IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`In re U.S. Patent No. 6,670,905
`Filed:
`June 14, 2000
`Issued:
`December 30, 2003
`Inventor: Steven K. Orr FILED ELECTRONICALLY
`
`
`
`
`
`
`
` PER 37 C.F.R. § 42.6(b)
`Assignee: Escort Inc.
`Title:
`Radar Warning Receiver With Position and Velocity Sensitive
`Functions
`
`
`
`Mail Stop PATENT BOARD, PTAB (37 C.F.R. § 42.6(b)(2))
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`Declaration of Dr. Chris Bartone, P.E.
`I, Chris Bartone, declare as follows:
`
`I. QUALIFICATIONS
`
`1.
`
` I earned a bachelor of science degree in electrical engineering
`
`from The Pennsylvania State University in 1983 with an emphasis and
`
`electromagnetics, communications, and antennas. I also earned a Masters in
`
`electrical engineering from The Naval Postgraduate School in 1987 with a
`
`Page 1 of 66
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`K-40 Electronics, LLC Exhibit 1007, page 1
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`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`In re U.S. Patent No. 6,670,905
`Filed:
`June 14, 2000
`Issued:
`December 30, 2003
`Inventor: Steven K. Orr FILED ELECTRONICALLY
`
`
`
`
`
`
`
` PER 37 C.F.R. § 42.6(b)
`Assignee: Escort Inc.
`Title:
`Radar Warning Receiver With Position and Velocity Sensitive
`Functions
`
`
`
`Mail Stop PATENT BOARD, PTAB (37 C.F.R. § 42.6(b)(2))
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`Declaration of Dr. Chris Bartone, P.E.
`I, Chris Bartone, declare as follows:
`
`I. QUALIFICATIONS
`
`1.
`
` I earned a bachelor of science degree in electrical engineering
`
`from The Pennsylvania State University in 1983 with an emphasis and
`
`electromagnetics, communications, and antennas. I also earned a Masters in
`
`electrical engineering from The Naval Postgraduate School in 1987 with a
`
`Page 1 of 66
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`K-40 Electronics, LLC Exhibit 1007, page 1
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`specialization in communications engineering. I also earned a doctoral
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`degree in electrical engineering from Ohio University in 1998.
`
`2.
`
`I have over 29 years of experience with communication,
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`navigation and surveillance systems.
`
`3.
`
` I am currently a professor in the School of Electrical
`
`Engineering and Computer Science at Ohio University. I have taught
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`undergraduate and graduate courses in radar and GPS.
`
`4.
`
` A listing of my publications and research is included in my
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`curriculum vitae, a copy of which is attached as Appendix A.
`
`I. My Status as an Independent Declarant
`
`5.
`
`I have been retained in this matter by K40 Electronics LLC.
`
`(“Petitioner”) to provide an analysis of the scope and content of two prior art
`
`references that existed prior to the earliest patent application underlying U.S.
`
`Patent No. 6,670,905 (“the ‘905 patent”). In particular, I analyzed whether
`
`certain elements of the claims of the ‘905 patent are described in the two
`
`prior art references.
`
`6.
`
`I am being compensated for my work. My fee is not contingent
`
`on the outcome of any matter or on any of the technical positions I explain in
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`this declaration. I have no financial interest in Petitioner.
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`Page 2 of 66
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`K-40 Electronics, LLC Exhibit 1007, page 2
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`7.
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`I have been informed that Escort Inc., (hereinafter referred to as
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`“Patentee”) owns the ‘905 patent. I have no financial interest in the Patentee
`
`or the ‘905 patent.
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`II. Description of the Relevant Field and the Relevant Timeframe
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`I have carefully reviewed the ‘905 patent.
`
`I have carefully reviewed U.S. Patent No. 6,252,544 to
`
`8.
`
`9.
`
`Hoffberg.
`
`10.
`
`I have carefully reviewed U.S. Patent No. 6,204,798 to
`
`Fleming.
