Case 6:20-cv-01001-ADA Document 1 Filed 10/28/20 Page 1 of 31
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`
`MicroPairing Technologies LLC,
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` Plaintiff,
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`v.
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`Toyota Motor Manufacturing Texas, Inc.,
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` Defendant.
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`
`
`
`
`
`
`
`
`
`
`Civil Action No. 6:20-cv-1001
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`Jury Trial Demanded
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`COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff MicroPairing Technologies LLC files this Complaint against Toyota Motor
`
`
`
`
`
`
`
`
`Manufacturing Texas, Inc. for infringement of U.S. Patent Nos. 6,629,033 (“the ’033 patent”),
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`6,778,073 (“the ’073 patent”), 7,793,136 (“the ’136 patent”), 8,380,383 (“the ’383 patent”),
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`8,953,816 (“the ’816 patent”), 9,697,015 (“the ’015 patent”), and 8,583,292 (“the ’292 patent”).
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`The ’033 patent, ’073 patent, ’136 patent, ’383 patent, ’816 patent, ’015 patent, and ’292 patent
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`are referred to collectively as the “patents-in-suit.”
`
`THE PARTIES
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`1.
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`Plaintiff MicroPairing Technologies LLC (“MicroPairing”) is a Texas limited
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`liability company located in Plano, Texas.
`
`2.
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`Defendant Toyota Motor Manufacturing Texas, Inc. (“Toyota Texas”) is a Texas
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`corporation with a regular and established place of business at 1 Lone Star Pass, San Antonio,
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`Texas 78624. Toyota may be served with process through its registered agent, CT Corporation
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`System, 1999 Bryan Street, Suite 900, Dallas, Texas 75201.
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`3.
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`Toyota Texas employs approximately 2,600 workers at its San Antonio
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`manufacturing facility, where it manufactures the Toyota Tundra and Toyota Tacoma pickup
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`trucks. Toyota Texas states that the “San Antonio plant is also our first plant to integrate
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`production facilities for many of our suppliers on the same grounds, and some under the same
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`roof. It’s truly state-of-the-art.” See https://www.toyota.com/usa/operations/map.html#!/tmmtx.
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`It also touts itself as “the home of the Toyota Tundra and Tacoma pickup trucks – built in the
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`Southside of San Antonio!” On information and belief, each Toyota Tundra and Tacoma is
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`manufactured with an infotainment system. Toyota Texas infringes one or more of the patents-
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`in-suit whenever it makes, uses, sells, or offers to sell a Tundra or Tacoma with such a system.
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`JURISDICTION AND VENUE
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`4.
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`This action arises under the patent laws of the United States, 35 U.S.C. § 101, et
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`seq. This Court’s jurisdiction over this action is proper under the above statutes, including 35
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`U.S.C. § 271, et seq., 28 U.S.C. § 1331 (federal question jurisdiction), and 28 U.S.C. § 1338
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`(jurisdiction over patent actions).
`
`5.
`
`This Court has personal jurisdiction over Toyota Texas in accordance with due
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`process and/or the Texas Long Arm Statute because, among other things, Toyota Texas is a
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`Texas corporation with a physical location in Texas.
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`6.
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`This Court also has personal jurisdiction over Toyota Texas in accordance with
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`due process and/or the Texas Long Arm Statute because Toyota Texas does business in this state
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`by, among other things, “recruit[ing] Texas residents, directly or through an intermediary located
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`in this state, for employment inside or outside this state.” TEX. CIV. PRAC. & REM. CODE §
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`17.042(3):
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`2
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`Case 6:20-cv-01001-ADA Document 1 Filed 10/28/20 Page 3 of 31
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`See, e.g., https://tmm.taleo.net/careersection/10020/jobsearch.ftl?lang=en#.
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`7.
