UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`DELL INC., DELL TECHNOLOGIES INC., HP INC., AND LENOVO (UNITED
`STATES) INC.,
`Petitioner
`
`v.
`
`UNIVERSAL CONNECTIVITY TECHNOLOGIES INC.,
`
`Patent Owner.
`
`DECLARATION OF ERIC WELCH
`
`Case No. IPR2024-01479
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`DELL/HP/LENOVO EXHIBIT 1003
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`TABLE OF CONTENTS
`
`
`I.
`Introduction ...................................................................................................... 1
`Background and Qualifications ....................................................................... 2
`II.
`III. Documents and Materials Considered ............................................................. 4
`IV. Relevant Legal Principles ................................................................................ 5
`V.
`Person of Ordinary Skill in the Art .................................................................. 9
`VI.
`’265 Patent .....................................................................................................10
`A. Overview .............................................................................................10
`B.
`Prosecution History .............................................................................20
`C.
`Summary of the Prosecution of EP12762781.8 ..................................23
`D.
`Summary of the Prosecution of JP2014502838 A ..............................26
`VII. Technology Background ................................................................................27
`VIII. Claim Construction ........................................................................................29
`IX. Summary of Opinions ....................................................................................31
`A. Overview of Iwamoto (EX1005, translation at EX1006) ...................32
`B.
`Overview of Hsieh (EX1008) .............................................................36
`C.
`Overview of Knight (EX1007) ............................................................39
`D. Overview of HDMI 1.3a (EX1010) ....................................................43
`Claims 1, 4-5, 8, 11, and 14-16 are Invalid ...................................................45
`A. Ground 1: Claims 1, 4-5, 8, 11, and 14-16 are Obvious
`Over Iwamoto ................................................................................................45
`1.
`Claim 1 ......................................................................................45
`
`X.
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`2.
`Claim 4: “The method of claim 1, further
`comprising: performing an AV data exchange between
`the first device and the second device.” ..............................................62
`3.
`Claim 5 ......................................................................................63
`4.
`Claim 8 ......................................................................................65
`5.
`Claim 11 ....................................................................................72
`6.
`Claim 14 ....................................................................................74
`7.
`Claim 15: “The system of claim 14, further
`comprising: detector logic to detect, while the
`communication logic is in the default operation mode, a
`coupling of the system to an AV device via the
`connector; and wherein the communication logic is
`further configured to perform an AV data exchange with
`the AV device in response to the detection.” ......................................75
`8.
`Claim 16: “The system of claim 15, wherein the
`detector logic is further configured to detect a change to
`the connectivity after the AV data exchange, wherein, in
`response to the detected change to the connectivity, the
`control logic further configured t place the
`communication logic into the AV sink operation mode.” ..................75
`Ground 2: Claims 1, 4-5, 8, 11, and 14-16 are Obvious
`B.
`Over Iwamoto in Combination with Hsieh ...................................................76
`1. Motivation to Combine Iwamoto and Hsieh. ...........................76
`2.
`Claims 1, 8, and 14....................................................................79
`Ground 3: Claims 1, 4-5, 8, 11, and 14-16 are Obvious
`C.
`Over Iwamoto in Combination with Knight ..................................................81
`1. Motivation to Combine Iwamoto and Knight. ..........................81
`2.
`Claims 1, 8, and 14....................................................................85
`D. Ground 4: Claims 1, 4-5, 8, 11, and 14-16 are Obvious
`Over Hsieh in Combination with Iwamoto ...................................................87
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`1. Motivation to Combine Hsieh and Iwamoto.............................87
`2.
`Claim 1 ......................................................................................89
`3.
`Claim 4: “The method of claim 1, further
`comprising: performing an AV data exchange between
`the first device and the second device.” ............................................100
`4.
`Claim 5 ....................................................................................100
`5.
`Claim 8 ....................................................................................101
`6.
`Claim 11 ..................................................................................107
`7.
