UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`RAYMARINE, INC.
`
`Petitioner
`
`v.
`
`NAVICO HOLDING AS
`
`Patent Owner
`
`____________
`
`Case IPR2013-00496
`
`Patent 8,305,840
`
`____________
`
`NAV-2001
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`1 of 43
`
`
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`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`RAYMARINE, INC.
`
`Petitioner
`
`v.
`
`NAVICO HOLDING AS
`
`Patent Owner
`
`____________
`
`Case IPR2013-00496
`
`Patent 8,305,840
`
`____________
`
`NAV-2001
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`1 of 43
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`
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`DECLARATION BY ALAN PROCTOR TO ESTABLISH CONCEPTION
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`AND REDUCTION TO PRACTICE PRIOR TO AUGUST 28, 2008
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`I, Alan Proctor, hereby declare and state that:
`
`1.
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`I am an employee of Navico, Inc., which is an affiliate of Navico
`
`Holding AS. Navico Holding AS is the owner of U.S. Patent No. 8,305,840 (“the
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`‘840 patent”) and Navico, Inc. has a license to the ‘840 patent. I understand that
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`this declaration is to be submitted in an Inter Partes Review proceeding on behalf
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`of Navico Holding AS.
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`2.
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`The ‘840 patent relates to a sonar assembly for imaging an underwater
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`environment beneath a watercraft traveling on the surface of a body of water. At
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`the time of the events and evidence presented herein it is my understanding that
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`Brian T. Maguire (hereinafter, “Mr. Maguire”), who is the inventor of the claimed
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`subject matter of the ‘840 patent, was under an obligation to assign the underlying
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`invention to Navico, Inc. Mr. Maguire assigned his rights in the invention to
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`Navico, Inc. on August 20, 2009, as recorded in the Patent Office at Reel 023181,
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`Frame 0828. Navico, Inc. remained the assignee of record for the ‘840 patent until
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`June 24, 2013, when Navico, Inc. assigned the ‘840 patent to Navico Holding AS,
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`as recorded in the Patent Office at Reel 030706, Frame 0152.
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`3.
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`I worked with and supervised Mr. Maguire at the time of the events
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`and evidence presented herein. In addition to having reviewed all of the evidence
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`presented herein and discussed the invention with Mr. Maguire many times during
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`our work together, I also took part in some of the events described herein.
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`4.
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`I have over 12 years of experience as an Engineer working in the field
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`of sonar technology, and have been employed continuously by Navico in the sonar
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`technology field since 2008. I was the Project Manager for the Imaging Sonar
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`Project that became Navico’s downscan sonar. I am currently the Manager of
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`R&D Technology, which includes having lead responsibility for Navico’s Sonar
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`Technology Program. I received a Masters of Science in Electrical Engineering
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`and a Bachelor of Science in Electrical Engineering from Kansas State University.
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`5.
`
`U.S. Patent No. 7,961,552 to Boucher et al. (“Boucher ‘552”) issued
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`on June 14, 2011, from U.S. Patent Application No. 12/231,054 (“the ‘054
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`application”) filed on August 28, 2008. Petitioner in the Inter Partes Review
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`proceeding of the ‘840 patent relies on Boucher ‘552 for purposes of an argument
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`under 35 U.S.C. § 103(a). In particular, the Petitioner alleges that Claims 1-2, 23,
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`30, and 73 of the ‘840 patent are obvious under 35 U.S.C. § 103(a) over Jong, C.D.
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`et al., Hyrdography, (1st ed. 2002) (“Hydrography”), an introductory-level textbook
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`published in 2002 (See, RAY-1003), in view of Boucher ‘552.
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`6.
