IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
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`
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`§
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`§
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`Civil Action No. 6:13-cv-309-MHS
`
`JURY TRIAL REQUESTED
`
` Plaintiff,
`
`v.
`
`
`
`Defendants.
`
`
`AMERICAN VEHICULAR SCIENCES
`LLC
`
`
`
`
`
`
`
`
`
`
`MERCEDES-BENZ U.S.
`INTERNATIONAL, INC. AND
`MERCEDES-BENZ USA, LLC
`
`
`AMERICAN VEHICULAR SCIENCES LLC’S PR 3-1 DISCLOSURE OF ASSERTED
`CLAIMS AND INFRINGEMENT CONTENTIONS AND PR 3-2 IDENTIFICATION OF
`DOCUMENT PRODUCTION ACCOMPANYING DISCLOSURE
`
`Pursuant to Local Patent Rules 3-1 and 3-2, Plaintiff American Vehicular Sciences LLC
`
`(“AVS”) hereby provides its Disclosure of Asserted Claims and Infringement Contentions
`
`against Defendants Mercedes-Benz U.S. International, Inc. and Mercedes-Benz USA, LLC
`
`(collectively “Mercedes”) and its Identification of Document Production Accompanying
`
`Disclosure.
`
`AVS presents these Infringement Contentions based on AVS’s analysis of the facts
`
`currently known to it based on AVS’s review of certain publicly available information. AVS’s
`
`statements concerning Mercedes’ accused products are based on publicly available materials
`
`which identify and describe Mercedes’ products that include Lane Keeping Assist, Active Lane
`
`Keeping Assist, Night View Assist Plus, Blind Spot Assist, and/or Active Blind Spot Assist
`
`technology. At this time, AVS has had no discovery to date from Mercedes. Accordingly, AVS
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`1
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`Mercedes-Benz USA, LLC, Petitioner - Ex. 1015
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`

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`reserves the right to supplement or alter its disclosure herein based on additional information
`
`obtained through formal discovery or other means concerning Mercedes’ products.
`
`I.
`
`INFRINGED CLAIMS- P.R. 3-1(a)
`
`AVS asserts that Mercedes infringe directly, contributorily, and/or by inducement one or
`
`more of the flowing claims:
`
`Claims 1, 2, 4, 7, 30, 31, 40, 41, 43, 46, 56, 59, 60, 61, 62, 77, 78, 81, 82, and 83 of U.S.
`
`Patent No. 6,772,057 (“the ’057 Patent”).
`
`AVS has identified these claims based on information currently known to it. Other claims
`
`of the asserted patents include limitations based on certain discrete components of the claimed
`
`apparatus or certain discrete steps of the claimed method that AVS has been unable to
`
`definitively determine based on information currently known to AVS. AVS, however, believes
`
`that discovery and further investigation may likely identify such additional claims that are
`
`infringed by the Accused Instrumentalities or use thereof, and AVS accordingly reserves the
`
`right to supplement its identification of claims and other disclosures in the course of discovery or
`
`further investigation.
`
`II.
`
`
`INDENTIFICATION OF ACCUSED INSTRUMENTALITIES AND CLAIM
`CHARTS- P.R 3-1(b)-(c)
`
`Based on present information and belief, AVS contends that the Asserted Claims are
`
`infringed by Mercedes motor vehicles of various versions and model years (“Mercedes
`
`Vehicles”), having the functionality described in the provided claim charts that have been made,
`
`used, sold, offered for sale, or imported by Mercedes and/or that have otherwise been used as
`
`intended by Mercedes (“Accused Instrumentalities”).
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`2 
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`2
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`Attached as Exhibit A, and incorporated herein in their entirety, is a chart identifying
`
`where each element of the Asserted Claims is met by various features or functionalities
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`possessed by a representative Mercedes Vehicle or implicated by the use of Mercedes Vehicles
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`(Accused Instrumentalities). In certain instances, the claim charts identify the features and
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`functionality by a Feature or Option name that AVS has determined Mercedes uses for the
`
`described features and functionalities. Other Features or Options with different names may be
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`used within or by Mercedes to describe the same or similar features and functionalities.
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`Similarly, in certain instances, the claim charts identify certain models of Mercedes Vehicles that
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`AVS has determined possess the described features and functionalities. AVS has not, however,
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`determined every model and model version that possesses the described features and
`
`functionalities, nor has AVS determined for each model and model version the model years in
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`which the model and model versions possessed the described features and functionalities. The
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`descriptions of the features and functionalities in the provided claim charts provide Mercedes
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`with sufficient information to identify the Features and Options implicated by AVS’s contentions
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`as well as the Models and Model Versions and their associated Model Years implicated by
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`AVS’s contentions.
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`AVS contends that any other Accused Instrumentality functions and/or operates in
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`substantially the same manner as shown in the representative chart, thereby infringing the
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`Asserted Claims. Unless otherwise indicated, the information provided that corresponds to each
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`claim element is considered to indicate that each claim element is found within each of the
`
`models and/or versions of Mercedes’ Accused Instrumentalities (see Exhibit A).
`
`As described further in the provided claim chart, Exhibit A, AVS accuses various
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`Mercedes Vehicles (various model years and trim levels) equipped with Lane Keeping Assist,
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`3 
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`3
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`Active Lane Keeping Assist, Night View Assist Plus, Blind Spot Assist, and/or Active Blind
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`Spot Assist technology including A-Class, B-Class, C-Class, CL-Class, CLA-Class, CLS-Class,
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`E-Class, GL-Class, GLK-Class, M-Class, S-Class, and SL-Class vehicles of infringing at least
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`claims 1, 2, 4, 7, 30, 31, 40, 41, 43, 46, 56, 59, 60, 61, 62, 77, 78, 81, 82, and 83 of the ’057
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`Patent.
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`III. IDENTIFICATION OF TYPE OF INFRINGEMENT ASSERTED- P.R 3-1(d)
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`At this time, AVS knows of no specific limitations of the asserted claims where
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`infringement depends on the doctrine of equivalents. AVS expressly reserves the right to
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`modify, augment, and/or supplement its assertion of infringement under the doctrine of
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`equivalents of any elements of any of the asserted claims after discovery from Mercedes and/or
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`third parties and/or after this Court has set forth its construction of the asserted claims.
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`IV. PRIORITY DATES OF ASSERTED CLAIMS -P.R. 3-1(e)
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`U.S. Patent Application No. 10/302,105 filed on November 22, 2002 resulted in the ’057
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`Patent. The 10/302,105 application claims priority to U.S. Patent Application No. 08/474,786
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`filed on June 7, 1995, now U.S. Patent No. 5,845,000. Claims 1, 2, 4, 7, 8, 30, 31, 40, 41, 43, 46,
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`56, 59-62, 77, 78, 81, 82, and 83 of the ’057 Patent have an effective filing date of June 7, 1995.
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`V. PLAINTIFF'S PRODUCTS- P.R. 3-1(f)
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`AVS is not presently relying on any assertion that its own apparatus, product, device,
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`process, method, act, or other instrumentality practices the claimed inventions.
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`VI. DOCUMENT PRODUCTION ACCOMPANYING DISCLOSURE
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`Pursuant
`
`to Patent Rule 3-2, AVS hereby provides
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`its Document Production
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`Accompanying Disclosure along with an identification of the categories to which each of the
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`documents corresponds.
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`4 
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`4
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`A. Documents Responsive to P.R. 3-2(a)
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`AVS is presently unaware of any relevant, non-privileged documents responsive to P.R.
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`3-2(a). AVS will supplement this response should any relevant, non-privileged documents be
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`identified in the future.
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`B. Documents Responsive to P.R. 3-2(b)
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`AVS is presently unaware of any relevant, non-privileged documents responsive to P.R.
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`3-2(b). AVS will supplement this response should any relevant, non-privileged documents be
`
`identified in the future.
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`C. Documents Responsive to P.R. 3-2(c)
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`Pursuant to P.R. 3-2(c), copies of the file histories of the five AVS patents asserted in
`
`Action Nos. 6:13cv307-MHS, 6:13cv308-MHS, 6:13cv309-MHS, and 6:13cv310-MHS, as well
`
`as the file histories for patents to which they are related and/or claim priority, are being
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`concurrently produced in all actions under Bates Numbers AVSFH0000000l - AVSFH00058395.
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`VII. CONCLUSION
`
`The information contained in these disclosures is based on AVS’s analysis of the facts
`
`currently known to it based on AVS’s review of publicly information reasonably available to it.
`
`Pertinent information about Mercedes’ Accused Instrumentalities is not available without
`
`engaging in further discovery. Thus, AVS reserves the right to supplement, modify, and/or
`
`amend these disclosures as new information becomes available and discovery progresses. AVS
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`anticipates that additional facts and relevant documents will be uncovered that will warrant
`
`supplementing and/or amending these disclosures.
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`5 
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`DATED: July 22, 2013
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`Respectfully submitted,
`
`
`
`/s/ Miranda Y. Jones
`Michael F. Heim (Texas Bar No. 09380923)
`Miranda Y. Jones (Texas Bar No.
`24065519)
`Robert A. Bullwinkel (Texas Bar No.
`24064327)
`HEIM, PAYNE & CHORUSH, LLP
`600 Travis, Suite 6710
`Houston, TX 77002
`Tel: 713-221-2000
`Fax: 713-221-2021
`
`Wesley Hill
`State Bar No. 24032294
`T. John Ward, Jr.
`State Bar No. 00794818
`WARD & SMITH LAW FIRM
`1127 Judson Road, Suite 220
`Longview, Texas 75601
`Tel: 903-757-6400
`Fax: 903-757-2323
`
`ATTORNEYS FOR PLAINTIFF
`AMERICAN VEHICULAR SCIENCES
`LLC
`
` 
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`6 
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that all counsel of record are being served with a copy
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`of this document by e-mail on July 22, 2013.
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`
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`
`
`/s/ Miranda Y. Jones
`Miranda Y. Jones
`
`
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`14881-v1/1079-0010
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`7
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` 
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`EXHIBIT A
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` 
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`
`
`EXHIBIT A
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`1
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`8
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`EXHIBIT A
`
`Infringement Claim Chart for U.S. Patent No. 6,772,057
`
`The Features/Options primarily relied upon in this chart are referred to by Mercedes as Lane Keeping Assist, Active Lane Keeping Assist,
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` 
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` 
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`Blind Spot Assist, and/or Active Blind Spot Assist technology. On present information and belief, AVS understands Lane Keeping Assist, Active
`
`Lane Keeping Assist, Blind Spot Assist, and/or Active Blind Spot Assist technology are/have been offered either as a stand-alone feature/option on
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`Mercedes-branded vehicles or as part of other packages. Further, on information and belief, AVS understands that this technology as provided on
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`various Mercedes-branded vehicles operates identically or substantially in the same manner for all such Mercedes-branded vehicles, at least with
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`respect to the elements of the asserted claims. Accordingly, this chart may rely on information obtained with respect to the use of these systems in
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`specific Mercedes-branded vehicles.
`
`To the extent discovery later shows that operation of this technology differs between different Mercedes-branded vehicle models or model
`
`years, at least with respect to the elements of the asserted claims, AVS reserves the right to amend or further supplement these contentions with
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`additional information learned in the course of discovery or further investigation. Moreover, based on AVS’s current information, the full extent to
`
`which these systems interact with or work in conjunction with or in parallel to other Mercedes systems, is not known. Such “interactions,” if
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`determined to exist in discovery or further investigation, could provide alternative bases for infringement of the identified claims or bases for
`
`infringement of additional claims. For all these reasons, AVS reserves the right to amend or further supplement these contentions with additional
`
`information learned in the course of discovery or further investigation
`
`Based on the information presently available to it, AVS contends that Mercedes directly infringes United States Patent No. 6,772,057 (“the
`
`’057 Patent”) by making, using, selling or offering to sell within the United States, or importing into the United States, Mercedes-branded vehicles
`
`2
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`9
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`

