UNITED STATES PATENT AND TRADEMARK OFFICE
`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`
`TOYOTA MOTOR NORTH AMERICA, INC., FORD MOTOR COMPANY, JAGUAR LAND
`ROVER NORTH AMERICA, LLC, SUBARU OF AMERICA INC., and VOLVO CARS OF
`NORTH AMERICA, LLC,
`Petitioner,
`
`v.
`
`CRUISE CONTROL TECHNOLOGIES LLC,
`Patent Owner.
`___________
`
`Case IPR2014‐00291
`Patent 6,324,463 B1
`___________
`
`Patent Owner’s Demonstrative Exhibits for Oral Hearing
`
`1
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`
`TOYOTA MOTOR NORTH AMERICA, INC., FORD MOTOR COMPANY, JAGUAR LAND
`ROVER NORTH AMERICA, LLC, SUBARU OF AMERICA INC., and VOLVO CARS OF
`NORTH AMERICA, LLC,
`Petitioner,
`
`v.
`
`CRUISE CONTROL TECHNOLOGIES LLC,
`Patent Owner.
`___________
`
`Case IPR2014‐00291
`Patent 6,324,463 B1
`___________
`
`Patent Owner’s Demonstrative Exhibits for Oral Hearing
`
`1
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`Instituted Anticipation Grounds
`• Ground A: Claims 1‐3, 5, 12‐14, 18, 19, 25‐27, 29‐31,
`and 34‐36 under 35 U.S.C. §102 as anticipated by
`Prometheus.
`
`2
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`No evidence of Prometheus publication date
`• Prometheus (Ex. 1003) appears to be a compilation of the
`following compilations of documents (some with handwriting):
`• A cover page and a “FAXLIST” (both undated) (pp. 1‐2);
`“Common European Demonstrator Autonomous Intelligent Cruise
`Control” (Apr. 11, 1991) (pp. 3‐16);
`“AICC Autonomous Intelligent Cruise Control” (undated) (pp. 21‐23);
`“Distance warning system” (undated) (p. 24);
`“CED 5: Autonomous Intelligent Cruise Control, Report No. 1of the
`System Functions Group” (Feb. 1991) (pp. 25‐44);
`“CED 5: Autonomous Intelligent Cruise Control, Preliminary report,
`System Function Decomposition” (undated and missing pages) (pp.
`45‐70)
`“CED 5: Autonomous Intelligent Cruise Control, Short descriptions of
`the dynamic CED 5 demonstrators shown at Torino BMM” (Nov.
`1991) (pp. 71‐89); and
`“CED 5: Autonomous Intelligent Cruise Control, Survey of the MMI
`activities System Functions Group” (Nov. 1991) (pp. 90‐122).
`
`•
`
`•
`•
`•
`
`•
`
`•
`
`•
`
`3
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`No evidence of Prometheus publication date
`• Petition solely references, “Objet: Scenario Du MMI‐
`AAC” (pp. 104‐111) which includes “Copyright ©
`1991” (p. 104)
`• But, the “Objet” paper is contained with the
`compilation “CED 5: Autonomous Intelligent Cruise
`Control, Survey of the MMI activities System Functions
`Group” includes “November 1991” (p. 90) but no
`copyright date
`
`4
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`(a) a speed controller for automatically maintaining the vehicle at a
`substantially constant cruising speed selected by the operator;
`
`‘463 Patent –Claim 2
`2. A cruise control system for a variable speed vehicle controlled by a human
`operator, comprising:
`(b) a cruise control enable switch associated with the controller for enabling and
`disabling the controller;
`(c) a set speed input in communication with the controller for selecting the
`cruising speed of the vehicle when the controller is enabled;
`(d) a memory that stores information representative of the selected cruising
`speed; and
`(e) a feedback system that substantially continuously communicates the selected
`cruising speed information to the operator of the vehicle until either the operator
`selects a subsequent cruising speed or the controller is disabled.
`
`5
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`Petition’s allegations regarding “a speed controller”
`• Petition alleges that “the system” in Prometheus is the claimed “cruise
`control system” and the claimed “speed controller”
`
`• Petitioner equates the preamble “cruise control system” with the “speed
`controller” claim element
`• This interpretation would improperly render express claim language
`superfluous. Stumbo v. Eastman Outdoors, 508 F.3d 1358, 1362 (Fed. Cir.
`2007)
`
`6
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`‘463 Patent –Claim 2
`2. A cruise control system for a variable speed vehicle controlled by a human
`operator, comprising:
`(a) a speed controller for automatically maintaining the vehicle at a substantially
`constant cruising speed selected by the operator;
`(b) a cruise control enable switch associated with the controller for enabling and
`disabling the controller;
`(c) a set speed input in communication with the controller for selecting the
`cruising speed of the vehicle when the controller is enabled;
`(d) a memory that stores information representative of the selected cruising
`speed; and
`(e) a feedback system that substantially continuously communicates the
`selected cruising speed information to the operator of the vehicle until either
`the operator selects a subsequent cruising speed or the controller is disabled.
`
`7
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`Petition’s allegations regarding “selected cruising
`speed information”
`• Petition alleges that “the selected cruising speed
`information” is communicated by green LEDs at speed
`marks every 10 km/h (Pet. at 20)
`
`8
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`‘463 Patent –Claim 12
`12. A method for visually communicating to the human operator of a
`vehicle having a cruise control system a cruising speed at which the
`vehicle is set, comprising:
`determining the speed at which the vehicle is traveling;
`activating the cruise control system at a desired cruising speed;
`control system is activated;
`maintaining the activated cruise control speed symbol upon temporary
`acceleration or deceleration of the vehicle;
`removing said symbol when the cruise control system is deactivated or a
`new cruising speed is selected.
`
`displaying a symbol indicative of the speed at which the cruise
`
`9
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`Petition’s allegations regarding Claim 12
`• Petition relies on the green LEDs as “displaying a symbol
`indicative of the speed at which the cruise control system is
`activated”(Pet. at 24)
`
`10
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`‘463 Patent –Claim 26
`26. A cruise control system for a variable speed vehicle controlled by a human
`operator, comprising:
`a speed controller for automatically maintaining the vehicle at a substantially
`constant preset speed;
`a set speed input in communication with the controller for selecting the preset
`speed;
`a memory device operable to store information representative of the preset speed;
`first visual display apparatus operable to display the indicative of the actual speed
`of the vehicle; and
`visual information indicative of the preset speed.
`
`second visual display apparatus operable to display the visual information
`indicative of an operation status of the speed controller, wherein the visual
`information displayable by the second visual display apparatus includes
`
`11
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`Petition’s allegations regarding Claim 18
`• For all of the “braking” limitations of Claim 18, Petitioner cites only to
`Yoshimitsu’sdiscussion of “Prior Art” (Ex. 1007, p. 3)
`
`12
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`a speed controller for automatically maintaining the vehicle at a
`
`‘463 Patent –Claim 26
`26. A cruise control system for a variable speed vehicle controlled by a human
`operator, comprising:
`substantially constant preset speed;
`a set speed input in communication with the controller for selecting the preset
`speed;
`a memory device operable to store information representative of the preset speed;
`first visual display apparatus operable to display the indicative of the actual speed
`of the vehicle; and
`second visual display apparatus operable to display the visual information
`indicative of an operation status of the speed controller, wherein the visual
`information displayable by the second visual display apparatus includes visual
`information indicative of the preset speed.
`
`13
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`Petition’s allegations regarding Claim 26
`• Petition alleges that the speedometer is the “first visual display
`apparatus” and a combination of the Consign Speed LEDs and the
`Warning Lights are the “second visual display apparatus” (Pet. at 36)
`• Petitioner admits: “Figure 3 illustrates the consign speed LEDs and
`warning lights are two separate visual displays” (Rep. at 12).
`
`14
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`‘463 Patent –Claim 34
`
`34. A method for providing an operator of a vehicle equipped with a cruise control device with
`information reflecting the operating status of the cruise control device, comprising:
`providing a cruise control device including:
`(a) a speed controller for automatically maintaining the vehicle at a substantially constant preset speed;
`(b) a set speed input in communication with the controller for selecting the preset speed;
`(c) a memory device operable to store information representative of the preset speed;
`(d) first visual display apparatus operable to display the indicative of the actual speed of the vehicle; and
`(e) second visual display apparatus operable to display the visual information indicative of an operation
`status of the speed controller, wherein the visual information displayable by the second visual display
`apparatus includes visual information indicative of the preset speed;
`activating the cruise control device; and
`device.
`
`operating the second visual display apparatus to indicate the active status of the cruise control
`
`15
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`Petition’s allegations regarding Claim 34
`• Switching the ON/OFF has nothing to do with “operating the second
`visual display apparatus”
`
`• Citations (pp. 109‐111 which correspond to pp. 6‐8 as numbered in the
`Petition) in the Reply were not in the Petition (Rep. at 13)
`
`16
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
`
`Respectfully submitted,
`John Kasha, Kasha Law
`Lead Counsel for Patent Owner
`
`Cruise Control Technologies LLC - Exhibit
`2002 – Toyota II v. CCT - IPR2014-00291
`
`
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