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:
`
`Issued:
`
`Inventor: Steven K. Orr
`
`Assignee: Escort Inc.
`
`Title:
`
`June 14, 2000
`
`December 30, 2003
`
`Radar Warning Receiver With Position and Velocity Sensitive
`Functions
`
`
`
`Mail Stop PATENT BOARD, PTAB
`Commissioner for Patents
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 6,670,905
`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. § 42.100 ET SEQ.
`
`
` 
`
` 
`
`

`

`TABLE OF CONTENTS
`
`TABLE OF CONTENTS .............................................................................................................. i 
`EXHIBIT LIST ............................................................................................................................. iii 
`I. 
` INTRODUCTION ................................................................................................................. 1 
`II.  MANDATORY NOTICES .................................................................................................. 1 
`A.  Real Party-In-Interest ....................................................................................................... 1 
`B.  Related Matters ................................................................................................................. 2 
`C.  Lead and Back-Up Counsel .............................................................................................. 2 
`D.  Service Information .......................................................................................................... 3 
`III.  PAYMENT OF FEES ......................................................................................................... 3 
`IV.  REQUIREMENTS FOR INTER PARTES REVIEW ...................................................... 4 
`A.  Grounds for Standing ....................................................................................................... 4 
`B.  Identification of Challenge ............................................................................................... 4 
`1.  The Specific Art and Statutory Ground(s) on Which the Challenge is Based ......... 4 
`2.  How the Construed Claims are Unpatentable under the Statutory Grounds
`Identified in 37 C.F.R. § 42.204(b)(2) and Supporting Evidence Relied upon to
`Support the Challenge .................................................................................................. 5 
`V.  FACTUAL BACKGROUND ............................................................................................... 6 
`A.  The ‘656 Patent Application ............................................................................................. 6 
`B.  The Prosecution History ................................................................................................... 6 
`C.  The ‘905 Patent .................................................................................................................. 7 
`D.  Petitioner’s Declaration Evidence ................................................................................... 9 
`E.  The Prior Art ................................................................................................................... 10 
`1.  Hoffberg ........................................................................................................................ 10 
`2.  Fleming.......................................................................................................................... 11 
`VI.  THRESHOLD LEGAL DETERMINATIONS .............................................................. 12 
`A.  Broadest Reasonable Construction ............................................................................... 12 
`1.  “Flag” ............................................................................................................................ 14 
`2.  “Rejectable Signal” ...................................................................................................... 15 
`VII.  GROUNDS OF UNPATENTABILITY ......................................................................... 15 
`A.  1 – 4, 11, 15 – 18, 22 – 33, 36 – 39, 41 – 57, 59 – 72, and 74 – 85 of The ‘905 Patent
`Are Anticipated by Hoffberg ................................................................................................. 15 
`
` 
`
`i 
`
`

`

`B.  Claims 1 – 2, 4 - 6, 11 – 12, 15 – 18, 22, 24 – 29, 36, 39, 41 – 55, 57 – 72, and 74 – 85 of
`the ‘905 patent are anticipated by Fleming under 35 U.S.C. § 102(e) ............................... 39 
`C.  Claims 1 – 6, 11 – 12, 15 – 18, 22 – 33, 36 – 39, 41 – 72, and 74 – 85 of the ‘905 patent
`Are Rendered Obvious by Fleming in View of Hoffberg .................................................... 56 
`VIII.  CONCLUSION ............................................................................................................... 57 
`
`
`ii 
`
`

`

`
`
`EXHIBIT LIST
`
`U.S. Patent No. 7,6,670,905 to Orr
`U.S. Patent No. 6,252,544 to Hoffberg
`U.S. Patent No. 6,204,798 to Fleming
`Excerpts from prosecution history of Application No.
`09/889,656
`Provisional application No. 60/139,097
`U.S. Patent No. 5,250,951 to Valentine (incorporated by
`reference into Hoffberg)
`Declaration of Dr. Christopher Bartone
`
`
`
`
`
`
`
`
`
`1001
`1002
`1003
`1004
`
`1005
`1006
`
`1007
`
`
`iii 
`
`

