which they are a part. Microsoft Corp. v. Multi-Tech Sys.,
`Inc., 357 F.3d 1340, 1347 (Fed. Cir. 2004).
`If a limitation of an embodiment described in the specification is not
`necessary to give meaning to a claim term, it would be “extraneous” and
`should not be read into the claim. See Hoganas AB v. Dresser Indus., Inc.,
`9 F.3d 948, 950 (Fed. Cir. 1993); E.I. du Pont de Nemours & Co. v. Phillips
`Petroleum Co., 849 F.2d 1430, 1433 (Fed. Cir. 1988). If the applicants for
`patent desire to be their own lexicographer, the purported definition must be
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`set forth in either the specification or prosecution history. See CCS Fitness,
`Inc. v. Brunswick Corp., 288 F.3d 1359, 1366 (Fed. Cir. 2002). Such a
`definition must be set forth with reasonable clarity, deliberateness, and
`precision. See Renishaw PLC v. Marposs Societa’ per Azioni, 158 F.3d
`1243, 1249 (Fed. Cir. 1998); In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir.
`1994). Only terms which are in controversy need to be construed, and only
`to the extent necessary to resolve the controversy. See Wellman, Inc. v.
`Eastman Chem. Co., 642 F.3d 1355, 1361 (Fed. Cir. 2011); Vivid Techs.,
`Inc. v. Am. Sci. & Eng’g, Inc., 200 F.3d 795, 803 (Fed. Cir. 1999).
`Petitioner proposes constructions for three claim terms: (1)
`“integration subsystem,” (2) “car audio/video system” and (3) “device
`presence signal.” Pet. 9–16. The terms (1) “integration subsystem” and (2)
`“car audio/video system” are recited in all challenged claims, whereas the
`term “device presence signal” is recited only in challenged claims 56 and
`106.
`
`1. “Integration subsystem”
`Each of independent claims 49, 73, 97, and 120 recites an “integration
`subsystem.” Ex. 1101, 42:30, 44:5, 45:50, 47:1.
`Petitioner argues because the term “subsystem” is used
`interchangeably in the ’342 patent with the term “module,” the claimed
`“integration subsystem” must be considered as a “means-plus-function”
`(MPF) element that must be construed under 35 U.S.C. § 112, 6th paragraph.
`See Williamson v. Citrix Online, LLC, 792 F.3d 1339, 1349 (Fed. Cir. 2015);
`Pet. 9. When the claimed “integration subsystem” is construed as a “means-
`plus-function” limitation, Petitioner argues “the claimed ‘integration
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`subsystem’ does not have sufficient corresponding structure disclosed in the
`specification [of the ’342 patent], and is therefore indefinite under 35 U.S.C.
`§ 112, 2nd paragraph.” Id. at 13. According to Petitioner, the flowchart of
`Figure 24 of the ’342 patent is considered as a “one-step algorithm” and, as
`such, “does not constitute sufficient corresponding structure for a computer-
`implemented function recited in a claim.” Id.
`Petitioner, relying on Dr. Matheson’s testimony (Ex. 1120 ¶¶ 73–84),
`then proposes that the term “integration subsystem” means “a
`microcontroller or processor provided within the portable device or the car
`audio/video system and programmed to perform the method of FIG. 24.” Id.
`at 15, 19 (emphasis in original); see also 13–15 (citing Ex. 1120 ¶ 84). The
`method of Figure 24 of the ’342 patent is reproduced below:
`
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`Figure 24 of the ’342 patent shows a method for wirelessly integrating a
`portable device for use with a car audio/video system.
`
`
`As shown in Figure 24, the method comprises determining a car
`audio/video system type and a portable device type at steps 1454–1456;
`loading a protocol conversion software block at step 1458; processing data
`from the portable device using the protocol conversion software block at
`step 1460 for transmission to the car audio/video system, via wireless link at
`
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`step 1466; and processing command from the car audio/video system using
`the protocol conversion software block for transmission to the portable
`device at step 1470. Ex. 1101, 38:9–67. Thus, the method of Figure 24 of
`the ’342 patent further requires the conversion of command/data using a
`protocol conversion software block corresponding to a determined car
`audio/video system type and a determined portable device type for format
`compatibility. For purposes of this decision, we refer to that requirement as
`the “command/data format conversion” limitation.
`Patent Owner does not propose a construction, but responds that the
`term “integration subsystem” does not invoke 35 U.S.C. § 112 ¶ 6 as argued
`by Petitioner. Prelim. Resp. 6. According to Patent Owner, the claims do
`not recite a “module” or a nonce term, and there is no authority for the
`proposition that the term “integration subsystem” must be considered a
`nonce term. Id. at 6–10. According to Patent Owner,
`Petitioner’s conclusion that the term “integration subsystem” is
`indefinite under 35 U.S.C. 112 ¶ 2 is incorrect because (1) the
`alleged functions of
`the
`integration subsystem are not
`“computer-implemented” and thus do not require an algorithm;
`(2) even if the functions required an algorithm, Figure 24 is
`sufficient; and (3) Petitioner ignores the voluminous algorithms
`and source code provided in the ’342 Patent specification that
`provide sufficient structure.
`
`Id. at 10; see also id. at 11–17.
`We agree with Patent Owner that Petitioner has not sufficiently shown
`that the term “integration subsystem” should be construed as a mean-plus-
`function recitation. As such, we decline to consider the term “integration
`subsystem” as a means-plus-function recitation under 35 U.S.C. § 112, ¶ 6
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`and Williamson, 792 F.3d at 1349. We also note that Petitioner may not, in
`an inter partes review, assert a ground of unpatentability based on
`indefiniteness under 35 U.S.C. § 112, ¶ 2. See 35 U.S.C. § 311(b).
`Turning now to Petitioner’s proposed construction of the term
`“integration subsystem,” that proposal is unpersuasive for several reasons.
`First, the proposed construction is too narrow by requiring the “integration
`subsystem” to be a microcontroller or processor programmed to perform the
`method of Figure 24 of the ’342 patent. In the Specification of the ’342
`patent, the term “integration subsystem” is described as follows.
`[t]he integration subsystem 932 contains circuitry similar to the
`circuitry disclosed in the various embodiments of the present
`invention discussed herein, and could include a PIC16F872 or
`PIC16F873 microcontroller manufactured by Microchip, Inc.
`and programmed in accordance with the flowchart discussed
`below with respect to FIG. 24.
`
`Ex. 1101, 34:63–35:1 (emphasis added).
`
`According to the ’342 patent’s Specification, the “circuitry similar to
`the circuitry disclosed in the various embodiments of the present invention”
`refers to various “integration” circuit embodiments shown in Figures 3A,
`3B1–3B2, 3C1–3C2, and 3D, including not only a microcontroller or
`processor but also several discrete components, such as resistors, diodes,
`capacitors, transistors, oscillators, amplifiers, and multiplexers for
`performing various “integration” functions. Ex. 1101, 12:55–16:29. In
`addition, the “integration subsystem” can also include:
`(1) “conversion circuitry (e.g., using the video format conversion
`chips discussed above with respect to FIG. 12a) for converting
`video information generated by the portable device 924 for
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`display on the display 918 of the car system 910 (e.g., by
`converting composite video signals to red, green, and blue
`(RGB) video signals, or vice versa)”;
`
`(2) “[t]he voice recognition subsystem 1336[, which could]
`comprise
`the HM2007
`speech
`recognition processor
`manufactured by Hualon Microelectric Corporation,
`the
`VRP6679 speech recognition processor manufactured by Oki,
`Inc., or any other suitable speech recognition processor”; and
`
`(3) “[t]he speech synthesizer 1338[, which] could include the RC
`8650 or RC 8660 speech synthesis chipsets manufactured by RC
`Systems, Inc., or any other suitable speech synthesizer.”
`
`
`Id. at 34:48–54, 36:53–58, 37:30–55, Fig. 23.
`
`Further, “the voice recognition subsystem 1336 and the speech
`synthesizer 1338 could [also] be formed on a single integrated circuit
`forming part of the integration subsystem 1332.” Id. at 37:48–51, Fig. 23.
`
`Thus, the term “integration subsystem” itself is not limited to a
`microcontroller or processor, nor is it limited to the functions described in
`the flowchart shown in Figure 24 of the ’342 patent. In that regard, we note
`that if the term “integration subsystem” is construed as a microcontroller or
`processor programmed to perform the method of Figure 24 of the ’342
`patent, as Petitioner proposes, then the additional functions of the claimed
`“integration subsystem” recited in the challenged claims would serve no
`meaningful purpose.
`Second, we note that a proper construction of “integration subsystem”
`must serve the purpose of “integration” as described in the ’342 patent’s
`Specification and must be a “subsystem” — subordinate to another system.
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`In the Specification of the ’342 patent, the term “integration” is expressly
`defined as follows:
`As used herein, the term “integration” or “integrated” is intended
`to mean [1] connecting one or more external devices or inputs to
`an existing car stereo or video system via an interface, [2]
`processing and handling
`signals, audio, and/or video
`information, [3] allowing a user to control the [external] devices
`via the car stereo or video system, and [4] displaying data from
`the devices on the car stereo or video system.
`Ex. 1101, 8:64–9:3 (emphasis added) (brackets added).
`When the specification of a patent contains a “special definition given
`to a claim term by the patentee,” that definition controls interpretation of the
`term as it is used in the claim. Phillips v. AWH Corp., 415 F.3d 1303, 1316
`(Fed. Cir. 2005) (en banc).
`The term “integration subsystem” is used in the ‘342 patent in relation
`to wireless integration embodiments between an existing car audio/video
`system and a portable device, shown in Figures 18–24. Ex. 1101, 33:43–
`38:67, Figs. 18–24. In particular, the ’342 patent’s Specification describes
`the “integration subsystem” as being positioned within the portable device,
`shown in Figure 18, or within the car audio/video system, shown in Figure
`19. Ex. 1101, 34:9–13, 35:23–28, Figs. 18–19.
`
`Based on the special definition of the term “integration” provided by
`the ’342 patent and other language in the claims, we construe the term
`“integration subsystem” as meaning:
`A subsystem to perform at least: (1) connecting one or more
`portable devices or inputs to the car audio/video system via an
`interface, (2) processing and handling signals, audio, and/or
`video information, (3) allowing a user to control the one or more
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`portable devices via the car audio/video system, and (4)
`displaying data from the one or more portable devices on the car
`audio/video system.
`
`2. “Car audio/video system”
`Independent claims 49 and 73 also require the “integration
`subsystem” in communication with a “car audio/video system.” Ex. 1101,
`42:30–31, 44:5–6. Similarly, independent claims 97 and 120 require the
`“integration subsystem” in communication with a wireless communication
`link between a “car audio/video system” and a portable device. Ex. 1101,
`45:46–51, 46:65–47:2.
`Petitioner proposes as the proper construction of “car audio/video
`system” “a car audio system, a car video system, or a car audio and video
`system.” Pet. 15. According to the ’342 patent’s Specification, the term
`“car audio/video system” is described as a car audio or a car video system.
`1101, 8:38–46. In addition,
`the terms “car stereo” and “car radio” are used interchangeably
`and are intended to include all presently existing car stereos,
`radios, video systems, such as physical devices that are present
`at any location within a vehicle, in addition to software and/or
`graphically- or display-driven receiver.
`
`Ex. 1101, 9:21–25.
`Patent Owner does not dispute Petitioner’s proposed construction.
`Prelim. Resp. 7. For purposes of this decision, we adopt Petitioner’s
`construction of the “car audio/video system” as “a car audio system, a car
`video system, or a car audio and video system.”
`
`
`16
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`3. “Device presence signal”
`Each of dependent claims 56 and 106 further recites: “integration
`subsystem generates a device presence signal and transmits the device
`presence signal to the car audio/video system to maintain the car audio/video
`system in a state responsive to the portable device.” Ex. 1101, 43:5–9,
`46:20–24. Regardless of the meaning of “device presence signal,” Petitioner
`has not shown a reasonable likelihood that it would prevail in establishing
`the unpatentability of claims 56 and 106. Thus, it is unnecessary to construe
`“device presence signal” in this proceeding.
`
`B. Legal Standard for 35 U.S.C. § 103(a)
`Having considered the meaning of the claims, we turn next to whether
`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 unpatentable under 35 U.S.C.
`§ 103(a) in view of the prior art submitted by Petitioner. Obviousness is
`determined on the basis of underlying factual inquiries, including: (1) the
`scope and content of the prior art; (2) differences between the claimed
`subject matter and the prior art; (3) the level of ordinary skill in the art; and
`(4) secondary considerations of nonobviousness. Graham v. John Deere
`Co., 383 U.S. 1, 17–18 (1966). A patent claim is unpatentable under 35
`U.S.C. § 103 if the differences between the claimed subject matter and the
`prior art are such that the subject matter as a whole would have been obvious
`at the time the invention was made to a person having ordinary skill in the
`art to which said subject matter pertains. KSR Int’l Co. v. Teleflex Inc., 550
`U.S. 398, 406 (2007). However, a conclusion of obviousness “cannot be
`
`17
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`sustained by mere conclusory statements; instead, there must be some
`articulated reasoning with some rational underpinning to support the legal
`conclusion of obviousness.” In re Kahn, 441 F.3d 977, 988 (Fed. Cir. 2006).
`For this decision, we determine that no express finding on the level of
`ordinary skill in the art is necessary, and that the level of ordinary skill in the
`art is reflected by the prior art of record. See Okajima v. Bourdeau,
`261 F.3d 1350, 1355 (Fed. Cir. 2001); In re GPAC Inc., 57 F.3d 1573, 1579
`(Fed. Cir. 1995); In re Oelrich, 579 F.2d 86, 91 (CCPA 1978).
`
`C. Alleged Obviousness of Claims 49–52, 55–57, 62, 63, and 71
`based on Ohmura and Berry
`
`Petitioner contends that claims 49–52, 55–57, 62, 63, and 71 are
`unpatentable under 35 U.S.C. § 103(a) as obvious over the combination of
`Ohmura and Berry. Pet. 24–33. To support its contention, Petitioner
`provides a claim chart and detailed explanations as to how the prior art
`meets each claim limitation. Id. at 28–33. Petitioner also relies upon a
`Declaration of Dr. Thomas Matheson, who has been retained as an expert
`witness by Petitioner for the instant proceeding. Ex. 1120.
