IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`AMERICAN VEHICULAR SCIENCES LLC
`
`Plaintiff,
`
`v.
`
`TOYOTA MOTOR CORPORATION, et al.
`
`Defendants.
`
`§
`§
`§
`§
`§
`§
`§ CASE NOS.:
`§
`6:12-cv-00410-MHS-JDL (Consolidated)
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`6:12-CV-00404-MHS-JDL (Lead)
`
`JURYTRIAL
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`AMERICAN VEHICULAR SCIENCES LLC'S DISCLOSURE OF ASSERTED CLAIMS
`AND INFRINGEMENT CONTENTIONS AND IDENTIFICATION OF DOCUMENT
`PRODUCTION ACCOMPANYING DISCLOSURE
`
`American Vehicular Sciences LLC ("A VS" respectfully serve their Disclosure of Asserted
`
`Claims and Infringement Contentions against Toyota Motor Corporation, Toyota Motor Sales,
`
`U.S.A., Inc., Toyota Motor Engineering & Manufacturing North America, Inc., Toyota Motor
`
`Manufacturing, Kentucky, Inc., Toyota Motor Manufacturing, Indiana, Inc., and Gulf States
`
`Toyota,
`
`Inc.
`
`(collectively, "Toyota") and
`
`its
`
`Identification of Document Production
`
`Accompanying Disclosure.
`
`AVS presents these Infringement Contentions based on AVS' analysis of the facts
`
`currently known to it based on A VS' review of certain publicly available information. A VS
`
`reserves the right to amend or further supplement these disclosures with additional information
`
`learned in the course of discovery or further investigation.
`
`1
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`IPR2013-00419 - Ex. 1015
`Toyota Motor Corp., Petitioner
`
`1
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`

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`I.
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`INFRINGED CLAIMS - P.R. 3-1(a)
`
`A VS asserts that the Toyota defendants infringe directly, contributorily, and/or by
`
`inducement one or more of the flowing claims:
`
`Claims 1-4, 7-10, 30-34, 37-41, 43, 46, 48, 49, 56, 59, 60-62, and 64 of U.S. Patent
`
`No. 6,772,057 ("the '057 Patent");
`
`Claims 23, 24, and 26 of U.S. Patent No. 7,202,776 ("the '776 Patent");
`
`Claims 1, 2, 5, 6, 13, 15, 16, and 19 of U.S. Patent No. 7,359,782 ("the '782
`
`Patent");
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`Claims 1,3,4, 12, 13, and 15 of U.S. Patent No. 7,783,403 ("the '403 Patent"); and
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`Claims 1,2,5,9, 15, and 16 of U.S. Patent No. 8,041,483 ("the '483 Patent").
`
`A VS has identified these claims based on information currently known to it. Other
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`claims of the asserted patents include limitations based on certain discrete components of the
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`claimed apparatus or certain discrete steps of the claimed method that A VS has been unable to
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`definitively determine based on information currently known to AVS. AVS, however, believes
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`that discovery and further investigation may likely identify such additional claims that are
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`infringed by the Accused Instrumentalities or use thereof, and A VS accordingly reserves the
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`right to supplement its identification of claims and other disclosures in the course of discovery or
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`further investigation. For example, AVS cannot determine based on the current information it
`
`has about the Accused Instrumentalities whether the Defendants infringe the following additional
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`claims:
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`Claims 5, 6, 35, 36, 44, 45, and 47 ofthe '057 Patent;
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`Claim 25 ofthe '776 Patent;
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`Claims 7, 12, 14, and 18 ofthe '782 Patent;
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`Claims 6-9, 14, and 16 ofthe '403 Patent; and
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`2
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`2
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`