`Claim 14 ..................................................................................107
`8.
`Claim 15: “The system of claim 14, further
`comprising: detector logic to detect, while the
`communication logic is in the default operation mode, a
`coupling of the system to an AV device via the
`connector; and wherein the communication logic is
`further configured to perform an AV data exchange with
`the AV device in response to the detection.” ....................................109
`9.
`Claim 16: “The system of claim 15, wherein the
`detector logic is further configured to detect a change to
`the connectivity after the AV data exchange, wherein, in
`response to the detected change to the connectivity, the
`control logic further configured t place the
`communication logic into the AV sink operation mode.” ................111
`Grounds 5-8: Claims 1, 4-5, 8, 11, and 14-16 are Obvious
`E.
`Over the References in Any of Grounds 1-4 in Further
`Combination with HDMI 1.3a .....................................................................111
`1. Motivation to Combine Iwamoto (Grounds 1-3) or
`Hsieh (Ground 4) with HDMI 1.3a ...................................................112
`2.
`Claims 1, 8, and 14..................................................................113
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`Exhibit No.
`1001
`1002
`1003
`1004
`1005
`1006
`1007
`1008
`1009
`1010
`1011
`1012
`
`1013
`1014
`
`1015
`
`1016
`
`1017
`
`1018
`
`1019
`
`1020
`
`1021
`
`1022
`
`1023
`
`TABLE OF EXHIBITS
`Description
`U.S. Patent No. 9,232,265 (the “’265 Patent”)
`Prosecution history of the ’265 Patent
`Declaration of Eric Welch
`Curriculum Vitae of Eric Welch
`JP 2009-60204 A to Iwamoto (“Iwamoto”)
`Certified English Translation of Iwamoto
`U.S. Pat. App. Pub. No. 2008/0028237 A1 to Knight (“Knight”)
`U.S. Pat. App. Pub. No. 2009/0046690 A1 to Hsieh (“Hsieh”)
`High-Definition Multimedia Interface V1.3a (HDMI 1.3a)
`Declaration of Steve Venuti regarding HDMI 1.3a
`EP2692118 B1
`Prosecution history of European Patent Application No.
`EP12762781.8 published as EP2692118 B1
`JP 2014509821 A
`Prosecution history of Japanese Patent Application No.
`JP2013502838A published as JP 2014-509821 A
`Declaration of Nathaniel Frank-White Regarding WayBack
`Machine URLs
`On-The-Go Supplement to the USB 2.0 Specification, Revision
`1.0a (June 24, 2003).
`U.S. Patent App. Pub. No. 2004/0019732 A1 to Overtoom et al.
`(“Overtoom”)
`U.S. Patent App. Pub. No. 2008/0005262 A1 to Wurzburg et al.
`(“Wurzburg”)
`U.S. Patent App. Pub. No. 2007/0255885 A1 to Bohm et al.
`(“Bohm”)
`Miguel Usach Merino, Powering ICs On and Off, available at
`https://www.analog.com/media/en/analog-dialogue/volume-
`49/number-1/articles/powering-ics-on-and-off.pdf. (“Merino”)
`U.S. Pat. App. Pub. No. 2010/0183004 A1 to Kobayashi
`(“Kobayashi”).
`U.S. Pat. App. Pub. No. 2010/0199298 A1 to Kabuto et al.
`(“Kabuto”)
`Microchip, Reset: Causes and Effects (Aug. 19, 2006), available
`at https://web.archive.org/web/20060819200514/
`https://ww1.microchip.com/downloads/en/devicedoc/reset.pdf
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`I.
`
`Introduction
`
`1. My name is Eric Welch. I have prepared this Declaration in connection
`
`with Dell Inc., Dell Technologies Inc., HP Inc., and Lenovo (United States) Inc.’s
`
`Petition for Inter Partes Review of U.S. Patent No. 9,232,265 (the “’265 Patent”)
`
`(EX1001), which is to be filed concurrently with this Declaration.
