`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`SDI TECHNOLOGIES, INC.,
`
`Petitioner
`
`v.
`
`BOSE CORPORATION,
`
`Patent Owner
`
`
`Patent No. 8,364,295
`Filing Date: December 7, 2006
`Issue Date: January 29, 2013
`Title: Interactive Sound Reproducing
`_______________
`
`Inter Partes Review No. IPR2014-000346
`
`____________________________________________________________
`
`AMENDED PETITION FOR INTER PARTES REVIEW
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. § 42.100 et seq.
`
`Pursuant to Paper No. 5, mailed January 29, 2014, Petitioner SDI
`
`Technologies, Inc. submits this Amended Petition, in which (a) the footnotes have
`
`been double spaced and (b) all argument has been removed from the claim charts.
`
`No substantive changes have been made to the Petition.
`
`

`

`
`
`TABLE OF CONTENTS
`
`INTRODUCTION ...........................................................................................1  
`I.  
`   NOTICE OF LEAD AND BACKUP COUNSEL ..........................................3  
`II.  
`   NOTICE OF EACH REAL-PARTY-IN-INTEREST ....................................3  
`III.  
`IV.   NOTICE OF RELATED MATTERS .............................................................3  
`V.  
`   NOTICE OF SERVICE INFORMATION .....................................................5  
`VI.   GROUNDS FOR STANDING .......................................................................5  
`VII.   STATEMENT OF PRECISE RELIEF REQUESTED ...................................5  
`VIII.   THRESHOLD REQUIREMENT FOR REVIEW ..........................................5  
`IX.   STATEMENT OF REASONS FOR RELIEF REQUESTED ........................6  
`A.  
`Technical Introduction to the ’295 Patent .............................................6  
`B.  
`Prior Art: The Sony Music System ......................................................7  
`C.  
`Prior Art: Creative Labs Nomad/Samsung Yepp MP3 Player .............8  
`D.  
`Altec Lansing ADA310 Remote Controlled Speakers .........................9  
`E.  
`   Prior Art: European Patent Application No. 0 929 170 .....................11  
`F.  
`   Prosecution History of the ’295 Patent ...............................................12  
`G.  
`Construction of the Claims .................................................................13  
`X.  
`FOR INVALIDITY .......................................................................................14  
`A.   Ground I .................................................................................................14  
`B.   Ground II ................................................................................................33  
`XI.   CONCLUSION .............................................................................................55
`  
`  
`
`CLAIM-BY-CLAIM EXPLANATION OF GROUNDS
`
`Prior Art: WinAmp 1.5, the IRMan, and the
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`ii
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`I.
`
`INTRODUCTION
`
`On July 25, 2013, SDI Technologies, Inc. (“SDI”) filed a Petition for Inter
`
`Partes Review of claims 1-21, 24, 27, 29-47, 50, 63, 64, 68-70, 73, 74, 77, and 78
`
`of United States Patent No. 8,364,295 (the “’295 Patent”), now styled SDI
`
`Technologies, Inc. v. Bose Corporation, Case No. IPR2012-00465 (the “465 IPR”).
`
`The Board’s Decision on Institution of Inter Partes Review granted SDI’s
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`Petition with respect to each of claims 1-21, 24, 27, 29-47, 50, 63, 64, 68-70, 73,
`
`74, 77, and 78, citing four grounds.
`
`The first two grounds were obviousness over the “SMS” and “Nomad”
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`references, the “Looney” reference being added for certain claims; the second two
`
`were obviousness over the “WinAmp” and “IRMan Web Pages” and “Altec
`
`Lansing Manual” references, the “Looney” reference being added for certain
`
`claims.
`
`Patent Owner Bose Corporation (“Bose”) has now accused SDI of infringing
`
`additional claims of the ’682 Patent, directed a feature in which the speaker is also
`
`“configured to respond to signals received from the computer.” These claims—25,
`
`26, 51, 52, 53, 55-59, 60-62, 75, and 76—can be grouped as follows:
`
`Dependent Claim 25, 26, 51, and 52: Claims 25 and 26 depend from
`
`independent claim 1 (which is a subject of the 465 IPR), adding that “the sound
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`reproduction device is configured to respond to signals received from the
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`  
`
`1
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`