`

`I.
`
` INTRODUCTION
`
`This Petition presents two anticipatory references, U.S. Patent No. 6,252,544
`
`to Hoffberg and U.S. Patent No. 6,204,798 to Fleming. Both of the references
`
`were cited but were not applied to the claims at issue in this petition by the
`
`Examiner. As explained in the accompanying declaration of Professor
`
`Christopher Bartone, Hoffberg meets all limitations of claims 1 – 4, 11, 15 – 18, 22
`
`– 33, 36 – 39, 41 – 57, 59 – 72, and 74 - 85 of the ‘905 patent and Fleming meeting
`
`all limitations of claims 1 – 2, 4 - 6, 11 – 12, 15 – 18, 22, 24 – 29, 36, 39, 41 – 55,
`
`57 – 72, and 74 – 85 of the ‘905 patent.
`
`The instant Petition also offers an obvious rejection premised upon a
`
`modification of Fleming which incorporates Hoffberg’s LIDAR detector and
`
`communications subsystem so that the improved intelligent radar detector offers
`
`enhanced laser protection and receives laser false alarm information provided by a
`
`remote database.
`
`
`II. MANDATORY NOTICES
`
`
`
`Pursuant to 37 C.F.R. § 42.8(a)(1), petitioner provides the following
`
`mandatory disclosures.
`
`A. Real Party-In-Interest
`Pursuant to 37 C.F.R. § 42.8(b)(1), Petitioner certifies that K40 Electronics
`
`LLC is the real party-in-interest.
`
`1 
`
`

`

`B. Related Matters
`Pursuant to 37 C.F.R. § 42.8(b)(2), Petitioner states that the ‘905 patent is
`
`asserted in co-pending litigation captioned Escort Inc. v. K-40 Electronics, LLC,
`
`S.D. Ohio, Case No. 1:12-cv-00937. This litigation remains pending. The patents-
`
`in-suit are U.S. Patents 6,670,905 and 7,999,721. This IPR petition is directed to
`
`U.S. Patent No. 7,999,905; a petition corresponding to U.S. Patent No. 7,999,721
`
`was filed on March 22, 2013 and was assigned Case Number IPR2013-00203.
`
`
`
`C. Lead and Back-Up Counsel
`
`Pursuant to 37 C.F.R. § 42.8(b)(3), Petitioner provides the following
`
`designation of counsel: Lead counsel is Greg Gardella (Reg. No. 46,045) and
`
`back-up counsel is Scott A. McKeown (Reg. No. 42,866).
`
`2 
`
`

`

`
`
`Service Information
`
`D.
`Pursuant to 37 C.F.R. § 42.8(b)(4), papers concerning this matter should be
`
`served on the following.
`
`Address: Greg Gardella or Scott McKeown
`Oblon Spivak
`1940 Duke Street
`Alexandria, VA 22314
`cpdocketgardella@oblon.com and
`cpdocketmckeown@oblon.com
`Telephone: (703) 413-3000
`Fax:
`
`(703) 413-2220
`
`Email:
`
`
`III. PAYMENT OF FEES
`
`The undersigned authorizes the Office to charge Deposit Account No. 15-
`
`0030 for any fees required by 37 C.F.R. § 42.15(a) for this Petition for inter partes
`
`review. The undersigned further authorizes payment for any additional fees that
`
`might be due in connection with this Petition to be charged to the above referenced
`
`Deposit Account and, additionally, requests that any overpayment of fees be
`
`credited to the above referenced Deposit Account.
`
`3 
`
`

`

`
`IV. REQUIREMENTS FOR INTER PARTES REVIEW
`
`As set forth below and pursuant to 37 C.F.R. § 42.104, each requirement for
`
`inter partes review of the ‘905 patent is satisfied.
`
`A. Grounds for Standing
`Pursuant to 37 C.F.R. § 42.104(a), Petitioner hereby certifies that the ‘905
`
`patent is available for inter partes review and that the Petitioner is not barred or
`
`estopped from requesting inter partes review challenging the claims of the ‘905
`
`patent on the grounds identified herein. The ‘905 patent has not been subject to a
`
`previous estoppel based proceeding of the AIA, and, the complaint served on K40
`
`referenced above in Section I(B) was served within the last 12 months.
`
`B. Identification of Challenge
`Pursuant to 37 C.F.R. §§ 42.104(b) and (b)(1), Petitioner requests inter
`
`partes review of claims 1 – 6, 11 – 12, 15 – 18, 22 – 33, 36 – 39, 41 – 72, and 74 -
`
`85 of the ‘905 patent, and that the Patent Trial and Appeal Board (“PTAB”)
`
`declare these claims unpatentable in view of the information cited herein.
`
`1.
`
`The Specific Art and Statutory Ground(s) on Which the
`Challenge is Based
`
`Pursuant to 37 C.F.R. § 42.204(b)(2), inter partes review of the ‘905 patent
`
`
`
`is requested in view of the following references, each of which is prior art to the
`
`‘905 patent under 35 U.S.C. § 102(e):
`
`4 
`
`

`

`(1) U.S. Patent No. 6,233,589 to Hoffberg (“Hoffberg”, attached as Ex.
`
`1002), issued June 26, 2001 from an application filed January 25, 1999. (Hoffberg
`
`claims priority to Provisional application No. 60/072,757, which was filed on
`
`January 27, 1998.) Hoffberg is prior art to the ‘905 patent under 35 U.S.C. §
`
`102(e).
`
`(2) U.S. Patent No. 6,204,798 to Fleming (“Fleming”, attached as Ex.
`
`1003), issued March 20, 2001 from an application filed on April 14, 1999.
`
`Fleming is prior art to the ‘905 patent under 35 U.S.C. § 102(e).
`
`Hoffberg anticipates claims 1 – 4, 11, 15 – 18, 22 – 33, 36 – 39, 41 – 57, 59
`
`– 72, and 74 – 85 of the ‘905 patent under 35 U.S.C. § 102(e).
`
`Fleming anticipates claims 1 – 2, 4 - 6, 11 – 12, 15 – 18, 22, 24 – 29, 36, 39,
`
`41 – 55, 57 – 72, and 74 – 85 the ‘905 patent under 35 U.S.C. § 102(e).
`
`Fleming renders obvious claims 1 – 6, 11 – 12, 15 – 18, 22 – 33, 36 – 39, 41
`
`– 72, and 74 – 85 the ‘905 patent under 35 U.S.C. § 103(a) when taken in
`
`combination with Hoffberg.
`
`2.
`
`How the Construed Claims are Unpatentable under the
`Statutory Grounds Identified in 37 C.F.R. § 42.204(b)(2)
`and Supporting Evidence Relied upon to Support the
`Challenge
`
`Pursuant to 37 C.F.R. § 42.204(b)(4), an explanation of how claims 1 – 6, 11
`
`
`
`– 12, 15 – 18, 22 – 33, 36 – 39, 41 – 72, and 74 – 85 of the ‘905 patent are
`
`unpatentable under the statutory grounds identified above, including the
`
`5 
`
`

`

`identification of where each element of the claim is found in the prior art, is
`
`provided in Section VII, below, in the form of claims charts. Pursuant to 37 C.F.R.
`
`§ 42.204(b)(5), the appendix numbers of the supporting evidence relied upon to
`
`support the challenges and the relevance of the evidence to the challenges raised,
`
`including identifying specific portions of the evidence that support the challenges,
`
`are provided in Section VII, below, in the form of claim charts.
`
`
`V.
`
`FACTUAL BACKGROUND
`A. The ‘656 Patent Application
`
`
`
`Application No. 09/889,656 (“the ‘656 application”, attached as Ex. 1004),
`
`which issued as the ‘905 patent, was filed as application No. PCT/US00/16410 on
`
`June 14, 2000. The ‘905 patent claims priority to two Provisional applications, the
`
`earliest of which is provisional application No. 60/139,097 (“the ‘097 application”,
`
`attached as Ex. 1005), filed on June 14, 1999.
`
`The ‘147 application describes a GPS-enabled radar detector that handles
`
`radar sources based upon previously stored geographically-referenced-information
`
`on such sources and data from the GPS receiver. (Ex. 1001, at Abstract.)
`
`B. The Prosecution History
`
`During prosecution of the ‘147 application, on September 27, 2002, the
`
`examiner rejected claims 1 – 42 and 86 - 95 under 35 U.S.C. § 112, second
`
`paragraph, allowed claims 43 – 85 in a first office action allowance, and rejected
`
`6 
`
`

`

`claims 86 – 136 under 35 U.S.C. § 102(b) under various references including
`
`Hoffberg and Fleming. (Ex. 1004.) After resolving the 35 U.S.C. § 112, second
`
`paragraph matter and canceling claims 86 – 136, a Notice of Allowance was
`
`issued. (Ex. 1004.) The ‘905 patent issued on December 30, 2003. (Ex. 1001.)
`
`C. The ‘905 Patent
`Figure 1 of the ‘905 patent (Ex. 1001) is shown below.
`
` 
`
`Figure 1 shows a vehicle 10 that is exposed to a police radar signal from a
`
`police radar gun 18 and a false alarm radar signal from a restaurant 16. (Ex. 1001
`
`at 8:32 – 37.) The vehicle 10 includes a radar detector that can identify the
`
`location and/or the velocity of the vehicle using a position determining device,
`
`such as a GPS receiver. The radar detector is able to use the information from the
`
`position determining device to enhance its decision-making abilities. (Ex. 1001 at
`
`8:37 – 43.)
`
`7 
`
`

`

`Figure 2 of the ‘905 patent discloses a radar detector 20.
`
` 
`
`The fusion processor 22 of the radar detector is connected to a microwave
`
`receiver 24, laser detector 28, a GPS receiver, memory 34, and display 38, and a
`
`speaker 40. (Ex. 1001 at 8:44 – 9:29.) The fusion processor 28 is also coupled to
`
`a Universal Serial Bus interface 46 that enables the fusion processor 28 to interface
`
`with a general-purpose computer that can perform “coordinate comparison tasks”
`
`as well as “provide navigational functions”. (Ex. 1001 at 9:54 – 67.)
`
`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. (Ex. 1001 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. (Ex. 1001 at 10:14 – 18.)
`
`8 
`
`

`

`D. Petitioner’s Declaration Evidence
`This Petition is supported by the declaration of Professor Christopher
`
`Bartone (Ex. 1007). Professor Bartone provides his assessment of the scope and
`
`content of the prior art.
`
`Prof. Bartone earned a bachelor of science degree in electrical engineering
`
`from The Pennsylvania State University in 1983 with an emphasis and
`
`electromagnetics, communications, and antennas. He also earned a Masters in
`
`electrical engineering from The Naval Postgraduate School in 1987 (with a
`
`specialization in communications engineering) and doctoral degree in electrical
`
`engineering from Ohio University in 1998.
`
`Prof. Bartone is currently a professor in the School of Electrical Engineering
`
`and Computer Science at Ohio University. He has taught both undergraduate and
`
`graduate courses in radar and GPS and has over 29 years of experience with
`
`communication, navigation and surveillance systems.
`
`9 
`
`

`

`
`
`E. The Prior Art
`
`1. Hoffberg
` 
`Hoffberg discloses a mobile communications device that includes a police
`
`radar detector, a LIDAR (Laser) detector, a GPS receiver, a communications
`
`subsystem, memory, and a central processor. (Ex. 1002 at 24:29 – 32.) A box has
`
`been placed around Hoffberg’s mobile communications device in a portion of
`
`Hoffberg’s Figure 1.
`
`
`
`10 
`
`

`

`Hoffberg’s mobile communications device 1 stores events, such as radar
`
`signal false alarms, in database memory 4. (Id. at 19:5 – 11 and 29:8 – 11.)
`
`Hoffberg’s device also stores vehicle speed and speed limits in database memory 4.
`
`(Id. at 22:66 – 23:3 and at 29:44 – 52.)
`
`Hoffberg’s device detects police radar signals, correlates the police radar
`
`signals with previously stored false alarms locations, and suppresses or modifies an
`
`alarm that is used to warn a user of police radar signals. (Id. at 29:8 – 11.)
`
`The device also exchanges event information, such as false alarm
`
`information, with other devices. (Id. at 27:49 – 55 and 28:57 – 29:13.) The
`
`device also includes a map that displays the locations of events. (Id. at 28:61 – 63
`
`and 34:6 – 45.)
`
`2. Fleming
`
`Fleming discloses a police radar detector that includes a GPS receiver.
`
`
`
`11 
`
`

`

`(Ex. 1003, at Figure 1.) As shown in Figure 1, Fleming’s radar detector includes a
`
`GPS receiver, an antenna, a detector circuit, an alert circuit, a program storage
`
`device (memory), and a microprocessor. The radar detector stores false alarm
`
`locations in memory. (Id. at 3:53 – 63.) The radar detector also stores vehicle
`
`velocity and speed limits in memory. (Id. at 5:47 – 51 and at 6:3 – 16.)
`
`Fleming’s radar detector determines whether or not to generate alerts to
`
`incoming radar signals based upon the position of the radar detector with respect to
`
`the locations of previously stored false alarms. (Id. at 3:38 – 52.) The radar
`
`detector also obtains false alarm information that was gathered by other radar
`
`detectors via general-purpose computers such as cell phones. (Id. at 3:65 – 4:5.)
`
`
`VI. THRESHOLD LEGAL DETERMINATIONS
`
`
`A. Broadest Reasonable Construction
`
`Pursuant to 37 C.F.R. § 42.204(b)(3), the claims subject to inter partes review
`
`shall receive the “broadest reasonable construction in light of the specification of
`
`the patent in which [they] appear[].” See 42 C.F.R. § 100(b); see also In re
`
`Swanson, No. 07-1534 (Fed. Cir. 2008); In re Trans Texas Holding Corp., 498
`
`F.3d 1290, 1298 (Fed. Cir. 2007) (citing In re Yamamoto, 740 F.2d 1569, 1571
`
`(Fed. Cir. 1984)). As the Federal Circuit noted in Trans Texas, the Office has
`
`traditionally applied a broader standard than a Court does when interpreting claim
`
`12 
`
`

`

`scope. Moreover, the Office is not bound by any district court claim construction.
`
`Trans Texas, 498 F.3d at 1297-98, 1301. Rather,
`
`the PTO applies to verbiage of the proposed claims the
`broadest reasonable meaning of the words in their
`ordinary usage as they would be understood by one of
`ordinary skill in the art, taking into account whatever
`enlightenment by way of definitions or otherwise that
`may be afforded by the written description contained in
`applicant’s specification. In re Morris, 127 F.3d 1048,
`1054-55, 44 U.S.P.Q.2d 1023, 1027-28 (Fed. Cir. 1997).
`
`Because the standards of claim interpretation used by the federal courts are
`
`different from the standards used by the Patent Office in claim examination
`
`proceedings (including this inter partes review), any claim interpretations used or
`
`applied in these proceedings are neither binding upon Petitioner in patent
`
`infringement litigation or on any other litigants, nor do such claim interpretations
`
`correspond to the construction of claims under the legal standards used by the courts.
`
`Accordingly, any interpretation of claims presented either implicitly or explicitly
`
`herein should not be viewed as constituting, in whole or in part, Petitioner’s own
`
`interpretation and/or construction of such claims for the purposes of litigation.
`
`Instead, any constructions in this proceeding should be viewed only under the
`
`“broadest reasonable construction” standard required here.
`
`All claimed terms not specifically addressed in this section have been
`
`accorded their broadest reasonable interpretation in light of the patent specification
`
`including their plain and ordinary meaning.
`
`13 
`
`

`

`1. “Flag”
`
` 
`
`The specification of the ‘905 patent uses the term flags to identify various
`
`conditions.
`
`“FIG 5. Is an illustration of a database structure used for storing flags
`
`identifying various conditions at a number of locations, as identified
`
`by cell coordinates;” (Ex. 1001 at 5:3 – 5.)
`
`“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.” (Id. at 9:63 – 67.)
`
`“The flag bits may identify various hazard conditions. For example, in
`
`the specific embodiment described below, there is an ‘always warn’
`
`flag bit that indicates that police activity has previously been
`
`confirmed at the location, and therefore the user should be warned of
`
`all apparent police radar signals at the location. (Id. at 12:21 – 26.)”
`
`Consistent with the foregoing context, the term “flag” is interpreted, under
`
`the broadest reasonable construction, to include a code that identifies some
`
`condition.
`
`
`
`14 
`
`

`

`2. “Rejectable Signal”
`
` 
`
`Claim 3 recites that the “information associated with geographic locations
`
`includes information identifying rejectable signals at a geographic location.” The
`
`term “rejectable signals” is not used in the specification of the ‘905 patent.
`
`However, the Summary section includes this passage:
`
`By adding GPS conditioning capabilities to a radar detector, the
`combination becomes a new product category that is capable of
`rejecting signals from any given location no matter what the nature of
`the microwave/laser signals might be from that location. (Ex. 1001 at
`4:37-41)
`
`Accordingly, “rejectable signals” is interpreted as including, under the broadest
`
`reasonable interpretation, any signals that may be rejected based on the location
`
`with which they are associated.
`
`VII. GROUNDS OF UNPATENTABILITY
`
`The references addressed below each anticipate and render obvious the
`
`claimed subject matter.
`
`A. 1 – 4, 11, 15 – 18, 22 – 33, 36 – 39, 41 – 57, 59 – 72, and 74 – 85 of The
`‘905 Patent Are Anticipated by Hoffberg
`
` 
`
`The following claim chart demonstrates, on a limitation-by-limitation basis,
`
`how claims 1 – 4, 11, 15 – 18, 22 – 33, 36 – 39, 41 – 57, 59 – 72, and 74 – 85 of
`
`the ‘905 patent are anticipated by Hoffberg under 35 U.S.C. § 102(e).
`
`15 
`
`