`
`2.
`
`In the course of preparing this Declaration, I reviewed the ’265 Patent,
`
`its prosecution file history, as well as the other documents discussed in this
`
`Declaration.
`
`3.
`
`I have been retained by Dell Inc., Dell Technologies Inc., HP Inc., and
`
`Lenovo (United States) Inc. (“Petitioners”) as an expert in the fields of electrical and
`
`software engineering, and product development for consumer, medical, industrial,
`
`aerospace, and other applications. I have been asked to provide my opinion
`
`regarding the state of the art of the technology described in the ’265 Patent and on
`
`the patentability of the claims of this patent. I am being compensated at my normal
`
`consulting rate for my time. My compensation is not dependent on and in no way
`
`affects the substance of my statements in this Declaration. I have no financial interest
`
`in the Petitioners, the ’265 Patent, or the owner of the ’265 Patent.
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`II. Background and Qualifications
`
`4. My professional qualifications, experience, publications, and
`
`presentations, as well as a list of previous cases in which I have provided expert
`
`testimony, are outlined in my curriculum vitae (EX1004).
`
`5.
`
`I am an expert with over 50 years of experience in the fields of electrical
`
`and software engineering, and product development for consumer, medical,
`
`industrial, aerospace, and other applications.
`
`6.
`
`From 1976 to 2007, I was Vice President of Engineering and CTO of
`
`InnoSys Incorporated and its Keyspan division. The Keyspan division developed
`
`and marketed to the retail channel several lines of computer peripheral and
`
`communications devices such as USB adapters, computer remote control devices,
`
`USB and FireWire add on cards, and related technology. I personally designed and
`
`developed core technology for the Keyspan business, resulting in an increase in sales
`
`from less than $1MM in 1997 to $13MM in 1999.
`
`7.
`
`From 2007 to the present, I have been president of Bramson Welch &
`
`Associates, Inc., an Engineering Services consultancy specializing in embedded
`
`systems, USB, Bluetooth, data communications, mobile devices, iPhone accessories,
`
`and litigation services, including data analysis and expert witness work. I serve as
`
`System Architect and Project Strategist on all Bramson Welch projects. I frequently
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`work with multiple client groups to coordinate design and architecture across many
`
`different technical and organizational domains.
`
`8.
`
`I have over twenty-five years of significant experience specifically with
`
`the development of USB peripherals, adapters, hosts, and special purpose devices.
`
`For example, I was responsible for the design and development of the Keyspan
`
`USB/serial adapter, the first working serial adapter for the Apple iMac in the mid-
`
`1990s, which is still shipping today. Also, for example, I was responsible for the
`
`design and development of Keyspan’s network-attached host adapter, a device with
`
`an ethernet network connection and four USB Host ports. In other examples, while
`
`at Keyspan and later at Bramson Welch, I was responsible for the design and
`
`development of dozens of USB peripheral devices, including class device interface
`
`(i.e., storage, HID, and communication adapters), and vendor-specific devices that
`
`do not fit any of the existing USB classes. I am also a senior member of the Institute
`
`of the Electrical and Electronics Engineers association (IEEE).
`
`9.
`
`I also have specific experience with USB entities that can function
`
`either as a USB Host or as a USB Device, including several prominent smartphone
`
`platforms, where role detection and role switching are important features.
`
`10. While many of my projects have been USB focused, I also have
`
`experience with other communication protocols, such as HDMI and Power Over
`
`Ethernet (“PoE”), among others. For example, I worked on a design study with
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`HDMI to evaluate existing USB adapter technology to assess its applicability. I have
`
`also worked on a number of smart phone USB/Ethernet adapters, including several
`
`with PoE technology.
`
`11.
`
`I have significant experience providing expert witness services in the
`
`areas of electrical and computer engineering, and in the course of this work and my
`
`own research and patenting activities, I have gained experience studying and
`
`analyzing patents and patent claims from the perspective of a person skilled in the
`
`art.
