HTC Corporation and HTC America, Inc.
`Petitioner Demonstratives
`
`HTC Corporation and HTC America, Inc.
`v.
`Advanced Audio Devices, LLC
`
`Case IPR2014-01156
`Patent No. 7,817,502 B2
`
`Oral Hearing
`September 17, 2015
`
`HTC, Ex. 1019
`HTC v. Advanced Audio Devices
`IPR2014-001156
`
`
`Petitioner Demonstratives
`
`HTC Corporation and HTC America, Inc.
`v.
`Advanced Audio Devices, LLC
`
`Case IPR2014-01156
`Patent No. 7,817,502 B2
`
`Oral Hearing
`September 17, 2015
`
`HTC, Ex. 1019
`HTC v. Advanced Audio Devices
`IPR2014-001156
`
`
`
`PTAB Instituted Grounds
`(Institution Decision, Paper 6, at 8, 22)
`
`IPR2014-01156
`
`HTC Demonstrative 502-2
`
`
`
`Nathan ‘259 (Ex. 1002)
`
`
`
`Nathan ‘255 (Ex. 1003)
`
`IPR2014-01156
`
`HTC Demonstrative 502-3
`
`
`
`Nathan ‘255 (Ex. 1003)
`
`•
`
`•
`
`New Selection Acquisition Mode:
`•
`“… the manager can access the mode of new
`selection acquisition by touching a button located
`on the touch screen.” (¶91)
`“The NSAM module is the new selections
`acquisition mode module. When this mode is
`activated, a new control screen appears. This mode
`is designed to assist the manager regarding the
`location or fast and efficient acquisition of titles of
`musical selections.” (¶92)
`“…a third panel for scanning the title database, for
`private use, to allow the system manager or owner
`to examine the database containing the available
`titles via the audiovisual data distribution network
`to control and retrieve said titles” (¶41)
`Customer Browsing and Selection Mode
`•
`“The CBSM module is the customer browsing and
`selection mode module. Access to this module is
`triggered from the "in service" mode by touching
`the screen. When the customer touches the screen,
`the screen display disappears to make room for a
`menu provided for powerful browsing assisted by
`digitized voice messages to guide the user in his
`choice of musical selections.” (¶99)
`“The first title selection panel proceeding to help
`customers find and select a desired title” (¶41)
`
`•
`
`IPR2014-01156
`
`HTC Demonstrative 502-4
`
`
`
`Nathan ‘259 (Ex. 1002)
`
`“A first object of the invention is to propose an apparatus which allows selection and downloading of digital
`data, and reproduction of these digital data for domestic apparatus or use of the device for karaoke.” (¶2)
`“Another object of the invention is to devise a modular device which allows the user to develop a design
`allowing storage of a plurality of audio or video or audiovisual information selections. This object is achieved by
`a second mass storage module (108) allowing the recording of a plurality of digitized audiovisual data.” (¶¶8-9)
`
`IPR2014-01156
`
`HTC Demonstrative 502-5
`
`
`
`
`
`Nathan ‘259 (Ex. 1002)
`
`The selection graphics
`screen shown in Fig. 10
`is displayed by button
`(1025) from any zone of
`the playback graphics
`screen. (¶74)
`
`Front (10) includes a red
`button (1019) which allows
`the “purchase" function
`described below. (¶46)
`This remote control device
`can trigger display of the
`graphics screen located in
`FIG. 9 when the "purchase"
`key equivalent to (1019) of
`the remote control is
`pressed. (¶46)
`
`Available songs (¶74)
`
`Purchase, check
`PIN/credit card,
`download (¶¶68-73)
`
`Select, add to
`queue (¶74))
`
`IPR2014-01156
`
`HTC Demonstrative 502-6
`
`
`
`Grounds 1 and 2 under 35 USC 103(a)
`Motivations to Combine
`
`Ground
`
`References
`
`1
`
`2
`
`Nathan ‘259 (Ex.
`1002)+ Nathan ‘255
`(Ex. 1003)
`Sound Blaster (Ex.
`1004) + Lucente (Ex.
`1005) + Ozawa (Ex.
