PTAB

IPR2018-00273

HTC Corp v. Salazar Joe

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Key Events
Petition
petition

1. Case Identification

2. Patent Overview

  • Title: Wireless and Wired Communications, Command, Control and Sensing System for Sound and/or Data Transmission and Reception
  • Brief Description: The ’467 patent discloses a system for wireless communication with and control of external electronic devices via a handset and base station. The core purported invention is an encoding technique that stores command codes as compressed "parameter sets" to reduce the memory space required compared to storing the entire command code sets.

3. Grounds for Unpatentability

Ground 1: Obviousness over Goldstein and Keenan - Claims 1-7, 10, 17, 23, 26-32, and 34 are obvious over Goldstein in view of Keenan.

  • Prior Art Relied Upon: Goldstein (Patent 5,410,326) and Keenan (Patent 4,866,434).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Goldstein, which discloses a universal programmable remote control, teaches every element of the challenged claims except for the specific memory compression technique. Goldstein’s remote includes a microprocessor, memory for storing command codes, a touch-screen user interface, and an IR transceiver. The missing element—storing command codes as smaller "parameter sets" to save memory—is explicitly taught by Keenan. Keenan describes a universal remote that stores compressed device control codes to make efficient use of available memory space, allowing more functions to be stored.
    • Motivation to Combine: A person of ordinary skill in the art (POSITA) would be motivated to incorporate Keenan's memory-saving compression techniques into Goldstein’s universal remote. Both references address the same field of universal remote controls. Since the number of devices a universal remote can control is limited by memory, a POSITA would look to known compression methods, like those in Keenan, to solve this known problem and enhance the functionality of Goldstein's device.
    • Expectation of Success: The combination was argued to be a predictable application of a known technique (data compression) to a known device (a universal remote) to achieve a predictable result (increased storage capacity). A POSITA would have a high expectation of success in implementing this combination.

Ground 2: Obviousness over Goldstein, Keenan, and Thompson - Claim 14 is obvious over Goldstein in view of Keenan and Thompson.

  • Prior Art Relied Upon: Goldstein (Patent 5,410,326), Keenan (Patent 4,866,434), and Thompson (Patent 5,465,401).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically targets claim 14, which depends from claim 10 and adds the limitation of a "backup battery power source" in the base station. Petitioner asserted that the combination of Goldstein and Keenan renders the base system of claim 10 obvious. Goldstein’s base station (a cable converter) was argued to already disclose a battery-backed RAM. Thompson was introduced for its teaching that a power supply for a personal communication device can comprise one or more batteries.
    • Motivation to Combine: The motivation to combine Goldstein and Keenan remained the same as in Ground 1. Petitioner argued a POSITA would be further motivated to incorporate a backup battery, as suggested by Thompson, into Goldstein’s base station for the well-known and predictable benefit of preserving system memory and settings during a power interruption. This was presented as a simple and common design choice for electronic devices.
    • Expectation of Success: Integrating a battery for backup power into an electronic device was a routine and well-understood practice at the time, leading to a high expectation of success.

4. Key Claim Construction Positions

  • For the purpose of the petition, Petitioner adopted several claim constructions from a parallel district court litigation (Joe Andrew Salazar v. HTC Corporation, 2:16-cv-1096 (EDTX)). Key constructions included:
    • "base station": Construed as "a device separate from the handset that has a telephone line interface." This construction was relevant to mapping Goldstein’s cable converter to the claimed base station.
    • "memory device ... configured to store a plurality of parameter sets ... such that the memory space required ... is smaller": Construed to mean a memory device that stores parameter sets used to recreate a desired command code set, where the parameter sets occupy less memory than the full code sets. This construction was central to the argument that Keenan supplied the missing inventive concept to Goldstein.

5. Relief Requested

  • Petitioner requests the institution of an inter partes review and the cancellation of claims 1-7, 10, 14, 17, 23, 26-32, and 34 of the ’467 patent as unpatentable.