PTAB

IPR2018-01129

Lectrosonics Inc v. Zaxcom

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1. Case Identification

2. Patent Overview

  • Title: Recording and Processing of Audio
  • Brief Description: The ’902 patent describes a system for recording audio from wireless devices, such as body packs worn by performers. The system addresses signal dropouts by creating a local, timestamped recording on the wireless device itself, which can later be synchronized with a remote recording to replace any audio data lost during wireless transmission.

3. Grounds for Unpatentability

Ground 1: Claims 7, 8, 11, 12, 14, and 15 are Anticipated or Obvious over Strub

  • Prior Art Relied Upon: Strub (Patent 6,825,875).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Strub, which discloses a system of wearable recording units for capturing audio and other data from participants in an event, teaches every element of the challenged claims. Strub’s wearable unit acquires local audio via a microphone, stores it in local memory, and wirelessly transmits it to other recording units. The unit includes a local clock (local timecode generator) for timestamping data and a receiver (e.g., a GPS receiver or SMPTE input port) for receiving a master time signal to synchronize multiple units. Petitioner asserted Strub discloses adding identifiers for the recording unit, the performer, and the specific recording track. For the method claims, Strub’s system allows for the post-event synchronization and integration of recordings from multiple units, which Petitioner mapped to the limitation of retrieving and combining local audio data with remote audio data.
    • Motivation to Combine (for §103 grounds): Not applicable for anticipation. For obviousness, Petitioner argued that any minor differences would have been obvious modifications based on Strub's own teachings and the knowledge of a POSITA.

Ground 2: Claims 7, 8, and 11 are obvious over Strub in view of Woo

  • Prior Art Relied Upon: Strub (Patent 6,825,875) and Woo (Patent 5,479,351).
  • Core Argument for this Ground:
    • Prior Art Mapping: As an alternative argument, Petitioner contended that if Strub’s time synchronization capabilities (via GPS or a direct SMPTE input) were not found to teach the claimed "master timecode generator," it would have been obvious to incorporate one as taught by Woo. Woo discloses a master clock system that receives GPS time signals and converts them into a standard SMPTE timecode format, specifically for synchronizing multiple audio and video recorders at a live performance.
    • Motivation to Combine: A POSITA would combine Woo’s master clock with Strub’s wearable recorder system to achieve more robust and standardized time synchronization across multiple devices. Woo expressly teaches that its master clock provides accurate synchronization and outputs a standard SMPTE format compatible with commercially available recording equipment, providing a clear motivation to solve the known challenge of synchronizing multiple recorders. This combination would yield the predictable result of an improved, more reliable multi-recorder system.

Ground 3: Claims 12, 14, and 15 are obvious over Strub in view of Wood

  • Prior Art Relied Upon: Strub (Patent 6,825,875) and Wood (WO 2004/091219).

  • Core Argument for this Ground:

    • Prior Art Mapping: Petitioner argued that if Strub's disclosure of post-event data integration was deemed insufficient to teach the method limitation of combining local audio with remote audio to correct for data loss, it would have been obvious to apply the dropout correction technique taught by Wood. Strub’s system of local recording and simultaneous wireless transmission creates the exact scenario where dropouts are a known problem. Wood directly addresses this problem by teaching a method to detect dropouts in a received broadcast, request a re-transmission of the lost data from a backup source, and combine the replacement data with the originally received signal to create a seamless output.
    • Motivation to Combine: A POSITA would be motivated to apply Wood's known technique to Strub's system to solve the well-known and admitted problem of wireless audio dropouts. Wood explicitly teaches that its method improves signal quality and produces a "program free of dropouts." Applying this known solution to improve the reliability of Strub's wireless system would have been a predictable and logical design choice.

  • Additional Grounds: Petitioner asserted additional obviousness challenges against claims 7, 8, and 11 based on combining Strub with Nagai (Application # 2002/0159179) or Gleissner (Application # 2004/0028241). These grounds relied on similar design modification theories, arguing Nagai and Gleissner provided well-known and conventional "audio input ports" (e.g., a "mike jack" or an "XLR plug connector") that a POSITA would have been motivated to add to Strub’s device for customization and microphone interchangeability.

4. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 7, 8, 11, 12, 14, and 15 of the ’902 patent as unpatentable.