`1006) + Hawkins (Ex.
`1007)
`
`Petition
`(Paper 1)
`
`2014
`Schmandt
`Declaration
`(Ex. 1009)
`
`Reply
`(Paper 21)
`
`17:4-18
`
`¶82
`
`11-12, 15
`
`2015
`Schmandt
`Rebuttal
`Declaration
`(Ex. 1014)
`¶¶13, 15
`
`36:20-
`42:15
`
`¶¶139-161
`
`16-23
`
`¶¶50-65
`
`IPR2014-01156
`
`HTC Demonstrative 502-7
`
`
`
`Ground 1: Nathan ‘259 in view of Nathan ‘255
`
`Element
`
`Challenged Claim
`
`1.Preamble
`
`1.A
`
`1.B
`
`1.C
`
`1.D
`
`1.E
`
`1.F
`
`1.G
`
`A method of storing sound tracks in a personal digital stereo audio player and
`playing the stored sound tracks for personal enjoyment, said method
`comprising:
`deploying the personal digital stereo audio player, wherein the personal digital
`stereo audio player comprises:
`a unitary, integral housing containing;
`
`at least non-volatile memory;
`
`and a processor connected to the non-volatile memory and configured for
`maintaining and selectively accessing and playing sound tracks stored in the
`non-volatile memory,
`the housing further comprising a display controlled by the processor,
`
`the processor being configured to cause the display to display a plurality of
`menus relating to a library of sound tracks,
`wherein all of the sound tracks in the library and their names are stored in the
`non-volatile memory of the personal digital stereo audio player,
`
`Petition
`(Paper 1)
`
`18:15-19:6
`
`19:7-12
`
`19:13 -20:3
`
`20:4-10
`
`20:11-21:3
`
`21:4-12
`
`2014
`Schmandt
`Declaration
`(Ex. 1008)
`¶85
`
`¶86
`
`¶87
`
`¶88
`
`¶89
`
`¶90
`
`21:13 -22:15
`
`¶91-93
`
`22:16-23:6
`See also element
`1.C 19:7,
`See also element
`1.F 21:13
`
`¶94
`See also 1.C,
`¶88, See also
`1.F, ¶91
`
`Reply
`(Paper
`20)
`
`*
`
`*
`
`*
`
`*
`
`12-14
`
`*
`
`*
`
`*
`
`IPR2014-01156
`
`* Claim element undisputed by AAD
`HTC Demonstrative 502-8
`
`
`
`Ground 1: Nathan ‘259 in view of Nathan ‘255
`
`Element
`
`Challenged Claim
`
`1.H
`
`1.I:
`
`1.J
`
`1.K
`
`1.L
`
`1.M
`
`1.N
`
`1.O
`
`wherein the menus include at least one of a list of names of sound tracks
`and a list of groups of sound tracks;
`a headphone jack in the housing;
`
`an input in the housing for receiving audio data;
`
`an amplifier operatively connected to the processor and the headphone jack
`and configured to amplify audio output signals produced during playing,
`which are transmitted to the headphone jack;
`and at least one touch-operable control in the housing and in
`communication with the processor,
`wherein the processor is configured such that at least one of the at least
`one touch-operable control is touchable to allow selection from the menus
`which the processor causes to be displayed on the display,
`at least one of the at least one touch-operable control is touchable to control
`the volume at which audio is played,
`at least one of the at least one touch-operable control is touchable to pause
`a sound track which is being played,
`
`Petition
`(Paper 1)
`
`23:7-20
`
`24:1 -2
`
`24:3-11
`
`2014
`Schmandt
`Declaration
`(Ex. 1008)
`¶95-96
`
`¶97
`
`¶98
`
`24:12-25:2
`
`¶99-100
`
`25:3-26:4
`
`¶101-103
`
`26:5-14
`
`¶104
`
`
`26:15-27:2 ¶105
`
`¶106
`
`
`27:3-7
`
`Reply
`(Paper
`20)
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`IPR2014-01156
`
`* Claim element undisputed by AAD
`HTC Demonstrative 502-9
`
`
`
`Ground 1: Nathan ‘259 in view of Nathan ‘255
`
`Element
`
`Challenged Claim
`
`1.P
`
`1.Q
`
`1.R
`
`1.S
`
`1.T
`
`1.U
`
`1.V
`
`1.W
`
`at least one of the at least one touch-operable control is touchable to stop a sound
`track as it is being played and play the next sound track in a group of sound tracks,
`at least one of the at least one touch-operable control is touchable to selectively
`power the personal digital stereo audio player on and off,
`and at least one of the at least one touch-operable control is touchable to select
`and play at least one of an individual sound track and a group of sound tracks
`through the headphone jack,