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`Further, this Court has personal jurisdiction over Toyota Texas because it has
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`engaged, and continues to engage, in continuous, systematic, and substantial activities within this
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`state, including the substantial marketing and sale of products and services within this state and
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`this District. Indeed, this Court has personal jurisdiction over Toyota Texas because it has
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`committed acts giving rise to MicroPairing’s claims for patent infringement within and directed
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`to this District, has derived substantial revenue from its goods and services provided to
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`individuals in this state and this District, and maintains a regular and established place of
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`business in this District, including its facilities in San Antonio, Texas.
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`8.
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`Relative to patent infringement, Toyota Texas has committed and continues to
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`commit acts in violation of 35 U.S.C. § 271, and has made, used, marketed, distributed, offered
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`for sale, and/or sold infringing products and services in this state, including in this District, and
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`otherwise engaged in infringing conduct within and directed at, or from, this District. Such
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`infringing products and services, namely Toyota Tundra and Tacoma vehicles with infotainment
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`3
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`systems, have been and continue to be distributed to, sold, and used in this District and the
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`infringing conduct has caused, and continues to cause, injury to MicroPairing, including injury
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`suffered within this District. These are purposeful acts and transactions in this state and this
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`District such that Toyota Texas reasonably should know and expect that it can be haled into this
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`Court because of such activities.
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`9.
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`Venue is proper in this District under 28 U.S.C. §§ 1391 and 1400(b) because a
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`substantial part of the events or omissions giving rise to the MicroPairing claims occurred in this
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`District. This includes extensive commission of acts of infringement in this District. Toyota
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`Texas also has a regular and established place of business in this District in the form of, at least,
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`its San Antonio-based manufacturing plant and related facilities. Indeed, Toyota Texas conducts
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`business in this District, including making and servicing infringing vehicles for, and offering to
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`sell, selling, and distributing infringing vehicles and related services to, Toyota Texas customers
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`in this District.
`
`THE PATENTS-IN-SUIT
`
`10.
`
`The ’033 patent is entitled, “Open Communication System for Real-Time
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`Multiprocessor Applications.” The ’033 patent lawfully issued on September 30, 2003 and
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`stems from U.S. Patent Application No. 09/841,753, which was filed on April 24, 2001. A copy
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`of the ’033 patent is attached hereto as Ex. 1.
`
`11.
`
`The ’073 patent is entitled, “Method and Apparatus for Managing Audio
`
`Devices.” The ’073 patent lawfully issued on August 17, 2004 and stems from U.S. Patent
`
`Application No. 09/892,295, which was filed on June 26, 2001. A copy of the ’073 patent is
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`attached hereto as Ex. 2.
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`4
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`12.
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`The ’136 patent is entitled, “Application Management System with Configurable
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`Software Applications.” The ’136 patent lawfully issued on September 7, 2010 and stems from
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`U.S. Patent Application No. 11/616,650, which was filed on December 27, 2006. A copy of the
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`’136 patent is attached hereto as Ex. 3.
`
`13.
`
`The ’383 patent is entitled, “Distributed vehicle control system.” The ’383 patent
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`lawfully issued on February 19, 2013 and stems from U.S. Patent Application No. 13/447,793,
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`which was filed on April 16, 2012. A copy of the ’383 patent is attached hereto as Ex. 4.
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`14.
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`The ’816 patent is entitled, “Method and Apparatus to Dynamically Configure a
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`Vehicle Audio System.” The ’816 patent lawfully issued on February 10, 2015 and stems from
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`U.S. Patent Application No. 13/196,654, which was filed on August 2, 2011. A copy of the ’816
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`patent is attached hereto as Ex. 5.
`
`15.
`
`The ’015 patent is entitled, “Vehicle Audio Application Management System
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`Using Logic Circuitry.” The ’015 patent lawfully issued on July 4, 2017 and stems from U.S.
`
`Patent Application No. 13/253,284, which was filed on October 5, 2001. A copy of the ’015
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`patent is attached hereto as Ex. 6.
`
`16.
`
`The ’292 patent is entitled, “System and method for restricting access to vehicle
`
`software systems.” The ’292 patent lawfully issued on November 12, 2013 and stems from U.S.
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`Patent Application No. 12/775,991, which was filed on May 7, 2010. A copy of the ’292 patent
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`is attached hereto as Ex. 7.
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`17. MicroPairing is the owner of the patents-in-suit with all substantial rights,
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`including the exclusive right to enforce, sue, and recover damages for past and future
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`infringements.
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`5
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`18.
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`The claims of the patents-in-suit are directed to patent eligible subject matter
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`under 35 U.S.C. § 101. They are not directed to an abstract idea, and the technologies covered
`
`by the claims comprise vehicle systems and/or consist of ordered combinations of features and
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`functions that, at the time of invention, were not, alone or in combination, well-understood,
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`routine, or conventional.
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`19.
`
`The specifications of the patents-in-suit disclose shortcomings in the prior art and
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`then explain, in detail, the technical way the claimed inventions resolve or overcome those
`
`shortcomings. For example, the ’033 patent explains that while “[c]ars include many different
`
`electro-mechanical and electronic systems . . . the processors that control these different car
`
`systems do not talk to each other.” Ex. 1 at 1:5-21. “This means that each one of these car
`
`systems has to provide a separate standalone operating system. . . . [and] [m]any of these
`
`different car processors may be underutilized since they are only used intermittently.” Id. To
`
`solve this problem, the ’033 patent discloses an invention where:
`
`multiple processors each run an Open Communication system that controls how
`data is transferred between processors based on data content as opposed to the
`links that connect the processors together. The open communication system enables
`data or messages to be effectively transferred and processed for real-time
`applications or other server based applications that may be running on the multiple
`processors in a secure environment regardless of processors, locations, or data
`links.
`
`Id. at 1:54-64 (emphasis added).
`
`20.
`
`Such a solution is embodied, for example, in claim 1 of the ’033 patent:
`
`A method for communicating between different software applications in a same
`mobile vehicle, comprising:
`
`individual communication managers with
`associating
`applications in the mobile vehicle;
`
`
`individual software
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`Case 6:20-cv-01001-ADA Document 1 Filed 10/28/20 Page 7 of 31
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`receiving messages at the different individual software applications in the mobile
`vehicle and generating messages from the different individual software applications
`in the mobile vehicle;
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`passing the received messages through the individual communication managers
`associated with different individual software applications receiving the messages
`before processing the messages with the different software applications receiving
`the messages in the mobile vehicle and passing the generated messages through
`the individual communication managers associated with the different individual
`software applications before sending the generated messages to other software
`the mobile vehicle,
`the communication managers each
`applications
`in
`independently attaching message labels to individual messages that individually
`identify different priority values for the individual messages; and
`
`performing different real-time mobile vehicle applications in the mobile vehicle
`according to the message labels.
`
`
`Id. at claim 1 (emphasis added). The differing priority values given to the respective message
`
`processed by given differing software applications thus allow all messages from all different
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`systems to be processed according to data content based on the message priority. This invention
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`thus creates an “open communication system [that] enables data or messages to be effectively
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`transferred and processed for real-time applications or other server based applications that may
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`be running on the multiple processors in a secure environment regardless of processors,
`
`locations, or data links.” Id. (emphasis added).
`
`21.
`
`The specification of the ’073 patent also discloses shortcomings in the prior art
`
`and then explains, in detail, the technical way the claimed inventions resolve or overcome those
`
`shortcomings. For example, the ’073 patent explains that car audio systems had a number of
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`issues, including that (1) “[a]ny other portable audio sources brought into the car cannot use the
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`car speakers or amplifier system;” (2) “in-dash audio devices or portable audio devices brought
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`into the car [] can disrupt the attention of the car driver;” and (3) “[o]ther types of audio devices,
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`such as cellular telephones, are difficult to operate and hear while driving in a car.” Ex. 2 at 1:5-
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`28. To solve these problems, the ’073 patent discloses the following invention:
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`7
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`A vehicle audio system includes a wireless audio sensor configured to wirelessly
`detect different portable audio sources brought into the vehicle. Audio output
`devices are located in the vehicle for outputting audio signals from the different
`audio sources. A processor selectively connects the different audio sources to the
`different audio output devices.
