PTAB

IPR2018-01130

Lectrosonics Inc v. Zaxcom

Log In

1. Case Identification

2. Patent Overview

  • Title: System for Recording Locally Generated Audio
  • Brief Description: The ’814 patent relates to a system for recording and processing audio from wireless devices. The technology aims to solve the problem of audio "dropouts" during wireless transmission by making a local, timestamped recording of the audio, which can then be synchronized with the received transmission to replace any lost data.

3. Grounds for Unpatentability

Ground 1: Obviousness over Strub Alone - Claims 1-4, 9, 10, 12, 15, 31, 36, 37, and 41-45 are obvious over Strub.

  • Prior Art Relied Upon: Strub (Patent 6,825,875).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Strub disclosed all limitations of the challenged claims. Strub teaches a wearable recording system that captures local audio (e.g., via a microphone), stores it in memory, and transmits it. Critically, Strub’s system includes an internal clock (a “local timecode generator”) that timestamps the recorded data for later synchronization. This clock can be synchronized to an external master time reference, such as a GPS signal or a conventional SMPTE timecode input, which Petitioner asserted meets the "master timecode generator" limitation. The system also includes a control unit for managing these functions and a receiver for receiving commands and data.
    • Motivation to Combine: Not applicable as this ground relies on a single reference.
    • Expectation of Success: Not applicable as this ground relies on a single reference.
    • Key Aspects: The core of this argument was that a single prior art reference taught a complete, wearable, timestamp-synchronized local audio recording and transmission system, rendering the ’814 patent’s claims an obvious implementation of known technology.

Ground 2: Obviousness over Strub in view of Woo - Claims 1-4, 9, 10, 12, 15, 31, 36, 37, and 41-45 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: This ground presented an alternative for the "master timecode generator" limitation. Petitioner argued that if Strub’s use of a GPS signal or an external SMPTE device was deemed insufficient, Woo explicitly taught a dedicated master clock. Woo’s clock receives a GPS time signal and converts it into a conventional SMPTE-formatted timecode output specifically for synchronizing multiple audio recorders, like the wearable units in Strub. The remaining limitations were met by Strub as detailed in Ground 1.
    • Motivation to Combine: A POSITA would combine Woo’s master clock with Strub's system to achieve highly accurate, industry-standard timecode synchronization across multiple recording devices. Strub itself teaches using external SMPTE timecodes, and Woo provides a well-known, reliable method for generating them. The combination would improve Strub’s system using a standard component for its intended purpose.
    • Expectation of Success: The integration was predictable, involving connecting a standard timecode generator (Woo) to a recording system designed to accept such signals (Strub) to achieve the known benefit of improved synchronization.

Ground 3: Obviousness over Strub in view of Dwyer - Claim 45 is obvious over Strub in view of Dwyer.

  • Prior Art Relied Upon: Strub (Patent 6,825,875) and Dwyer (Patent 6,571,211).
  • Core Argument for this Ground:
    • Prior Art Mapping: This ground specifically targeted claim 45, which requires the local timestamp to be stored "in a header of said audio file." Petitioner contended that while Strub taught timestamping, it did not explicitly disclose the file format for storing this information. Dwyer was introduced to supply this teaching, as it discloses a portable audio recorder that generates header information—including a timestamp—and stores it within the audio file itself to aid file management.
    • Motivation to Combine: A POSITA would be motivated to implement Dwyer’s file structure in Strub’s system to gain the explicit benefit taught by Dwyer: improved identification and management of audio files. This was a logical and known method for organizing recorded data.
    • Expectation of Success: Applying a known data storage method (Dwyer's file header) to the timestamped data generated by Strub's system was a straightforward design choice with a high expectation of achieving predictable organizational benefits.
  • Additional Grounds: Petitioner asserted numerous additional obviousness challenges combining Strub with other references. These included combinations with Nagai (Application # 2002/0159179) and Gleissner (Application # 2004/0028241) to teach specific conventional features such as a "mike jack" or "XLR plug" as the audio input port, removable flash memory cards, and a bodypack form factor.

4. Relief Requested

  • Petitioner requests institution of an inter partes review (IPR) and cancellation of claims 1-4, 9, 10, 12, 15, 31, 36, 37, and 41-45 of the ’814 patent as unpatentable.