`
`12. My curriculum vitae contains further details regarding my experience,
`
`education, publications, and other qualifications which allow me to render expert
`
`opinions in connection with this proceeding.
`
`III. Documents and Materials Considered
`
`13.
`
`In forming my opinions, in addition to my knowledge, education,
`
`training, and experience, I have considered the materials cited in this Declaration
`
`and the documents and things that I have obtained, or that have been provided to me,
`
`as listed in the Table of Exhibits.
`
`14.
`
`I reserve the right to supplement or amend this Declaration if additional
`
`information that affects my opinions becomes available.
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`IV. Relevant Legal Principles
`
`15.
`
`I am not an attorney, and I offer no opinions on the law. Counsel has
`
`informed me of legal standards that apply to the issue of patent validity. I have
`
`applied these standards in arriving at my conclusions.
`
`16.
`
`I understand that in an inter partes review the petitioner has the burden
`
`of proving a proposition of unpatentability by a preponderance of the evidence. I
`
`understand this standard is different from the standard that applies in a district court,
`
`where I understand a challenger bears the burden of proving invalidity by clear and
`
`convincing evidence.
`
`17.
`
`I understand that a patent claim is invalid based on anticipation if a
`
`single prior art reference discloses all of the features of that claim in a way that
`
`enables one of ordinary skill in the art to make and use the invention. Each of the
`
`claim features may be expressly or inherently present in the prior art reference. I
`
`understand that if the prior art necessarily functions in accordance with, or includes
`
`a claim’s feature, then that prior art inherently discloses that feature.
`
`18.
`
`I understand that a patent may not be valid even though the invention
`
`is not identically disclosed or described in the prior art if the differences between the
`
`subject matter sought to be patented and the prior art are such that the subject matter
`
`as a whole would have been obvious to a person having ordinary skill in the art in
`
`the relevant subject matter at the time the invention was made.
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`19.
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`I understand that obviousness must be tested as of the time the invention
`
`was made. I understand that the test for obviousness is what the combined teachings
`
`of the prior art references would have suggested, disclosed, or taught to one of
`
`ordinary skill in the art.
`
`20.
`
`I understand that, to determine if a claim is obvious, the following
`
`factors should be considered: (1) the level of ordinary skill in the art at the time the
`
`invention was made; (2) the scope and content of the prior art; (3) the differences
`
`between the claimed invention and the prior art; and (4) secondary considerations,
`
`including evidence of commercial success, long-felt but unsolved need, unsuccessful
`
`attempts by others, copying of the claimed invention, unexpected and superior
`
`results, acceptance and praise by others, independent invention by others, and the
`
`like.
`
`21. For example, I understand that the combination of familiar elements
`
`according to known methods is likely to be obvious when it does no more than yield
`
`predictable results. I also understand that an obviousness analysis need not seek out
`
`precise teachings directed to the specific subject matter of the challenged claim
`
`because a court can take account of the inferences and/or creative steps that a person
`
`of ordinary skill in the art would employ.
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`22.
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`I understand that the following rationales may be used to determine
`
`whether a piece of prior art can be combined with other prior art or with other
`
`information within the knowledge of one of ordinary skill in the art:
`
`• Combining prior art elements according to known methods to yield
`predictable results;
`
`• Simple substitution of one known element for another to obtain predictable
`results;
`
`• Predictable use or combination of prior art elements according to their
`established functions;
`
`• Use of known techniques to improve similar devices (methods, or
`products) in the same way;
`
`• Applying a known technique to a known device (method, or product) ready
`for improvement to yield predictable results;
`
`• “Obvious to try” - choosing from a finite number of identified, predictable
`solutions, with a reasonable expectation of success;
`
`• Known work in one field of endeavor may prompt variations of it for use
`in either the same field or a different one based on design incentives or
`other market forces if the variations would have been predictable to one of
`ordinary skill in the art; or
`
`• Some teaching, suggestion, or motivation in the prior art that would have
`led one of ordinary skill to modify the prior art reference or to combine
`prior art reference teachings to arrive at the claimed invention.
