48  
`
`
`
`for said vehicle are increasing and road speed and engine speed for said vehicle are decreasing.
`activates said fuel overinjection notification circuit if both throttle position and manifold pressure
`On information and belief, the accused Audi vehicles include a processor subsystem that
`See, e.g., citations for claim element 4E.
`
`
`
`
`
`is decreasing.
`The accused Audi vehicles include a means for determining when engine speed for said vehicle
`See, e.g., citations for claim element 4D.
`
`
`
`vehicle is increasing.
`The accused Audi vehicles include a means for determining when manifold pressure for said
`See, e.g., citations for claim element 2C.
`
`
`
`vehicle is increasing.
`The accused Audi vehicles include a means for determining when throttle position for said
`See, e.g., citations for claim element 4B.
`
`The accused Audi vehicles  include a means for determining when road speed for said vehicle is
`
`See, e.g., citations for claim 1.
`
`to claim 7 wherein said processor subsystem further comprises:
`The accused Audi vehicles include an apparatus for optimizing operation of a vehicle according
`
`Corresponding Element in Audi Vehicles
`
`
`
`
`
`decreasing.
`
`
`
`and
`said vehicle is increasing;
`when throttle position for
`12C. means for determining
`vehicle is decreasing;
`when road speed for said
`12B. means for determining
`comprises:
`subsystem further
`wherein said processor
`vehicle according to claim 7
`optimizing operation of a
`12A. Apparatus for
`Claim 12
`
`
`
`
`
`and
`said vehicle is increasing;
`when manifold pressure for
`12D. means for determining
`
`vehicle is decreasing;
`when engine speed for said
`12E. means for determining
`
`notification circuit if both
`fuel overinjection
`subsystem activating said
`12F. said processor
`
`
`
`
`
`VWGoA - Ex. 1008 - Part II
`Volkswagen Group of America, Inc., Petitioner
`Case No. IPR2015-00276
`701
`
`

`
`49  
`
`
`
`Corresponding Element in Audi Vehicles
`
`See, e.g., citations for claim elements 1E, 1G.
`
`
`
`
`
`
`decreasing.
`for said vehicle are
`road speed and engine speed
`vehicle are increasing and
`manifold pressure for said
`throttle position and
`Claim 12
`
`
`
`
`
`702
`
`

`
`The accused Audi vehicles  include a plurality of sensors coupled to the vehicle having an engine,
`
`The accused Audi vehicles include an apparatus for optimizing operation of a vehicle.
`
`Corresponding Element in Audi Vehicles
`
`processor subsystem, said fuel overinjection notification circuit issuing a notification that
`The accused Audi vehicles include a fuel overinjection notification circuit coupled to said
`
`50  
`
`present and prior levels for each one of said plurality of sensors.
`memory subsystem storing therein a manifold pressure set point, an engine speed set point, and
`The accused Audi vehicles have a memory subsystem, coupled to said processor subsystem, said
`
`See, e.g., citations for claim element 1D.
`
`
`
`
`
`of sensors, to receive data therefrom.
`The accused Audi vehicles include a processor subsystem, coupled to each one of said plurality
`
`
`
`See, e.g., citations for claim element 1C.
`
`
`
`speed sensor, an engine speed sensor, a manifold pressure sensor and a throttle position sensor
`said plurality of sensors, which collectively monitor operation of said vehicle, including a road
`
`See, e.g., citations for claim element 1B.
`
`
`
`
`
`See, e.g., citations for claim 1.
`
`
`
`
`
`notification circuit coupled
`13E. a fuel overinjection
`of sensors;
`for each one of said plurality
`and present and prior levels
`an engine speed set point,
`manifold pressure set point,
`subsystem storing therein a
`subsystem, said memory
`coupled to said processor
`13D. a memory subsystem,
`therefrom;
`sensors, to receive data
`one of said plurality of
`subsystem, coupled to each
`13C. a processor
`throttle position sensor;
`pressure sensor and a
`speed sensor, a manifold
`speed sensor, an engine
`vehicle, including a road
`monitor operation of said
`sensors, which collectively
`an engine, said plurality of
`coupled to a vehicle having
`13B. a plurality of sensors
`vehicle, comprising:
`optimizing operation of a
`13A. Apparatus for
`Claim 13
`
`
`
`
`
`703
`
`

