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`Exhibit 2023
`
`Exhibit 2023
`
`
`
`Patent Owner LocatioNet Systems, Ltd.’s
`Trial Demonstratives
`
`1
`
`
`
`Issue: Whether Petitioner has met its
`burden to prove that Claim 18 of the ‘970
`Patent is anticipated by the Elliot reference
`
`2
`
`
`
`“The system architecture of the ‘970 patent
`requires that each mobile platform location
`system be associated with a ‘map database’
`and a ‘map engine’ …. For example, the ‘map
`database’ and ‘map engine’ recited in claim
`18 allow a system subscriber to customize a
`map by selecting which data to be
`incorporated on the map or the level of detail
`displayed on the map, such as street names,
`etc. … The ‘970 patent’s specific system
`architecture, including the associated ‘map
`database’ and ‘map engine,’ also enables
`dynamic functions such as supplying
`navigation information, managing movement
`of resources, such as for route planning
`between multiple destinations, billing and/or
`advertising and emergency service
`management.”
`- Ex. 2016, Mandayam Decl., at ¶¶35-36
`(citing Ex. 1001, Col. 5, lines 13-18, 37-42) 3
`
`
`
` 18. A system for location tracking of mobile platforms, each of which is equipped each with a
`tracking unit, each being adapted to determine the location of a respective mobile platform
`according to a property that is predetermined for each mobile platform; the system
`comprising:
`(a) a location server communicating through a user interface with at least one subscriber
`equipped with a browser; said communication having inputs that include at least the
`subscriber identity, the mobile platform identity and map information;
`(b) at least one mobile platform location system coupled to said location server for
`receiving the mobile platform identity and map information that pertain to mobile
`platforms associated with the respective mobile platform location system; each one of
`said mobile platform location systems being associated with a map database and map
`engine for manipulating said map database;
`(c) at least one remote tracking service communicating with said respective mobile
`platform location system for receiving mobile platform identity and returning mobile
`platform location information;
`the at least one mobile platform location system being adapted to receive said mobile
`platform location information and access said map database for correlating map to said
`location information, so as to obtain correlated location information;
`said location server being adapted to receive the correlated location information and forward
`them to said browser.
`
`
`
`
`
`
`
`
`
`
`
`4
`
`
`
` Patent Owner’s Proposed Construction:
`
`The ordinary and customary meaning of the term “map database”
`is a collection of map data that is organized so that it can easily
`be accessed, searched, managed, and updated.
`
` Ex. 2016, Mandayam Decl. at 13, ¶28; Paper 35, PO’s Response, at 10-
`11; Paper 47, PO’s Opposition to Petitioner’s Motion to Exclude
`Evidence, at 4-5; Ex. 1019, Mandayam Depo. Tr. at page 60, line 15 to
`page 61, line 4.
`
`5
`
`
`
` Patent Owner’s Proposed Construction:
`
`The ordinary and customary meaning of the term “map engine” is
`a program or module for accessing, searching, managing, and
`updating the map database.
`
` Ex. 2016, Mandayam Decl. at 16, ¶32; Paper 35, PO’s Response, at 13-
`14; Paper 47, PO’s Opposition to Petitioner’s Motion to Exclude
`Evidence, at 4-5; Ex. 1019, Mandayam Depo. Tr. at page 61, line 25 to
`page 63, line 8.
`
`6
`
`
`
` Ex. 1001, ‘970 Patent, Col. 4, lines 15-20; Ex. 2016, Mandayam Decl. at 13, ¶28; Paper
`35, PO’s Response, at 10-11; Paper 44, PO’s Motion for Observations Re Cross-Exam, at
`12, Observation #20.
`
` Ex. 1001, ‘970 Patent, Col. 5, lines 45-50; Ex. 2016, Mandayam Decl. at 13, ¶28; Paper
`35, PO’s Response, at 10-11; Paper 44, PO’s Motion for Observations Re Cross-Exam, at
`12, Observation #21.
`
`7
`
`
`
` Ex. 1001, ‘970 Patent, Col. 3, lines 21-25; Ex. 2016, Mandayam Decl. at 13, ¶28; Paper
`35, PO Response, at 10-11; Paper 44, PO’s Motion for Observations Re Cross-Exam, at
`11, Observation #19.