`
`23.
`
`I understand that when a work is available in one field of endeavor,
`
`design incentives and/or other market forces, for example, can prompt variations of
`
`it, either in the same field or a different one. Moreover, if a person of ordinary skill
`
`can implement a predictable variation, I understand this likely bars its patentability.
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`24.
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`I understand that another factor to be considered is common sense. For
`
`example, I understand that common sense teaches that familiar items may have
`
`obvious uses beyond their primary purposes, and, in many cases, a person of
`
`ordinary skill will be able to fit the teachings of multiple patents together like pieces
`
`of a puzzle.
`
`25.
`
`I understand that the Supreme Court articulated additional guidance for
`
`obviousness in its KSR decision. My understanding is that the Supreme Court said
`
`that technical people of ordinary skill look for guidance in other solutions to
`
`problems of a similar nature, and that the obviousness inquiry must track reality, and
`
`not legal fictions. I have relied on these understandings in expressing the opinions
`
`set forth below.
`
`26.
`
`I understand that, for purposes of my analysis in this inter partes review
`
`proceeding, the terms appearing in the patent claims should be interpreted according
`
`to their “ordinary and customary meaning.” In determining the ordinary and
`
`customary meaning, the words of a claim are first given their plain meaning that
`
`those words would have had to a person of ordinary skill in the art (“POSITA”). I
`
`understand that the structure of the claims, the specification, and the file history also
`
`may be used to better construe a claim insofar as the plain meaning of the claims
`
`cannot be understood. Moreover, treatises and dictionaries may be used, albeit under
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`limited circumstances, to determine the meaning attributed by a POSITA to a claim
`
`term at the time of filing. I have followed this approach in my analysis.
`
`27.
`
`I also understand that the words of the claims should be interpreted as
`
`they would have been interpreted by a POSITA at the time the alleged invention was
`
`made (not today). I have been asked to use the priority date of March 31, 2011.
`
`V.
`
`Person of Ordinary Skill in the Art
`
`28.
`
`In order to determine the characteristics of a POSITA of the ’265
`
`Patent, I have used March 31, 2011 as the relevant time frame. My understanding is
`
`that this is the alleged earliest priority date of the application that resulted in the ’265
`
`Patent. For purposes of this Declaration, any reference to the priority date of the ’265
`
`Patent is intended to refer to this March 31, 2011 date.
`
`29.
`
`In determining the characteristics of a person of ordinary skill in the art
`
`for the ’265 Patent, I have considered the state of the art of audio/visual data
`
`communications devices and interfaces at that time, the types of problems
`
`encountered with providing for bidirectional data and power in such interfaces, and
`
`the solutions that then existed. I have also considered the then-existing technology
`
`for bidirectional communication of audio/visual data, including the sophistication of
`
`the technology involved, and the education and experience of those working in the
`
`field at that time. I have also considered my personal knowledge and experience in
`
`the field at that time, including those I worked and interacted with regarding
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`audio/visual communication systems. I have also considered the knowledge,
`
`education, and experience of those in academia and industry at that time that were
`
`working, innovating, or performing research in the field of audio/visual
`
`communications.
`
`30.
`
`It is my opinion that a POSITA for the ’265 Patent at the time of this
`
`filing date would have had a Bachelor’s degree in Electrical Engineering, Computer
`
`Engineering, or an equivalent field, and at least three years of academic or industry
`
`experience with data communications systems or interfaces, including at least some
`
`experience with serial or display data communications systems or interfaces.
`
`31. Given this background, a POSITA would have been familiar with at
`
`least the HDMI industry standard and knowledgeable about the design and operation
`
`of standardized audio/visual interfaces and systems.
`
`32. Based on my background and qualifications, I am currently and was as
`
`of the priority date of the ’265 Patent at least a POSITA in the subject matter of the
`
`’265 Patent.