`
`11. Based on my review of these materials, I believe that the
`
`relevant field for purposes of the ‘905 patent is police radar detection
`
`devices. I have been informed that the relevant timeframe is prior to June
`
`14, 1999.
`
`12. As described in Section I above, I have extensive experience in
`
`both radar systems and GPS receivers. Based on my experience, I have a
`
`good understanding of the relevant field in the relevant timeframe.
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`
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`III. The Person of Ordinary Skill in the Relevant Field in the Relevant
`Timeframe
`
`
`
`13.
`
`I have been informed that “a person of ordinary skill in the
`
`relevant field” is a hypothetical person to whom an expert in the relevant
`
`field could assign a routine task with reasonable confidence that the task
`
`would be successfully carried out. I have been informed that the level of
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`skill in the art is evidenced by the prior art references.
`
`14. The prior art discussed herein demonstrates that a person of
`
`ordinary skill in the art, before June 14, 1999, was aware of a device that
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`included a radar detector, a laser detector, GPS receiver, a central processor,
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`memory, and a user interface that included a map. This prior art device
`
`would suppress or modify warnings to incoming radar signals by correlating
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`the incoming radar signals with false alarm information stored in memory.
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`15. The prior art also demonstrates that a person of ordinary skill in
`
`the art was aware of a police radar detector that included a GPS receiver, a
`
`processor, memory, and an alert circuit. The radar detector would compare
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`the location, frequency, and signal strength of incoming radar signals to false
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`alarm information stored in the radar detector’s memory to determine
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`whether to generate, suppress, or modify an alert to the incoming radar
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`signal.
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`K-40 Electronics, LLC Exhibit 1007, page 4
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`16. Based on my experience, I have an understanding of the
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`capabilities of a person of ordinary skill in the relevant filed. I have
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`supervised and directed many such persons over the course of my career.
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`IV. Background of the Technology
`
`
`17. Before June 14, 1999, police used radar and laser signals to
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`monitor a vehicle’s speed and determine if the vehicle was complying with
`
`posted speed limits. If the vehicle was exceeding the posted speed, then the
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`police officer could issue a speeding ticket to the driver of the vehicle.
`
`18.
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`In an effort to avoid speeding tickets and before June 14, 1999,
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`companies developed and marketed devices that detected police radar and
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`laser signals and alerted the users to the incoming signals. When alerted to
`
`the incoming signals, the users would verify their compliance with the
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`posted speed and, if necessary, reduce the speed of their vehicles to comply
`
`with the posted speed.
`
`19. Before June 14, 1999, there were many different sources of
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`radar signals in the frequency range used by police to monitor vehicle speed.
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`For example, before June 14, 1999, automatic door openers at many
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`commercial establishments operated in a frequency range used by police
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`radar.
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`20. The devices that were intended to alert users to police radar
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`signals often alerted users to these other sources of radar. As a result, before
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`June 14, 1999, the devices would generate what was known as “false
`
`alarms”. These false alarms were annoying to users and made it difficult for
`
`users to distinguish between actual police radar signals and false alarm radar
`
`signals.
`
`V. The ‘905 Patent
`
`21. Figure 1 of the ‘905 patent is shown below.
`
`22. Figure 1 of the ‘905 patent shows a vehicle 10 that is exposed
`
`to a police radar signal from a police radar gun 18 and a false alarm radar
`
`
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`signal from a restaurant 16. (Orr at 8:32 – 37.)
`
`23. According to the ‘905 patent:
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` “vehicle 10 is equipped with a radar detector able to identify
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`the present coordinates and/or velocity of the vehicle, e.g. using
`
`an associated GPS receiver or alternatively a receiver of land-
`
`based signals such as LORAN. The radar detector is able to use
`
`this information to enhance its decision-making abilities.” (Orr
`
`at 8:37 – 43.)
`
`24. Figure 2 of the ‘905 patent discloses a radar detector 20.
`
`
`
`25. The fusion processor 22 is connected to a microwave receiver
`
`24 (“X/K/KA Band Detector”), laser detector 28, a GPS receiver, memory
`
`34, and display 38, and a speaker 40. (Orr at 8:44 – 9:29.)