`wherein the personal digital stereo audio player is configured to display on the
`display at least one of time elapsed (ascending) and time remaining (descending)
`for the sound track being played,
`wherein the personal digital stereo audio player is configured such that the non-
`volatile memory stores a library of sound tracks that is received by the input and
`which has been pre-selected by a user,
`wherein the non-volatile memory comprises at least one of a Hard Disk Drive,
`solid state memory, and random address memory,
`said method further comprising: inputting audio data through the input of the
`personal digital stereo audio player to cause audio data to be received by the
`personal digital stereo audio player,
`whereby sound tracks become stored in the non-volatile memory as digital data;
`
`Petition
`(Paper 1)
`
`27:8-13
`
`2014
`Schmandt
`Declaration
`(Ex. 1008)
`¶107
`
`27:14-19
`
`¶108
`
`27:20-
`28:11
`28:12-17
`
`28:18-
`29:10
`29:10-13
`
`¶109
`
`¶110
`
`¶111
`
`¶112
`
`29:14-17
`
`¶113
`
`29:18-20
`
`¶114
`
`Reply
`(Paper
`20)
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`*
`
`IPR2014-01156
`
`* Claim element undisputed by AAD
`HTC Demonstrative 502-10
`
`
`
`Ground 1: Nathan ‘259 in view of Nathan ‘255
`
`Element
`
`Challenged Claim
`
`Petition
`(Paper 1)
`
`1.X
`
`1.Y
`
`1.Z
`
`and touching a one of the at least one touch-operable control in order to display on the
`display at least one of a list of names of sound tracks, and a list of groups of sound
`tracks,
`touching a one of the at least one touch-operable control to play at least one of a
`specific sound track and a group of sound tracks through the headphone jack,
`and touching a one of the at least one touch-operable control to control the volume at
`which sound tracks are played through the headphone jack.
`
`30:1-4
`
`30:5-7
`
`30:8
`
`2014 Schmandt
`Declaration
`(Ex. 1009)
`¶115
`
`¶116
`
`¶117
`
`Reply
`(Paper
`21)
`*
`
`12-14
`
`*
`
`IPR2014-01156
`
`* Claim element undisputed by AAD
`HTC Demonstrative 502-11
`
`
`
`Motivation to Combine
`Sound Blaster, Lucente, and Ozawa
`
`“In my opinion, a person of ordinary skill in the art would consider the teachings of each of Sound Blaster,
`Lucente, and Ozawa to be pertinent in designing a digital audio player, such as a computer with digital audio
`playback capability… A person of ordinary skill in the art would therefore consider Sound Blaster, Lucente, and
`Ozawa to be within the same field and would naturally consider the teachings of one to be relevant to the
`other…
`“In my opinion, a person of ordinary skill in the art would recognize that the functionality provided by the
`software taught by Sound Blaster, including recording and storing audio files, would provide similar benefits in
`a portable personal computer using a touch screen interface, such as the pen computer discussed in Lucente,
`for the same reason they would be beneficial in a personal computer (whether a desktop or laptop) using an
`interface such as a mouse… Lucente teaches that the touch screen computer it describes is intended to
`maintain the capability to be used for a wide range of software programs… In light of this overlap, and the
`similarity between the audio subsystems and audio input and output hardware of Sound Blaster and Lucente, a
`person of ordinary skill in the art would be motivated to combine a system with the flexibility, portability, and
`ease of use of Lucente with the audio management capabilities of Sound Blaster. Similarly, a person of ordinary
`skill in the art would recognize that the downloaded library of Ozawa could be improved using the
`organizational methods (e.g. sorting into playlists) of Sound Blaster…
`“In my opinion, combining the elements claimed by Challenged Claims of the 403 Patent into a single unit
`would not produce any benefits that would not be readily apparent to a person of ordinary skill in the art
`familiar with the teachings of Sound Blaster, Lucente, and Ozawa.”