`
`VI.
`
`’265 Patent
`
`A. Overview
`
`33. U.S. Patent No. 9,232,265 to Maxwell et al. is entitled “Method,
`
`Apparatus, and System for Transitioning an Audio/Video Device Between a Source
`
`Mode and a Sink Mode” and was issued on January 5, 2016.
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`34. The ’265 Patent is directed to techniques and mechanisms for
`
`controlling an audio-video (“AV”) device to operate as an AV source or an AV sink
`
`at different times. Id. at 2:21-31, 1:19-23, abstract. The ’265 Patent explains that
`
`conventional AV devices include hardware, such as a High-Definition Multimedia
`
`Interface (HDMI) connector, for coupling to another device to exchange AV
`
`information. Id. at 1:32-35. Some conventional AV devices, such as camcorders,
`
`cameras, computers, smart phones, video game consoles, DVD players, DVRs, and
`
`set-top boxes, operate as sources and send AV information to other devices via the
`
`connector. Id. at 1:32-43. The ’265 Patent further explains that other conventional
`
`AV devices, such as televisions, monitors, displays, computers, and projectors,
`
`operate as sinks to receive AV information via the connector. Id. at 1:44-45. The
`
`claimed AV device includes logic to selectively operate the device as an AV source
`
`or as an AV sink, which purports to improve upon the prior art by reducing the area
`
`taken up by multiple AV connectors, accommodating “the increasing variety of
`
`combinations of AV devices which may be coupled to one another to exchange AV
`
`information,” and preventing hardware damage caused by the connection of two AV
`
`source devices. Id. at 2:21-31, 1:50-59, 3:64-4:15.
`
`35. As illustrated in Fig. 1 below, the claimed system 100 for exchanging
`
`AV information includes a first AV device 110 with AV logic 112 to implement AV
`
`communications between first device 110 and one or more other devices, such as
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`second device 120 or third device 130. Id. at 3:23-27, Fig. 1. First AV device 110
`
`includes functionality of a conventional AV source device and/or a conventional AV
`
`sink device. Id. at 3:34-36. More particularly, first device 110 may be capable of
`
`receiving data and/or power as an AV sink or providing data and/or power as an AV
`
`source. Id. at 5:46-57. First AV device 110 may also include a connector 114 with
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`a plurality of channels which are compatible with an AV standard, such as an HDMI
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`standard. Id. at 3:43-49. The connector 114 may couple first device 110 via
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`interconnect 122 to second device 120 for an exchange of information from second
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`device 120 to first device 110, or from first device 110 to second device 120. Id. at
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`3:50-63. To that end, second device 120 may also include logic to implement both
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`AV source functionality and AV sink functionality. Id.
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`Id. at Fig. 1.
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`36. Fig. 5, reproduced below, illustrates the AV logic of the first AV device
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`in further detail. Id. at 10:29-34, Fig. 5. AV logic may include control logic 505 to
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`“receive information indicating a presence or absence of one or more characteristics
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`regarding connectivity” of the first device with a second device via HDMI connector
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`510, and “variously place communication logic 580…at different times in
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`different…operation modes,” including sink and source modes. Id. at 10:40-45,
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`10:63-11:6. AV logic may also include detection logic 520 to detect a supply voltage
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`output, a signal line termination, extended display identification data (EDID), digital
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`data functionality, a clock signal, or the like. Id. at 10:46-53. Messages from
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`detection logic 520 may indicate to control logic whether and/or how the system is
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`to transition between operating modes. Id. at 10:63-11:6. Control logic may then
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`configure a switch 530 of communication logic 580 to switch between transmit logic
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`540 for source mode operation and receive logic 550 for sink mode operation. Id. at
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`11:7-13.
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`Id. at Fig. 5.
