PTAB

IPR2018-00972

Lectrosonics Inc v. Zaxcom Inc

1. Case Identification

2. Patent Overview

  • Title: Apparatus and Method for RF and Audio Signal Processing
  • Brief Description: The ’307 patent discloses a wireless audio system designed to solve transmission "dropout" issues. The system features a wearable local audio device that both wirelessly transmits audio to a remote recorder and simultaneously records a local copy, which can later be combined with the remote recording to correct any lost audio data.

3. Grounds for Unpatentability

Ground 1: Obviousness over Strub, Nagai, and Wood - Claims 1-11 are obvious over Strub in view of Nagai and Wood.

  • Prior Art Relied Upon: Strub (Patent 6,825,875), Nagai (Application # 2002/0159179), and Wood (WO 2004/091219).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Strub discloses the core system of a wearable recording unit that locally records audio, contains memory and a controller, and wirelessly transmits audio to a remote recorder. However, Strub does not explicitly detail certain conventional components. Nagai was cited to supply these known elements, teaching a portable audio recorder with a standard "mike jack" for an audio input port and a removable "memory card" for storage. Wood was introduced to teach the final claimed function: retrieving locally stored data to repair a deficient remote recording. Wood explicitly discloses detecting dropouts in a broadcast signal, requesting re-transmission of the lost data from a local source, and combining it to create a seamless output, directly mapping to the ’307 patent's purported novelty.
    • Motivation to Combine: A POSITA would combine Strub with Nagai to implement well-known, predictable components like standard I/O ports and memory cards to improve usability, component interchangeability, and field serviceability. A POSITA would have been motivated to incorporate Wood's established dropout correction technique into Strub’s system because Strub acknowledged that recordings could be deficient, and wireless transmission dropouts were a known problem in the art for which Wood provided a direct and effective solution.
    • Expectation of Success: Petitioner asserted that combining these elements involved the straightforward application of known technologies for their intended purposes. Integrating standard ports and memory (Nagai) into a wearable recorder (Strub) and applying a known data-repair technique (Wood) would have yielded the predictable result of a more robust and reliable wireless recording system.

Ground 2: Anticipation by Lee - Claims 1-7 and 10-14 are anticipated by Lee.

  • Prior Art Relied Upon: Lee (Application # 2006/00270465).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner contended that Lee discloses a nearly identical system anticipating most of the challenged claims. Lee teaches a wearable "Body Pack Transceiver" (BPT) worn by a performer (e.g., a law enforcement officer) that locally records audio to a memory buffer and wirelessly transmits it to a remote in-vehicle transceiver (IVT). Crucially, Petitioner argued Lee explicitly discloses the key "retrieve and combine" feature: when the BPT goes "out of range," the audio stream is automatically saved to the local memory buffer and is later transmitted to the IVT to be "seamlessly recorded with the appropriate video" once the connection is re-established. Lee's BPT was also asserted to teach the other limitations of the independent claims, including an audio input port for an optional lavaliere microphone, receivers for time and digital data, and memory.

Ground 3: Anticipation by Strub - Claims 12-14 are anticipated by Strub.

  • Prior Art Relied Upon: Strub (Patent 6,825,875).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner asserted that Strub alone discloses all steps of method claim 12. This includes locally receiving audio from a performer, transmitting it to a remote recorder, and locally recording it in a wearable device. The petition argued that Strub's primary disclosure of using timestamps for the post-event synchronization of recordings from multiple separate units inherently teaches the claimed step of retrieving local audio data and combining it with remotely recorded audio data. For dependent claim 13, Strub's use of a GPS receiver to generate timestamps was argued to provide the claimed "master time data" (hours, minutes, seconds). For dependent claim 14, Strub's system controller manipulates audio data by adding identifiers for the recording unit or performer (via biometric data), satisfying the claim's limitations.
  • Additional Grounds: Petitioner asserted additional obviousness challenges, including combinations of Strub with Gleissner (Application # 2004/0028241) to teach an alternative audio port (XLR connector), and an obviousness challenge over Lee in view of Nagai to add features like a headphone jack and removable memory card.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1-14 of the ’307 patent as unpatentable.