`
`
`Id. at 2:31-36.
`
`
`22.
`
`The ’073 patent specification goes on to describe an “audio manager 14 [that]
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`detects and communicates with the different wireless audio sources using any one of a variety of
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`wireless communication protocols, such as Bluetooth or IEEE 802.11.” Id. at 2:39-42. This
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`audio manager also “detect[s] different portable audio output devices and any audio output
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`devices contained in the audio output device.” Id. at 2:53-60. The audio manager further
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`“displays the different audio output devices on GUI 30.” Id. at 2:61-62. “The audio manager 14
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`in block 42 monitors the area around and inside the vehicle 12 for any audio sources or audio
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`output devices that may be transmitting a wireless signal. Any detected audio sources or audio
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`output devices are displayed on the GUI 30 in block 44. The data manager in block 46 then
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`determines what applications are associated with the different audio sources.” Id. at 3:25-36. To
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`decide which applications to output to audio,
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`The data manager 14 in block 50 identifies any priorities and security values
`associated with the identified audio applications. In block 52, the data manager 14
`identifies requests to output different ones of the audio sources to different ones of
`the audio output devices. The selected audio application may have a higher priority
`than the audio application that is currently connected to the selected audio output
`device. If the priority of the requesting audio application is the same or higher than
`the currently connected audio application, then the audio manager 14 in block 56
`replaces the audio application currently coupled to the audio output device with the
`selected audio application. If the requesting audio application has a lower priority
`than the audio application currently coupled to the audio output device, then the
`audio manager in block 54 will not connect the new audio application.
`
`
`Id. at 3:25-36.
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`23.
`
`Solutions to the problems outlined in the ’073 patent are, for example, embodied
`
`in claim 10:
`
`A vehicle audio system, comprising:
`
` a
`
` wireless audio sensor configured to wirelessly detect different audio sources
`brought into or next to a vehicle;
`
`wireless audio output devices for outputting audio data having assigned priority
`values; and
`
` a
`
` processor for selectively connecting the different audio sources to the audio
`output devices according to the assigned priority values for the audio data.
`
`
`Id. at claim 10. The wireless audio sources are connected selectively to differing audio output
`
`devices according to the assigned priority values for the audio data. A wireless audio sensor
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`detects the different sources brought into the vehicle, and a processor connects these sources to
`
`the output devices. This claim solves the issues of (1) other portable audio sources not being
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`able to use the car speakers; (2) audio devices potentially distracting the driver; and (3) other
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`types of audio devices being difficult to hear and operate while driving a car.
`
`24.
`
`The specification of the ’136 patent also discloses shortcomings in the prior art
`
`and then explains, in detail, the technical way the claimed inventions resolve or overcome those
`
`shortcomings. The specification of the ’136 patent discusses Java virtual machines (JVMs),
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`which make “it possible for Java application programs to be built that can run on any platform
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`without having to be rewritten or recompiled by the programmer for each separate platform.”
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`Ex. 3 at 1:27-34. The specification also describes the Jini system, which “extends the Java
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`application environment from a single virtual machine to a network of machines. . . . The Jini
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`infrastructure provides mechanisms for devices, services, and users to join and detach from a
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`network. Jini systems are more dynamic than is currently possible in networked groups where
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`configuring a network is a centralized function done by hand.” Id. at 1:34-47.
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`25.
`
`“However, the Java/Jini approach is not without its disadvantages. Both Java and
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`Jini are free, open source applications. The Java application environment is not designed for
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`controlling messaging between different machines.” Id. at 1:48-58. “For example, the Java
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`application is not concerned about the protocols between different hardware platforms. Jini has
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`some built-in security that allows code to be downloaded and run from different machines in
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`confidence. However, this limited security is insufficient for environments where it is necessary
`
`to further restrict code sharing or operation sharing among selected devices in a secure embedded
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`system.” Id.
`
`26.
`
`To solve these problems, the ’136 patent proposes a “Secure Real-time Executive
`
`(SRE) 14 [which] provides an extension to the JVM 16 and allows Java to run on different
`
`processors for real-time applications. The SRE 20 manages messaging, security, critical data,
`
`file I/O multiprocessor task control and watchdog tasks in the Java environment as described
`
`below.” Id. at 2:35-43. “For example, the SRE 14 may prevent noncritical vehicle applications,
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`such as audio control, from being loaded onto processor 16.” Id. at 2:66-3:6.
`
`27.
`
`The advantages of the invention of the ’136 patent are taught as follows:
`
`The SRE 14 allows any variety of real-time, mission critical, nonreal-time and
`nonmission critical Java applications to be loaded onto the multiprocessor system
`15. The SRE 14 then automatically manages the different types of applications and
`messages to ensure that the critical vehicle applications are not corrupted and
`processed with the necessary priority. The SRE 14 is secure software that cannot
`be manipulated by other Java applications.
`
`The SRE 14 provides priority preemption on a message scale across the entire
`system 15 and priority preemption on a task scale across the entire system 15. So
`the SRE 14 controls how the JVMs 10 talk to each other and controls how the JVMs
`10 are started or initiated to perform tasks. The SRE 14 allows programmers to
`write applications using Java in a safe and secure real time environment. Thus,
`viruses can be prevented by SRE 14 from infiltrating the system 15.
`
`Id. at 3:15-30.
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`28.
`
`An important aspect of the invention of the ’136 patent is the message manager:
`
`The message manager 50 determines the priority of sent and received messages. If
`the data transmitted and received by the sensor fusion thread 76 is higher priority
`than other data transmitted and received on the processor 84, then the sensor fusion
`data will be given priority over the other data. The task manager 58 controls the
`priority that the sensor fusion thread 76 is giving by processor 84. If the sensor
`fusion thread 76 has higher priority than, for example, an audio application that is
`also being run by processor 84, then the sensor fusion thread 76 will be performed
`before the audio application.
`
`Id. at 4:60-5:3.
`
`29.
`
`Solutions to the problems outlined by the ’136 patent are embodied in, for example,
`
`claim 31:
`
`An apparatus, comprising:
`
` a
`
` multiprocessor system configured to:
`
`
`identify a new device that is not currently coupled to the multiprocessor system;
`
`detect a communication protocol used by the new device and connect the new
`device to the multiprocessor system when signaling from the new device conforms
`to a communication protocol used in the multiprocessor system;
`
`configure the new device into the multiprocessor system when a data protocol
`operated by the new device conforms with a data protocol used in the
`multiprocessor system;
`
`display an image representing the new device on a graphical interface;
`
`identify data codes in the signaling from the new device identifying an application
`running on the new device, a data type used on the new device, and a security level
`associated with data stored in the new device;
`
`use the identified security level to prevent unauthorized data from being loaded into
`the multiprocessor system;
`
`identify a stored application in memory in the multiprocessor system that uses the
`same data type used on the new device and download the stored application from
`memory into a processor in the multiprocessor system;
`
`display an image on the graphical user interface representing the stored application
`loaded into the processor in the multiprocessor system; and
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`use the stored application to direct data exchanged with the portable device to a
`selectable output or a selectable input identified on the graphical interface.
`
`
`Id. at claim 31.
`
`
`30.