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`computer” and that the signals “are transmitted via a signal path of the connector.”
`
`Claims 51 and 52 similarly depend from independent claim 27 (which is a subject
`
`of the 465 IPR), adding the same features.
`
`Claim 53 and Its Dependents: Independent claim 53 tracks independent
`
`claim 27 (which, again, is a subject of the 465 IPR), except that it removes the
`
`requirement that the computer “has a plurality of user functions” and adds that the
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`connector is also configured to “receive signals from the computer.” Dependent
`
`claims 55 to 58 and 75 generally correspond to claims depending from claims 1 or
`
`27 that are already subjects of the 465 IPR.
`
`Claim 59 and Its Dependents: Independent claim 59 also tracks
`
`independent claim 27, except that it adds that the computer is configured to
`
`provide music from a plurality of sources (a feature taken from claim 1) and adds
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`that the connector is also configured to “receive signals from the computer.”
`
`Dependent claims 60 to 62 and 76 generally correspond to claims depending from
`
`claim 27 that are also subjects of the 465 IPR.
`
`This Petition challenges these additional claims of the ’295 patent, all of
`
`which add to subject matter already being treated in the 465 IPR that the speaker
`
`receives signals from the computer. As discussed in more detail below, this feature
`
`is explicitly described in the Altec Lansing Manual, rendering the additional claims
`
`invalid based on the second combination cited in the 465 Decision (WinAmp/
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`  
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`2
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`