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`Claim 6 ofthe '483 Patent.
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`II.
`
`INDENTIFICATION OF ACCUSED INSTRUMENTALITIES AND CLAIM
`CHARTS - P.R 3-1(b)-(c)
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`Based on present information and belief, A VS contends that the Asserted Claims are
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`infringed by Toyota motor vehicles of various versions and model years, including motor
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`vehicles marketed under the Toyota, Lexus, or Scion brands ("Toyota Vehicles"), having the
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`functionality described in the provided claim charts that have been made, used, sold, offered for
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`sale, or imported by Toyota and/or that have otherwise been used as intended by Toyota
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`("Accused Instrumentalities").
`
`Attached as Exhibits A-E, and incorporated herein in their entirety, are charts identifying
`
`where each element of the Asserted Claims is met for various features or functionalities
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`possessed by a representative Toyota Vehicle or implicated by the use of Toyota Vehicles
`
`(Accused Instrumentalities).
`
`In certain instances, the claim charts identify the features and
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`functionality by a Feature or Option name that AVS has determined Toyota uses for the
`
`described features and functionalities. Other Features or Options with different names may be
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`used within or by Toyota to describe the same or similar features and functionalities. Similarly,
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`in certain instances, the claim charts identify certain models of Toyota Vehicles that AVS has
`
`determined possess the described features and functionalities. A VS has not, however,
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`determined every model and model version that possesses the described features and
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`functionalities, nor has A VS determined for each model and model version the model years in
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`which the model and model versions possessed the described features and functionalities. The
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`descriptions of the features and functionalities in the provided claim charts provide Toyota with
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`sufficient information to identify the Features and Options implicated by AVS' contentions as
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`3
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`3
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`

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`well as the Models and Model Versions and their associated Model Years implicated by AVS'
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`contentions.
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`AVS contends that any other Accused Instrumentality functions and/or operates in
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`substantially the same manner as shown in the representative chart, thereby infringing the
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`Asserted Claims. Unless otherwise indicated, the information provided that corresponds to each
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`claim element is considered to indicate that each claim element is found within each of the
`
`above-described models and/or versions of Toyota' Accused Instrumentalities.
`
`As described further in the provided claim chart, Exhibit A, AVS accuses various Toyota
`
`Vehicles and the use of these Vehicles, including but not limited to various model years of
`
`Lexus' IS, IS F, IS C, ES, GS, LS, RX, GX, LX, CTh, RXh, GSh, and LSh products and
`
`Toyota's Venza, Land Cruiser, Camry, Avalon, Sienna, and Prius products, that include
`
`monitoring and/or control systems for monitoring and responding to objects exterior to the
`
`vehicle, including but not limited to Pre-Collision (or Crash), Advanced Pre-Collision (or Crash)
`
`including its Active Pedestrian Detection System and/or Advanced Obstacle Detection
`
`capabilities, Blind Spot, Night View, Lane Departure (Keep) and Auto-Dimming Headlight
`
`systems/functionalities, of infringing at least claims 1-4, 7-10, 30-34, 37-41, 43, 46, 48, 49, 56,
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`59,60-62, and 64 of the '057 Patent.
`
`As described further in the provided claim chart, Exhibit B, AVS accuses various Toyota
`
`Vehicles and the use of these Vehicles, including but not limited to various model years of
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`Toyota's Avalon, Sequoia, and Sienna product, that include systems for obtaining information
`
`about objects in the environment outside of and around the vehicle, including but not limited to
`
`Dynamic Laser Cruise Control, of infringing at least claims 23, 24, and 26 of the '776 patent.
`
`4
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`4
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`

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`As described further in the provided claim chart, Exhibit C, A VS accuses various Toyota
`
`Vehicles and the use of these Vehicles, including but not limited to various model years of
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`Lexus' IS, IS F, IS C, ES, GS, LS, RX, GX, LX, CTh, RXh, GSh, and LSh products and
`
`Toyota's, Land Cruiser, Camry, Sienna, and Prius products, that include monitoring and/or
`
`control systems for monitoring and responding to objects exterior to the vehicle, including but
`
`not limited to Pre-Collision (or Crash), Advanced Pre-Collision (or Crash), including its Active
`
`Pedestrian Detection System and/or Advanced Obstacle Detection capabilities, and Blind Spot
`
`systems/functionalities, of infringing at least claims 1, 2, 5, 6, 13, 15, 16, and 19 of the '782
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`patent.
`
`As described further in the provided claim chart, Exhibit D, AVS accuses various Toyota
`
`Vehicles and the use of these Vehicles, including but not limited to various model years of
`
`Lexus' LS and LSh products, that include monitoring and/or control systems for monitoring and
`
`responding to objects exterior to the vehicle, including but not limited to its Advanced Pre(cid:173)
`
`Collision (or Crash) including its Active Pedestrian Detection System and/or Advanced Obstacle
`
`Detection capabilities, of infringing at least claims 1,3,4,12,13, and 15 ofthe '403 patent.
`
`As described further in the provided claim chart, Exhibit B, A VS accuses various Toyota
`
`Vehicles and the use of these Vehicles, including but not limited to various model years of
`
`Lexus' IS, IS F, IS C, ES, GS, LS, RX, GX, LX, CTh, RXh, GSh, and LSh products and
`
`Toyota's, Land Cruiser, Sienna, and Prius products, that include monitoring and/or control
`
`systems for monitoring and responding to objects exterior to the vehicle, including but not
`
`limited to Pre-Collision (or Crash) and Advanced Pre-Collision (or Crash), including its Active
`
`Pedestrian Detection System and/or Advanced Obstacle Detection capabilities, of infringing at
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`least claims 1,2,5, 9, 15, and 16 ofthe '483 patent.
`
`5
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`5
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`

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`III.
`
`IDENTIFICATION OF TYPE OF INFRINGEMENT ASSERTED - P.R 3-1(d)
`
`A VS contends that the each element of each asserted claim is literally present for the
`
`Accused Instrumentalities. In the alternative, with respect to any claim limitation that may be
`
`found not to be literally met for the Accused Instrumentalities, however, A VS contends that
`
`these elements are present under the doctrine of equivalents.
`
`IV.
`
`PRIORITY DATES OF ASSERTED CLAIMS -P.R. 3-1(e)
`
`U.S. Patent Application No. 10/302,105 filed on November 22,2002 resulted in the '057
`
`Patent. The 10/302,105 application claims priority to U.S. Patent Application No. 08/474,786
`
`filed on June 7, 1995, now U.S. Patent No. 5,845,000. Claims 1-4, 7-10, 30-34, 37-41, 43, 46,
`
`48,49,56,59,60-62, and 64 of the '057 Patent have an effective filing date of June 7, 1995.
`
`U.S. Patent Application No. 11/034,325 filed on January 12, 2005 resulted in the '776
`
`Patent. The 11/034,325 application claims priority to U.S. Patent Application No. 091177,041
`
`filed on October 22, 1998, now U.S. Patent No. 6,370,475. Claims 23, 24, and 26 of the '776
`
`Patent have an effective filing date of October 22, 1998.
`
`U.S. Patent Application No. 111183,598 filed on July 18, 2005 resulted in the '782 Patent.
`
`The 111183,598 application claims priority to U.S. Patent Application No. 09/024,085 filed on
`
`February 17, 1998, now U.S. Patent No. 6,209,909. Claims 1,2, 5, 6, 13, 15, 16, and 19 of the
`
`'782 Patent have an effective filing date of February 17, 1998.
`
`U.S. Patent Application No. 11/874,275 filed on October 18, 2007 resulted in the '403
`
`Patent. The 11/874,275 application claims priority to U.S. Patent Application No. 09/851,362
`
`filed on May 8,2001, now U.S. Patent No. 7,049,945. Claims 1, 3,4, 12, 13, and 15 of the '403
`
`Patent have an effective filing date of May 8, 2001.
`
`6
`
`6
`
`

`

`U.S. Patent Application No. 11/926,192 filed on October 29, 2007 resulted in the '483
`
`Patent. The 111926,192 application claims priority to U.S. Patent Application No. 111111,474
`
`filed on April 21, 2005, now U.S. Patent No. 7,209,221. Claims 1,2,5,9, 15, and 16 of the '483
`
`Patent have an effective filing date of April 21, 2005.
`
`V.
`
`PLAINTIFF'S PRODUCTS - P.R. 3-1(f)
`
`A VS is not presently relying on any assertion that its own apparatus, product, device,
`
`process, method, act, or other instrumentality practices the claimed inventions.
`
`VI. DOCUMENT PRODUCTION ACCOMPANYING DISCLOSURE
`
`A.
`
`Documents Responsive to P.R. 3-2(a)
`
`AVS is presently unaware of any relevant, non-privileged documents responsive to P.R.
`
`3-2(a). AVS will supplement this response should any relevant, non-privileged documents be
`
`identified in the future.
`
`B.
`
`Documents Responsive to P.R. 3-2(b)
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`A VS is presently unaware of any relevant, non-privileged documents responsive to P.R.
`
`3-2(b). A VS will supplement this response should any relevant, non-privileged documents be
`
`identified in the future.
`
`C.
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`Documents Responsive to P.R. 3-2(c)
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`Pursuant to P.R. 3-2(c), copies ofthe file histories of the AVS patents for the Consolidate
`
`Cases have been produced previously in conjunction with case 6: 12-cv-00407 under Bates
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`Numbers AVSFHOOOOOOOI AVSFH00058395.
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`VII. CONCLUSION
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`The information contained in these disclosures is based on A VS' analysis of the facts
`
`currently known to it based on A VS' review of publicly information reasonably available to it.
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`7
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`7
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`

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`Pertinent information about Defendants' Accused Instrumentalities is not available without
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`engaging in further discovery. Thus, A VS reserves the right to supplement, modify, and/or
`
`amend these disclosures as new information becomes available and discovery progresses. A VS
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`anticipates that additional facts and relevant documents will be uncovered that will warrant
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`supplementing and/or amending these disclosures.
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`8
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`8
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`

`

`DATED: February 1, 2013
`
`/Deryretrios Anaipakos//
`L~"%"~:r'exas Bar No. 0079{25§/
`danaipakos@azalaw.com
`Amir Alavi
`Texas Bar No. 00793239
`aalavi@azalaw.com
`Steven J. Mitby
`Texas Bar No. 24037123
`smitby@azalaw.com
`Brian E. Simmons
`Texas Bar No. 24004922
`bsimmons@azalaw.com
`AHMAD, ZA VITSANOS, ANAIPAKOS, ALAVI &
`MENSING, P.C.
`1221 McKinney Street, Suite 3460
`Houston, TX 77010
`Telephone: 713-655-1101
`Facsimile: 713-655-0062
`
`T. John Ward, Jr.
`Texas Bar No. 00794818
`jw@wsfirm.com
`Wesley Hill
`Texas Bar No. 24032294
`wh@wsfirm.com
`WARD & SMITH LAW FIRM
`111 W. Tyler Street
`Longview, TX 75601
`Telephone: (903) 757-6400
`Facsimile: (903) 757-2323
`
`ATTORNEYS FOR PLAINTIFF
`
`9
`
`9
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`

`

`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the above and foregoing document
`has been served on all counsel of record as indicated below on the 1st daX,JJf~February, 2013.
`(
`" ;;\
`
`, .. ,,_ .. J
`
`'"c,
`
`ByU.S. Mail
`
`ByU.S. Mail
`
`Tom Henson
`Ramey & Flock, P.C.
`100 East Ferguson, Suite 500
`Tyler, TX 75702
`Telephone: (903) 597-3301
`Facsimile: (903) 597-2413
`
`George E. Badenoch
`John Flock
`Thomas R. Makin
`A. Antony Pfeffer
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004-1007
`Telephone: (212) 425-7200
`Facsimile: (212) 425-5288
`
`10
`
`10
`
`

`

`1
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`
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`information learned in the course of discovery or further investigation.
`the elements of the asserted claims, AVS reserves the right to amend or further supplement these contentions with additional
`later shows that operation of the systems, features, and functionality as provided by Gentex and Denso differ, at least with respect to
`with respect to the systems, features, and functionality as provided by either or both of Gentex and Denso. To the extent discovery
`manner. Thus, while Gentex has recently been dismissed as a defendant in the Consolidated Cases, this chart may rely on information
`are, at least with respect to the elements of the asserted claims, parallel systems that operate identically or substantially in the same
`Vehicles can be sourced from different vendors, including Gentex and Denso. On information and belief, AVS understands that these
`and Automatic High Beam Dimming. Additionally, it is AVS understanding that this functionality as provided on various Toyota
`detection of approaching or approached vehicles is referred to by various other names, including Smart Beam, Automatic High Beam,
`1 AVS understands that the Auto-Dimming Headlight system, which dims or otherwise affects the headlights in response to the
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`Collision (or Crash) System has a “couple of big extras,” including Driver Attention Monitor and Active Pedestrian Detection System,
`certain actions to mitigate the likelihood of collision. As also described in the source material of Endnote 1, the Advanced Pre-
`features and functionality relate to detecting additional vehicles in a vehicle’s path, determining the chance of collision, and taking
`have certain features and functionality in common. (See Endnote 1). As described in the source material of Endnote 1, the common
`On information and belief, AVS understands that the Pre-Collision (or Crash) System and Advanced Pre-Collision (or Crash) System
`
`further supplement these contentions with additional information learned in the course of discovery or further investigation.
`respect to the elements of the asserted claims, for Lexus branded and Toyota branded vehicles, AVS reserves the right to amend or
`branded and Toyota branded vehicles. To the extent discovery later shows that operation of the Features/Options differs, at least with
`Accordingly, this chart may rely on information obtained with respect to the use of the Features/Options in either or both of Lexus
`Features/Options operate identically or substantially in the same manner, at least with respect to the elements of the asserted claims.
`understands that to the extent these Features/Options are available on Lexus branded, Toyota branded, and other branded products, the
`a stand-alone feature/option on Toyota Vehicles or as part of other options or packages. On information and belief, AVS further
`systems/functionalities. On present information and belief, AVS understands that these Features/Options is/has been offered either as
`(Keep); and Auto-Dimming Headlight1
`Obstacle Detection; Blind Spot detection; Night View; Lane Departure
`Pre-Collision (or Crash) System, including related functionality referred to as Active Pedestrian Detection System and/or Advanced
`Depending on the claim, the Features/Options primarily relied upon in this chart are the Pre-Collision (or Crash) System; Advanced
`
`Infringement Chart for U.S. Patent No. 6,772,057
`
`Pursuant to P. R. 3-1(c)
`
`Exhibit A
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`11
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`

`2
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`
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`for satisfying a claim or claim element, these unique features are separately addressed.
`elements where they are relevant. When the unique features of the Advanced Pre-Collision (or Crash) system provide a separate basis
`Pre-Collision (or Crash) System and Advanced Pre-Collision (or Crash) System are addressed jointly for those claims and claim
`which in some materials is also referred to as Advanced Obstacle Detection. According, in the chart below, the common features of
`
`Infringement Chart for U.S. Patent No. 6,772,057
`
`
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`
`
`12
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`

`

`3
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`collisions.
`position, distance, and speed of any obstacle in front of the vehicle as part of a system intended to prevent
`illustrated material depicts and describes the use of front millimeter wave radar and a camera to detect the
`on any objects in the environment and generate a signal characteristic of the received waves. The
`receiver arranged to receive waves from the environment exterior of the vehicle which contain information
`Based on information and belief, AVS contends that the Accused Instrumentalities comprise at least one
`Common Features
`Pre-Collision (Or Crash) and Advanced Pre-Collision (OR Crash)
`Dimming Headlight systems/functionalities.
`Advanced Obstacle Detection capabilities, Blind Spot, Night View, Lane Departure (Keep) and Auto
`Crash), Advanced Pre-Collision (or Crash) including its Active Pedestrian Detection System and/or
`monitoring and responding to objects exterior to the vehicle, including but not limited to Pre-Collision (or
`Vehicles (“Accused Instrumentalities”) comprise one or more monitoring and/or control systems for
`Based on information and belief, AVS contends that various Toyota Vehicles and methods related to these
`
`
`
`
`
`
`
`
`
`systems/functionalities, infringe this claim and claims depending therefrom.
`capabilities, Blind Spot, Night View, Lane Departure (Keep) and Auto-Dimming Headlight
`Collision (or Crash) including its Active Pedestrian Detection System and/or Advanced Obstacle Detection
`to objects exterior to the vehicle, including but not limited to Pre-Collision (or Crash), Advanced Pre-
`Sienna, and Prius products, that include monitoring and/or control systems for monitoring and responding
`RX, GX, LX, CTh, RXh, GSh, and LSh products and Toyota’s Venza, Land Cruiser, Camry, Avalon,
`to these Vehicles, including but not limited to various model years of Lexus’ IS, IS F, IS C, ES, GS, LS,
`Based on present information and belief, AVS contends that various Toyota Vehicles and methods related
`
`
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`elements, for monitoring an environment exterior to the vehicle.
`Each of the Accused Instrumentalities comprises a monitoring system, as will be described in the following
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`Accused Toyota Instrumentality
`
`Infringement Chart for U.S. Patent No. 6,772,057
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`Claim Claim
`
`
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`waves; and
`of the received
`characteristic
`signal
`and generate a
`environment
`the
`any objects in
`information on
`contain
`vehicle which
`exterior of the
`environment
`from the
`receive waves
`arranged to
`receiver
`at least one
`
`comprising:
`vehicle,
`exterior of a
`environment
`an
`for monitoring
`arrangement
`monitoring
`1. A
`Element
`
`
`
`
`
`1a
`
`1-pre
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`13
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`

`4
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`
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`convert the received waves into a form that can be used by the computer.
`other characteristics of the object. A processor, possibly part of the collision determining computer, must
`determining computer that determines the possibility of a collision based on the position, speed, path, and
`information about the detected objects. The illustrated material depicts and describes a collision-
`It is inherent that the system will have a processor that will convert the received waves that will have
`
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`Infringement Chart for U.S. Patent No. 6,772,057
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`14
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`
`
`Q.Pr • .c. __ .emo
`8. Pr • .Qeoh~_
`1. __ U._'_
`6. ....,.....V_~1OOhlOIOrI
`5. &""" oot..-t", twt.O
`•. _GM-Rallo SleM"IQOOIl.Qlo-
`
`2. on... mom""", caonerlI
`3. __ ._,_
`I.SI/Ir""""",,,a
`
`5
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`
`
`
`
`Safety System
`Configuration of the Pre-Crash
`
`detQ'TT1he jf a crash is immnent. If it is, the
`slOO'hg angle. and ya'll-rate nputs to
`computer. '1klidl monitors vehicle speed,
`
`in c:orrbination with the PJe-Crash Safety
`bad weather with poor visibitityl, worKing
`any obstacle n front of the car (even in
`detect the position, dist8l'J09 and speed of
`The camera end the millinetre-'NaVe radar
`
`suspension controrJ and pre-cmsh seat-belt.
`pre-crash brake, pre-crash brake assist,
`consists of a cameram, millimetre-wave rad8l,
`Toyota's Pre-Crash Safety system (PCS)
`
`sensor with excellent object-recognition capability
`Pre-Crash Safety system working in combination with a
`
`TECHNOLOGY
`
`mitigates damage to the driver and passengers.
`determines In advance whether a collision is unavoidable and
`prompting action for avoid the collision. Moreover, the system
`collision of which the driver is unaware and alerts the driver, thereby
`Toyota's Pre-Crash Safety system recognizes the possibility of a
`
`Infringement Chart for U.S. Patent No. 6,772,057
`
`15
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`

`6
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`
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`detection.
`wave radar is augmented by stereo cameras and infrared technology that enhances nighttime object
`For APCS’s Active Pedestrian Detection System (Advanced Obstacle Detection), the front millimeter
`distance, and speed of any obstacle in front of the vehicle as part of a system intended to prevent collisions.
`illustrated material depicts and describes the use of front millimeter wave radar to detect the position,
`on any objects in the environment and generate a signal characteristic of the received waves. The
`receiver arranged to receive waves from the environment exterior of the vehicle which contain information
`Based on information and belief, AVS contends that the Accused Instrumentalities comprise at least one
`Advanced Pre-Collision (OR Crash) - Unique Features
`
`
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`
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`a processor must convert the received waves into a form that can be used by the APCS system.
`vehicle and determine their distance from the vehicle, as depicted and described in the illustrated materials,
`can be used by the vehicles electrical systems. In order to detect the presence of a pedestrian in front of a
`It is inherent that the system will have a processor that will convert the received waves into a signal that
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`Infringement Chart for U.S. Patent No. 6,772,057
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`16
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`7
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`Infringement Chart for U.S. Patent No. 6,772,057
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`17
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`8
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`Infringement Chart for U.S. Patent No. 6,772,057
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`18
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`would not only transmit waves but would receive the reflected waves.
`illustrated material depicts and describes radar devices mounted in the rear bumper of the vehicle that
`on any objects in the environment and generate a signal characteristic of the received waves. The
`receiver arranged to receive waves from the environment exterior of the vehicle which contain information
`Based on information and belief, AVS contends that the Accused Instrumentalities comprise at least one
`Blind Spot
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`convert the received waves into a form that can be used by the system.
`spot as opposed to an empty road, as depicted and described in the illustrated materials, a processor must
`that can be used by the vehicles electrical systems. In order to detect the presence of a vehicle in a blind
`It is inherent that the system will have a processor that will convert the reflected radar waves into a signal
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`Based on information and belief, AVS contends that the Accused Instrumentalities comprise at least one
`Night View
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`this function, a processor must convert the received waves into a form that can be used by the system.
`the system discriminating pedestrians from trees and other objects within the image. In order to perform
`a signal that can be used by the vehicles electrical systems. The illustrated materials describe and depict
`It is inherent that the system will have a processor that will convert the images received by the camera into
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`illustrated material depicts and describes a camera that would receive waves.
`on any objects in the environment and generate a signal characteristic of the received waves. The
`receiver arranged to receive waves from the environment exterior of the vehicle which contain information
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`received waves into a form that can be used by the system.
`structure (white lines/ yellow lines). In order to perform this function, a processor must convert the
`the system using a camera and recognizing lines on certain types of roads, even recognizing the road
`a signal that can be used by the vehicles electrical systems. The illustrated materials describe and depict
`It is inherent that the system will have a processor that will convert the images received by the camera into
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`illustrated material depicts and describes a camera that would receive waves.
`on any objects in the environment and generate a signal characteristic of the received waves. The
`receiver arranged to receive waves from the environment exterior of the vehicle which contain information
`Based on information and belief, AVS contends that the Accused Instrumentalities comprise at least one
`Lane Departure (Keep)
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`Auto Dimming Headlight
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`The Gentex materials similarly describe and depict that the mirror has circuit boards and micro-controllers.
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`part of Night View System having a sensing ECU.
`signal characteristic of the received waves. For the Denso system, the Automatic High Beam system is a
`Integrated Circuit and CPU, which can be expected to process the received waves and create an electronic