`
`26. The fusion processor 22 is also coupled to a Universal Serial
`
`Bus interface 46 that enables the fusion processor 22 to interface with a
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`general-purpose computer that can perform “coordinate comparison tasks”
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`as described elsewhere in the ‘905 patent.
`
`“Where a general purpose host computer is connected via the
`
`USB interface, it will likely be based on a higher scale CPU
`
`chip and thus be able to efficiently carry out complex
`
`coordinate comparison tasks such as are described below, and
`
`such tasks may be delegated to the host CPU rather than carried
`
`out in fusion processor 22. The host CPU can also anticipate the
`
`need for information about particular coordinates based upon
`
`vehicle movements, and respond by retrieving records within
`
`proximity of the current location for ready delivery to fusion
`
`processor 22. The host computer can also provide navigational
`
`functions to the driver, potentially using stored signal
`
`information and flag bits to provide the user with location-
`
`specific information about driving hazards and potential police
`
`stakeout locations.” (Orr at 9:54 – 67.)
`
`27. As discussed in the above portion of the ‘905 patent, the
`
`general-purpose computer can also “provide navigational functions to the
`
`driver”.
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`28. The USB interface also enables the downloading of signal
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`information from other hosts via the Internet. (Orr at 10:1 - 5.)
`
`29. The “coordinate comparison” tasks include comparing the radar
`
`detector’s immediate coordinates with a stored list of the coordinates of
`
`unwanted stationary sources, i.e., false alarm sources. (Orr at 10:12 – 14.)
`
`If the radar detector receives a microwave or laser signal within a certain
`
`distance of one of these sources, then additional constraints are applied
`
`before alerting the user to the incoming signal. (Orr at 10:14 – 18.)
`
`30. Claim 1 of the ‘905 patent is directed to a navigation and police
`
`activity warning device as detailed below.
`
`“1. A police warning receiver comprising:
`
`a receiver section adapted to receive electromagnetic signals
`
`indicative of police activity;
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`an alert section responsive to the receiver section and adapted to
`
`provide an alert if a received electromagnetic signal correlates
`
`to a police signal; and
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`a position determining circuit generating a location signal;
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`Page 9 of 66
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`K-40 Electronics, LLC Exhibit 1007, page 9
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`wherein the alert section receives the location signal and is
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`adapted to one of alter and not provide the alert if the location
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`signal correlates to a location of a rejectable signal.” (Orr at
`
`claim 1.)
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`VI. Claim Interpretation
`
`31.
`
`In proceedings before the USPTO, I understand that the claims
`
`of an unexpired patent are to be given their broadest reasonable
`
`interpretation in view of the specification from the perspective of one skilled
`
`in the art.
`
`32.
`
`I have been informed that a reference will qualify as prior art if
`
`it is dated prior to June 14, 1999.
`
`33.
`
`I have been informed that a patent claim can be found
`
`unpatentable as obvious where the differences between the subject matter
`
`sought to be patented and the prior art are such that the subject matter as a
`
`whole would have been obvious at the time the invention was made to a
`
`person having ordinary skill in the relevant field. I understand that an
`
`obviousness analysis involves a consideration of (1) the scope and content of
`
`the prior art; (2) the differences between the claimed inventions and the prior
`
`art; (3) the level of ordinary skill in the pertinent art; and (4) secondary
`
`considerations of non-obviousness.
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`Page 10 of 66
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`VII. Hoffberg
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`34.
`
` Hoffberg describes a mobile communications device.
`
`(Hoffberg at Abstract.) Hoffberg’s mobile communications device 1 is
`
`shown in the left side of Hoffberg’s Figure 1. A box has been placed around
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`Hoffberg’s mobile communications device in Hoffberg’s Figure 1.
`
`
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`35. As shown above, the mobile communications device 1 includes
`
`a radar detector 18, a LIDAR (laser) detector 19, a GPS receiver 2, a
`
`processor 6, and a database memory 4. In operation, the device warns users
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`of police speed monitoring activities.