`

`1. A police warning receiver comprising:
`
`
`
`(Ex. 1002 at Figure 1, box added.)
`“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.” (Id. at 20:3 – 7, emphasis added.)
`“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.” (Id. at 24:29 –
`32.)
`“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.” (Ex. 1002 at 30:36 – 38.)
`See Declaration of Dr. Chris Bartone (Ex. 1007) at ¶¶34 – 36.
`a receiver section adapted to receive electromagnetic signals indicative of
`police activity;
`“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.”
`(Ex. 1002 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.”
`
`16 
`
`

`

`(Id. 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.” (Id. at 33:10 – 15.)
`One of the many ‘radar detection’ patents that Hoffberg incorporates by
`reference at 9:43 – 58, is U.S. Patent No. 5,250,951 to Valentine, which discloses
`the well-known Valentine One police radar detector:
`
`
`
`(Ex. 1006 at Figure 1.)
`“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.” (Ex. 1006 at 6:5 –
`21.)
`See Declaration of Dr. Chris Bartone (Ex. 1007) at ¶¶37-39.
`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
`“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.” (Ex. 1002 at 29:8 – 11.)
`“In a preferred embodiment, an event sensor is provided, such as a police radar
`
`17 
`
`

`

`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.” (Id. at 33:10 – 18.)
`Hoffberg incorporates by reference at 9:43 – 58 U.S. Patent No. 5,250,951 to
`Valentine, which discloses a radar detector which distinguishes between police
`radar and other signals. See claim 1 “receiver section” citations.
`See Declaration of Dr. Chris Bartone (Ex. 1007) at ¶¶40-41.
`a position determining circuit generating a location signal;
`Hoffberg’s device includes a position determining circuit, i.e., a GPS receiver.
`“The location sensing system 2 comprises a known GPS receiver, which
`produces data that is analyzed by the processor 6. (Ex. 1002. at 64:45 – 47.)
`See Declaration of Dr. Chris Bartone (Ex. 1007) at ¶42.
`wherein the alert section receives the location signal and is adapted to one of
`alter and not provide the alert if the location signal correlates to a location of
`a rejectable 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 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.” (Ex 1002 at 18:64 – 19:4, emphasis added.)
`“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.” (Id. 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 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.” (Id. at 26:45 – 54.)
`“Therefore, it is noted that the present invention provides a means for mapping
`
`18 
`
`

`

`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.” (Id. 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 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. ” (Id. at 22:18 – 29, emphasis added.)
`See Declaration of Dr. Chris Bartone (Ex. 1007) at ¶43.
`2. The police warning receiver of claim 1, wherein said electromagnetic
`signals include radar signals in a radar band.
`“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.”
`(Ex. 1002 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.”
`(Id. 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.” (Id. at 33:10 – 15.)
`
`19 
`
`

`

`See Declaration of Dr. Chris Bartone (Ex. 1007) at ¶44.
`3. The police warning receiver of claim 1, wherein said electromagnetic
`signals are carried in the visible or infrared spectrum.
`“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 can be calculated. A LIDAR detector therefore
`seeks to detect the characteristic pulsatile infrared energy.” (Ex. 1002 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.”
`(Id. at 30:44 – 46.)
`See Declaration of Dr. Chris Bartone (Ex. 1007) at ¶45.
`4. The police warning receiver of claim 1, wherein the alert section further
`correlates said rejectable signal to said received electromagnetic signal, and
`alters the alert based upon the result of the correlation.
`“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.” (Ex. 1002 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.” (Id. at 29:8 – 11.)
`See also citations for claim 42.
`See Declaration of Dr. Chris Bartone (Ex. 1007) at ¶¶46, and 69-70.
`11. The police warning receiver of claim 1 further comprising storage for
`flags associated with geographic locations, said flags identifying rejectable
`signals at each geographic location.
`“The syste