PTAB

IPR2014-01146

Universal Remote Control Inc v. Universal Electronics Inc

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System and Method for Activity Based Configuration of an Entertainment System
  • Brief Description: The ’207 patent describes a home entertainment system that uses a controlling device (e.g., a remote control) to configure an audio-visual (AV) receiver and multiple connected appliances. The system allows a user to select a desired "activity" (e.g., "Watch a Movie"), which then automatically configures the appropriate input source device and output destination device.

3. Grounds for Unpatentability

Ground 1: Anticipation/Obviousness over '831 Application - Claims 12-15 are anticipated by, or in the alternative obvious over, Dubil under 35 U.S.C. §§ 102 and 103.

  • Prior Art Relied Upon: Dubil (Application # 2003/0120831).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Dubil discloses every element of the challenged claims. Dubil teaches a remote control system that configures a multi-component entertainment system according to a selected "activity set." Petitioner asserted that Dubil’s system associates an "activity key" on the remote with a specific system configuration, including selecting an input source and an output destination. When a user selects an activity, Dubil's remote communicates commands to the system components to execute the configuration, and the remote automatically re-maps its own keys to control the relevant devices for that activity. The petition further mapped the limitation of downloading configurations from a computing device (claim 13) to Dubil's disclosure of updating the remote via an internet-based service.
    • Motivation to Combine (for §103 grounds): In the alternative to anticipation, Petitioner argued that any minor differences would have been obvious modifications. For instance, if Dubil was found not to explicitly disclose that a user selection signal is transmitted from the remote in response to an appliance being selected, it would be an obvious implementation detail, as the remote must communicate the user’s choice to the system.
    • Expectation of Success (for §103 grounds): Petitioner contended a person of ordinary skill in the art (POSITA) would have a high expectation of success in implementing any minor variations, as the underlying technology was well-known.

Ground 2: Obviousness over Niles in view of Dubil and/or Kozakai - Claims 12-15 are obvious over Niles in view of the '831 application and/or the '204 patent under 35 U.S.C. §103.

  • Prior Art Relied Upon: Niles (IntelliControl Reference Manual, Apr. 2002), Dubil (’831 application), and Kozakai (’204 patent).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Niles discloses a base home theater automation system with a central "Main System Unit" (MSU) and a tabletop remote that provides "one-touch" operation by pressing a "Master Key." This key triggers a pre-programmed sequence of events, including selecting video and audio inputs to configure the system. Petitioner argued that while Niles teaches the core system, Dubil and Kozakai provide the missing elements. Specifically, Dubil teaches the automatic configuration of the remote control itself based on the selected activity, and Kozakai teaches a remote that, upon a single button press (e.g., "play"), sends separate commands to both a source device (VTR) and a destination device (TV) simultaneously.
    • Motivation to Combine (for §103 grounds): A POSITA would combine Niles with Dubil to enhance the Niles system with the known and advantageous feature of automatically remapping the remote control's keys to suit the selected activity, a feature explicitly taught by Dubil. Similarly, a POSITA would look to a reference like Kozakai to implement the control of both source and destination devices from a single command key on the Niles remote, as this was a known method for simplifying user interaction in entertainment systems. The combination was presented as a predictable integration of known features to improve a base system.
    • Expectation of Success (for §103 grounds): A POSITA would have reasonably expected success in combining these known remote control and system configuration technologies, as they addressed common problems with predictable solutions.

4. Key Claim Construction Positions

  • "Device" vs. "Appliance": Petitioner argued that based on their interchangeable use within the ’207 patent’s specification, these terms should be construed to have the same meaning for the purposes of the inter partes review (IPR).
  • "Activity Key": Petitioner proposed that this term should be construed simply as any key or button on the controlling device that corresponds to a pre-defined configuration of the entertainment system, rather than requiring a specific or unique type of key.

5. Relief Requested

  • Petitioner requests institution of an IPR and cancellation of claims 12-15 of the ’207 patent as unpatentable.