`
`51  
`
`upshift notification circuit and said downshift notification circuit.
`received from said plurality of sensors, when to activate said fuel overinjection circuit, said
`The accused Audi vehicles include a processor subsystem that determines based upon data
`
`See, e.g., citations for claim element 1G.
`
`
`
`
`
`vehicle is being operated at an insufficient engine speed; and
`subsystem, said downshift notification circuit issuing a notification that said engine of said
`The accused Audi vehicles include a downshift notification circuit coupled to said processor
`
`
`
`See, e.g., citations for claim element 7F.
`
`
`
`is being operated at an excessive speed.
`subsystem, said upshift notification circuit issuing a notification that said engine of said vehicle
`The accused Audi vehicles include an upshift notification circuit coupled to said processor
`
`See, e.g., citations for claim element 1F.
`
`
`
`
`
`Corresponding Element in Audi Vehicles
`
`excessive fuel is being supplied to said engine of said vehicle.
`
`See, e.g., citations for claim element 1E.
`
`
`
`
`
`
`
`circuit, said upshift
`said fuel overinjection
`sensors, when to activate
`from said plurality of
`based upon data received
`subsystem determining,
`13H. said processor
`and
`an insufficient engine speed;
`vehicle is being operated at
`that said engine of said
`circuit issuing a notification
`said downshift notification
`to said processor subsystem,
`notification circuit coupled
`13G. a downshift
`excessive speed;
`being operated at an
`said engine of said vehicle is
`issuing a notification that
`upshift notification circuit
`processor subsystem, said
`circuit coupled to said
`13F. an upshift notification
`engine of said vehicle;
`fuel is being supplied to said
`notification that excessive
`notification circuit issuing a
`said fuel overinjection
`to said processor subsystem,
`
`Claim 13
`
`704
`
`

`
`52  
`
`
`
`
`
`Corresponding Element in Audi Vehicles
`
`
`
`
`circuit.
`downshift notification
`notification circuit and said
`
`Claim 13
`
`
`
`705
`
`

`
`vehicle is increasing.
`The accused Audi vehicles include a means for determining when throttle position for said
`Subsystem 12.
`the ’781 patent relating to Road Speed Sensor 18, Memory Subsystem 14, and Processor
`is increasing or decreasing” are described in, for example, Figures 1 and 2 and associated text of
`materials(s) that perform the claimed function of “determining when road speed for said vehicle
`To the extent that 35 U.S.C. §112(6) applies to this claim limitation, the structure(s), act(s), or
`
`to claim 13 wherein said processor subsystem further comprises:
`The accused Audi vehicles include an apparatus for optimizing operation of a vehicle according
`
`Corresponding Element in Audi Vehicles
`
`
`
`
`
`The accused Audi vehicles  include a means for determining when road speed for said vehicle is
`
`
`
`See, e.g., citations for claim 1.
`
`See, e.g., citations for claim element 2B.
`
`increasing or decreasing.
`
`
`
`
`
`pressure set point.
`The accused Audi vehicles include a means for comparing manifold pressure to said manifold
`See, e.g., citations for claim element 2C.
`
`
`
`
`
`The accused Audi vehicles include a means for comparing engine speed to said RPM set point.
`See, e.g., citations for claim element 2D.
`
`15F. means for determining The accused Audi vehicles include a means for determining when manifold pressure is
`set point;
`engine speed to said RPM
`15E. means for comparing
`
`See, e.g., citations for claim element 5E.
`
`53  
`
`
`
`
`
`manifold pressure set point;
`manifold pressure to said
`15D. means for comparing
`
`said vehicle is increasing;
`when throttle position for
`15C. means for determining
`
`
`
`
`
`decreasing;
`vehicle is increasing or
`when road speed for said
`15B. means for determining
`
`comprises:
`subsystem further
`13 wherein said processor
`vehicle according to claim
`optimizing operation of a
`15A. Apparatus for
`Claim 15
`
`
`
`706
`
`

