PTAB

IPR2015-01730

Distributing Co LLC v. DOK Solution LLC

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Petition
petition

1. Case Identification

2. Patent Overview

  • Title: System, Method and Apparatus for Supporting and Providing Power to a Music Player
  • Brief Description: The ’667 patent discloses an audio system featuring a cradle designed to physically support and provide power to portable digital music players of various sizes. The cradle includes a cavity with internal ledges to accommodate different devices and a structure for routing a power and data cable.

3. Grounds for Unpatentability

Ground 1: Claims 1, 2, 6, 9, 11, 12, and 17 are obvious over Strauser in view of Apple iPod documentation.

  • Prior Art Relied Upon: Strauser (Application # 2008/0197050) and Apple iPod user manuals.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Strauser disclosed all key limitations of the independent claims. Strauser taught an "Adaptable digital music player cradle" for sequentially supporting multiple music players of different sizes. This cradle included a base with a cavity, a support wall, a trough for routing a data cable, and critically, a plurality of ledges of decreasing size within the cavity. These ledges were explicitly sized to hold different models of Apple iPods (e.g., 80GB, 30GB, Nano), thereby forming the claimed "decreasingly sized sub-openings." Strauser also disclosed connecting the cradled device to a computer system via a cable (such as a USB cable) that could provide power, mapping to the claimed power port and connector limitations. The computer system itself was argued to be an "audio system" for managing and transferring music.
    • Motivation to Combine: The motivation was explicit. Strauser expressly stated its cradle was designed for use with specific "Apple Corporation" iPod models. A person of ordinary skill in the art (POSITA), when designing a cradle for these specific, named products, would have been directly motivated to consult the associated product literature, such as Apple's user manuals. This documentation provided necessary details on the connectors (e.g., the 30-pin connector) and cables (e.g., the 30-pin to USB cable) used for charging and data transfer, which would be essential for properly designing the cradle's cavity and cable routing features.
    • Expectation of Success: A POSITA would have a high expectation of success in using the official documentation for a commercial product like an iPod to inform the design of a compatible accessory. This represented a routine and predictable design approach, not an inventive leap.

Ground 2: Claims 1, 2, 4, 6, 7, 9, 11, 12, and 17 are obvious over JP '125 in view of general knowledge.

  • Prior Art Relied Upon: JP ’125 (Japanese Patent Publication 10-023125) and general knowledge of a POSA.
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that JP ’125, which disclosed a "Mobile Phone Holder For Computer," taught the core elements of the claimed invention. JP ’125’s holder served as the claimed "cradle," its main body as the "base," its opening as the "cavity," and its slit for a cable as the "trough." Petitioner argued that the holder's structure, with a front opening part that was wider at the top and narrower at the bottom, inherently created ledges and "decreasingly sized sub-openings." This structure would allow a narrow phone to rest on lower ledges at the bottom of the cavity, while a wider phone would be supported by higher ledges. The computer to which the holder attaches was presented as the "audio system." The requirement of a power-passing connector was argued to be an obvious feature based on the ’667 patent’s own admission of known prior art and general knowledge of charging mobile devices.
    • Motivation to Combine/Modify: The primary motivation was to improve functionality. A POSITA would know that mobile devices, the subject of JP ’125, come in various sizes and shapes. It would have been a simple and obvious modification to adapt the JP ’125 holder to sequentially accommodate differently-sized devices to broaden its marketability. A POSITA would be motivated to use the inherent ledge structure to hold wider devices securely upright, thereby achieving the express benefit taught by JP ’125 of preventing "data communication failure" by stabilizing the device.
    • Expectation of Success: Modifying a simple mechanical holder to accommodate devices of various common sizes using steps or ledges was a well-understood and predictable design choice. A POSITA would have a high expectation of successfully implementing such a modification to achieve the desired result of a more versatile holder.

4. Key Claim Construction Positions

  • Petitioner requested the Board adopt claim constructions from a related district court litigation for the purposes of the inter partes review (IPR) only.
    • "Ledge": Petitioner proposed construing this term as "a narrow surface that sticks out from a wall."
    • "Decreasingly Sized Sub-Openings": Petitioner proposed the construction "decreasingly sized sub-openings towards a bottom of the cavity, formed by at least one step, where each sub-opening is sized corresponding to a different sized digital music player."

5. Relief Requested

  • Petitioner requested institution of an IPR and cancellation of claims 1, 2, 4, 6, 7, 9, 11, 12, and 17 of the ’667 patent as unpatentable.