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`K-40 Electronics, LLC Exhibit 1007, page 11
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`36. Hoffberg’s device warns users of police activities.
`
`“Therefore, it is typically desired to have advance warnings of
`disruptions, which include accidents, icing, rain, sun glare, lane
`closures, road debris, police action, exits and entrances, and the
`like, in order to allow the driver to avoid the involved region or
`plan accordingly.” (Hoffberg at 20:3 – 7.)
`
`“According to one embodiment of the invention, the functions
`are integrated into a single device, including police radar and
`LIDAR detectors, user output, memory, central processor, GPS
`receiver and RF transceiver.” (Hoffberg at 24:29 – 32.)
`
`“Therefore, it is noted that the present invention provides a
`means for mapping events and for analyzing their significance.”
`(Hoffberg at 28:61 – 63.)
`
`“It is noted that, in the case of ‘false alarms’, the response of
`the unit is to detect the event, e.g., radar signal, correlate it with
`a stored ‘false alarm’ event, and suppress an alarm or modify
`the alarm signal.” (Hoffberg at 29:8 – 11.)
`
`“False alarms, due to security systems, traffic control and
`monitoring systems, and the like, may also be recorded, to
`increase the reliability any warnings provided.” (Hoffberg at
`30:36 – 38.)
`
`“In a preferred embodiment, an event sensor is provided, such
`as a police radar and laser speed detection equipment system
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`(e.g., ‘radar detector’) is provided. This may employ a modified
`commercially available radar detector, to produce a serial data
`stream or parallel signal set. For example, radar detectors
`providing an alpha-numeric display often transmit data to the
`display controller by means of a serial data signal.” (Hoffberg
`at 33:10 – 18.)
`
`37. Hoffberg’s mobile communications device includes a receiver
`
`that receives radar and laser signals that police use to determine a vehicle’s
`
`speed and compliance with posted speed limits.
`
`“Radar detectors typically are employed to detect operating
`emitters of X (10.5 GHz), K (25 GHz) and Ka (35 GHz) radar
`emissions from traffic control devices or law enforcement
`personnel for detecting vehicle speed by the Doppler effect.”
`(Hoffberg at 19:16 – 20.)
`
`“The preferred embodiment according to the present invention
`provides an event detector, which, in turn is preferably a police
`radar 18 and LIDAR 19 detector.” (Hoffberg at 30:44 – 46.)
`
`“In a preferred embodiment, an event sensor is provided, such
`as a police radar and laser speed detection equipment system
`(e.g., ‘radar detector’) is provided. This may employ a modified
`commercially available radar detector, to produce a serial data
`stream or parallel signal set.” (Hoffberg at 33:10 – 15.)
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`Page 13 of 66
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`38. Hoffberg incorporates by reference a number of patents related
`
`to radar detectors at Hoffberg 9:43 - 58. One of those patents is U.S. Patent
`
`No. 5,250,951 to Valentine (“Valentine”). Components of a radar detector
`
`are shown in Figure 1 of Valentine.
`
`
`
`39. Valentine describes the circuits of a radar detector. For
`
`example, Valentine discloses a radar detector that includes a “receiver
`
`means” that receives radar signals.
`
`“The radar detector 100 of FIG 1 monitors one or more police
`radar bands to sense radar signals 102 incident upon receiver
`means comprising antennas 104 … Signals received by the
`antennas 104F, 104R are passed to connector means comprising
`a switching circuit 106 in the illustrated embodiment for
`connecting signals from the antennas 104F, 104R to detector
`means which detects incoming signals and distinguished radar
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`signals from noise such that valid incoming radar signals can be
`indicated to the person using the detector 100.” (Valentine at
`6:5 – 21.)
`
`40. Hoffberg’s mobile communications device warns a user with a
`
`warning if a valid incoming radar signal is detected.
