Obviousness

To: Lead Patent Counsel
From: Senior Patent Analyst
Date: April 30, 2026
Subject: Obviousness Analysis of U.S. Patent No. 9,766,801

1. Introduction

This memorandum provides a non-infringement and invalidity analysis of U.S. Patent No. 9,766,801 ("the '801 patent") under 35 U.S.C. § 103. The analysis is based on the prior art references cited during the patent's prosecution, as detailed in the preliminary report. A person of ordinary skill in the art (POSITA) at the time of the invention would likely have a Bachelor's degree in computer science or electrical engineering, with experience in embedded systems, mobile application development, and human-machine interface (HMI) design, particularly within the automotive or consumer electronics industry.

The core concept of the '801 patent involves a dynamic assignment of a portable terminal's functions to an in-car device's physical controls, based on information exchanged between the two devices, including control types and operational priorities. This analysis contends that the independent claims of the '801 patent would have been obvious to a POSITA in light of the combination of Srinivasan (U.S. Patent No. 8,644,809 B2) and Chae (U.S. Patent Application Pub. No. 2009/0158223 A1), with additional context provided by Vaisanen (U.S. Patent No. 8,639,228 B2).

2. Obviousness Analysis of Independent Claims

Primary Combination: Srinivasan in view of Chae

a) Rationale for Combination

A person of ordinary skill in the art, starting with the system disclosed in Srinivasan, would be motivated to improve upon it by incorporating the teachings of Chae.

Srinivasan teaches the foundational concept of the '801 patent: an in-car head unit transmits its HMI capabilities (e.g., number and type of buttons, screen size) to a connected mobile device, and the mobile device adapts its user interface and control scheme accordingly. This addresses the problem of creating a universal interface that works across different vehicles with varying control layouts.

However, Srinivasan is less explicit about the precise logic or data structure used by the mobile device to map its functions to the car's controls. A POSITA seeking to implement Srinivasan's system would look for a practical method to manage these mappings. Chae provides just such a method by disclosing a "control command table" that explicitly maps the controls of an external device (like a car stereo) to the functions of a mobile terminal.

The motivation to combine these references is strong and direct. A POSITA would see Chae's "control command table" as an obvious and logical way to implement the adaptation and control-mapping function described in Srinivasan. Combining them would result in a system where the in-car device's capabilities (per Srinivasan) are used to populate or select from a structured map (per Chae) to create a functional and context-aware remote-control interface. The '801 patent's concept of "operation assignment information" is, in essence, a more descriptive term for Chae's control command table, and using it to configure the interface described by Srinivasan would be a natural engineering step.

b) Application to Independent Claims

• Analysis of Claim 1 (In-car Information System):
  Claim 1 requires the portable terminal to have "operation assignment information" that includes "priority levels" and to use this to assign its functions to the in-car device's controls.

  • Srinivasan discloses the in-car device sending its control capabilities ("actuation information") to the portable terminal, which then adapts its operation.
  • Chae discloses the use of a "control command table" to map functions to keys. A POSITA, when implementing this table for a complex application with more functions than available keys, would find it obvious to add a "priority" field to this table. This is a standard and well-known software design practice to resolve conflicts and ensure that the most important functions (e.g., "answer call," "play/pause") are always assigned a physical control if a suitable one is available.
  • Therefore, combining Srinivasan's capability-exchange framework with Chae's mapping table, and including a priority field as a routine design choice, renders the core elements of claim 1 obvious. The terminal receives control information (Srinivasan), uses a prioritized table to assign functions (Chae + routine optimization), and then processes signals from the in-car device based on that assignment. The transmission of this mapping back to the car to display corresponding icons is also a natural extension, as taught by the general remote-UI principles in both Srinivasan and Vaisanen.

• Analysis of Claim 8 (In-car Device):
  Claim 8 describes an embodiment where the in-car device performs the assignment. It receives "operation assignment information" from the terminal and uses it to map the terminal's functions to its own controls.

  • The combination of Srinivasan and Chae teaches a system where all the necessary information for this mapping is exchanged between the two devices. Srinivasan provides the car's control information, and Chae provides the terminal's function-to-control mapping preferences (the "operation assignment information").
  • To a POSITA, the decision of whether the "assignment" logic resides on the portable terminal or the in-car device is a mere design choice, not an inventive step. It is a common practice in distributed computing to shift processing load between a host and a client device depending on their respective capabilities. A car manufacturer might prefer to house the logic in its more powerful, certified head unit for safety and consistency.
  • Therefore, it would have been obvious to a POSITA to take the system of Srinivasan and Chae and simply move the assignment-processing step from the phone to the car. In this arrangement, the phone sends its "control command table" (operation assignment information) to the car, and the car's processor performs the final mapping to its own known hardware. This directly anticipates the architecture described in Claim 8.

• Analysis of Claim 11 (Portable Terminal):
  Claim 11 is the mirror image of Claim 8, describing the portable terminal's role in the car-centric assignment architecture.

  • For the same reasons articulated for Claim 8, a POSITA would find it obvious for the portable terminal to be configured to support this architecture. The terminal would simply package its list of operations and their control preferences/priorities (as taught by Chae) and transmit this "operation assignment information" to the in-car device (as taught by the communication principles in Srinivasan). It would then simply listen for and execute the resulting "operating commands" sent back from the car. This is a straightforward implementation of the client-side of the system described in Claim 8.

3. Conclusion

The independent claims of the '801 patent describe a system that is a predictable and obvious combination of known elements in the prior art. Srinivasan ('809) teaches the foundational architecture of a car and phone exchanging HMI capabilities to enable remote control. Chae ('223) teaches the use of a mapping table to define the relationship between remote buttons and phone functions. A person of ordinary skill in the art would have been motivated to combine these teachings to create a more robust and organized system. The addition of "priority levels" is a routine and predictable design improvement for managing such a mapping system. Finally, the choice of whether to locate the final assignment logic in the phone (Claim 1) or the in-car device (Claims 8 and 11) is a well-understood engineering trade-off and does not constitute an inventive step.

Therefore, the independent claims of U.S. Patent No. 9,766,801 are likely invalid as obvious under 35 U.S.C. § 103 over the combination of Srinivasan and Chae.