`
` Ex. 1001, ‘970 Patent, Claim 18; Ex. 2016, Mandayam Decl. at 13, ¶28; Paper 35, PO
`Response, at 10-11; Paper 44, PO’s Motion for Observations Re Cross-Exam, at 13,
`Observation #22.
`
`8
`
`
`
` Dictionary of Computer Words, Houghton Mifflin Company (1998),
`Ex. 2017 at 61 (defining “database”).
`An organized collection of information that can be
`searched, retrieved, changed, and sorted using a collection
`of programs known as a database management system.
` Personal Computer Dictionary, Random House (2nd Ed. 1996),
`Ex. 2018 at 126 (defining “database”).
`
`A collection of information organized in such a way that a
`computer program can quickly select desired pieces of
`data.
`
` Paper 35, PO’s Response, at 11; Ex. 2016, Mandayam Decl. at ¶28.
`
`9
`
`
`
` Ex. 1001, ‘970 Patent, Col. 4, lines 15-20; Ex. 2016 , Mandayam Decl. at 16, ¶32; Paper
`35, PO’s Response, at 13-14; Paper 44, PO’s Motion for Observations Re Cross-Exam, at
`12, Observation #20.
`
` Ex. 1001, ‘970 Patent, Col. 5, lines 45-50; Ex. 2016, Mandayam Decl. at 16, ¶32; Paper
`35, PO’s Response, at 13-14; Paper 44, PO’s Motion for Observations Re Cross-Exam, at
`12, Observation #21.
`
`10
`
`
`
` Ex. 1001, ‘970 Patent, Col. 4,
`lines 15-20.
`
` Ex. 2022, Rosenberg Depo. Tr.
`at 102:9-23, 104:18-105:5;
`Paper 44, PO’s Motion for
`Observations Re Cross-Exam, at
`12, Observation #20.
`
`11
`
`
`
` Ex. 1001, ‘970 Patent, Col. 5, lines
`45-50.
`
` Ex. 2022, Rosenberg Depo. Tr. at
`112:21-113:19; Paper 44, PO’s
`Motion for Observations Re Cross-
`Exam, at 12, Observation #21.
`
`12
`
`
`
` Ex. 1001, ‘970 Patent, Col. 3, lines 21-25; Ex. 2016, Mandayam Decl. at 16, ¶32; Paper
`35, PO’s Response, at 13-14; Paper 44, PO’s Motion for Observations Re Cross-Exam, at
`11, Observation #19.
`
` Ex. 1001, ‘970 Patent, Claim 18; Ex. 2016, Mandayam Decl. at 16, ¶32; Paper 35, PO’s
`Response, at 13-14; Paper 44, PO’s Motion for Observations Re Cross-Exam, at 13,
`Observation #22.
`
`13
`
`
`
`
`
`‘970 Patent Specification: “the
`step of correlating the location o
`
` Ex. 1001, ‘970 Patent, Col. 3,
`lines 21-25.
`
` Ex. 2022, Rosenberg Depo. Tr.
`at 100:2-18; Paper 44, PO’s
`Motion for Observations Re
`Cross-Exam, at 11, Observation
`#19.
`
`14
`
`
`
` Ex. 1001, ‘970 Patent, Claim
`18.
`
` Ex. 2022, Rosenberg Depo. Tr.
`at 122:12-123:3; Paper 44,
`PO’s Motion for Observations
`Re Cross-Exam, at 13,
`Observation #22.
`
`15
`
`
`
` Webster’s New World Dictionary of Computer Terms, Macmillan (5th
`ed. 1994) (defining “engine”).
`
`The portion of the program that determines how the
`program manages and manipulates data. Another name for
`processor.
`
` Ex. 2019 at 208; Paper 35, PO’s Response, at 13-14, Ex. 2016,
`Mandayam Decl. at 16, ¶32.
`
`16
`
`
`
` Petitioner relies on the following disclosure in Elliot for the “map
`database” and “map engine for manipulating said map database”:
`(1) “web server 34 [] functions as a web interface for [] central
`control system [20],” (quoting Ex. 1003, col. 7, ll. 1–7);
`(2) “web server [34] with its associated files provides graphical maps
`capable of showing the current and historical locations of []
`device [12],” (quoting Ex. 1003, col 3, ll. 2–4);
`(3) “[m]any commercial software programs are available for
`producing and manipulating graphics and images, including
`road map graphics images. Such graphical map images may be
`displayed within a web page when a Web browser runs a
`document,” (quoting Ex. 1003, col. 9, ll. 17–27); and
`(4) “[t]he ‘X’ mark for pointing to the current location of the child
`(i.e., the device) may be superimposed in the map image,”
`(quoting Ex. 1003, col. 9, ll. 28–30).
` Paper 18, Institution Decision, at 16; Paper 6, Petition, at 31-33; Paper 35, PO’s
`Response, at 2-3.
`
`17
`
`
`
`Petitioner: “Web server” is not a “map
`database”
`
`Nowhere does the Petition or the Board‘s Decision allege that the Web
`
`historical locations of the device" (emphasis added). Elliot, 3:2-4. The P0 ignores
`
`server disclosed b Elliott satisfies the claimed "ma database.” For example, the
`
`PO acknowledges that both the Petition and the Decision cite ”[a] web server with
`
`its associatedfiles provides graphical maps capable of showing the current and
` Petitioner’s Reply to Patent Owner’s Response, Paper 39 at 3.
`
`> Petitioner’s Reply to Patent Owner’s Response, Paper 39 at 3.
`
`18
`
`
`
`
`
`Petitioner: “Associated Files”
`
`Nowhere does the Petition or the Board‘s Decision allege that the Web
`
`its associated 1!es:r0vides_m : hical mans capable of showing the current and historical locations of the device" (emphasis added). Elliot, 3:2-4. The P0 ignores
`
`server disclosed by Elliott satisfies the claimed ”map database.” For example, the
`
`PO acknowledges that both the Petition and the Decision cite ”| a| web server with
`
` Petitioner’s Reply to Patent Owner’s Response, Paper 39 at 3.
`
`> Petitioner’s Reply to Patent Owner’s Response, Paper 39 at 3.
`
`19
`
`
`
`
`
` Ex. 2022, Rosenberg Depo. Tr., 19:8-12; Paper 44, PO’s Motion for
`Observations Re Cross-Exam, at 1, Observation #1.
`
`20
`
`
`
` Ex. 2022, Rosenberg Depo. Tr. at 21:9-14, 21:20-22, Paper 44, PO’s
`Motion for Observations Re Cross-Exam, at 2, Observation #3.
`
`21
`
`
`
` Ex. 2022, Rosenberg Depo. Tr. at 20:10-18; Paper 44, PO’s Motion for
`Observations Re Cross-Exam, at 1-2, Observation #2.
`
`22
`
`
`
` Ex. 2022, Rosenberg Depo. Tr. at 24:13-20, Paper 44, PO’s Motion for
`Observations Re Cross-Exam, at 3, Observation #5.
`
`23
`
`
`
` Ex. 2022, Rosenberg Depo. Tr. at 28:16-25; Paper 44, PO’s Motion for
`Observations Re Cross-Exam, at 3, Observation #5.
`
`24
`
`
`
` Ex. 2022, Rosenberg Depo. Tr. at 56:4-17; Paper 44, PO’s Motion for
`Observations Re Cross-Exam, at 4, Observation #7.
`
`25
`
`
`
` Ex. 2022, Rosenberg Depo. Tr. at 68:16-21, 69:15-21; Paper 44, PO’s
`Motion for Observations Re Cross-Exam, at 7-9, Observations #12, #14.
`
`26
`
`
`
` Ex. 2022, Rosenberg Depo. Tr. at 70:11-22; Paper 44, PO’s Motion for
`Observations Re Cross-Exam, at 8, Observation #13.
`
`27
`
`
`
` Ex. 2022, Rosenberg Depo. Tr. at 82:19-83:11; Paper 44, PO’s Motion
`for Observations Re Cross-Exam, at 10, Observation #17.
`
`28
`
`
`
` Ex. 2022, Rosenberg Depo. Tr. at 79:2-13; Paper 44, PO’s Motion for
`Observations Re Cross-Exam, at 9, Observation #15.
`
`29
`
`
`
` Ex. 2022, Rosenberg Depo. Tr. at 64:5-16; Paper 44, PO’s Motion for
`Observations Re Cross-Exam, at 6, Observation #10.
`
`30
`
`
`
` Ex. 2022, Rosenberg Depo. Tr. at 87:9-13; Paper 44, PO’s Motion for
`Observations Re Cross-Exam, at 10, Observation #18.
`
`31
`
`
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