`

`IRMan/Altec Lansing). These claims are also invalid in light of the first
`
`combination (SMS/Nomad/Looney), as it would have been obvious to one of skill
`
`in the art at the time of the invention to have the speaker respond to signals from
`
`the computer such as, for example, in determining whether the computer was on
`
`prior to attempting to communicate with it, a common feature of electronic
`
`communication protocols, in order to, for example, avoid futile communicates with
`
`a device that is not present or not turned on.
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`II. NOTICE OF LEAD AND BACKUP COUNSEL
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`
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`
`
`
`
`
`
`
`Lead Counsel:
`
`
`
`
`
`
`
`
`
`
`
`Matthew B. Lowrie (Reg. No. 38,228)
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`Tel: 617-342-4006; Fax: 617-342-4001
`
`Backup Counsel:
`
`Aaron W. Moore (Reg. No. 52,043)
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`
`
`
`
`Address:
`
`
`
`
`
`
`
`
`
`Tel: 617-342-4007; Fax: 617-342-4001
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`Foley & Lardner LLP
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`111 Huntington Avenue, Boston, MA 02199
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`
`
`
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`III. NOTICE OF EACH REAL-PARTY-IN-INTEREST
`
`The real-party-in-interest is SDI Technologies, Inc.
`
`IV. NOTICE OF RELATED MATTERS
`
`As noted above, claims 1-21, 24, 27, 29-47, 50, 63, 64, 68-70, 73, 74, 77,
`
`and 78 of the ’295 Patent are the subject of instituted IPR2013-00465. SDI is
`
`today filing a motion to join this proceeding with the 465 IPR.
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`  
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`3
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`The ’295 patent has been asserted in the following action: Bose Corporation
`
`v. SDI Technologies, Inc. (D. Mass. Case No. 13-cv-10277-WGY), filed on
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`February 13, 2013 and still pending.
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`The immediate parent of the ’295 patent, U.S. Patent No. 7,277,765 (the
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`“’765 patent”), was asserted in Bose Corporation v. SDI Technologies, Inc., et al.
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`(D. Mass. Case No. 09-cv-11439), which resulted in a grant of summary judgment
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`of non-infringement of all asserted claims, which is pending on appeal.
`
`The parent ’765 patent is also the subject of Inter Partes Reexamination No.
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`95/001,260, in which all claims stand rejected. The Board affirmed the Examiner’s
`
`rejections and also added a new ground of rejection. The patent owner reopened
`
`prosecution, the Examiner entered the new ground of rejection in addition to the
`
`others, and the appeal is again before the Board. In addition, the parent ’765 patent
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`was the subject of Inter Partes Reexamination Request No. 95/001,332, which
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`presented some of the art presented in this petition. That request was denied,
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`however, because all of the claims of the of the ’765 patent were rejected at the
`
`time the ’332 reexamination request was filed.
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`A continuation of the ’295 patent, U.S. Patent 8,401,682 (the “’682 patent”),
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`is the subject of IPR2013-00350.
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`4
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`V. NOTICE OF SERVICE INFORMATION
`
`Please address all correspondence to the lead counsel at the address shown
`
`above. Petitioner also consents to electronic service by email at
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`mlowrie-PTAB@foley.com and amoore-PTAB@foley.com.
`
`VI. GROUNDS FOR STANDING
`
`Petitioner hereby certifies that the patent for which review is sought is
`
`available for inter partes review and that the petitioner is not barred or estopped
`
`from requesting an inter partes review challenging the patent claims on the
`
`grounds identified in the petition.
`
`VII. STATEMENT OF PRECISE RELIEF REQUESTED
`
`The Petitioner respectfully requests that claims 25, 26, 51, 52, 53, 55-59, 60-
`
`62, 75, and 76 of U.S. Patent No. 8,364,295 (Ex. 1001) be canceled based on the
`
`following grounds of invalidity, explained in detail (including relevant claim
`
`constructions) in the following sections.
`
`VIII. THRESHOLD REQUIREMENT FOR REVIEW
`A petition for Inter Partes Review must demonstrate “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). This Petition meets the threshold.
`
`Each of the elements of the subject claims of the ’295 patent are taught as
`
`explained below in the proposed rejections, with an appropriate motivation to
`
`combine where the proposed rejection is under 35 U.S.C. § 103(a).
`
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`5
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`IX. STATEMENT OF REASONS FOR RELIEF REQUESTED
`A. Technical Introduction to the ’295 Patent
`
`The ’295 patent (Exhibit 1001) is directed to “an audio system attachable to
`
`a computer” that includes a powered speaker. One embodiment of the system of
`
`the ’295 patent is illustrated schematically in Figure 1, with the computer being the
`
`large box (20) on the right, and the sound reproduction device (the speaker) being
`
`the large box (10) on the left.
`
`
`
`The independent claims are generally directed to the capability of the remote
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`(item 17 in the patent) to control both the speaker (item 10) directly and the
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`computer (item 20) indirectly though an IR receiver that is located in the speaker.
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`This is illustrated schematically below.
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`6
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`B.
`
`Prior Art: The Sony Music System
`
`The prior art Sony Music System Manual (Ex. 1002), which bears a 1998
`
`Copyright date, describes a portable music player that included a remote control.
`
`The manual is prior art under 35 U.S.C. § 102(b). The system could be connected
`
`to a Sony MiniDisc player, in which case the remote control supplied with the
`
`boom box would control the Music System directly (e.g., the volume) and would
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`also control the MiniDisc player through the Music System, as in the system of the
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`’295 patent. (See Exhibit 1002, at 41-44.) The Sony Music System (below, left) is
`
`shown on page 4 of the manual, and the connection to the MiniDisc player (below,
`
`right) is illustrated on page 41:
`
`
`
`
`
`
`
`A schematic illustration of the Sony Music System, which is virtually
`
`identical to that for the patented system on the preceding page, is provided below.
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`  
`
`
`
`7
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`C.
`
`Prior Art: Creative Labs Nomad/Samsung Yepp
`MP3 Player
`The Creative Labs Nomad MP3 Player Manual (Ex. 10051), which bears a
`
`June 1999 date, describes a portable MP3 player, in a form factor that resembled
`
`the Sony MiniDisc player, that played music from any one of a number of sources,
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`including internal memory, removable memory cards, music downloaded to the
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`memory or the memory cards from the internet, and a built-in FM radio. The
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`manual is prior art under 35 U.S.C. § 102(b). The device is also described in an
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`August 19, 1999 PCWorld article (Exhibit 1006).
`
`
`
`
`
`The Creative Nomad device was also released in 1999 as the Samsung Yepp
`
`                                                                                                                
`exhibits common to the 465 IPR retain the same numbering as in the 465 IPR.  
`  
`
`YP-D40, as shown in the April 1999 issue of Popular Science magazine (Exhibit
`
`1 In light of the Motion for Joinder, and in order to avoid confusion, Petitioner has
`
`omitted exhibit numbers 1003, 1004, 1013, 1014, and 1015, so that the rest of the
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`8
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`

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`1007) and an April 29, 1999 Samsung Press Release (Exhibit 1008), which
`
`describes it as a “digital audio device that allows the user to download music files
`
`from the Internet or other on-line services” that included an FM tuner. The
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`magazine and press release are prior art under 35 U.S.C. § 102(b).
`
`D.
`
`Prior Art: WinAmp 1.5, the IRMan, and the Altec Lansing
`ADA310 Remote Controlled Speakers
`
`WinAmp, described on pages 65-93 of Guy Hart-Davis and Rhonda Holmes,
`
`MP3! (Sybex Inc. 1999) (excerpted as Ex. 1009), was a widely-used computer
`
`software package for playing MP3s. According to the records on the U.S.
`
`Copyright Office, the MP3! book was published on September 10, 1999 (see
`
`Exhibit 1016), making it prior art under 35 U.S.C. § 102(b). MP3! describes how
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`WinAmp would play locally stored music files, as well as music streamed from
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`internet radio stations.
`
`The IRMan, described in the web pages of its manufacturer, Evation,
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`captured by archive.org on June 8, 1999 (Ex. 1010), was a system that included a
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`remote control unit and an IR receiver that connected to a computer. The purpose
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`of the system was to allow the remote control to control software running on the
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`9
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`computer, including MP3 software and, in particular, WinAmp. The June 8, 1999
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`web pages are prior art under 35 U.S.C. § 102(b).2
`
`The Altec Lansing ADA310 speaker system, described in a 1998 Manual
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`(Exhibit 1011) and an October 17, 1997 Business Wire article (Exhibit 1012) was a
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`set of powered computer speakers that included a remote control for controlling the
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`operation of the speakers and were configured to accept audio in either digital or
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`analog format. The Manual and Article are prior art under 35 U.S.C. § 102(b).
`
`The combination of WinAmp, the IRMan, and the Altec Lansing speakers
`
`would have provided the same functionality as the system of the ’295 patent,
`
`except that there would be two remotes (one for the speaker and one for the
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`IRMan), and the IRMan signal would not pass though the speaker:
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`                                                                                                                
`
`2 The IRMan web pages are available in the Internet Archive at web.archive.org/
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`web/19990508121919/http://www.evation.com/irman/index.html, where the
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`number sequence “19990508” in the URL establishes a prior art date no later than
`May 8, 1999, 1998. See MPEP § 2128; e.g., Ex Parte Molander, Appeal 2008-
`2589, Application 09/845,537, pp. 9-12 (B.P.A.I. March 17, 2009); Ex Parte
`
`Shaouy, Appeal 2007-0987, Application 09/810,992 (B.P.A.I. May 24, 1997).  
`  
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`10
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`Thus, the primary difference between this combination and the claimed
`
`invention is that the invention combines the remotes of the IRMan and ADA310
`
`speaker and places the IRMan receiver in the speaker. The functionality is the
`
`
`
`same.
`
`Of particular relevance to this Petition, the 1998 Manual explains that
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`“[c]omputers that are USB (universal serial bus) equipped can control all speaker
`
`functions from the desktop.” (Ex. 1011, at 3.) This is done with software that runs
`
`on the computer and includes a graphic user interface. (Id.) In addition, the
`
`speaker does not have a power switch but, instead, “[w]hen audio is received . . .
`
`the speaker turns on automatically.” (Ex. 1011, at 4.) Thus, the speaker was
`
`configured to respond to signals received from the computer.
`
`E.
`
`Prior Art: European Patent Application No. 0 929 170
`
`European Patent Application No. 0 929 170 (the “EP ’170 Application,”
`
`Exhibit 1018), titled “Methods, systems and apparatus for providing device status
`
`information within a communication network,” was published on July 14, 1999,
`
`making it prior art under 35 U.S.C. 102(b). The application describes a home
`
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`11
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`audio/visual network in which TVs, PCs, and other devices can be coupled
`
`together. Paragraph 42 of the application explains that “[w]ithin a communications
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`network where devices can communicate and control other devices, it is important
`
`that devices and associated software objects be aware of the current status of
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`devices in the network to provide effective communication, control and reporting
`
`functions.”
`
`F.
`
`Prosecution History of the ’295 Patent
`
`The continuation application for the ’295 patent was filed December 7, 2006
`
`with one claim and assigned Serial Number 11/608,034. The one claim was
`
`rejected as anticipated on June 12, 2008. On October 15, 2008, the applicant
`
`canceled claim 1 and added new claims 44-67. On January 15, 2009, in response
`
`to a restriction requirement, the applicant elected claims 44-57, 59-61, and 64. On
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`April 17, 2009, the examiner finally rejected those claims and anticipated by the
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`same reference that had anticipated claim 1.
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`The applicant then filed an RCE, canceling all of the claims and presenting
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`new claims 68-130, filed a supplemental response adding claim 131, and filed
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`another supplemental response adding claim 132. On March 22, 2010, the
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`examiner rejected claims 68-132 on double patenting grounds in light of the parent
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`’765 patent. On August 17, 2010, the applicant interviewed the case and then, on
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`August 23, 2010, the applicant filed a terminal disclaimer, canceled claims 69-71,
`
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`12
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`77, and 99-132, added new claims 133-142, and amended claim 68, the only
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`independent claim. On February 28, 2011, the examiner issued a Notice of
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`Allowance and the applicant paid the issue fee on March 4, 2011. On March 30,
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`2011, the Office mailed and Issue Notification.
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`On April 15, 2011, the applicant filed a petition to withdraw from issue,
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`which was granted. On September 23, 2011, the applicant cancelled the claims
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`that had been allowed, and submitted new claims 143-218, along with new prior
`
`art. On February 2, 2012, the applicant interviewed the case again. On February
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`29, 2012, the applicant filed a preliminary amendment, amending various claims
`
`and adding claims 219-225. On June 1, 2012, the applicant filed another
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`preliminary amendment, adding claim 226. On December 21, 2012, the examiner
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`issued a Notice of Allowance, stating that the claims were allowable for “the same
`
`reasoning as set forth by the applicants/remarks of amendments filed 08/23/2010
`
`and 02/29/2012,” which merely paraphrased the claims. The applicant paid the
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`issue fee the day and the patent issued on January 29, 2013.
`
`G. Construction of the Claims
`
`The claim terms are presumed to take on their broadest reasonable
`
`construction, except as described below.
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`13
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`

`In the decision instituting the 465 IPR, the Board construed the following
`
`terms that are relevant to this Petition, and SDI believes those terms should be
`
`afforded the same construction in this proceeding.
`
`Term
`
`“computer”
`
`Construction
`
`“any machine capable of receiving input,
`processing, storing, and outputting data”
`
`“computer that is configured to
`provide audio information from
`any one of a plurality of sources,
`including digital music files
`stored on the computer and a
`network accessible by the
`computer”
`
`Additionally, the Board construed “network” and “audio information from
`
`Only requires a computer configured to
`provide audio information from either one or
`more of digital music files stored on a
`computer, or one or more of different
`networks accessible by a computer, but, it
`does not preclude providing the information
`from both types of sources.
`
`the network via the computer,” but neither is material to the grounds upon which
`
`the Board instituted the 465 IPR, or the grounds presented here.
`
`X. CLAIM-BY-CLAIM EXPLANATION OF GROUNDS
`FOR INVALIDITY
`A. Ground I
`
`Claims 25, 26, 51, 52, 53, 55-59, 60-62, 75, and 76 are invalid under 35
`
`U.S.C. § 103 in view of the combination of MP3! book, describing WinAmp (Ex.
`
`1009), the IRMan Web Pages (Ex. 1010), and the Altec Lansing Manual (Ex.
`
`1011) (or the Altec Lansing Press Release (Ex. 1012), describing the same device).
`
`It would have been obvious to make this combination because IRMan device was
`
`  
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`14
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`

`intended to control the WinAmp MP3 player software running on a computer, and
`
`the Altec Lansing speakers were designed to play computer audio.
`
`It would have been obvious to use the control circuitry in the ADA310
`
`housing to control both the speaker and the computer (i.e., to combine to IR
`
`receivers of the speaker and the IRMan), in order to, for example, reduce clutter
`
`and duplication. (See Lippman Decl., Exhibit 1017, ¶ 39-41.) This same
`
`combination forms the basis for Grounds 3 and 4 of the instituted 465 IPR.
`
`The additional element addressed in this Petition—the speaker responding to
`
`signals from the computer—is explicit in the Altec Lansing Manual, which states
`
`that “[c]omputers that are USB (universal serial bus) equipped can control all
`
`speaker functions from the desktop.” (Ex. 1011, at 3.) The computer is controlling
`
`the speaker by transmitting electrical signals to which the speaker responds. In
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`addition, the reference explains that “[w]hen audio is received . . . the speaker turns
`
`on automatically.” (Ex. 1011, at 4.) Again, the computer is transmitting electrical
`
`signals (music signals, in this case) to which the computer responds.
`
`This combination is detailed in the following claim charts. Bold borders
`
`denote claims that are the subject of only this Petition, as opposed to claims that
`
`are part of the 465 IPR but are also included below because they are parents of
`
`dependent claims addressed in this Petition.
`
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`15
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`

`’295 Patent
`
`1. An audio system configured to
`connect to a separate computer that is
`configured to provide audio
`information from any one of a
`plurality of sources, including digital
`music files stored on the computer and
`a network accessible by the computer,
`the audio system comprising:
`
`(A) a sound reproduction device
`comprising:
`
`a housing;
`
`one or more speakers located at least
`partially within the housing;
`
`an amplifier located within the
`housing for powering the one or
`more speakers;
`
`WinAmp Plus IRMan Plus Altec
`Lansing ADA310 Speakers
`
`The combination is a powered speaker
`system (the ADA310) intended to
`connect to a personal computer, and a
`personal computer running WinAmp
`software that provided audio
`information from any one of a plurality
`of sources, including stored digital
`music files and the internet. (See MP3!,
`Ex. 1009, at 72-74 (describing how to
`play tracks and Internet streams);
`ADA310 Manual, Ex. 1011.)
`
`The ADA310 speaker was a sound
`reproduction device. (See ADA310
`Manual, Ex. 1011.)
`
`The speaker had a housing. (See
`ADA310 Manual, Ex. 1011.)
`
`There were one or more speakers
`located within the housing. (See
`ADA310 Manual, Ex. 1011.)
`
`The speakers had amplifiers located
`within the housing, 10W in the small
`speakers and 24W in the subwoofer.
`(See ADA Manual, Ex. 1011, at 7 (5W
`per driver in the satellites).)
`
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`16
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`

`control circuitry located within the
`housing; and
`
`a connector located at least partially
`within the housing that is configured
`to provide a physical and electrical
`connection exclusively between the
`sound reproduction device and the
`computer,
`
`Both the ADA310 and the IRMan
`provided control circuitry for receiving
`IR signals, as described below. (See
`ADA310 Manual, Ex. 1011, at 6 (IR
`receiver); IRMan Web Page, Ex. 1010,
`at 1 (“Irman can receive the infrared
`signals transmitted by all sorts of
`remotes. It converts these signals to
`computer commands understood by
`software in your PC.”).)
`
`The speaker had a connector
`(connections for the speaker audio) that
`would have been at least partially within
`the housing, providing a physical and
`electrical connection exclusively
`between the speaker and the computer.
`(See ADA310 Manual, Ex. 1011, 4-5.)
`
`wherein the connection includes one
`or more signal paths configured to (i)
`receive audio information from the
`computer corresponding to the
`digital music files stored on the
`computer and audio information
`from the network via the computer,
`and (ii) transmit to the computer
`signals for controlling the computer;
`and
`
`In the combination, the connection in
`the speaker would include signal paths
`configured to (i) receive audio from the
`computer corresponding to the digital
`music files stored on the computer and
`audio from the network via the
`computer (audio to the speaker), and (ii)
`transmit to the computer, signals for
`controlling the computer (IRMan
`control signals).
`
`(B) a remote control device configured
`to transmit signals representing at least
`a first type of command from a user
`and a second type of command from a
`user to the sound reproduction device,
`
`The speaker remote and the IRMan
`remote were configured to transmit
`signals representing first and second
`types of commands from a user, as
`described below.
`
`  
`
`17
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`

`

`wherein the first type of command is
`a command to control a user function
`of the sound reproduction device and
`the second type of command is a
`command to control a user function
`of the computer,
`
`wherein the control circuitry is
`configured to receive the signals
`from the remote control and, in
`response to receiving such signals:
`(i) control the user function of the
`sound reproduction device when the
`user issues a command of the first
`type, and (ii) transmit to the
`computer, via a signal path of the
`connector, a signal for controlling
`the user function of the computer
`when the user issues a command of
`the second type.
`
`The first type of command (i.e., from
`the speaker remote) would control a
`user function of the sound reproduction
`device (e.g., volume) and the second
`(i.e., from the IRMan remote) would
`control a user function of the MP3
`player software running on the
`computer (e.g., stop or play). (See
`ADA310 Manual, Ex. 1011, at 7
`(showing the remote); IRMan Web
`Page, Ex. 1010, at 1 (“Imagine
`controlling Winamp with a normal
`remote to choose exactly the song you
`want.”).)
`
`The control circuitry would receive the
`signals from the remote and (i) control
`the user function of the sound
`reproduction device if the command
`was of the first type (i.e., from the
`speaker remote), and (ii) transmitted to
`the computer, via a signal path of the
`connector, a signal for controlling the
`user function of the computer if the user
`issued a command of the second type
`(i.e., from the IRMan remote). (See
`ADA310 Manual, Ex. 1011, at 7
`(showing the remote and describing its
`operation); IRMan Web Page, Ex. 1010,
`at 1 (“Imagine controlling Winamp with
`a normal remote to choose exactly the
`song you want.”).)
`
`18
`
`  
`
`  
`
`