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`Independent Claim 1 of the ‘840 patent recites:
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`1. A sonar assembly for imaging an underwater environment beneath
`
`a watercraft traveling on a surface of a body of water, the sonar
`
`assembly comprising:
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`a housing mountable to the watercraft;
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`a single linear downscan transducer element positioned within
`
`the housing, the linear downscan transducer element having a
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`substantially rectangular shape configured to produce a fan-shaped
`
`sonar beam having a relatively narrow beamwidth in a direction
`
`parallel to a longitudinal length of the linear downscan transducer
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`element and a relatively wide beamwidth in a direction perpendicular
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`to the longitudinal length of the transducer element, the linear
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`downscan transducer element being positioned with the longitudinal
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`length thereof extending in a fore-to-aft direction of the housing;
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`wherein the linear downscan transducer element is positioned
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`within the housing to project fan-shaped sonar beams in a direction
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`substantially perpendicular to a plane corresponding to the surface of
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`the body of water, said sonar beams being repeatedly emitted so as to
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`sequentially insonify different fan-shaped regions of the underwater
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`environment as the watercraft travels; and
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`a sonar signal processor receiving signals representative of
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`sonar returns resulting from each of the fan-shaped sonar beams and
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`processing the signals to produce sonar image data for each fan-
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`shaped region and to create an image of the underwater environment
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`as a composite of images of the fan-shaped regions arranged in a
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`progressive order corresponding to the travel of the watercraft.
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`7.
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`Dependent Claim 2 of the ‘840 patent recites:
`
`2.
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`The sonar assembly of claim 1, wherein the linear downscan
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`transducer element is configured to operate at a selected one of at least
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`two selectable operating frequencies.
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`8.
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`Independent Claim 23 of the ‘840 patent recites:
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`23. A sonar system for imaging an underwater environment
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`beneath a watercraft traveling on a surface of a body of water, the
`
`sonar system comprising:
`
`a single linear downscan transducer element positioned within a
`
`housing that is mountable to the watercraft, the linear downscan
`
`transducer element having a substantially rectangular shape
`
`configured to produce a fan-shaped sonar beam having a relatively
`
`narrow beamwidth in a direction parallel to longitudinal length of the
`
`linear downscan transducer element and a relatively wide beamwidth
`
`in a direction perpendicular to the longitudinal length of the
`
`transducer element, the linear downscan transducer element being
`
`positioned with the longitudinal length thereof extending in a fore-to-
`
`aft direction of the housing;
`
`wherein the linear downscan transducer element is positioned to
`
`project fan-shaped sonar beams in a direction substantially
`
`perpendicular to a plane corresponding to the surface of the body of
`
`water, said sonar beams being repeatedly emitted so as to sequentially
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`insonify different fan-shaped regions of the underwater environment
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`as the watercraft travels;
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`a sonar module configured to enable operable communication
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`with the linear downscan transducer element, the sonar module
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`including:
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`and
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`a sonar signal processor to process sonar return signals,
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`at least one transceiver configured to provide
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`communication between the linear downscan transducer
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`element and the sonar signal processor,
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`the sonar signal processor receiving signals
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`representative of sonar returns resulting from each of the fan-
`
`shaped sonar beams and processing the signals to produce sonar
`
`image data for each fan-shaped region and to create an image of
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`the underwater environment as a composite of images of the
`
`fan-shaped regions arranged in a progressive order
`
`corresponding to the travel of the watercraft.
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`9.
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`Dependent Claim 30 of the ‘840 patent recites:
`
`30.
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`The sonar system of claim 23, wherein the linear downscan
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`transducer element is configured to operate at a selected one of at least
`
`two selectable operating frequencies.
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`10.
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`Independent Claim 73 of the ‘840 patent recites:
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`73. A sonar imaging apparatus comprising:
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`a housing mountable to a watercraft that traverses a surface of a
`
`body of water, the watercraft defining a center plane that extends from
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`fore to aft and that is perpendicular to the surface of the body of
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`water;
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`a linear transducer element positioned within the housing, the
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`linear transducer element being configured to produce a fan-shaped
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`sonar beam having a longitudinal beamwidth in a direction parallel to
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`a longitudinal length of the linear transducer element that is
`
`significantly less than a transverse beamwidth of the sonar beam in a
`
`direction perpendicular to the longitudinal length of the transducer
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`element;
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`wherein the housing is configured for mounting to the
`
`watercraft such that the longitudinal length of the linear transducer
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`element is parallel to said center plane, and
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`wherein the transverse beamwidth of the sonar beam is
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`sufficiently wide in relation to a direction in which the linear
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`transducer element is aimed such that the transverse beamwidth spans
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`from a port side of said center plane to a starboard side of said center
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`plane, said fan-shaped sonar beam being repeatedly emitted so as to
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`sequentially insonify different fan-shaped regions of an underwater
`
`environment beneath the watercraft as the watercraft travels across the
`
`surface of the water; and
`
`a sonar signal processor receiving signals representative of
`
`sonar returns resulting from each of the fan-shaped sonar beams and
`
`processing the signals to produce sonar image data for each fan-
`
`shaped region and to create an image of the underwater environment
`
`as a composite of images of the fan-shaped regions arranged in a
`
`progressive order corresponding to the travel of the watercraft.