`
`
`
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`
`(1) Ohmura: Exhibit 1102
`Ohmura1 discloses car audio/video system 100 mounted in vehicle 1
`and portable devices 200a–200b carried into vehicle 1 by passengers that
`communicate wirelessly with car audio/video system 100, shown in Figures
`1 and 2. Ex. 1102 ¶ 56, Abstract. Ohmura’s Figure 1 is reproduced below
`with additional markings inserted, in red, for illustration.
`
`
`Ohmura’s Figure 1 shows car audio/video system 100 with display 24
`mounted in vehicle 1 and portable devices 200a–200b that communicate
`wirelessly with car audio/video system 100.
`
`
`
`
`1 Ohmura (Ex. 1102) was published on October 11, 2001, has a filing date
`of April 9, 2001 and, as such, qualifies as prior art under 35 U.S.C. § 102(b)
`against the ’342 patent.
`
`19
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`
`Ohmura’s Figure 2 is reproduced below with additional markings
`inserted, in red, for illustration.
`
`
`
`Ohmura’s Figure 2 shows car audio/video system 100 with display 24 that
`communicates wirelessly with portable devices 200a–200b, via Bluetooth.
`
`As shown in Ohmura’s Figure 2, car audio/video system 100
`transmits/receives music data (“music file”) to/from portable devices 200a–
`200b, via transmission/reception modules 110, 2052 using a short-range
`radio such as Bluetooth, and controls operation of portable devices 200a–
`200b. Ex. 1102 ¶¶ 84–85, 89.
`
`
`2 In Ohmura’s Figure 2, only portable device 200a is shown in detail.
`However, it is understood that portable device 200b has the same
`transmission/reception module as portable device 200a.
`20
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`
`Ohmura describes the use of an “audio menu” on display 24 of car
`audio/video system 100, as shown in Figure 7, to provide a visual display of
`a playlist of music data (e.g., music titles, artist names and data volumes) for
`user selection of music data from a music source (e.g., FM, AM, car-
`mounted CD or external portable devices A–D) for an output destination
`(e.g., car-mounted speakers or external portable devices A–D). Ex. 1102
`¶¶ 113–115. Figure 7 of Ohmura is reproduced below with additional
`markings inserted, in red, for illustration.
`
`Ohmura’s Figure 7 shows an “audio menu” screen provided on display 24 of
`car audio/video system 100 to allow a user to select music data from a music
`source D11 (portable devices 200a–200b) for an output destination D13.
`
`
`21
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`
`(2) Berry: Exhibit 1103
`Berry discloses the use of an interface specifier (protocol conversion
`
`software block) corresponding to a specific combination of display type
`(determined car audio/video system type) and device type (determined
`portable device type) in the context of a car audio/video system equipped
`with reconfigurable control panel/display subsystem 10, shown in Figure 1,
`for processing and translating commands and data for format compatibility
`between a portable device and a car audio/video system. Ex. 1103, 3:62–
`4:3, 4:55–61, Abstract and Fig. 1.
`
`Berry’s Figure 1 is reproduced below:
`
`
`Figure 1 of Berry shows a control panel/display subsystem 10 of a car
`audio/video system to interact with multiple portable devices.
`
`
`According to Berry, human-machine interface (HMI) controller 34 in
`
`display subsystem 30 (shown in Figure 2) interfaces with a portable device
`(such as an MP3 player or a cellular phone) connected to a car audio/video
`system and issues control commands thereto according to a received input
`22
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`(such as a voice input). See id. at 3:6–4:14, 4:55–61. Based on the display
`type identifier for the car audio/video system and the device type identifier
`for the portable device, HMI controller 34 loads a corresponding interface
`specifier in order to support interaction between the two components, i.e., to
`process user input events, to process device events, to render graphic
`displays, and to process and translate commands and data between the
`portable device and the car audio/video system. See id. at 3:27–39, 3:62–
`7:9, 5:14–40, 6:26–27, 6:45–50.
`(3) Analysis of Obviousness
`Independent claim 49 recites a “multimedia device integration
`
`system” which comprises: “an integration subsystem” and first and second
`wireless interfaces, and requires the “integration subsystem” inter alia:
`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 to the car
`audio/video system for playing on the car audio/video system.
`
`Ex. 1101, 42:29–47 (emphasis added). Claims 50–52, 55–57, 62, 63, and 71
`depend, directly or indirectly, from claim 49. In all challenged claims 49–
`52, 55–57, 62, 63, and 71 of the ’342 patent, the “audio generated by the
`portable device” is the result of playing the a
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