`
`The specification of the ’383 patent also discloses shortcomings in the prior art
`
`and then explains, in detail, the technical way the claimed inventions resolve or overcome those
`
`shortcomings. The specification of the ’383 patent explains, for instance, that “[c]ars include
`
`many different electro-mechanical and electronic systems … the processors that control these
`
`different car systems do not talk to each other.” Ex. 4 at 2:55-3:3. “This means that each one of
`
`these car systems has to provide a separate standalone operating system … [and] [m]any of these
`
`different car processors may be underutilized since they are only used intermittently.” Id. To
`
`solve this problem, the ’383 patent discloses an invention comprising:
`
`A multiprocessor system used in a car, home, or office environment includes
`multiple processors that run different real-time applications. A dynamic
`configuration system runs on the multiple processors and includes a device
`manager, configuration manager, and data manager. The device manager
`automatically detects and adds new devices to the multiprocessor system, and the
`configuration manager automatically reconfigures which processors run the real-
`time applications. The data manager identifies the type of data generated by the
`new devices and identifies which devices in the multiprocessor system are able to
`process the data.
`
` A
`
` communication system for a mobile vehicle, home, or office environment
`includes multiple processors. The multiple processors each run an Open
`Communication system that controls how data is transferred between processors
`based on data content as opposed to the links that connect the processors together.
`The open communication system enables data or messages to be effectively
`transferred and processed for real-time applications or other server based
`applications that may be running on the multiple processors in a secure environment
`regardless of processors, locations, or data links.
`
`31.
`
`Such a solution is embodied, for example, in claim 1 of the ’383 patent:
`
`A distributed vehicle control system, comprising:
`
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`Id. at 4:13-34.
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`multiple processors in a distributed multi-processor system;
`
` a
`
` secure real-time executive (SRE) operating in the distributed multi-processor
`system, wherein the SRE operates on each processor independently and wherein
`each independently operating SRE comprises a message manager associated with
`an application running on each of the processors and configured to associate
`priority values with messages transmitted by the applications and to control the
`processing sequence of messages received by applications according to a
`predetermined priority scheme;
`
` a
`
` first processor in the distributed processing system running a first application,
`wherein the first processor receives a first message from the first application and
`associates a first priority value with the first message;
`
` a
`
` second processor in the distributed processing system running a second
`application, wherein the SRE running on the second processor receives a second
`message from the second application and associates a second priority value with
`the second message;
`
` a
`
` third processor in the distributed processing system running a third application,
`wherein the SRE running on the third processor receives the first message and
`associated first priority from the first processor and receives the second message
`and associated second priority from the second processor and responsive to
`receiving the priority associated messages, determines the sequence in which the
`third application handles the priority associated messages using the predetermined
`priority scheme.
`
`Id. at claim 1.
`
`32.
`
`The specification of the ’816 patent also discloses shortcomings in the prior art
`
`and then explains, in detail, the technical way the claimed inventions resolve or overcome those
`
`shortcomings. The specification of the ’816 patent discusses how “[c]ars include many different
`
`electro-mechanical and electronic applications. . . . [But] [g]enerally the processors that control
`
`these different car systems do not talk to each other.” Ex. 5 at 1:17-32. “For example, separate
`
`processors and separate user interfaces are required for the car temperature control system and
`
`for the car audio system. Many of these different car processors may be underutilized since they
`
`are only used intermittently.” Id. And “[e]ven when multiple processors in the car do talk to
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`each other, they are usually so tightly coupled together that it is impossible to change any one of
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`these processors without disrupting all of the systems that are linked together.” Id. at 1:33-41.
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`Furthermore, “[i]ntegration of new systems into a car is also limited. Car systems are designed
`
`and selected well before the car ever built. . . . Because after market devices cannot be integrated
`
`into car control and interface systems, it is often difficult for the driver to try and operate these
`
`after market devices.” Id. at 1:42-49.
`
`33.
`
`To solve these problems, the ’816 patent teaches:
`
`A multiprocessor system used in a car, home, or office environment includes
`multiple processors that run different real-time applications. A dynamic
`configuration system runs on the multiple processors and includes a device
`manager, configuration manager, and data manager. The device manager
`automatically detects and adds new devices to the multiprocessor system, and the
`configuration manager automatically reconfigures which processors run the real-
`time applications. The data manager identifies the type of data generated by the
`new devices and identifies which devices in the multiprocessor system are able to
`process the data.