`
`11.
`
`Prior to August 28, 2008, the effective filing date of Boucher ‘552,
`
`Mr. Maguire had reduced to practice, tested, and successfully operated the claimed
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`invention of, at least, Claims 1, 2, 23, 30, and 73 of the ‘840 patent in the United
`
`States.
`
`12.
`
`In support of the foregoing statement of Paragraph 11, attached as
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`Exhibit A is a partially redacted email from Mr. Maguire to me and other Navico
`
`engineers. (Only names and dates have been redacted.) At that time, Mr. Maguire,
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`these other engineers, and I were working in sonar technology and employed by
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`Navico, Inc. I have reviewed the non-redacted version of Exhibit A, and declare
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`that the email is dated and was sent prior to August 28, 2008.
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`(a) Mr. Maguire states “Here are some images we have from a side-scan
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`prototype gone wrong. The elements were potted facing almost strait [sic] down.”
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`The “elements” Mr. Maguire tested were “side-scan” sonar elements, referring to
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`long and narrow rectangular transducer elements. The transducer elements were
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`maintained (“potted”) in their housing facing down, rather than to the side.
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`(b) Mr. Maguire states “you do get great images of what is in the water
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`column and a good idea of the bottom structure directly below the boat.” The
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`“water column” refers to the water between the transducer element and the lake
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`bottom. The “bottom structure” refers to, for example, submerged trees and rocks
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`on the lake bottom.
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`(c) Mr. Maguire includes two actual images produced by the transducer
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`element connected to a sonar module during the testing. The images show trees
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`and lake bottom structure directly below the boat as it traveled across the surface.
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`(d) The sonar module included a sonar signal processor to process the sonar
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`return signals and a transceiver to provide communication between the linear
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`downscan transducer and the sonar signal processor. The sonar signal processor
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`included a display to create an image of the underwater environment as shown in
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`the two images in Mr. Maguire’s e-mail.
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`(e) Mr. Maguire states “I think this could be a nice complement to side-scan
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`or may make a good standalone product.” The “complement to side-scan” refers to
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`the ability of the downscan transducer elements to generate images below the boat
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`in the gap between the port and starboard side-scan transducer images.
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`13.
`
`In further support of the statement of Paragraph 11, attached as
`
`Exhibit B is a partially redacted first excerpt from a Lab notebook by Mr.
`
`Maguire. This first excerpt is entitled “Lake Testing” and details “Lab #10 down-
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`scan.” I have reviewed the non-redacted version of Exhibit B, and declare that it is
`
`dated prior to August 28, 2008, and accurately reflects testing performed prior to
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`August 28, 2008.
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`(a) Mr. Maguire states “Tested Lab #10 as down-scan (pointed down),” and
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`confirms the presence of me and three other Navico engineers. “Lab#10” refers to
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`one of many Navico prototype sonar transducers for downscan imaging.
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`(b) Mr. Maguire states “Lab #10 contains one xdcr.” The reference to
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`“xdcr” is common short-hand for “transducer,” and the reference to “one xdcr”
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`refers to a single rectangular, i.e., linear, transducer element.
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`(c) Mr. Maguire states “Images looked very good even at 800 KHz.,”
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`Navico tested its rectangular downscan transducers at this frequency.
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`(d) Mr. Maguire includes an image of the Lab #10 housing mounted to a
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`boat. The housing was mounted to the stern of the boat, extending in a fore-to-aft
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`position parallel to the surface of the water. This housing and mounting confirm
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`the testing of Lab #10 “as down-scan (pointed down),” and illustrate positioning
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`the rectangular transducer to project its fan-shaped beam down, perpendicular to
`
`the surface of the water.