`

`25. The audio system of claim 1
`wherein the sound reproduction device
`is configured to respond to signals
`received from the computer.
`
`26. The audio system of claim 25
`wherein signals to the computer and
`signals from the computer to the sound
`reproduction device are transmitted
`via a signal path of the connector.
`
`27. An audio system configured to
`connect to a separate computer that
`has a plurality of user functions, a
`subset of the user functions relating to
`control of audio information, the audio
`system comprising:
`
`(A) a sound reproduction device
`comprising:
`
`The speakers were configured to
`respond to signals received from the
`computer.
`“Computers that are USB (universal
`serial bus) equipped can control all
`speaker functions from the desktop.”
`(ADA310 Manual, Ex. 1011, at 3.) This
`is done with software that runs on the
`computer, using a graphic user
`interface. (Id.) The control necessarily
`would be accomplished by electrical
`signals to which the speaker would
`respond.
`In addition, the ADA310 speaker did
`not have a power switch but, instead,
`“[w]hen audio is received . . . the
`speaker turns on automatically.” (Id., at
`4.) Thus, the speaker also responded to
`music signals from the computer.
`
`The signals to the computer and signals
`from the computer to the sound
`reproduction system are transmitted via
`a signal path of the connector.
`
`The combination includes an audio
`system configured to connect to a
`personal computer that had a plurality
`of user functions, not all of which
`related to control of audio information.
`The computer could be turned on/off or
`run other types of software.
`
`The ADA310 speaker was a sound
`reproduction device. (See ADA310
`Manual, Ex. 1011.)
`
`  
`
`19
`
`

`

`a housing;
`
`one or more speakers located at least
`partially within the housing;
`
`an amplifier located within the
`housing for powering the one or
`more speakers;
`
`control circuitry located within the
`housing;
`
`and a connector located at least
`partially within the housing that is
`configured to provide a physical and
`electrical connection exclusively
`between the sound reproduction
`device and the computer,
`
`The speaker had a housing. (See
`ADA310 Manual, Ex. 1011.)
`
`There were one or more speakers
`located within the housing. (See
`ADA310 Manual, Ex. 1011.)
`
`The speakers had amplifiers located
`within the housing, 10W in the small
`speakers and 24W in the subwoofer.
`(See ADA Manual, Ex. 1011, at 7 (5W
`per driver in the satellites).)
`
`Both the ADA310 and the IRMan
`provided control circuitry, as described
`below. (See ADA310 Manual, Ex. 1011,
`at 6 (IR receiver); IRMan Web Page,
`Ex. 1010, at 1 (“Irman can receive the
`infrared signals transmitted by all sorts
`of remotes. It converts these signals to
`computer commands understood by
`software in your PC.”).)
`
`The speaker had a connector
`(connections for the speaker audio) that
`would have been at least partially within
`the housing, providing a physical and
`electrical connection exclusively
`between the speaker and the computer.
`(See ADA310 Manual, Ex. 1011, 4-5.)
`
`  
`
`20
`
`

`

`wherein the connection includes one
`or more signal paths configured to (i)
`receive audio information from the
`computer, and (ii) transmit to the
`computer signals for controlling the
`computer; and
`
`(B) a remote control device configured
`to transmit signals representing at least
`a first type of command from a user
`and a second type of command from a
`user to the sound reproduction device,
`
`wherein the first type of command is
`a command to control user function
`of the sound reproduction device and
`the second type of command is a
`command to control a user function
`of the computer relating to control of
`audio information,
`
`In the combination, the connection in
`the speaker would include signal paths
`configured to (i) receive audio from the
`computer corresponding to the digital
`music files stored on the computer and
`audio from the network via the
`computer (audio to the speaker), and (ii)
`transmit to the computer, signals for
`controlling the computer (IRMan
`control signals).
`
`The speaker remote and the IRMan
`remote were configured to transmit
`signals representing first and second
`types of commands from a user.
`
`The first type of command (i.e., from
`the speaker remote) would control a
`user function of the sound reproduction
`device (e.g., volume) and the second
`(i.e., from the IRMan remote) controlled
`a user function of the MP3 player
`software running on the computer (e.g.,
`stop or play). (See ADA310 Manual,
`Ex. 1011, at 7 (showing the remote);
`IRMan Web Page, Ex. 1010, at 1
`(“Imagine controlling Winamp with a
`normal remote to choose exactly the
`song you want.”).)
`
`  
`
`21
`
`

`

`wherein the control circuitry is
`configured to receive the signals
`from the remote control and, in
`response to receiving such