PTAB

IPR2014-01102

Universal Remote Control Inc v. Universal Electronics Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Remotely Upgradeable Universal Remote Control
  • Brief Description: The ’077 patent relates to a universal remote control system containing a microprocessor and non-volatile memory for storing infrared (IR) code data. The system is designed to be remotely upgradeable by allowing the code data and instructions in its memory to be updated via a connection to an external source, such as a computer.

3. Grounds for Unpatentability

Ground 1: Obviousness over Wozniak, CS-232 Manual, and Hastreiter - Claim 13 is obvious over Wozniak in view of the CS-232 Manual and Hastreiter.

  • Prior Art Relied Upon: Wozniak (Patent 4,918,439), the CS-232 Manual ("CORE Serial Interface (CS-232) Manual"), and Hastreiter (Patent 4,667,181).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Wozniak disclosed a universal remote control with all major components, including a CPU, memory, and a serial port for receiving "data" from an external source. Petitioner asserted that any ambiguity in Wozniak about whether this "data" included IR codes was resolved by the CS-232 Manual. The manual, published by the assignee of Wozniak for the same commercial product, explicitly taught using the serial interface to download and replace data in the remote’s memory, including IR codes. To meet the "input means" limitation requiring a specific keyboard circuit with diodes, Petitioner relied on Hastreiter, which disclosed the exact "uniquely designed" keyboard circuit claimed in the ’077 patent for minimizing microprocessor interconnections.
    • Motivation to Combine: A Person of Ordinary Skill in the Art (POSITA) would combine Wozniak and the CS-232 Manual because the manual was created for the commercial embodiment of the remote described in the Wozniak patent, making its teachings directly applicable for enabling the full functionality of the device. A POSITA would combine this system with Hastreiter's keyboard design to achieve the well-known and desirable goal of reducing circuit complexity and the number of electrical connections, a routine design optimization.
    • Expectation of Success: The combination involved implementing a documented interface protocol (CS-232 Manual) for its intended purpose on the corresponding hardware (Wozniak) and substituting a known, advantageous keyboard circuit (Hastreiter) for a standard one. These were all well-understood technologies, ensuring a high expectation of success.

Ground 2: Obviousness over Ciarcia and Hastreiter - Claim 13 is obvious over Ciarcia in view of Hastreiter.

  • Prior Art Relied Upon: Ciarcia ("Build a Trainable Infrared Master Controller," BYTE March 1987) and Hastreiter (Patent 4,667,181).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that the Ciarcia article provided a complete blueprint for a programmable universal remote control, teaching an "infrared Master Controller" with a microprocessor, RAM, and an RS-232 interface for connecting to an IBM PC. Ciarcia expressly taught using the interface to download "synthesis data," including IR signal data, from the PC to the remote's memory to program its functions. This combination disclosed nearly every element of claim 13. For the specific diode-based keyboard circuit recited in the "input means" limitation, Petitioner again relied on Hastreiter, arguing it taught the exact design missing from Ciarcia's keypad disclosure.
    • Motivation to Combine: A POSITA building the remote described in Ciarcia would have been motivated to incorporate the keyboard design from Hastreiter to achieve a more efficient and compact design by minimizing the interconnections between the keypad and the microprocessor. This was a common and well-understood engineering trade-off.
    • Expectation of Success: Integrating Hastreiter's keyboard circuit into the Ciarcia system represented a simple substitution of one known component for another to achieve a predictable result. A POSITA would have reasonably expected this straightforward combination of known elements to work as intended.

4. Key Claim Construction Positions

  • Petitioner argued that claim 13 includes several means-plus-function limitations that should be construed based on the structures disclosed in the ’077 patent specification.
  • "input means...": Petitioner proposed this term be construed as the structure disclosed in the specification for inputting commands, which includes a set of keys or push buttons, a keyboard circuit with diodes between row and column lines (as shown in Fig. 9B), and a CPU programmed to scan the keyboard.
  • "data coupling means...": Petitioner construed this term's function as enabling "code data for creating appropriate IR lamp driver instructions" to be supplied from an external source for direct entry into memory. The corresponding structure was identified as a terminal of a serial receiving port coupled directly to an input port of the CPU (as shown in Fig. 9B). Petitioner alternatively argued that the specification lacked sufficient corresponding structure for this function.
  • "coupling means...": This term was construed as the structure for connecting the remote to an external device, identified as a cable with a first connector for the remote's terminal and a second interface connector for a computer, modem, or television set, as depicted in Figures 20-25 of the patent.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claim 13 of Patent 5,228,077 as unpatentable.