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`14.
`
`In further support of the statement of Paragraph 11, attached as
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`Exhibit C is a partially redacted second excerpt from a Lab notebook by Mr.
`
`Maguire. This second excerpt is entitled “Lake Testing” and details “Lab #9, 10,
`
`11, 13.” I have reviewed the non-redacted version of Exhibit C, and declare that it
`
`is dated and accurately reflects testing performed prior to August 28, 2008.
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`(a) The second excerpt refers to “Testing side and down scan at dive park,”
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`and states “Down-scan did well at 800KHz, but could not image the bus or plane
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`very well at 455KHz. The down scan lab#10 looked good in deep water (110 ft).”
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`This refers to testing the rectangular downscan transducer element Lab #10
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`attached to a boat on the water, and generating good images of a submerged bus
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`and airplane at 800 kHz, but not at 455 kHz.
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`(b) The reference to generating images at 800 kHz and 455 kHz refers to
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`operating the downscan transducer element at one of at least two frequencies.
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`(c) Another excerpt states “Lab#13 used one side and one down,” and
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`concludes “Should be OK to put down and sides in same housing and fire at same
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`time.” This refers to placing multiple parallel rectangular transducer elements in
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`the same housing with the “down” transducer pointed down below the watercraft
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`and the “side” transducers pointed to the side of the watercraft (port and starboard).
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`(d) Additional linear downscan transducer elements were tested (e.g., Lab
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`#14, #15, #16, etc.) prior to August 28, 2008, including transducer elements
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`approximately 120 mm long by 3 mm wide.
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`15.
`
`In further support of the statement of Paragraph 11, attached as
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`Exhibit D is a copy of pages from a partially redacted Lab notebook kept by Mr.
`
`Maguire. I recognize the handwriting as that of Mr. Maguire and recognize his
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`signature on the page. One excerpt states “Lake testing on [date A] and [date B]
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`indicated that there may be a use to making a down scan xdcr to give greater
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`definition of the water column and ground below the boat.” I have reviewed the
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`non-redacted version of Exhibit D, and declare that the section detailed on page 17,
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`and date A and date B referred to in the above quotation, are dated and accurately
`
`reflect testing performed prior to August 28, 2008.
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`(a) The notebook section includes the drawing below:
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`1. The drawing shows a linear housing mounted to the stern of a
`
`watercraft with a single line therein denoting a rectangular transducer
`
`element.
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`2. The drawing includes two handwritten notes with arrows pointed at
`
`the transducer. The notes state: “xdcr with rectangle element array”
`
`and “rectangular elements pointed strait [sic] down.”
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`3. The drawing shows a down-facing fan-shaped beam emitted by the
`
`rectangular element and includes a note stating “rectangular element
`
`gives desired beam angle of ~1° x 50°.”
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`4. The drawing shows the orientation of the transducer housing,
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`transducer element therein, and fan-shaped beam with respect to the
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`watercraft, the surface of the water, and the direction of travel of the
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`watercraft, as represented by the arrow pointing from the stern to the
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`bow of the watercraft.
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`(b) Mr. Maguire includes another drawing and states “result: gives great
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`definition of bottom directly below the boat and excellent target definition of
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`targets in the water column. Trees look like trees and rocks look like rocks.
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`Basically side-scan with no shadows. Screen will look like this with trees.”
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`The fan-shaped sonar beams are emitted as the boat travels. The sonar returns are
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`received and processed for each fan-shaped region to create an image of the
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`underwater environment as a composite of images arranged in a progressive order
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`(moving right to left) corresponding to the travel of the watercraft, as shown in the
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`drawing of Exhibit D and images of Exhibit A.
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`16. As further support for the statement of Paragraph 11, the following is a table
`
`that lists each claimed element of Claims 1, 2, 23, 30, and 73 and matches that
`
`element with at least one corresponding Exhibit that provides evidence of
`
`conception and reduction to practice of the claim element by Mr. Maguire prior to
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`August 28, 2008.
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`Independent Claim 1
`
`Exhibit(s)
`
`A sonar assembly for imaging
`
`Exhibit A: The actual images shown in Exhibit A
`
`an underwater environment
`
`were created by a sonar assembly for imaging an
`
`beneath a watercraft traveling
`
`underwater environment beneath a watercraft
`
`on a surface of a body of water,
`
`traveling on a surface of a body of water, as
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`the sonar assembly comprising:
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`shown by the following elements.
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`Exhibit D: The drawings in the lab notebook
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`show a sonar transducer housing mounted on a
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`watercraft and examples of images created by a
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`sonar assembly.
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`a housing mountable to the
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`Exhibit B: The image shows a housing
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`watercraft;
`
`mountable to a watercraft.
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`Exhibit D: The drawings show a housing
`
`mountable to a watercraft.
`
`a single linear downscan
`
`Exhibit B: The image shows a long and narrow
`
`transducer element positioned
`
`housing for the transducer element.
`
`within the housing,
`
`Exhibit D: The drawing shows a single linear
`
`downscan transducer element positioned within
`
`the housing, with captions pointing to a
`
`“rectangular element pointed strait [sic] down,”
`
`and “xdcr with rectangle element array.”
`
`the linear downscan transducer
`
`Exhibit D: The drawing shows a linear downscan
`
`element having a substantially
`
`transducer element having a substantially
`
`rectangular shape configured to
`
`rectangular shape configured to produce a fan-
`
`produce a fan-shaped sonar
`
`shaped sonar beam having a relatively narrow
`
`beam having a relatively
`
`beamwidth (e.g., 1°) in a direction parallel to a
`
`narrow beamwidth in a
`
`longitudinal length of the linear downscan
`
`direction parallel to a
`
`transducer element and a relatively wide
`
`longitudinal length of the linear
`
`beamwidth (e.g., 50°) in a direction
`
`downscan transducer element
`
`perpendicular to the longitudinal length of the
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`and a relatively wide
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`transducer element. The drawing shows a line
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`beamwidth in a direction
`
`representing the linear transducer and states
`
`perpendicular to the
`
`“rectangular element pointed strait [sic] down,”
`
`longitudinal length of the
`
`“xdcr with rectangle element array,” and
`
`transducer element,
`
`“rectangular element gives desired beam angle of
`
`~ 1° x 50°.”
`
`the linear downscan transducer
`
`Exhibit D: The drawing shows the linear
`
`element being positioned with
`
`downscan transducer element being positioned
`
`the longitudinal length thereof
`
`with the longitudinal length thereof extending in
`
`extending in a fore-to-aft
`
`a fore-to-aft direction of the housing, with a
`
`direction of the housing;
`
`caption stating “xdcr with rectangle element
`
`array.”
`
`wherein the linear downscan
`
`Exhibit D: The drawing shows a linear downscan
`
`transducer element is
`
`transducer element positioned within the housing
`
`positioned within the housing
`
`to project fan-shaped sonar beams in a direction
`
`to project fan-shaped sonar
`
`substantially perpendicular to a plane
`
`beams in a direction
`
`corresponding to the surface of the body of
`
`substantially perpendicular to a
`
`water.
`
`plane corresponding to the
`
`Exhibit A: The email states “[t]he elements were
`
`surface of the body of water,
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`potted facing almost strait [sic] down,” and that
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`you get “a good idea of the bottom structure
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`directly below the boat.”
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`Exhibit B: The image of the transducer housing
`
`shows it mounted to the stern of the boat,
`
`extending in a fore-to-aft direction parallel to the
`
`surface of the water to project sonar beams
`
`perpendicular to the surface of the water.
`
`said sonar beams being
`
`Exhibit A: The images shown in Exhibit A were
`
`repeatedly emitted so as to
`
`created by sonar beams being repeatedly emitted
`
`sequentially insonify different
`
`so as to sequentially insonify different fan-
`
`fan-shaped regions of the
`
`shaped regions of the underwater environment as
`
`underwater environment as the
`
`the watercraft travels.
`
`watercraft travels; and
`
`Exhibit C: Energizing the downscan transducer
`
`at 455 kHz or 800 kHz sequentially insonifies
`
`different fan-shaped regions (see Exhibit D) of
`
`the underwater environment as the watercraft
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`travels.
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`Exhibit D: The arrow pointing from the stern to
`
`the bow of the boat reflects the direction of travel
`
`of the watercraft.
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`a sonar signal processor
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`Exhibit A: The images shown in Exhibit A were
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`receiving signals representative
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`created by a sonar signal processor receiving
`
`of sonar returns resulting from
`
`signals representative of sonar returns resulting
`
`each of the fan-shaped sonar
`
`from each of the fan-shaped sonar beams and
`
`beams and processing the
`
`processing the signals to produce sonar image
`
`signals to produce sonar image
`
`data for each fan-shaped region and to create an
`
`data for each fan-shaped region
`
`image of the underwater environment as a
`
`and to create an image of the
`
`composite of images of the fan-shaped regions
`
`underwater environment as a
`
`arranged in a progressive order corresponding to
`
`composite of images of the fan-
`
`the travel of the watercraft.
`
`shaped regions arranged in a
`
`Exhibit D: The arrow extending from the stern to
`
`progressive order
`
`the bow of the boat shows the direction of travel
`
`corresponding to the travel of
`
`of the watercraft. The data from the repeated
`
`the watercraft.
`
`(455 kHz or 800 kHz) fan-shaped underwater
`
`regions is processed to produce image data and
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`create a sequential composite of images from
`
`right to left corresponding to the travel of the
`
`watercraft.
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`Dependent Claim 2
`
`Exhibit(s)
`
`The sonar assembly of claim 1,
`
`Exhibit C: The lab notebook describes that the
`
`wherein the linear downscan
`
`linear downscan transducer element is configured
`
`transducer element is
`
`to operate at a selected one of at least two
`
`configured to operate at a
`
`selectable operating frequencies. It states
`
`selected one of at least two
`
`“[d]ownscan did well at 800KHz, but could not
`
`selectable operating
`
`image the bus or plane very well at 455KHz.”
`
`frequencies.
`
`Independent Claim 23
`
`Exhibit(s)
`
`A sonar system for imaging an
`
`Exhibit A: The actual images shown in Exhibit A
`
`underwater environment
`
`were created by a sonar system for imaging an
`
`beneath a watercraft traveling
`
`underwater environment beneath a watercraft
`
`on a surface of a body of water,
`
`traveling on a surface of a body of water, as
`
`the sonar system comprising:
`
`shown by the following elements.
`
`Exhibit D: The drawings in the lab notebook
`
`show a sonar transducer housing mounted on a
`
`watercraft and examples of images created by a
`
`sonar system.
`
`a single linear downscan
`
`Exhibit B: The image shows a long and narrow
`
`NAV-2001
`
`21 of 43
`
`
`
`transducer element positioned
`
`housing for the transducer element, and a
`
`within a housing that is
`
`housing mountable to a watercraft. The excerpt
`
`mountable to the watercraft,
`
`states that “Lab #10” is “down-scan (pointed
`
`down)” and “contains one xdcr.”
`
`Exhibit D: The drawing shows a single linear
`
`downscan transducer element positioned within
`
`the housing that is mountable to a watercraft,
`
`with captions pointing to a “rectangular element
`
`pointed strait [sic] down,” and “xdcr with
`
`rectangle element array.”
`
`the linear downscan transducer
`
`Exhibit D: The drawing shows a linear downscan
`
`element having a substantially
`
`transducer element having a substantially
`
`rectangular shape configured to
`
`rectangular shape configured to produce a fan-
`
`produce a fan-shaped sonar
`
`shaped sonar beam having a relatively narrow
`
`beam having a relatively
`
`beamwidth (e.g., 1°) in a direction parallel to a
`
`narrow beamwidth in a
`
`longitudinal length of the linear downscan
`
`direction parallel to
`
`transducer element and a relatively wide
`
`longitudinal length of the linear
`
`beamwidth (e.g., 50°) in a direction
`
`downscan transducer element
`
`perpendicular to the longitudinal length of the
`
`and a relatively wide
`
`transducer element. The drawing shows a single
`
`NAV-2001
`
`22 of 43
`
`
`
`beamwidth in a direction
`
`line representing the linear transducer, and states
`
`perpendicular to the
`
`“rectangular element pointed strait [sic] down,”
`
`longitudinal length of the
`
`“xdcr with rectangle element array,” and
`
`transducer element,
`
`“rectangular element gives desired beam angle of
`
`~ 1° x 50°.”
`
`the linear downscan transducer
`
`Exhibit D: The drawing shows the linear
`
`element being positioned with
`
`downscan transducer element being positioned
`
`the longitudinal length thereof
`
`with the longitudinal length thereof extending in
`
`extending in a fore-to-aft
`
`a fore-to-aft direction of the housing, with a
`
`direction of the housing;
`
`caption stating “xdcr with rectangle element
`
`array.”
`
`wherein the linear downscan
`
`Exhibit D: The drawing shows a linear downscan
`
`transducer element is
`
`transducer element positioned within the housing
`
`positioned to project fan-
`
`to project fan-shaped sonar beams in a direction
`
`shaped sonar beams in a
`
`substantially perpendicular to a plane
`
`direction substantially
`
`corresponding to the surface of the body of
`
`perpendicular to a plane
`
`water.
`
`corresponding to the surface of
`
`Exhibit A: The email states “[t]he elements were
`
`the body of water,
`
`potted facing almost strait [sic] down,” and that
`
`you get “a good idea of the bottom structure
`
`NAV-2001
`
`23 of 43
`
`
`
`directly below the boat.”
`
`Exhibit B: The image of the transducer housing
`
`shows it mounted to the stern of the boat,
`
`extending in a fore-to-aft direction parallel to the
`
`surface of the water to project sonar beams
`
`perpendicular to the surface of the water.
`
`said sonar beams being
`
`Exhibits A: The images shown in Exhibit A were
`
`repeatedly emitted so as to
`
`created by sonar beams being repeatedly emitted
`
`sequentially insonify different
`
`so as to sequentially insonify different fan-
`
`fan-shaped regions of the
`
`shaped regions of the underwater environment as
`
`underwater environment as the
`
`the watercraft travels.
`
`watercraft travels;
`
`Exhibit C: Energizing the downscan transducer
`
`at 455 kHz or 800 kHz sequentially insonifies
`
`different fan-shaped regions (see Exhibit D) of
`
`the underwater environment as the watercraft
`
`travels.
`
`Exhibit D: The arrow pointing from the stern to
`
`the bow of the boat reflects the direction of travel
`
`of the watercraft.
`
`NAV-2001
`
`24 of 43
`
`
`
`a sonar module configured to
`
`Exhibit A: The images in Exhibit A were created
`
`enable operable communication
`
`by a sonar module configured to enable operable
`
`with the linear downscan
`
`communication with the linear downscan
`
`transducer element, the sonar
`
`transducer element.
`
`module including:
`
`a sonar signal processor to
`
`Exhibit A: The images in Exhibit A were created
`
`process sonar return signals,
`
`by a sonar signal processor processing sonar
`
`and
`
`return signals.
`
`at least one transceiver
`
`Exhibit A: The actual images in Exhibit A were
`
`configured to provide
`
`created via a transceiver configured to provide
`
`communication between the
`
`communication between a linear downscan
`
`linear downscan transducer
`
`transducer element and the sonar signal
`
`element and the sonar signal
`
`processor.
`
`processor,
`
`the sonar signal processor
`
`Exhibit A: The images in Exhibit A were created
`
`receiving signals representative
`
`by a sonar signal processor receiving signals
`
`of sonar returns resulting from
`
`representative of sonar returns resulting from
`
`each of the fan-shaped sonar
`
`each of the fan-shaped sonar beams and
`
`beams and processing the
`
`processing the signals to produce sonar image
`
`NAV-2001
`
`25 of 43
`
`
`
`signals to produce sonar image
`
`data for each fan-shaped region and to create an
`
`data for each fan-shaped region
`
`image of the underwater environment as a
`
`and to create an image of the
`
`composite of images of the fan-shaped regions
`
`underwater environment as a
`
`arranged in a progressive order corresponding to
`
`composite of images of the fan-
`
`the travel of the watercraft.
`
`shaped regions arranged in a
`
`Exhibit D: The arrow extending from the stern to
`
`progressive order
`
`the bow of the boat shows the direction of travel
`
`corresponding to the travel of
`
`of the watercraft. The data from the repeated
`
`the watercraft.
`
`(455 kHz or 800 kHz) fan-shaped underwater
`
`regions is processed to produce image data and
`
`create a sequential composite of images from
`
`right to left corresponding to the travel of the
`
`watercraft.
`
`Dependent Claim 30
`
`Exhibit(s)
`
`The sonar system of claim 23,
`
`Exhibit C: The lab notebook describes that the
`
`wherein the linear downscan
`
`linear downscan transducer element is configured
`
`transducer element is
`
`to operate at a selected one of at least two
`
`configured to operate at a
`
`selectable operating frequencies. It states
`
`NAV-2001
`
`26 of 43
`
`
`
`selected one of at least two
`
`“[d]ownscan did well at 800KHz, but could not
`
`selectable operating
`
`image the bus or plane very well at 455KHz.”
`
`frequencies.
`
`Independent Claim 73
`
`Exhibit(s)
`
`A sonar imaging apparatus
`
`Exhibit A: The actual images shown in Exhibit A
`
`comprising:
`
`were created by a sonar imaging apparatus as
`
`shown by the following elements.
`
`Exhibit D: The drawings in the lab notebook
`
`show a sonar imaging apparatus as shown by the
`
`following elements.
`
`a housing mountable to a
`
`Exhibit B: The image shows a housing
`
`watercraft that traverses a
`
`mountable to a watercraft.
`
`surface of a body of water, the
`
`Exhibit D: The drawing shows a housing
`
`watercraft defining a center
`
`mountable to a watercraft that traverses a surface
`
`plane that extends from fore to
`
`of a body of water, the watercraft defining a
`
`aft and that is perpendicular to
`
`center plane that extends from fore to aft (see the
`
`the surface of the body of
`
`arrow pointing from the stern to the bow) and
`
`water;
`
`that is perpendicular to the surface of the body of
`
`water.
`
`NAV-2001
`
`27 of 43
`
`
`
`a linear transducer element
`
`Exhibit B: The image shows a long and narrow
`
`positioned within the housing,
`
`housing for the transducer element.
`
`Exhibit D: The drawing shows a linear
`
`transducer element positioned within the
`
`housing, with captions pointing thereto stating
`
`“rectangular element pointed strait [sic] down,”
`
`and “xdcr with rectangle element array.”
`
`the linear transducer element
`
`Exhibit D: The drawing shows a linear downscan
`
`being configured to produce a
`
`transducer element configured to produce a fan-
`
`fan-shaped sonar beam having
`
`shaped sonar beam having a longitudinal
`
`a longitudinal beamwidth in a
`
`beamwidth in a direction parallel to a
`
`direction parallel to a
`
`longitudinal length of the linear transducer
`
`longitudinal length of the linear
`
`element that is significantly less (e.g., 1°) than a
`
`transducer element that is
`
`transverse beamwidth (e.g., 50°) of the sonar
`
`significantly less than a
`
`beam in a direction perpendicular to the
`
`transverse beamwidth of the
`
`longitudinal length of the transducer element.
`
`sonar beam in a direction
`
`The drawing shows the fan-shaped beam being
`
`perpendicular to the
`
`produced by the linear transducer element, and
`
`longitudinal length of the
`
`the caption states “rectangular element gives
`
`NAV-2001
`
`28 of 43
`
`
`
`transducer element;
`
`desired beam angle of ~ 1° x 50°”
`
`wherein the housing is
`
`Exhibit B: The image shows a housing
`
`configured for mounting to the
`
`configured for mounting to the watercraft such
`
`watercraft such that the
`
`that the longitudinal length of the linear
`
`longitudinal length of the linear
`
`transducer element is parallel to said center
`
`transducer element is parallel to
`
`plane.
`
`said center plane, and
`
`Exhibit D: The drawing shows a housing
`
`mounted to the watercraft such that the
`
`longitudinal length of the linear transducer
`
`element is parallel to said center plane.
`
`wherein the tr
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