`
`“It is noted that, in the case of ‘false alarms’, the response of
`the unit is to detect the event, e.g., radar signal, correlate it with
`a stored ‘false alarm’ event, and suppress an alarm or modify
`the alarm signal.” (Hoffberg at 29:8 – 11.)
`
`“In a preferred embodiment, an event sensor is provided, such
`as a police radar and laser speed detection equipment system
`(e.g., ‘radar detector’) is provided. This may employ a modified
`commercially available radar detector, to produce a serial data
`stream or parallel signal set. For example, radar detectors
`providing an alpha-numeric display often transmit data to the
`display controller by means of a serial data signal.” (Hoffberg
`at 33:10 – 18.)
`
`41.
`
` Valentine, which as discussed above, is incorporated by
`
`reference by Hoffberg, discloses an alarms circuit that warns users when
`
`“valid incoming radar signals”, i.e., incoming radar signals that are
`
`distinguished from noise, are detected.
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`Page 15 of 66
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`K-40 Electronics, LLC Exhibit 1007, page 15
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`“The radar detector 100 of FIG 1 monitors one or more police
`radar bands to sense radar signals 102 incident upon receiver
`means comprising antennas 104 … Signals received by the
`antennas 104F, 104R are passed to connector means comprising
`a switching circuit 106 in the illustrated embodiment for
`connecting signals from the antennas 104F, 104R to detector
`means which detects incoming signals and distinguished radar
`signals from noise such that valid incoming radar signals can be
`indicated to the person using the detector 100.” (Valentine at
`6:5 – 21.)
`
`42. Hoffberg’s mobile communications device includes a GPS
`
`receiver that determines the position of the device.
`
`“According to one embodiment of the invention, the functions
`are integrated into a single device, including police radar and
`LIDAR detectors, user output, memory, central processor, GPS
`receiver and RF transceiver.” (Hoffberg at 24:29 – 32.)
`
`Page 16 of 66
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`K-40 Electronics, LLC Exhibit 1007, page 16
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`“The location sensing system 2 comprises a known GPS
`receiver, which produces data that is analyzed by the processor
`6. In an alternate embodiment, the GPS receiver includes its
`own processor and outputs coordinate positions, e.g., Cartesian
`coordinates, latitude and longitude, to the communications
`device processor 6, e.g., through a serial port or data bus, such
`as PC card, Universal Serial Bus (USB), Firewire (IEEE 1394),
`peripheral connect interface (PCI), or other bus, such as that
`present within an automobile for communication of signals
`between subsystems.” (Hoffberg at 26:45 – 54)
`
`43. Hoffberg’s mobile communications device suppresses or
`
`modifies warnings if the location of the device correlates to a location of a
`
`rejectable signal, i.e., a false alarm location.
`
`“According to one embodiment of the invention, the functions
`are integrated into a single device, including police radar and
`LIDAR detectors, user output, memory, central processor, GPS
`receiver and RF transceiver.” (Hoffberg at 24:29 – 32.)
`
`“The location sensing system 2 comprises a known GPS
`receiver, which produces data that is analyzed by the processor
`6. In an alternate embodiment, the GPS receiver includes its
`own processor and outputs coordinate positions, e.g., Cartesian
`coordinates, latitude and longitude, to the communications
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`Page 17 of 66
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`device processor 6, e.g., through a serial port or data bus, such
`as PC card, Universal Serial Bus (USB), Firewire (IEEE 1394),
`peripheral connect interface (PCI), or other bus, such as that
`present within an automobile for communication of signals
`between subsystems.” (Hoffberg at 26:45 – 54.)
`
`“Therefore, it is noted that the present invention provides a
`means for mapping events and for analyzing their significance.
`Thus, this embodiment does not merely rely on processed
`sensor outputs to supply information to the user; rather, sensor
`outputs may be filtered based on past experience with the
`particular location in question. If a particular user does not have
`direct experience with a location, then the experience of others
`at that location may be substituted or combined to improve
`analysis of the sensor signal. Therefore, the signal analysis from
`the sensor need not be subjected to a relatively high threshold to
`avoid false alarms. A low threshold is acceptable because other
`information is employed to determine the nature of the physical
`elements which give rise to the event and sensor activation.