`Ex. 1008 (Schmandt Decl., ¶¶ 147-149)
`Petition (Paper 1) at 33-39
`
`IPR2014-01156
`
`HTC Demonstrative 502-16
`
`
`
`Compatible Hardware
`
`
`
`M-Wave Audio
`subsystem
`Headphone port
`Microphone port
`Line in/out ports
`
`Schmandt Rebuttal Declaration:
`•
`[S]ound functionality for a variety of computing devices,
`including laptops and tablets with touch screens, was well-
`known at the time of the alleged invention, and a person of
`ordinary skill in the art would understand that the basic
`software concepts illustrated in Sound Blaster, including the
`use and management of playlists, could be adapted to work
`in a variety of computer systems having the appropriate
`hardware to play back sound files stored in memory, and
`would have a reasonable expectation of success… Ex. 1013,
`¶55.
`[A] person of ordinary skill in the art would understand the
`teachings of the Sound Blaster reference to be applicable to
`other types of busses or connections beyond the specific ISA
`example used on that particular card. Id., ¶56.
`The purpose of using a standard bus such as ISA, PCI, or MCA
`is to provide a common interface for hardware designers to
`allow their components to connect. Adapting hardware such
`as a sound card to utilize a known bus standard would have
`been a routine task well within the ability of a person of
`ordinary skill in the art, and would not have required undue
`experimentation. Id.
`Lucente discloses the use of Mwave Audio. Mwave audio was
`SoundBlaster compatible. Id., ¶57.
`
`•
`
`•
`
`•
`
`IPR2014-01156
`
`HTC Demonstrative 502-17
`
`
`
`Compatible Hardware
`
`Petition at 36-37:
`•
`Ozawa describes a portable audio device that
`uses personal computer technology (e.g. ISA,
`AT and PCT buses - Ozawa at 7: 27- 38; 9: 15-
`23) for the input and storage of audio, along
`with dedicated push-button controls such as
`direction, input and mode keys (e.g. fast-
`forward, play, rewind, stop and pause keys)
`are on the front panel of the housing for
`controlling playback of stored audio. The
`Ozawa device allows a user to selectively
`download music from a network service
`center, save that music to a hard disc within
`the player, and listen to music through
`headphones. The Ozawa device fits in a
`single rectangular housing and includes a
`CPU, RAM, hard disc for storing audio data,
`LCD display, 20 modem, headphone terminal
`and microphone terminal on its upper
`surface.
`
`IPR2014-01156
`
`HTC Demonstrative 502-18
`
`
`
`Compatible Software
`Touch-screen tablets/laptops
`Including IBM Tablets
`running Windows by 1997
`[I]n 1997 Fujitsu sold tablet
`computers running the
`Windows 95 operating system,
`such as the Fujitsu Stylistic
`1200. The Fujitsu Stylistic
`featured a touch-screen display
`along with a row of dedicated
`touch-sensitive controls
`immediately under the touch
`screen, including controls for
`sound playback, and a pen that
`could be pressed against the
`touch screen to achieve the
`same functions as left or right
`mouse clicks on a Windows 95
`machine without a touch
`screen:
`Ex.1008, ¶ 49
`
`Ex. 1008, App. J
`
`U.S. Patent No. 5,983,073… describes a laptop computer with
`a touch screen that could operate with a GUI based operating
`system such as Microsoft Windows 3.1
`Ex.1008, ¶ 50
`
`Ex. 1013, App. W
`
`IPR2014-01156
`
`HTC Demonstrative 502-19
`
`
`
`Conclusion
`
`PTAB should invalidate and cancel
`challenged claims based on instituted grounds
`
`IPR2014-01156
`
`HTC Demonstrative 502-20
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