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`that include A-Class, B-Class, C-Class, CL-Class, CLA-Class, CLS-Class, E-Class, GL-Class, GLK-Class, M-Class, S-Class, and SL-Class vehicles
`
`that include Lane Keeping Assist, Active Lane Keeping Assist, Night View Assist Plus, Blind Spot Assist, and/or Active Blind Spot Assist
`
`technology (“Accused Instrumentalities”). AVS also contends that Mercedes indirectly infringes the ’057 Patent by actively inducing and
`
`contributing to its customers’ direct infringement of the asserted claims.
`
`’057 Claim 1
`
`1. [pre] Amonitoring
`arrangement for
`monitoringan
`environment exterior of
`avehicle, comprising:
`
`information and belief, AVS contends that the Accused Instrumentalities include a monitoring
`Based on present
`arrangement for monitoring an environment exterior of a vehicle.
`
`Elements in Accused Instrulnentali
`
`See hm;://techcenter.mercedes-benz.com/en/lane keeping assist/detail.html
`See hm;://techcenter.mercedes-benz.com/en/active lane keeping assist/detail.html
`See hm;://techcenter.mercedes-benz.com/en/blind spot assist/detail.htn1l
`See ht_tp://techcenter.mercedes-benz.com/en/active blind spot assist/detail.ht1nl
`Seeh
`://techcenter.mercedes-benz.com/en/ni
`tview lus with s otli
`t/detail.ht1n1
`
`[a] at least one receiver Based on present information and belief, AVS contends that the Accused Instrumentalities include at least one receiver
`arranged to receive
`arranged to receive waves from the environment exterior of the vehicle which contain information on any objects in the
`waves from the
`environment and generate a signal characteristic of the received waves.
`environment exterior of
`
`the vehicle which
`contain information on
`any objects in the
`environment and
`generate a signal
`characteristic of the
`
`received waves; and
`
`“Our driver assistance systems utilize technologies such as cameras, radar, and infrared.”
`hflps://wwwyoutube.com/watch?v=thNLg Tasgs (0:38-41)
`
`Lane Keeping Assist and Active Lane Keeping Assist technology use a camera to receive waves that contain
`information on, e.g., the road surface and boundary lines. The cameras generate a signal characteristic of these
`waves.
`
`See hm;://techcenter.mercedes-benz.com/en/lane keeping assist/detail.html
`See ht_tp://techcenter.mercedes-benz.com/en/active lane keeping assist/detail.html
`
`10
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`

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`Lane Keeping Assist
`
`1 Lane Keeping Assist camera
`
`Lane Keeping Assist (vehicles with Lane Tracking package)
`Lane Keeping Assist monitors the area in front ofyour vehicle by means of camera 1 attne top ofthe windscreen. Lane Keeping
`Assist detects lane markings on the road and warns you before you leave your lane unintentionally.
`
`Seeh
`
`://www4.mercedes—benz.com/manual-cars/ba/cars/w166/en/overview/fahrs steme7.hlml
`
`11
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`

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`Active Lane Keeping Assist
`
`1 Active Lane Keeping Assist camera
`
`Active Lane Keeping Assist (vehicles with Active Driving Assistance package]:
`Active Lane Keeping Assist monitors the area in front ofyour vehicle by means of a camera atthe top oftne windscreen.
`Active Lane Keeping Assist detects lane markings on the road and warns ‘you before you leave your lane unintentionally.
`if you do not react to the warning. 3 lane-correcting application ofthe brakes can bring the vehicle back into the original lane.
`
`hm;://www4.mercedes-benz.com/manual-cars/ba/cars/w1 66/en/overviewlfahrsysteme8 .hlml
`
`The camera and image processing system “detect[s] road markings by evaluating the difference in contrast
`between the road surface and the markings.”
`o ://www.benzinsider.com/2008/1 1/mercedes-benz-tecda
`
`12
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`

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`’057 Claim 1
`
`Elements in Accused Instnunentali
`
`Seeh
`
`://www.dail
`
`otion.com/video/xl4shl mercedes-benz-active-lane-kee in -assist-technolo
`
`auto
`
`Blind Spot Assist and Active Blind Spot Assist use “close-range radar sensors to detect vehicles.” The radars
`generate a signal characteristic of these waves.
`hm;://techcenter.mercedes—benz.com/en/blind spot assist/detail.htn1l
`
`Blind Spot Assist and Active Blind Spot Assist “employ[] six short-range radar sensors located in the front and
`rear bumpers that monitor the zone to the side and rear of the car on both the lefi and the righ .”
`hm;://wWw.autoblog.com/2007/09/28/mercedes-benz-adds-radar-based-blind-spot-assist/
`
`13
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`

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`’057 Claim 1
`
` .
`
`Elements in Accused Instrumentali
`
`E
`
`
`
`h
`
`I
`
`-I1 ml:-x In-n/\\
`\
`
`I28
`
`hmgs://wwwyoutube.com/watch?v=thNLg Tasggs
`
`Night View Assist Plus technology uses an infrared camera to receive waves that contain information on, e.g.,
`objects in the surrounding environment. The infrared receiver generate a signal characteristic of these waves.
`h
`://techcenter.mercedes-benz.com/en/ni
`t view lus with s otli
`t/detai1.html
`
`14
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`

`
`’057 Claim 1
`
`Night View Assist Plus camera
`
`1 Night View Assist Plus camera
`
`lligtit View Assist Plus
`ln addition to the illumination provided try‘ the normal headlamps, Night View Assist Plus uses infrared light to illuminate the road.
`Night View Assist Plus camera 1 picks up the infrared light and displays a greyscale image in the COMAND display. This enables
`you to see the roads course and any obstacles in good time. If pedestrian recognition is activated. pedestrians recognised oythe
`system are highlighted in the Night View Assist Plus disp~la'y.
`
`h
`
`://www4.mercedes-benz.com/manual-cars/ba/cars/w166/en/overview/fahrs steme4.html
`
`[b] a processor coupled
`to said at least one
`
`receiver and comprising
`trained pattern
`recognition means for
`processing the signal to
`provide a classification,
`identification or
`location of the exterior
`
`Based on present information and belief, AVS contends that the Accused Instrumentalities include a processor coupled to
`said at least one receiver and comprising trained pattern recognition means for processing the signal to provide a
`classification, identification or location of the exterior object, said trained pattern recognition means being structured and
`arranged to apply a trained pattern recognition algorithm generated from data of possible exterior objects and patterns of
`received waves from the possible exterior objects to provide the classification, identification or location of the exterior
`object.
`
`Lane Keeping Assist and Active Lane Keeping Assist use an electronic control unit to identify boundary lines on the road
`surface.
`
`15
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`

`
`Elements in Accused Instrumentali
`
`See hm;://techcenter.mercedes-benz.com/en/lane keeping assist/detail.ht1nl
`See h
`://techcenter.mercedes-benz.com/en/active lane kee in
`assist/detail.htrnl
`
`The camera and image processing system “detect[s] road markings by evaluating the difference in contrast between the
`road surface and the markings.”
`See h
`://www.benzinsider.com/2008/11/mercedes-benz-tecda -lane—kee in -assist/.
`
`object, said trained
`pattern recognition
`means being structured
`and arranged to apply a
`trained pattern
`recognition algorithm
`generated from data of
`possible exterior
`objects and patterns of
`received waves from
`
`the possible exterior
`objects to provide the
`classification,
`identification or
`location of the exterior
`
`object;
`
`See ://www.dail
`
`otion.com/video/xl4sh1 mercedes—benz—active—lane-kee in —assist-technolo
`
`auto
`
`“The image-processing system sends data to an electronic control unit, which determines the position of the car
`
`and detects when it leaves its lane on the left or right.”
`
`hgp://www.benzinsider.com/2008/1 1/mercedes-benz-tecday-lane-keeping-assisfl
`
`Blind Spot Assist and Active Blind Spot Assist use “close-range radar sensors to detect vehicles.” A processor will
`receive and process the signals to determine whether there is a vehicle located in the blind spot. “The warning area
`extends approx. 3.5 m to either side of the vehicle and 3 m beyond the rear end. Detected vehicles which are overtaking
`are indicated immediately after entering the monitoring zone when the relative speed difference between the vehicles does
`not exceed 16 krn/h. Vehicles which have just been overtaken are indicated following a delay of 1.5 seconds after entering
`
`16
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`

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`’057 Claim 1
`
`Elements in Accused Instrumentali
`
`the monitored zone. This avoids disturbing, unintended warnings.”
`hm://techcenter.mercedes-benz.com/en/blind spot assist/detail.ht1nl
`
`\
`
`'l‘| ml:-x lwn/\_\
`\
`
`I28
`
`hgps://wwwyoutube.com/watch?v=thNLg TasQs
`
`Night View Plus detects, e. g., pedestrians and on-coming cars. “Persons on the carriageway can be detected and flashed
`up over a range of up to 80 m. The complex control soflware of NIGHT VIEW ASSIST PLUS directs the spotlight at
`detected persons. The control software also detects vehicles ahead or oncoming vehicles with their lights on and prevents
`the flashing spotlight function from dazzling these motorists. When travelling at approx. 70 km/h, test drivers recognised
`a pedestrian on average 25 metres or 1.3 seconds earlier than without the spotlight function — seconds that can make all
`the difference.”
`
`ht ://techcenter.mercedes-benz.com/en/nit view lus with sotlit/detail.ht1nl
`
`17
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`

`
`’057 Claim 1
`
`Elements in Accused Instrumentali
`
`[c] whereby a system in Based on present information and belief, AVS contends that in the Accused Instruinentalities, a system in the vehicle is
`the vehicle is coupled
`coupled to said processor such that the operation of the system is affected in response to the classification, identification
`to said processor such
`or location of the exterior object.
`that the operation of the
`system is affected in
`response to the
`classification,
`identification or
`
`“Lane Keeping Assist warns the driver by vibrations on the steering wheel as soon as it detects that the vehicle is
`unintentionally wandering out of its lane.”
`ht_tp://techcenter.mercedes-benz.com/en/lane keeping assist/detail.htn1l
`
`location of the exterior
`object.
`
`“Active Lane Keeping Assist is able to give you a wake-up call and protect you from the serious consequences of
`a collision — if necessary through targeted brake application.”
`hm;://tecl1center.mercedes—benz.com/en/active lane keeping assist/detail.htn1l
`
`“If the system determines that the car is leaving its lane unintentionally, it activates an electric motor, causing the
`steering wheel to vibrate — a discreet yet highly effective way of prompting the driver to countersteer. The timing
`of the warning depends on the width of the road and the type of lane markings. If the car crosses over a continuous
`line on the road, as opposed to a broken one, the system emits its warning earlier.”
`h
`://www.benzinsider.com/2008/11/mercedes—benz-tecda -lane-kee in -assist
`
`Lane Keeping Assist and Active Lane Keeping Assist may also apply the brakes.
`h
`s://www. outube.com/watch?v=mtNChPi9 4
`
`Lane Keeping Assist and Active Lane Keeping Assist may also display a warning indication:
`
`18
`
`

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`’057 Claim 1
`
`hm}://wwwyoutube.com/watch?v=mtNChPi9 49
`
`Blind Spot Assist “monitors the area which the driver is unable to take in via the mirrors, indicates in the exterior
`mirror when vehicles are located in this zone and additionally sounds an acoustic warning when the driver
`activates the indicator. .
`.
`. “hen the system detects another vehicle, this is indicated to the driver by a red warning
`triangle which lights up in the relevant exterior mirror. An acoustic warning will additionally sound if the indicator
`is activated despite the visual warning.”
`h
`://techcenter.mercedes-benz.com/en/blind s ot assist/detail.ht1nl
`
`h
`
`://techcenter.mercedes-benz.com/en/active blind s ot assist/detail.html
`
`“The Active Blind Spot Assist intervenes if you do not react to the signal, using the electronic stability program
`ESB to brake.”
`
`hgps://www.youtube.com/watch?v=thNLg Tasgs (1:38-44)
`
`19
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`

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`’057 Claim 1
`
`Elements in Accused Instrumentali
`
`Night View Plus can “present the night—time road scene on the display, indicating identified persons; optionally, a
`spotlight can flash up pedestrians at the side of the road. .
`.
`. The spotlight function is activated at a speed of 45
`km/h when the automatic light fimctions and NIGHT VIEW ASSIST PLUS are on. An additional aperture in the
`projection module of one headlamp enables selective light distribution for the spotlight fimction”
`
`htt
`
`://techcente1‘.1ne1‘cedes-benz.co111/en/ni
`
`t view l11s with s otli
`
`mm IHl'l"( ml:-x |u-n/ l\
`
`hflps://wwwyoutube.co1n/watch?v=thNLg Tasg gs
`
`’057 Claim 2
`
`Elements in Accused Instrumentali
`
`1 3
`
`20
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`

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`’057 Claim 2
`
`2. The arrangement of
`claim 1, wherein said at
`least one receiver
`comprises a pair of
`receivers spaced apart
`from one another.
`
`’057 Claim 4
`
`4. The arrangement of
`claim 1, wherein the
`monitoring
`arrangement further
`comprises a transmitter
`for transmitting waves
`into the environment
`exterior of the vehicle
`
`whereby said at least
`one receiver is arranged
`to receive waves
`
`transmitted by said
`transmitter and
`
`reflected by any
`exterior ob'ects.
`
`’057 Claim 7
`
`7. The arrangement of
`claim 1, wherein the
`another system is a
`display viewable by the
`driver and arranged to
`show an irna - e or icon
`
`Based on present information and belief, AVS contends that the Accused Instrurnentalities include a pair of receivers
`spaced apart from one another. For example, cameras are located inside the windscreen. Radars are located on the
`bumpers.
`
`Elements in Accused Instrumentali
`
`See claim 1.a.
`
`Based on present information and belief, AVS contends that the Accused Instrmnentalities further comprises a transmitter
`for transmitting waves into the environment exterior of the vehicle whereby said at least one receiver is arranged to
`receive waves transmitted by said transmitter and reflected by any exterior objects.
`
`Elements in Accused Instrumentali
`
`The close range radar sensors used in Blind Spot Assist and Active Blind Spot Assist transmit and then receive reflected
`radar waves.
`
`See claim 1.a.
`
`Based on present information and belief, AVS contends that the Accused Instrumentalities include a display viewable by
`the driver and arranged to show an image or icon of the exterior object (e.g., the lane, the vehicle in the blind spot, or a
`pedestrian).
`
`Elements in Accused Instrumentali
`
`See claim 1.c.
`
`21
`
`

`
`’057 Claim 7
`
`Elements in Accused Instrumentali
`
`
`
`Based on present information and belief, AVS contends that the Accused Instrumentalities comprise a vehicle.
`
`Elements in Accused Instrumentali
`
`See claim 1 preamble.
`
`’057 Claim 30
`
`30. [pre] A vehicle
`including a monitoring
`arrangement for
`monitoring an
`environment exterior of
`
`the vehicle, the
`
`monitoring
`arrangement
`com risin :
`
`[a] at least one receiver Based on present information and belief, AVS contends that the Accused Instrumentalities comprise at least one receiver
`arranged on a rear view arranged on a rear view mirror of the vehicle to receive waves from the environment exterior of the vehicle which contain
`mirror of the vehicle to
`information on any objects in the enviromnent and generate a signal characteristic of the received waves
`receive waves from the
`
`environment exterior of See claim l.a’s description of Lane Keeping Assist, Active Lane Keeping Assist, and Night View Plus, which use a
`the vehicle which
`receiver arranged on a rear View mirror of the vehicle.
`contain information on
`
`any objects in the
`environment and
`
`generate a signal
`characteristic of the
`
`received waves; and
`
`[b] a processor coupled Based on present infonnation and belief, AVS contends that the Accused Instrumentalities comprise a processor coupled
`to said at least one
`to said at least one receiver and arranged to classify or identify the exterior object based on the signal and thereby provide
`receiver and arranged
`the classification or identification of the exterior object.
`to classify or identify
`the exterior object
`based on the signal and
`thereby provide the
`classification or
`identification of the
`
`See claim 1.b’s description of Lane Keeping Assist, Active Lane Keeping Assist, and Night View Plus.
`
`exterior obiect;
`
`22
`
`

`
`’057 Claim 30
`
`Elements in Accused Instrumentali
`
`[c] whereby a system in Based on present information and belief, AVS contends that in the Accused Instrumentalities, a system in the vehicle is
`the vehicle is coupled
`coupled to said processor such that the operation of the system is affected in response to the classification or identification
`to said processor such
`of the exterior object.
`that the operation of the
`system is affected in
`response to the
`classification or
`identification of the
`exterior ob'ect.
`
`See claim 1.c’s description of Lane Keeping Assist, Active Lane Keeping Assist, and Night View Plus.
`
`Elements in Accused Instrulnentali
`
`Based on present information and belief, AVS contends that the Accused Instrumentalities comprise trained pattern
`recognition means for processing the signal to provide the classification or identification of the exterior object, said
`trained pattem recognition means being structured and arranged to apply a pattern recognition algorithm generated from
`data of possible exterior objects and patterns of received waves from the possible exterior objects.
`
`See claim l.b’s description of Lane Keeping Assist, Active Lane Keeping Assist, and Night View Plus.
`
`31. The vehicle of
`claim 30, wherein said
`processor comprises
`trained pattern
`recognition means for
`processing the signal to
`provide the
`classification or
`identification of the
`
`exterior object, said
`trained pattern
`recognition means
`being structured and
`arranged to apply a
`pattern recognition
`algorithm generated
`fiom data of possible
`exterior objects and
`patterns of received
`waves from the
`
`possible exterior
`ob'ects.
`
`23
`
`

`
`’057 Claim 40
`
`40. [pre] A monitoring
`arrangement for
`monitoring an
`environment exterior of
`
`a vehicle, com risin :
`[a] a plurality of
`receivers arranged apart
`from one another and to
`receive waves from
`
`different parts of the
`environment exterior of
`the vehicle which
`contain infonnation on
`
`any objects in the
`environment and
`
`generate a signal
`characteristic of the
`
`received waves; and
`
`[b] a processor coupled
`to said receivers and
`
`arranged to classify,
`identify or locate the
`exterior object based on
`the signals generated by
`said receivers and
`
`thereby provide the
`classification
`identification or
`location of the exterior
`
`object,
`[c] whereby a system in
`the vehicle is coupled
`to said processor such
`that the operation of the
`s stem is affected in
`
`information and belief, AVS contends that the Accused Instnnnentalities include a monitoring
`Based on present
`arrangement for monitoring an environment exterior of a vehicle.
`
`Elements in Accused Instrulnentali
`
`See claim 1 preamble.
`
`Based on present information and belief, AVS contends that the Accused Instlumentalities comprise a plurality of
`receivers arranged apart from one another and to receive waves from different parts of the environment exterior of the
`vehicle which contain information on any objects in the environment and generate a signal characteristic of the received
`waves.
`
`The plurality of receivers include cameras and short-range radar sensors, which are arranged in different locations and
`receive waves from different parts of the environment.
`
`See claim 1.a.
`
`Based on present information and belief, AVS contends that the Accused Instrumentalities comprise a processor coupled
`to said receivers and arranged to classify, identify or locate the exterior object based on the signals generated by said
`receivers and thereby provide the classification, identification or location of the exterior object.
`
`See claim 1.b.
`
`Based on present information and belief, AVS contends that in the Accused Instrumentalities, a system in the vehicle is
`coupled to said processor such that the operation of the system is affected in response to the classification, identification
`or location of the exterior object.
`
`See claim 1.c.
`
`24
`
`

`
`’057 Claim 40
`
`response to the
`classification,
`identification or
`location of the exterior
`ob'ect.
`
`Elements in Accused Instrumentali
`
`Elements in Accused Instrnmentali
`
`41. The arrangement of Based on present information and belief, AVS contends that the Accused Instrumentalities comprise trained pattern
`claim 40, wherein said
`recognition means for processing the signal to provide the classification, identification or location of the exterior object,
`processor comprises
`said trained pattern recognition means being structured and arranged to apply a trained pattern recognition algorithm
`trained pattern
`generated from data of possible exterior objects and patterns of received waves from the possible exterior objects.
`recognition means for
`processing the signal to
`provide the
`classification,
`identification or
`location of the exterior
`
`See claim 1.b.
`
`object, said trained
`pattern recognition
`means being structured
`and arranged to apply a
`trained pattern
`recognition algorithm
`generated from data of
`possible exterior
`objects and patterns of
`received waves from
`
`the possible exterior
`ob'ects.
`
`Elements in Accused Instrumentality
`’057 Claim 43
`43. The arrangement of Based on present infonnation and belief, AVS contends that the Accused Instrumentalities comprise a transmitter for
`claim 40, whe