`It is noted that, in the case of ‘false alarms’, the response of
`the unit is to detect the event, e.g., radar signal, correlate it
`with a stored ‘false alarm’ event, and suppress an alarm or
`modify the alarm signal.” (Hoffberg at 28:61 – 29:11,
`emphasis added.)
`
`“The memory stores information describing the event as
`well as the location of the event. Preferably, the memory is not
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`K-40 Electronics, LLC Exhibit 1007, page 18
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`organized as a matrix of memory addresses corresponding to
`locations, e.g., a ‘map’, but rather in a record format having
`explicitly describing the event and location, making storage of
`the sparse matrix more efficient and facilitating indexing and
`sorting on various aspects of each data record. Additional
`information, such as the time of the event, importance of the
`event, expiration time of the event, source and reliability of the
`event information, and commercial and/or advertising
`information associated with the event may be stored. ”
`(Hoffberg at 22:18 – 29, emphasis added.)
`
`44. Hoffberg’s mobile communications device receives radar
`
`signals in the X, K, and Ka radar bands and warns a user to those signals.
`
`“Radar detectors typically are employed to detect operating
`emitters of X (10.5 GHz), K (25 GHz) and Ka (35 GHz) radar
`emissions from traffic control devices or law enforcement
`personnel for detecting vehicle speed by the Doppler effect.”
`(Hoffberg at 19:16 – 20.)
`
`“The preferred embodiment according to the present invention
`provides an event detector, which, in turn is preferably a police
`radar 18 and LIDAR 19 detector.” (Hoffberg at 30:44 – 46.)
`
`“In a preferred embodiment, an event sensor is provided, such
`as a police radar and laser speed detection equipment system
`
`Page 19 of 66
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`K-40 Electronics, LLC Exhibit 1007, page 19
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`(e.g., ‘radar detector’) is provided. This may employ a modified
`commercially available radar detector, to produce a serial data
`stream or parallel signal set.” (Hoffberg at 33:10 – 15.)
`
`45. Hoffberg’s mobile communications device receives infrared
`
`laser signals and warns a user to those signals.
`
`“LIDAR devices emit an infrared laser signal, which is then
`reflected off a moving vehicle and analyzed for delay, which
`relates to distance. Through successive measurements, a speed
`[sic] can be calculated. A LIDAR detector therefore seeks to
`detect the characteristic pulsatile infrared energy.” (Hoffberg at
`19:33 – 38, emphasis added.)
`
`“The preferred embodiment according to the present invention
`provides an event detector, which, in turn is preferably a police
`radar 18 and LIDAR 19 detector.” (Hoffberg at 30:44 – 46.)
`
`46. Hoffberg’s mobile communications device detects the event,
`
`e.g., radar signal, correlates it with a stored ‘false alarm’ event, and
`
`suppresses an alarm or modifies the alarm signal.
`
`“The system provides a memory for storing events and
`respective locations. Preferably, further information is also
`stored, such as a time of the event, its character or nature,
`and other quantitative or qualitative aspects of the
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`Page 20 of 66
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`information or its source and/or conditions of acquisition. This
`memory may be a solid state memory or module, rotating
`magnetic and/or optical memory devices, or other known types
`of memory.” (Hoffberg at 18:64 – 19:4, emphasis added.)
`
`“It is noted that, in the case of ‘false alarms’, the response of
`the unit is to detect the event, e.g., radar signal, correlate it
`with a stored ‘false alarm’ event, and suppress an alarm or
`modify the alarm signal.” (Hoffberg at 29:8 – 11, emphasis
`added.)
`
`47. Hoffberg’s mobile communications device stores flags, i.e.,
`
`signals indicating the existence or status of particular conditions, that are
`
`associated with geographic locations that identify rejectable signals, i.e.,
`
`false alarms.
`
`“The system provides a memory for storing events and
`respective locations. Preferably, further information is also
`stored, such as a time of the event, its character or nature,
`and other quantitative or qualitative aspects of the
`information or its source and/or conditions of acquisition. This
`memory may be a solid state memory or module, rotating
`magnetic and/or optical memory devices, or other known types
`of memory.” (Hoffberg at 18:64 – 19:4, emphasis added.)
`
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`Page 21 of 66
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`“The events to be stored may be detected locally, such as
`through a detector for radar and/or laser emission source, radio
`scanner, traffic or road conditions (mechanical vehicle sensors,
`visual and/or infrared imaging, radar or LIDAR analysis,
`acoustic sensors, or the like), places of interest which may be
`selectively identified, itinerary stops, and/or fixed locations.”
`(Hoffberg at 19:5 – 11.)
`
`“False alarms, due to security systems, traffic control and
`monitoring systems, and the like, may also be recorded, to
`increase the reliability any warnings provided.” (Hoffberg at
`30:36–38.)
`
`48. Hoffberg’s mobile communications device stores the location
`
`of and the “character or nature” of events, such as rejectable signals, i.e.,
`
`false alarm signals, in event records.
`
`“The system provides a memory for storing events and
`respective locations. Preferably, further information is also
`stored, such as a time of the event, its character or nature,
`and other quantitative or qualitative aspects of the
`information or its source and/or conditions of acquisition. This
`memory may be a solid state memory or module, rotating
`magnetic and/or optical memory devices, or other known types
`of memory.” (Hoffberg at 18:64 – 19:4, emphasis added.)
`
`
`Page 22 of 66
`
`K-40 Electronics, LLC Exhibit 1007, page 22
`
`
`
`“The events to be stored may be detected locally, such as
`through a detector for radar and/or laser emission source, radio
`scanner, traffic or road conditions (mechanical vehicle sensors,
`visual and/or infrared imaging, radar or LIDAR analysis,
`acoustic sensors, or the like), places of interest which may be
`selectively identified, itinerary stops, and/or fixed locations.”
`(Hoffberg at 19:5 – 11.)
`
`“The memory stores information describing the event as well as
`the location of the event. Preferably, the memory is not
`organized as a matrix of memory addresses corresponding to
`locations, e.g., a ‘map’, but rather in a record format having
`explicitly describing the event and location, making storage
`of the sparse matrix more efficient and facilitating indexing and
`sorting on various aspects of each data record.” (Hoffberg at
`22:18 – 24, emphasis added.)
`
`“It is noted that, in the case of ‘false alarms’, the response of
`the unit is to detect the event, e.g., radar signal, correlate it
`with a stored ‘false alarm’ event, and suppress an alarm or
`modify the alarm signal.” (Hoffberg at 29:8-11, emphasis
`added.)
`
`“False alarms, due to security systems, traffic control and
`monitoring systems, and the like, may also be recorded, to
`increase the reliability any warnings provided.” (Hoffberg at
`30:36–38.)
`
`Page 23 of 66
`
`K-40 Electronics, LLC Exhibit 1007, page 23
`
`
`
`
`49. Hoffberg’s mobile communications device includes various
`
`connectors, such as RJ-11 and RJ-12 connectors, and USB connectors.
`
`Hoffberg’s device also stores false alarm information on a large number of
`
`different memory devices, such as dynamic random access memory, non-
`
`volatile memory, CDROM, etc. Prior to June 14, 1999, Automobiles
`
`routinely used dynamic random access memory, non-volatile memory, and
`
`CDROMs.
`
`“The memory 4 may be of any standard type, for example,
`static random access memory, dynamic random access
`memory, ferroelectric memory, magnetic domain memory
`(e.g., diskette, hard disk), non-volatile semiconductor
`memory (e.g., UV-EPROM, EEPROM, Flash, non-standard
`electrically erasable programmable non-volatile memory),
`optically readable memory (e.g., R-CDROM, RW-CDROM,
`R-DVD, etc.), scanning/tunneling micromechanical memory
`systems, and the like. Preferably, common memory devices,
`such as 72 or 168 pin dynamic RAM single inline memory
`modules (SIMMs) are employed, at least for a volatile portion
`of the memory, allowing simple upgrades and industry standard
`compatibility.” (Hoffberg at 27:36 – 48, emphasis added.)
`
` “For example, a central database 20 may provide consolidated
`and reliable data. The relevant portion of the database 20
`
`Page 24 of 66
`
`K-40 Electronics, LLC Exhibit 1007, page 24
`
`
`
`may be downloaded by telephone through a modem 21,
`either through a physical connection 23 (e.g., RJ-11 or RJ-
`12 jack) or through an acoustic coupler 22, through the public
`switched telephone network, Internet or other network 24, to a
`database server 25.” (Hoffberg at 28:5 – 8, emphasis added.)
`
`“In an alternate embodiment, the GPS receiver includes its own
`processor and outputs coordinate positions, e.g., Cartesian
`coordinates, latitude and longitude, to the communications
`device processor 6, e.g., through a serial port or data bus, such
`as PC card, Universal Serial Bus (USB), Firewire (IEEE
`1394), peripheral connect interface (PCI), or other bus, such as
`that present within an automobile for communication of
`signals between subsystems.” (Hoffberg at 26:47 – 54,
`emphasis added.)
`
`“If the PDA and GPS are not integrated, a preferred interface
`comprises a computer standard low to medium speed serial data
`interface, such as RS-232, RS-422, or USB …” (Hoffberg at
`33:44 – 46, emphasis added.)
`
`“If a particular user does not have direct experience with a
`location, then the experience of others at that location may be
`substituted or combined to improve analysis of the sensor
`signal. … It is noted that, in the case of ‘false alarms’, the
`response of the unit is to detect the event, e.g., radar signal,
`correlate it with a stored ‘false alarm’ event, and suppress an
`
`Page 25 of 66
`
`K-40 Electronics, LLC Exhibit 1007, page 25
`
`
`
`alarm or modify the alarm signal.” (Hoffberg at 28:66 –
`29:11.)
`
`“False alarms, due to security systems, traffic control and
`monitoring systems, and the like, may also be recorded, to
`increase the reliability any warnings provided.” (Hoffberg at
`30:36–38.)
`
`50. Hoffberg’s mobile communications device has a training mode
`
`in which the Hoffberg device learns of false alarm locations.
`
`“These logical paradigms are provided in known manner, and,
`especially in the case of neural network-based system, a
`training aspect may be supplied with the system to allow it to
`adapt to the preferences and capabilities of the user.” (Hoffberg
`at 28:31–35, emphasis added.)
`
`“For example, in a radar detector embodiment, mobile police
`radar ‘traps’ are often relocated, so that a particular location of
`one event should not be perpetuated beyond its anticipated or
`actual relevance. In this case, expirations may be stored, or
`calculated based on a ‘type’ of event according to a set of rules.
`False alarms, due to security systems, traffic control and
`monitoring systems, and the like, may also be recorded, to
`increase the reliability any warnings provided.” (Hoffberg at
`30:31–38, emphasis added.)
`
`Page 26 of 66
`
`K-40 Electronics, LLC Exhibit 1007, page 26
`
`
`
`
`51. Hoffberg’s mobile communications device stores rejectable
`
`signal, i.e., false alarm, information. Hoffberg’s device does not limit the
`
`storing of false alarm information to instances in which information was
`
`previously stored regarding the false alarm location.
`
`“The system provides a memory for storing events and
`respective locations. Preferably, further information is also
`stored, such as a time of the event, its character or nature, and
`other quantitative or qualitative aspects of the information or its
`source and/or conditions of acquisition. This memory may be a
`solid state memory or module, rotating magnetic and/or optical
`memory devices, or other known types of memory.
`
`The events to be stored may be detected locally, such as
`through a detector for radar and/or laser emission source, radio
`scanner, traffic or road conditions (mechanical vehicle sensors,
`vis
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