`The illustrated materials describe and depict that the Denso camera module has an Application Specific
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`captures images based on light received through it, implying, it received electromagnetic radiations.
`can be a miniature camera on a chip. The camera captures images of its surroundings. The camera
`illustrated materials depict and describe imaging sensors situated on the rear-view mirror. These sensors
`on any objects in the environment and generate a signal characteristic of the received waves. The
`receiver arranged to receive waves from the environment exterior of the vehicle which contain information
`Based on information and belief, AVS contends that the Accused Instrumentalities comprise at least one
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`river-safety
`hllp:/Iwww.genlex.com/aulomotive/products/d
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`hltp://www.genlex.com/aulomotive/mirror-as-module
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`cost and space, while reducini part counts and overall vehicle complexity.
`components (sensors, circuit boards, micro'controllers, etc.) can be shared with other advanced features to save
`Automatic-dimming mirrors use a combination of sensors and complex electronics to dim. Many of these
`2. Common Electronics
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`assist#30
`e/producls/forward-driving(cid:173)
`http://www . gentex. c omiaulomotiv
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`control electronics as part of the mirror.
`optimized in the Gentex SmartBeam system with the camera and the
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`hardware currently being appUed to new vehicle appUcations. Space is
`and control "constant ON" high beam systems for advanced headlamp
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`SmartBeam products will produce continuously variable low-beam patterns
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`usage according to surrounding traffic conditions. Next-generation
`automatically operate a vehicle's high beams in order to optimize their
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`auto-dimming mirror combined with algorithmic decision-making to
`SmartBeam uses a miniature camera-on-a-chip integrated into a Gentex
`Lighting Assist· SmartBeam®
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`http://www.gentex.com/automotiveiproduct-cateqories
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`" ... -"
`• c
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`.0
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`iii
`"'E
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`__ 7-"_-ICamera [reception
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`means]
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`Assist
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`Blind Zone
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`Rear
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`Assist
`Driving
`Forward
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`Exterior of the Vehicle
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`indicates a presence of pattern recognition technique.
`information derived from the waves reflected from obstacles; and the object-recognition capability
`computer indicates the presence of a processor, which determines the possibility of a collision based on the
`objects and patterns of received waves from the possible exterior objects. The collision determining
`recognition system with a trained pattern recognition algorithm obtained from data of possible exterior
`capabilities, the collision determining computer or other aspects of the system would use a trained pattern
`other objects that are in the vehicle’s path. On information and belief, AVS contends that to have these
`weather with poor visibility. Thus the system identifies objects and discriminates certain objects from
`the obstacle determine whether a collision is unavoidable. The system is able to do this even in bad
`vehicle or another obstacle ahead and that based on the position, speed, path, and other characteristics of
`The illustrated materials describe and depict that the collision determining computer can detect either a
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`provide the classification, identification or location of the exterior object.
`from data of possible exterior objects and patterns of received waves from the possible exterior objects to
`recognition means being structured and arranged to apply a trained pattern recognition algorithm generated
`signal to provide a classification, identification or location of the exterior object, said trained pattern
`coupled to said at least one receiver and comprising trained pattern recognition means for processing the
`Based on information and belief, AVS contends that the Accused Instrumentalities comprise a processor
`Common Features
`Pre-Collision (Or Crash) and Advanced Pre-Collision (OR Crash)
`Dimming Headlight systems/functionalities.
`Advanced Obstacle Detection capabilities, Blind Spot, Night View, Lane Departure (Keep) and Auto
`Crash), Advanced Pre-Collision (or Crash) including its Active Pedestrian Detection System and/or
`monitoring and responding to objects exterior to the vehicle, including but not limited to Pre-Collision (or
`Vehicles (“Accused Instrumentalities”) comprise one or more monitoring and/or control systems for
`Based on information and belief, AVS contends that various Toyota Vehicl