`
`On information and belief, the accused Audi vehicles include a processor subsystem that
`
`54  
`
`speed and engine speed for said vehicle are decreasing.
`set or if both throttle position and manifold pressure for said vehicle are increasing and road
`said vehicle are increasing and manifold pressure for said vehicle is above said manifold pressure
`activates said fuel overinjection notification circuit if both road speed and throttle position for
`On information and belief, the accused Audi vehicles include a processor subsystem that
`Subsystem 12.
`text of the ’781 patent relating to RPM Sensor 20, Memory Subsystem 14, and Processor
`vehicle is increasing or decreasing” are described in, for example, Figures 1 and 2 and associated
`materials(s) that perform the claimed function of “determining when engine speed for said
`To the extent that 35 U.S.C. §112(6) applies to this claim limitation, the structure(s), act(s), or
`
`See, e.g., citations for claim elements 1E, 1G.
`
`
`
`
`
`
`
`decreasing.
`The accused Audi vehicles include a means for determining when engine speed is increasing or
`See, e.g., citations for claim element 4D.
`
`Corresponding Element in Audi Vehicles
`
`
`
`increasing.
`
`
`
`
`
`See, e.g., citations for claim element 4E.
`
`
`
`15I. said processor
`decreasing;
`for said vehicle are
`road speed and engine speed
`vehicle are increasing and
`manifold pressure for said
`throttle position and
`pressure set or if both
`above said manifold
`pressure for said vehicle is
`increasing and manifold
`position for said vehicle are
`road speed and throttle
`notification circuit if both
`fuel overinjection
`subsystem activating said
`15H. said processor
`
`increasing or decreasing;
`when engine speed is
`15G. means for determining
`
`increasing;
`when manifold pressure is
`
`Claim 15
`
`707
`
`

`
`55  
`
`
`
`
`
`See, e.g., citations for claim element 10F.
`and both throttle position and manifold pressure for said vehicle are increasing.
`activates said downshift notification circuit if both road speed and engine speed are decreasing
`On information and belief, the accused Audi vehicles include a processor subsystem that
`
`
`
`and engine speed for said vehicle is at or above said RPM set point.
`are increasing, manifold pressure for said vehicle is at or below said manifold pressure set point
`activates said upshift notification circuit if both road speed and throttle position for said vehicle
`
`Corresponding Element in Audi Vehicles
`
`
`
`See, e.g., citations for claim elements 1F, 1G.
`
`
`
`
`
`
`increasing.
`pressure for said vehicle are
`position and manifold
`decreasing and both throttle
`and engine speed are
`circuit if both road speed
`downshift notification
`subsystem activating said
`15J. said processor
`RPM set point; and
`vehicle is at or above said
`engine speed for said
`pressure set point and
`at or below said manifold
`pressure for said vehicle is
`increasing, manifold
`position for said vehicle are
`both road speed and throttle
`upshift notification circuit if
`subsystem activating said
`
`Claim 15
`
`
`
`708
`
`

`
`having an engine and another object in front of the accused vehicles.
`The accused Audi vehicles include a radar detector that determines a distance separating a vehicle
`
`accused vehicles.
`determine a distance separating a vehicle having an engine and another object in front of the
`For example, the accused Audi vehicles include one or more systems with radar detectors that
`
`56  
`
`
`
`
`
`The accused Audi vehicles include an apparatus for optimizing operation of a vehicle.
`
`Corresponding Element in Audi Vehicles
`
`
`
`See, e.g., citations for claim 1.
`
`
`
`
`
`vehicle;
`object in front of said
`having an engine and an
`distance separating a vehicle
`radar detector determining a
`17B. a radar detector, said
`
`
`
`vehicle, comprising:
`optimizing operation of a
`17A. Apparatus for
`Claim 17
`
`
`
`709
`
`

`
`at 109; Audi-7 at 114-15; Audi-9 at 95; Audi-10 at 93).
`(See, e.g., Exhibits Audi-1 at 88; Audi-2 at 101; Audi-3 at 92; Audi-4 at 95; Audi-5 at 86; Audi-6
`
`57  
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`
`
`
`
`
`
`
`
`Corresponding Element in Audi Vehicles
`
`17B1. Audi Adaptive Cruise Control:
`
`Claim 17
`
`
`
`710
`
`

`
`41).
`(See Exhibit Audi-18, 2012 A7 Running Gear and Suspension Systems Self-Study Program at
`
`
`
`
`
`58  
`
`
`
`Corresponding Element in Audi Vehicles
`
`
`
`
`
`Claim 17
`
`711
`
`

`
`(See, e.g., Exhibits Audi-1 at 92; Audi-2 at 105-06; Audi-3 at 96-97; Audi-4 at 99; Audi-5 at 90;
`
`59  
`
`
`
`
`
`Corresponding Element in Audi Vehicles
`
`17B2. Audi Braking Guard:
`
`
`
`
`
`
`
`Claim 17
`
`712
`
`

`
`The accused Audi vehicles include at least one sensor coupled to said vehicle for monitoring
`Audi-5 at 97; Audi-6 at 117; Audi-7 at 130-33; Audi-9 at 106; Audi-10 at 101).
`(See, e.g., Exhibits Audi-1 at 99; Audi-2 at 110; Audi-3 at 101; Audi-3 at 103; Audi-4 at 103;
`
`60  
`
`
`
`
`
`Corresponding Element in Audi Vehicles
`
`Audi-6 at 113; Audi-7 at 127; Audi-9 at 99; Audi-10 at 97).
`
`17B3. Audi Side Assist:
`
`
`
`
`
`
`
`
`
`17C. at least one sensor
`
`Claim 17
`
`713
`
`

`
`at least one sensor, to receive data therefrom.
`The accused Audi vehicles include a processor subsystem, coupled to said radar detector and said
`
`
`
`See, e.g., citations for claim element 1C.
`
`
`
`level for each one of said at least one sensor.
`set point, an RPM set point, a present level for each one of said at least one sensor and a prior
`said memory subsystem storing a first vehicle speed/stopping distance table, a manifold pressure
`The accused Audi vehicles include a memory subsystem, coupled to said processor subsystem,
`
`
`
`that use one or more vehicle speed/stopping distance tables stored in one or more memories.
`For example, on information and belief, the accused Audi vehicles include one or more systems
`
`61  
`
`
`
`
`
`See, e.g., citations for claim elements 1A-1D.
`
`sensor, a throttle position sensor and an engine speed sensor.
`operation thereof, said at least one sensor including a road speed sensor, a manifold pressure
`
`Corresponding Element in Audi Vehicles
`
`See, e.g., citations for claim element 1B.
`
`
`
`
`
`
`
`
`
`sensor;
`each one of said at least one
`sensor and a prior level for
`each one of said at least one
`set point, a present level for
`pressure set point, an RPM
`distance table, a manifold
`vehicle speed/stopping
`subsystem storing a first
`subsystem, said memory
`coupled to said processor
`17E. a memory subsystem,
`data therefrom;
`least one sensor, to receive
`radar detector and said at
`subsystem, coupled to said
`17D. a processor
`engine speed sensor;
`position sensor and an
`pressure sensor, a throttle
`speed sensor, a manifold
`sensor including a road
`thereof, said at least one
`monitoring operation
`coupled to said vehicle for
`
`Claim 17
`
`714
`
`

`
`62  
`
`
`
`
`
`
`
`Corresponding Element in Audi Vehicles
`
`17E1. Audi Adaptive Cruise Control:  
`
`  
`
`
`
`Claim 17
`
`715
`
`

`
`63  
`
`
`
`89; Audi-6 at 111-12; Audi-7 at 118-20; Audi-9 at 97-98; Audi-10 at 95-96).
`(See, e.g., Exhibits Audi-1 at 90-91; Audi-2 at 104; Audi-3 at 95; Audi-4 at 97-98; Audi-5 at 88-
`
`
`
`
`
`  
`
`Corresponding Element in Audi Vehicles
`
`Claim 17
`
`
`
`716
`
`

`
`at 50).
`(See, e.g., Exhibit Audi-19, 2011 A8 Running Gear and Suspension Systems Self-Study Program
`
`64  
`
`
`
`
`
`
`
`
`
`Corresponding Element in Audi Vehicles
`
`
`
`Claim 17
`
`
`
`717
`
`

`
`Audi-6 at 113; Audi-7 at 127; Audi-9 at 99; Audi-10 at 97).
`(See, e.g., Exhibits Audi-1 at 92; Audi-2 at 105-06; Audi-3 at 96-97; Audi-4 at 99; Audi-5 at 90;
`
`
`
`
`
`65  
`
`Corresponding Element in Audi Vehicles
`
`17E2. Audi Braking Guard:
`
`
`
`
`
`
`
`Claim 17
`
`718
`
`

`
`Audi-6 at 117; Audi-7 at 130-34; Audi-9 at 106; Audi-10 at 101).
`(See, e.g., Exhibits Audi-1 at 99; Audi-2 at 110; Audi-3 at 101; Audi-4 at 103; Audi-5 at 97;
`
`66  
`
`
`
`
`
`Corresponding Element in Audi Vehicles
`
`
`
`17E3. Audi Side Assist:
`
`
`
`
`
`
`
`Claim 17
`
`719
`
`

`
`an object.
`subsystem, said vehicle proximity alarm circuit issuing an alarm that said vehicle is too close to
`The accused Audi vehicles include a vehicle proximity alarm circuit coupled to said processor
`performance testing systems use vehicle speed/stopping distance tables stored in memory.
`electronic speed control (ESC) systems) included in the accused Audi vehicles, and safety and
`brake control systems (e.g., ABS, TCS, BAS, ESC, etc.) and speed control systems (e.g.,
`On information and belief, additional vehicle systems, including but not limited to electronic
`
`Corresponding Element in Audi Vehicles
`
`
`
`
`
`
`
`issue an alarm to indicate that the vehicle is too close to an object.
`For example, the accused Audi vehicles include one or more systems that include circuits that
`
`67  
`
`
`
`
`
`an object;
`said vehicle is too close to
`circuit issuing an alarm that
`vehicle proximity alarm
`processor subsystem, said
`alarm circuit coupled to said
`17F. a vehicle proximity
`
`Claim 17
`
`720
`
`

`
`(See, e.g., Exhibits Audi-1 at 89; Audi-2 at 102; Audi-3 at 93; Audi-4 at 96; Audi-5 at 87; Audi-6
`
`68  
`
`
`
`
`
`Corresponding Element in Audi Vehicles
`
`17F1. Audi Adaptive Cruise Control:
`
`
`
`
`
`
`
`Claim 17
`
`721
`
`

`
`(See, e.g., Exhibits Audi-1 at 194; Audi-5 at 192; Audi-6 at 110; Audi-9 at 196).
`
`Corresponding Element in Audi Vehicles
`
`at 110; Audi-7 at 120-22; Audi-9 at 96; Audi-10 at 94).
`
`
`
`
`
`69  
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`
`
`
`
`
`
`
`
`Claim 17
`
`722
`
`

`
`70  
`
`
`
`Audi-6 at 113; Audi-7 at 127; