NO: 420717US
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`TOYOTA MOTOR CORP.,
`Petitioner,
`
`
`
`v.
`
`
`LEROY G. HAGENBUCH,
`Patent Owner.
`__________________
`
`Case IPR2013-00638
`Patent U.S. 8,014,917
`__________________
`
`PETITIONER TOYOTA MOTOR CORP.’S
`DEMONSTRATIVE EXHIBITS
`
`
`
`
`
`
`
`
`
`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`TOYOTA MOTOR CORP.,
`Petitioner,
`
`
`
`v.
`
`
`LEROY G. HAGENBUCH,
`Patent Owner.
`__________________
`
`Case IPR2013-00638
`Patent U.S. 8,014,917
`__________________
`
`PETITIONER TOYOTA MOTOR CORP.’S
`DEMONSTRATIVE EXHIBITS
`
`
`
`
`
`
`
`
`
`
`Toyota Motor Corp.
`v.
`LeRoy G. Hagenbuch
`
`IPR2013-00638
`Patent 8,014,917
`
`Trial Hearing
`
`Petitioner Toyota Motor Corporation’s Demonstrative
`Exhibits DX-1 through DX-51 for November 20, 2014 Oral Argument
`
`IPR2013-00638
`
`Toyota DX-1
`
`
`
`Grounds of Institution
`
` Claims 4, 9–17, 21, and 26–34 are unpatentable
`under § 103(a) over Aoyanagi, Steiner, and Oishi
` Claims 4, 9–17, 21, and 26–34 are unpatentable
`under § 103(a) over Aoyanagi, Steiner, and
`Vollmer
` Claim 35 is unpatentable under § 103(a) over
`Aoyanagi and Hagenbuch ’835
` Claims 36–38 are unpatentable under § 103(a)
`over Aoyanagi, Hagenbuch ’835, and Steiner
`IPR2013-00638
`Toyota DX-2
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 1
`[a] A method for recording operation of a vehicle, the method
`comprising:
`[b] monitoring production related parameters of the vehicle,
`[c] including a ground speed of the vehicle,
`[d] a position of a throttle for an engine of the vehicle and
`[e] a degree of braking of the vehicle;
`[f] monitoring vital sign parameters of the vehicle, including
`information indicative of a change in the velocity of the
`vehicle;
`[g] detecting a collision of the vehicle in response to a sudden
`change in the velocity of the vehicle;
`[h] automatically sending a wireless distress signal from the
`vehicle in response to detecting the collision; and
`[i] capturing the production-related parameters of the vehicle
`before detection of the collision and the vital sign parameters
`after detection of the collision.
`
`‘917 Patent – Claim 18
`[a] A method for recording operation of a vehicle, the method
`comprising:
`[b] monitoring production related parameters of the vehicle,
`[c] including a ground speed of the vehicle,
`[d] a position of a throttle for an engine of the vehicle and
`[e] an on/off status of a braking system of the vehicle;
`[f] monitoring vital sign parameters of the vehicle, including
`information indicative of a change in the velocity of the
`vehicle;
`[g] detecting a collision of the vehicle in response to a sudden
`change in the velocity of the vehicle;
`[h] automatically sending a wireless distress signal from the
`vehicle in response to detecting the collision; and
`[i] capturing the production-related parameters of the vehicle
`before detection of the collision and the vital sign parameters
`after detection of the collision.
`
`IPR2013-00638
`
`Toyota DX-3
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi describes recording operations of a vehicle
`with recording apparatus 12. (Ex. 1103, 71:1:6–9;
`72:1:6–12.)
`
`‘917 Patent – Claim 1
`
`[a] A method for
`recording operation of
`a vehicle, the method
`comprising:
`‘917 Patent – Claim 18
`[a] A method for
`recording operation of
`a vehicle, the method
`comprising:
`
`IPR2013-00638
`
`Toyota DX-4
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi monitors production-related parameters
`“us[ing] sensors to record data of the running
`conditions of the vehicle.” (Ex. 1103, 71:1:6–9.)
`
`‘917 Patent – Claim 1
`
`[b] monitoring
`production related
`parameters of the
`vehicle,
`‘917 Patent – Claim 18
`[b] monitoring
`production related
`parameters of the
`vehicle,
`
`IPR2013-00638
`
`Toyota DX-5
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 1
`
`[c] including a ground
`speed of the vehicle,
`‘917 Patent – Claim 18
`[c] including a ground
`speed of the vehicle,
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi teaches monitoring the ground speed of the
`vehicle with vehicle speed sensors 14. (Ex. 1103,
`71:1:54–71:2:2.)
`
`IPR2013-00638
`
`Toyota DX-6
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi teaches monitoring the throttle position with
`“a rotation angle sensor 24 mounted within the intake
`manifold 22a of the engine 22.” (Ex. 1103, 71:2:18–27.)
`
`‘917 Patent – Claim 1
`
`[d] a position of a
`throttle for an engine
`of the vehicle and
`‘917 Patent – Claim 18
`[d] a position of a
`throttle for an engine
`of the vehicle and
`
`IPR2013-00638
`
`Toyota DX-7
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`DISPUTED CLAIM ELEMENT
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi teaches “a hydraulic pressure sensor 28
`provided at the hydraulic pressure cylinder brake 32
`activated by a brake 30.” (Ex. 1103, 71:2:28–35.)
`
`‘917 Patent – Claim 1
`
`[e] a degree of braking
`of the vehicle;
`‘917 Patent – Claim 18
`[e] an on/off status of
`a braking system of the
`vehicle;
`
`IPR2013-00638
`
`Toyota DX-8
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 1
`
`[f] monitoring vital sign
`parameters of the vehicle,
`including information
`indicative of a change in the
`velocity of the vehicle;
`‘917 Patent – Claim 18
`[f] monitoring vital sign
`parameters of the vehicle,
`including information
`indicative of a change in the
`velocity of the vehicle;
`
`IPR2013-00638
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi teaches “us[ing] sensors to record data of
`the running conditions of the vehicle.” (Ex. 1103,
`71:1:6–9.) Aoyanagi monitors information
`indicative of a change in velocity with an
`acceleration sensor 18. (Ex. 1103, 71:2:3–6.)
`
`Toyota DX-9
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`DISPUTED CLAIM ELEMENT
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi detects a collision “when a shock
`occurs and then the vehicle speed becomes zero
`in a short time.” (Ex. 1103, 72:2:21–23.)
`
`‘917 Patent – Claim 1
`
`[g] detecting a collision of the
`vehicle in response to a
`sudden change in the velocity
`of the vehicle;
`‘917 Patent – Claim 18
`[g] detecting a collision of the
`vehicle in response to a
`sudden change in the velocity
`of the vehicle;
`
`IPR2013-00638
`
`Toyota DX-10
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 1
`
`[h] automatically sending
`a wireless distress signal
`from the vehicle in
`response to detecting
`the collision; and
`‘917 Patent – Claim 18
`[h] automatically sending
`a wireless distress signal
`from the vehicle in
`response to detecting
`the collision; and
`
`IPR2013-00638
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Oishi describes “an apparatus which can
`automatically notify an automobile accident after
`obtaining the impact force of the accident….” (Ex.
`1105, 634:1:3–6.) Further, Oishi teaches that a
`wireless distress signal is sent using “radio
`transmitter 12.” (Ex. 1105, 634:1:40–45.)
`
`Toyota DX-11
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 1
`
`[i] capturing the production-
`related parameters of the
`vehicle before detection of
`the collision and the vital
`sign parameters after
`detection of the collision.
`‘917 Patent – Claim 18
`[i] capturing the production-
`related parameters of the
`vehicle before detection of
`the collision and the vital
`sign parameters after
`detection of the collision.
`IPR2013-00638
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi teaches “captur[ing] respective data that are input
`from respective sensors…and to sequentially delete old data
`when the capacity of memory is full so as to take in the
`latest data.” (Ex. 1103, 72:1:62–67.) “[W]hen an accident
`occurs, the recording apparatus can keep recording for a
`specific period of time after receiving shocks and the like.”
`(Ex. 1103, 72:1:33–36.)
`
`Toyota DX-12
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`DISPUTED CLAIM ELEMENT
`
`‘917 Patent – Claim 4
`
`The method of claim 1
`wherein the
`production-related
`parameters include a
`load on the engine.
`‘917 Patent – Claim 21
`The method of claim
`18 wherein the
`production-related
`parameters include a
`load on the engine.
`
`IPR2013-00638
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi monitors a load on the engine by detecting
`“acceleration pedal position.” (Ex. 1103, 71:2:18.)
`Specifically, Aoyanagi teaches “detecting the butterfly
`position of an intake manifold 22a activated by an
`accelerator 26 through a rotation angle sensor 24
`mounted within the intake manifold 22a of the engine
`22.” (Ex. 1103, 71:2:20–23.)
`
`Steiner’s system also monitors “a load on the engine”
`by monitoring and recording “total fuel consumed.” (Ex.
`1110, 7:44–56.)
`
`Toyota DX-13
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 9
`[a] An apparatus for recording operation of a vehicle, the
`apparatus comprising:
`[b] sensors for monitoring production-related parameters
`of the vehicle, where the parameters include,
`[c] ground speed of the vehicle,
`[d] a position of a throttle for an engine of the vehicle and
`[e] a degree of braking by a braking system of the vehicle;
`[f] a first memory for capturing information from one or
`more of the sensors for monitoring production-related
`parameters;
`[g] a second memory for receiving the information from the
`first memory;
`
`‘917 Patent – Claim 26
`[a] An apparatus for recording operation of a vehicle, the
`apparatus comprising:
`[b] sensors for monitoring production-related parameters
`of the vehicle, where the parameters include
`[c] ground speed of the vehicle,
`[d] a position of a throttle for an engine of the vehicle and
`[e] an on/off status of a braking system of the vehicle;
`[f] a first memory for capturing information from one or
`more of the sensors for monitoring production-related
`parameters;
`[g] a second memory for receiving the information from the
`first memory;
`
`IPR2013-00638
`
`Toyota DX-14
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 9
`[h] sensors for monitoring vital signs of the vehicle, where
`the vital signs include a collision of the vehicle;
`[i] a processor in communication with the production-
`related and vital sign sensors and the first and second
`memories for transferring into the second memory the
`information captured by the first memory in response to
`detection of the collision of the vehicle,
`[j] where the information includes data from one or more
`of the production-related parameters before detection of
`the collision and data from one or more of the vital signs
`sensors after detection of the collision; and
`[k] a transmitter for automatically transmitting a distress
`signal in response to detection of the collision of the
`vehicle.
`
`‘917 Patent – Claim 26
`[h] sensors for monitoring vital signs of the vehicle, where
`the vital signs include a collision of the vehicle;
`[i] a processor in communication with the production-
`related and vital sign sensors and the first and second
`memories for transferring into the second memory the
`information captured by the first memory in response to
`detection of the collision of the vehicle,
`[j] where the information includes data from one or more
`of the production-related parameters before detection of
`the collision and data from one or more of the vital signs
`sensors after detection of the collision; and
`[k] a transmitter for automatically transmitting a distress
`signal in response to detection of the collision of the
`vehicle.
`
`IPR2013-00638
`
`Toyota DX-15
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi describes recording operations of a vehicle
`with recording apparatus 12. (Ex. 1103, 71:1:6–9;
`72:1:6–12.)
`
`‘917 Patent – Claim 9
`
`[a] An apparatus for
`recording operation of
`a vehicle, the
`apparatus comprising:
`‘917 Patent – Claim 26
`[a] An apparatus for
`recording operation of
`a vehicle, the
`apparatus comprising:
`
`IPR2013-00638
`
`Toyota DX-16
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi monitors production-related
`parameters “us[ing] sensors to record data of
`the running conditions of the vehicle.” (Ex.
`1103, 71:1:6–9.)
`
`‘917 Patent – Claim 9
`
`[b] sensors for monitoring
`production-related parameters
`of the vehicle, where the
`parameters include,
`‘917 Patent – Claim 26
`[b] sensors for monitoring
`production-related parameters
`of the vehicle, where the
`parameters include,
`
`IPR2013-00638
`
`Toyota DX-17
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 9
`
`[c] ground speed of
`the vehicle,
`‘917 Patent – Claim 26
`[c] ground speed of
`the vehicle,
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi teaches monitoring the ground speed of the
`vehicle with vehicle speed sensors 14. (Ex. 1103,
`71:1:54–71:2:2.)
`
`IPR2013-00638
`
`Toyota DX-18
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi detects accelerator pedal position with “a
`rotation angle sensor 24 mounted within the intake
`manifold 22a of the engine 22.” (Ex. 1103, 71:2:18–27.)
`
`‘917 Patent – Claim 9
`
`[d] a position of a
`throttle for an engine
`of the vehicle and
`‘917 Patent – Claim 26
`[d] a position of a
`throttle for an engine
`of the vehicle and
`
`IPR2013-00638
`
`Toyota DX-19
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`DISPUTED CLAIM ELEMENT
`
`‘917 Patent – Claim 9
`
`[e] a degree of braking
`by a braking system of
`the vehicle;
`‘917 Patent – Claim 26
`[e] an on/off status of
`a braking system of the
`vehicle;
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi detects brake pedal position with “a hydraulic
`pressure sensor 28 provided at the hydraulic pressure
`cylinder brake 32 activated by a brake 30.” (Ex. 1103,
`71:2:28–35.) The incremental levels of hydraulic
`pressure detected by the pressure sensor 28
`correspond to degrees of braking. (Ex. 1111 ¶ 95.)
`
`IPR2013-00638
`
`Toyota DX-20
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi discloses “a single-chip microcomputer 42 that is
`integrally created with a CPU, an A/D converter, and a
`memory.” (Ex. 1103, 72:1:6–8.) The memory captures
`information from the sensors by recording the latest sensor
`data at set intervals into memory. (Ex. 1103, 72:1:62–67.)
`
`‘917 Patent – Claim 9
`
`[f] a first memory for
`capturing information from
`one or more of the sensors
`for monitoring production-
`related parameters;
`‘917 Patent – Claim 26
`[f] a first memory for
`capturing information from
`one or more of the sensors
`for monitoring production-
`related parameters;
`
`IPR2013-00638
`
`Toyota DX-21
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 9
`
`[g] a second memory
`for receiving the
`information from the
`first memory;
`‘917 Patent – Claim 26
`[g] a second memory
`for receiving the
`information from the
`first memory;
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Steiner teaches a data memory 506 having first and
`second memory areas. The first memory “is
`implemented by using a 60 byte area in data memory
`506, as a circular buffer.” (Ex. 1110, 8:1–3.) The second
`memory is a “separate area in data memory 506,
`[which] is allocated for retaining the contents of the
`circular buffer [i.e., the first memory]” when there is a
`collision. (Ex. 1110, 8:17–30.)
`
`IPR2013-00638
`
`Toyota DX-22
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 9
`
`[h] sensors for
`monitoring vital signs
`of the vehicle, where
`the vital signs include a
`collision of the vehicle;
`‘917 Patent – Claim 26
`[h] sensors for
`monitoring vital signs
`of the vehicle, where
`the vital signs include a
`collision of the vehicle;
`
`IPR2013-00638
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi describes “sensors to record data of the
`running conditions of the vehicle.” (Ex. 1103, 71:1:6–9.)
`Aoyanagi teaches detecting a collision with vehicle
`speed sensor 14 and acceleration sensor 18 “when a
`shock occurs and then the vehicle speed becomes zero
`in a short time.” (Ex. 1103, 71:1:54–71:2:2; 71:2:3–6;
`72:2:21–23.)
`
`Toyota DX-23
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 9
`
`[i] a processor in communication with
`the production-related and vital sign
`sensors and the first and second
`memories for transferring into the
`second memory the information
`captured by the first memory in
`response to detection of the collision
`of the vehicle,
`‘917 Patent – Claim 26
`[i] a processor in communication with
`the production-related and vital sign
`sensors and the first and second
`memories for transferring into the
`second memory the information
`captured by the first memory in
`response to detection of the collision
`of the vehicle,
`IPR2013-00638
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi discloses a processor in communication with all sensors and
`memory with “a single-chip microcomputer 42 that is integrally created with
`a CPU.” (Ex. 1103, 72:1:6–9.) Aoyanagi teaches that the recording apparatus
`with integrated CPU (central processing unit), “capture[s] [into memory]
`respective data that are input from respective sensors.” (Ex. 1103, 72:1:62–
`64.)
`
`Aoyanagi’s apparatus is controlled by the CPU, which is in communication
`with the sensors, memory, and A/D converter. (Ex. 1111 ¶¶ 98, 116; see also
`Ex. 1103, Fig. 4.)
`
`Continued to next slide
`
`Toyota DX-24
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 9
`
`[i] a processor in communication with
`the production-related and vital sign
`sensors and the first and second
`memories for transferring into the
`second memory the information
`captured by the first memory in
`response to detection of the collision of
`the vehicle,
`‘917 Patent – Claim 26
`[i] a processor in communication with
`the production-related and vital sign
`sensors and the first and second
`memories for transferring into the
`second memory the information
`captured by the first memory in
`response to detection of the collision of
`the vehicle,
`IPR2013-00638
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Continued from previous slide
`
`Steiner discloses microprocessor 504 in communication with sensors, e.g.
`sensor inputs 630, and a first and second memory, e.g. data memory 506,
`that transfers information from the first memory to the second memory in
`response to a collision. (Ex. 1110, 6:64–7:3, 8:17–30; Fig. 6.)
`
`Toyota DX-25
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 9
`
`[j] where the information includes data
`from one or more of the production-
`related parameters before detection of
`the collision and data from one or
`more of the vital signs sensors after
`detection of the collision; and
`‘917 Patent – Claim 26
`[j] where the information includes data
`from one or more of the production-
`related parameters before detection of
`the collision and data from one or
`more of the vital signs sensors after
`detection of the collision; and
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi teaches capturing production-related and vital
`sign parameters prior to the collision by “captur[ing]
`respective data that are input from respective sensors…and
`to sequentially delete old data when the capacity of
`memory is full so as to take in the latest data.” (Ex. 1103,
`72:1:62–67.)
`
`Aoyanagi’s system continues to record both production-
`related and vital sign parameters after a collision: “when an
`accident occurs, the recording apparatus can keep
`recording for a specific period of time after receiving
`shocks and the like.” (Ex. 1103, 72:1:33–36.)
`
`IPR2013-00638
`
`Toyota DX-26
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Oishi describes “an apparatus which can
`automatically notify an automobile accident
`after obtaining the impact force of the
`accident….” (Ex. 1105, 634:1:3–6.) Further, Oishi
`teaches a wireless distress signal sent using
`“radio transmitter 12.” (Ex. 1105, 634:1:40–45.)
`
`‘917 Patent – Claim 9
`
`[k] a transmitter for
`automatically transmitting a
`distress signal in response to
`detection of the collision of
`the vehicle.
`‘917 Patent – Claim 26
`[k] a transmitter for
`automatically transmitting a
`distress signal in response to
`detection of the collision of
`the vehicle.
`
`IPR2013-00638
`
`Toyota DX-27
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Steiner teaches a second, permanent memory with
`the “separate area in data memory 506, [which] is
`allocated for retaining the contents of the circular
`buffer [(i.e., a first memory)].” (Ex. 1110, 8:28–30.)
`
`‘917 Patent – Claim 10
`
`An apparatus of claim 9
`wherein the second
`memory is a permanent
`memory.
`‘917 Patent – Claim 27
`An apparatus of claim 26
`wherein the second
`memory is a permanent
`memory.
`
`IPR2013-00638
`
`Toyota DX-28
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi monitors for a collision with vehicle speed
`sensor 14 and acceleration sensor 18 by determining
`that a collision has occurred “when a shock occurs
`and then the vehicle speed becomes zero in a short
`time.” (Ex. 1103, 71:1:54–71:2:2; 71:2:3–6; 72:2:21–
`23.)
`
`‘917 Patent – Claim 11
`
`An apparatus of claim 9
`wherein one of the vital
`signs sensors is an
`accelerometer.
`‘917 Patent – Claim 28
`An apparatus of claim 26
`wherein one of the vital
`signs sensors is an
`accelerometer.
`
`IPR2013-00638
`
`Toyota DX-29
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 12
`
`An apparatus of claim 9
`wherein the information
`indicates a change in the speed
`of the vehicle both before and
`after detection of the collision.
`‘917 Patent – Claim 29
`An apparatus of claim 26
`wherein the information
`indicates a change in the speed
`of the vehicle both before and
`after detection of the collision.
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi monitors information indicative of a change in
`velocity with acceleration sensor 18. (Ex. 1103, 71:2:3–
`6.)
`
`Aoyanagi teaches “captur[ing] respective data that are
`input from respective sensors…and to sequentially
`delete old data when the capacity of memory is full so
`as to take in the latest data.” (Ex. 1103, 72:1:62–67.)
`
`Aoyanagi also teaches: “when an accident occurs, the
`recording apparatus can keep recording for a specific
`period of time after receiving shocks and the like.” (Ex.
`1103, 72:1:33–36.)
`
`IPR2013-00638
`
`Toyota DX-30
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`DISPUTED CLAIM ELEMENT
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi teaches “detecting the
`hydraulic pressure of a hydraulic
`pressure cylinder brake 32 by a
`hydraulic pressure sensor 28 provided
`at the hydraulic pressure cylinder brake
`32 activated by a brake 30.” (Ex. 1103,
`71:2:28–35.)
`
`‘917 Patent – Claim 13
`
`An apparatus of claim 9 wherein the
`sensors for monitoring production-
`related parameters includes a sensor
`for detecting an on/off status of the
`braking system.
`‘917 Patent – Claim 30
`An apparatus of claim 26 wherein the
`sensors for monitoring production-
`related parameters includes a sensor
`for detecting an on/off status of the
`braking system.
`
`IPR2013-00638
`
`Toyota DX-31
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 14
`
`An apparatus of claim 9
`wherein the information
`includes one or more positions
`of the throttle leading up to
`the detection of the collision.
`‘917 Patent – Claim 31
`An apparatus of claim 26
`wherein the information
`includes one or more positions
`of the throttle leading up to
`the detection of the collision.
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi teaches monitoring the position of the
`throttle for the engine by detecting accelerator pedal
`position with “a rotation angle sensor 24 mounted
`within the intake manifold 22a of the engine 22.” (Ex.
`1103, 71:2:18–27.)
`
`Aoyanagi teaches “captur[ing] respective data that are
`input from respective sensors…and to sequentially
`delete old data when the capacity of memory is full so
`as to take in the latest data.” (Ex. 1103, 72:1:62–67.)
`
`IPR2013-00638
`
`Toyota DX-32
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`DISPUTED CLAIM ELEMENT
`
`‘917 Patent – Claim 15 Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi teaches “a hydraulic pressure sensor 28 provided at
`the hydraulic pressure cylinder brake 32 activated by a brake
`30.” (Ex. 1103, 71:2:28–35.) The incremental levels of
`hydraulic pressure detected by the pressure sensor 28
`correspond to degrees of braking. (Ex. 1111 ¶¶ 142–43.)
`
`Aoyanagi teaches “captur[ing] respective data that are input
`from respective sensors…and to sequentially delete old data
`when the capacity of memory is full so as to take in the latest
`data.” (Ex. 1103, 72:1:62–67.)
`
`An apparatus of claim 9
`wherein the information
`includes the degree of
`braking leading up to the
`detection of the collision.
`‘917 Patent – Claim 32
`An apparatus of claim 26
`wherein the information
`includes the on/off status
`of the braking system
`leading up to the
`detection of the collision.
`
`IPR2013-00638
`
`Toyota DX-33
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`‘917 Patent – Claim 16
`
`An apparatus of claim 15
`wherein the information
`includes one or more positions
`of the throttle leading up to
`the detection of the collision.
`‘917 Patent – Claim 33
`An apparatus of claim 32
`wherein the information
`includes one or more positions
`of the throttle leading up to
`the detection of the collision.
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi teaches detecting accelerator pedal position
`with “a rotation angle sensor 24 mounted within the
`intake manifold 22a of the engine 22.” (Ex. 1103,
`71:2:18–27.)
`
`Aoyanagi teaches “captur[ing] respective data that are
`input from respective sensors…and to sequentially
`delete old data when the capacity of memory is full so
`as to take in the latest data.” (Ex. 1103, 72:1:62–67.)
`
`IPR2013-00638
`
`Toyota DX-34
`
`
`
`Aoyanagi in view of
`Steiner and Oishi
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Oishi (Ex. 1105)
`Aoyanagi teaches monitoring a state of a seat belt
`with “seat belt fastened sensor.” (Ex. 1103,
`71:2:62–64.)
`
`‘917 Patent – Claim 17
`
`An apparatus of claim 9 wherein the
`sensors for monitoring production-
`related parameters of the vehicle
`include a sensor for determining a
`state of a seat belt in the vehicle.
`‘917 Patent – Claim 34
`An apparatus of claim 26 wherein
`the sensors for monitoring
`production-related parameters of
`the vehicle include a sensor for
`determining a state of a seat belt in
`the vehicle.
`
`IPR2013-00638
`
`Toyota DX-35
`
`
`
`Aoyanagi in view of
`Steiner and Vollmer
`
`‘917 Patent – Claim 1
`
`[h] automatically sending
`a wireless distress signal
`from the vehicle in
`response to detecting
`the collision; and
`‘917 Patent – Claim 18
`[h] automatically sending
`a wireless distress signal
`from the vehicle in
`response to detecting
`the collision; and
`
`IPR2013-00638
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Vollmer (Ex. 1107)
`Vollmer teaches that the emergency call device
`makes emergency calls that are “triggered
`automatically.” (Ex. 1107, 2:14.) Further, Vollmer
`teaches that the “control unit 3” sends the distress
`signal wirelessly “via cellular telephone 1.” (Ex. 1107,
`6:18–19.)
`
`Toyota DX-36
`
`
`
`Aoyanagi in view of
`Steiner and Vollmer
`
`Aoyanagi (Ex. 1103) in view of
`Steiner (Ex. 1110) and Vollmer (Ex. 1107)
`Vollmer teaches that the emergency call device
`makes emergency calls that are “triggered
`automatically.” (Ex. 1107, 2:14.)
`
`‘917 Patent – Claim 9
`
`[k] a transmitter for
`automatically transmitting
`a distress signal in response
`to detection of the collision
`of the vehicle.
`‘917 Patent – Claim 26
`[k] a transmitter for
`automatically transmitting
`a distress signal in response
`to detection of the collision
`of the vehicle.
`
`IPR2013-00638
`
`Toyota DX-37
`
`
`
`Aoyanagi in view of
`Hagenbuch ’835
`
`‘917 Patent – Claim 35
`[a] A method for recording operation of a vehicle, the method comprising:
`[b] monitoring positions of a throttle for an engine for the vehicle and
`[c] a load carried by the vehicle;
`[d] detecting a collision of the vehicle; and
`[e] recording one or more positions of the throttle and
`[f] a condition of the load preceding the detection of the collision.
`
`IPR2013-00638
`
`Toyota DX-38
`
`
`
`Aoyanagi in view of
`Hagenbuch ’835
`
`‘917 Patent – Claim 35
`
`[a] A method for recording
`operation of a vehicle, the
`method comprising:
`
`Aoyanagi (Ex. 1103) in view of
`Hagenbuch ’835 (Ex. 1108)
`Aoyanagi describes recording operations of a
`vehicle with recording apparatus 12. (Ex.
`1103, 71:1:6–9; 72:1:6–12.)
`
`IPR2013-00638
`
`Toyota DX-39
`
`
`
`Aoyanagi in view of
`Hagenbuch ’835
`
`‘917 Patent – Claim 35
`
`[b] monitoring positions of a
`throttle for an engine for the
`vehicle and
`
`Aoyanagi (Ex. 1103) in view of
`Hagenbuch ’835 (Ex. 1108)
`Aoyanagi teaches monitoring the position of
`the throttle for the engine by detecting
`accelerator pedal position with “a rotation
`angle sensor 24 mounted within the intake
`manifold 22a of the engine 22.” (Ex. 1103,
`71:2:18–27.)
`
`IPR2013-00638
`
`Toyota DX-40
`
`
`
`Aoyanagi in view of
`Hagenbuch ’835
`
`‘917 Patent – Claim 35
`
`Aoyanagi (Ex. 1103) in view of
`Hagenbuch ’835 (Ex. 1108)
`[c] a load carried by the vehicle; Hagenbuch ‘835 describes an apparatus that
`monitors “a load on the engine” by
`monitoring “net pressure reading[s]
`correspond[ing] to the weight of the load
`carried by the truck 11 in its truck body 13.”
`(Ex. 1108, 23:55–57.)
`
`IPR2013-00638
`
`Toyota DX-41
`
`
`
`Aoyanagi in view of
`Hagenbuch ’835
`
`‘917 Patent – Claim 35
`
`[d] detecting a collision of the
`vehicle; and
`
`Aoyanagi (Ex. 1103) in view of
`Hagenbuch ’835 (Ex. 1108)
`Aoyanagi detects a collision “when a shock
`occurs and then the vehicle speed becomes
`zero in a short time.” (Ex. 1103, 72:2:21–23.)
`
`IPR2013-00638
`
`Toyota DX-42
`
`
`
`Aoyanagi in view of
`Hagenbuch ’835
`
`‘917 Patent – Claim 35
`
`[e] recording one or more
`positions of the throttle and
`
`Aoyanagi (Ex. 1103) in view of
`Hagenbuch ’835 (Ex. 1108)
`Aoyanagi teaches detecting accelerator pedal
`position with “a rotation angle sensor 24
`mounted within the intake manifold 22a of
`the engine 22.” (Ex. 1103, 71:2:18–27.)
`
`Aoyanagi teaches “captur[ing] respective data
`that are input from respective sensors…and to
`sequentially delete old data when the
`capacity of memory is full so as to take in the
`latest data.” (Ex. 1103, 72:1:62–67.)
`
`IPR2013-00638
`
`Toyota DX-43
`
`
`
`Aoyanagi in view of
`Hagenbuch ’835
`
`[f] a condition of the
`load preceding the
`detection of the
`collision.
`
`‘917 Patent – Claim 35 Aoyanagi (Ex. 1103) in view of
`Hagenbuch ’835 (Ex. 1108)
`Hagenbuch ’835 describes an apparatus that monitors
`“a load on the engine” by monitoring “net pressure
`reading[s] correspond[ing] to the weight of the load
`carried by the truck 11 in its truck body 13.” (Ex. 1108,
`23:51–57.) Hagenbuch ’835 further teaches that the
`load carried by the vehicle is recorded into memory
`RAM 107. (Id. at 23:57–59, 24:31–37.)
`
`Aoyanagi teaches “captur[ing] respective data that are
`input from respective sensors…and to sequentially
`delete old data when the capacity of memory is full so
`as to take in the latest data.” (Ex. 1103, 72:1:62–67.)
`Toyota DX-44
`
`IPR2013-00638
`
`
`
`Aoyanagi in view of
`Hagenbuch ’835 and Steiner
`
`’917 Patent – Claim 36
`
`’917 Patent – Claim 37
`
`’917 Patent – Claim 38
`
`[a] The method of claim 35 [a] The method of claim 35 [a] The method of claim 35
`[b] including monitoring a
`[b] including monitoring a
`[b] including monitoring a
`status of a braking system
`status of a seat belt and
`ground speed of the
`of the vehicle and
`vehicle and
`[c] recording the status in
`[c] recording the status in
`response to detection of
`response to detection of
`the collision.
`the collision.
`
`[c] recording the status in
`response to detection of
`the collision.
`
`IPR2013-00638
`
`Toyota DX-45
`
`
`
`Aoyanagi in view of
`Hagenbuch ’835 and Steiner
`
`‘917 Patent – Claim 36
`
`[a] The method of claim 35
`
`[b] including monitoring a
`status of a braking system of
`the vehicle and
`
`[c] recording the status in
`response to detection of the
`collision.
`
`Aoyanagi (Ex. 1103) i
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