`
`
`Id. at 1:65-2:8.
`
`
`34.
`
`The specification of the ’816 patent describes an embodiment of the invention as
`
`follows:
`
`FIGS. 5 and 6 show how a new device is added to the multiprocessor system 8.
`Each of the existing processors A, B, C, and D after power-up are configured to
`identify a set or subset of the processors in the multiprocessor system 8. A new
`device 72 is brought into the multiprocessor system 8 either via a hardwired link or
`a wireless link. For example, the device E may send out signals over any one or
`more of a 802.11 wireless link 67, Blue tooth wireless link 71 or send out signals
`over a hardwired Ethernet link 69. Depending on what communication protocol is
`used to send signals, one or more of the processors A, B, C or D using a similar
`communication protocol detect the processor E in block 74 (FIG. 6). All of the
`processors may be connected to the same fiber optic or packet switched network
`that is then used to communicate the information from processor E to the other
`processors.
`
`One of the device managers 46 in the multiprocessor system 8 checks the signals
`from processor E checks to determine if the signals are encrypted in a recognizable
`protocol in block 76. The device manager in the processor receiving the signals
`
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`Case 6:20-cv-01001-ADA Document 1 Filed 10/28/20 Page 15 of 31
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`from processor E then checks for any data codes from the new device signals in
`block 76. The data codes identify data types used in one or more applications by
`processor E. A device ID for processor E is then determined from the output signals
`in block 80.
`
`If all these data parameters are verified, the device managers 46 in one or more of
`the processors A, B, C and D add the new processor E to their processor arrays in
`block 82. For example, processor A adds processor E to the processor array in
`memory 65. After being incorporated into the multiprocessor system 8, the
`processor E or the applications running on the processor E may be displayed on a
`graphical user interface in block 84.
`
`
`Id. at 4:51-5:7.
`
`
`35.
`
`Solutions to the problems outlined by the ’816 patent are embodied, for example,
`
`in claim 1:
`
`A method of operating a vehicle audio system having a wired audio source, a
`display, multiple speakers and a logic circuit configured to:
`
`sense the availability of a wireless audio device that is located within or proximate
`to the vehicle;
`
`identify a wireless audio device record from among a plurality of different wireless
`audio device records previously identified and stored in memory, wherein the
`wireless device record includes previously identified data codes from the wireless
`audio device and from a first software application running on the wireless audio
`device;
`
`responsive to identifying the data codes and first software application running on
`the wireless audio device from the stored record, download a copy of a second
`software application selected from the memory and process data from the wireless
`audio device with the second software application;
`
`provide a user with an option to direct sound from the wireless audio device through
`at least a first one of the speakers of the vehicle audio system or back to a speaker
`in the wireless audio device.
`
`
`Id. at claim 1.
`
`
`36.
`
`The specification of the ’015 patent also discloses shortcomings in the prior art
`
`and then explains, in detail, the technical way the claimed inventions resolve or overcome those
`
`15
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`Case 6:20-cv-01001-ADA Document 1 Filed 10/28/20 Page 16 of 31
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`shortcomings. The ’015 patent identifies the same problems as the ’816 patent specification.
`
`See Ex. 6 at 2:56-3:31.
`
`37.
`
`To solve these problems, the ’015 patent teaches:
`
`A multiprocessor system used in a car, home, or office environment includes
`multiple processors that run different real-time applications. A dynamic
`configuration system runs on the multiple processors and includes a device
`manager, configuration manager, and data manager. The device manager
`automatically detects and adds new devices to the multiprocessor system, and the
`configuration manager automatically reconfigures which processors run the real-
`time applications. The data manager identifies the type of data generated by the
`new devices and identifies which devices in the multiprocessor system are able to
`process the data.
`
`
`Ex. 6 at 4:14-26.
`
`
`38.
`
`The specificatio