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`37. The ’265 Patent explains that connecting two AV source devices can
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`risk damage to the devices’ transmission hardware. Id. at 3:64-4:11. For example,
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`the two AV sources may simultaneously attempt to drive power in opposite
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`directions on the power channel of the connector or may attempt to drive data signals
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`in opposite directions on the same data channel of the connector. Id. The claimed
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`invention purportedly addresses this problem by providing a control mechanism to
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`“prevent one or more aspects of AV Source functionality from being provided during
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`operation of first device 110.” Id. at 4:12-15. Specifically, the AV logic 112 may be
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`prevented from operating in AV source operation mode—in which AV logic 112 is
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`configured to provide a supply voltage, a digital data signal, or a particular amount
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`of impedance on a channel of connector 114 (id. at 4:15-26)—until “certain
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`connectivity conditions are subsequently identified” (id. at 7:57-67).
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`38.
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`In operation, the AV logic 112 selects an operation mode based on an
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`event at the first device 110—for example, a power-up event, a power-down event,
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`or a reset event. Id. at 4:27-30. The AV logic may also transition between modes
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`based on whether the device 110 detects a particular characteristic of the second
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`device 120 (or the absence thereof), which indicates whether the second device 120
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`is a source or a sink. Id. at 34-38. For example, a +5V supply voltage may indicate
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`that the second device 120 is a source in a system where the connector 114 is
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`“compatible with an interface standard which stipulates that an AV Source is to
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`provide a supply voltage to its corresponding AV Sink—e.g. the +5V output to be
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`provided from Source to Sink according to HDMI, as on pin 18 of a 19-pin HDMI
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`connector.” Id. at 4:41-46. Similarly, a clock signal may also indicate that the second
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`device 120 is a source, in a system with a connector 114 that is “compatible with an
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`interface standard which stipulates that an AV Source is to provide a clock signal to
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`an AV Sink—e.g. the DDC_SCL signal to be provided from Source to Sink
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`according to HDMI, as on pin 15 of a 19-pin HDMI connector.” Id. at 4:55-62. As
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`another example, such a characteristic may include whether a particular amount of
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`impedance is being provided by second device 120, in a system where connector
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`114 is “compatible with an interface standard which stipulates that a particular pull-
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`up impedance is to be implemented at an AV Sink—e.g. a 47 kQ pull-up resistance
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`which HDMI requires be provided at an AV Sink for a SDA line (e.g. pin 16 of a
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`19-pin HDMI connector).” Id. at 4:63-5:4.
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`39.
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`In response to a power up, power down, or reset event, the AV logic
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`112 may automatically place the device into “a default operation mode which
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`prevents the second supply voltage from being provided…at the channel of the
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`connector,” as would occur if the device were in source mode. Id. at 5:59-62, 6:25-
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`32. The default operation mode may similarly prevent a first total amount of
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`impedance for a data channel of the connector from being provided by the device,
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`as would also occur if the device were in source mode. Id. at 6:33-39. In one
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`embodiment, the default operation mode is an AV sink operation mode Id. at 6:32-
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`33, Fig. 2A.
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`40.
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`In response to detecting that a second connected device is a source (i.e.,
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`is providing power, a clock signal, or a certain level of impedance), the AV logic
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`112 may “automatically place the…AV device into some first operation mode which
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`prevents a providing of the second supply voltage,” as would occur if the first device
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`were in source mode. Id. at 6:52-7:8, Fig. 2B. This limits the possibility of circuit
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`damage due to conflicting output signals from two coupled AV devices which are
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`each attempting to operate as an AV source. Id. at 7:11-14.
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`Id. at Figs. 2A, 2B.
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`41. The device may transition between sink and source mode depending on
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`connectivity characteristics detected at the connector. Id. at 8:32-35. For example, a
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`first device may initialize to sink mode by default in response to a reset, power-on,
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`or power-off event. Id. at 8:65-67. The first device may then periodically test for
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`some indication that a second device is connected and determine whether the second
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`device is a source or sink. Id. at 9: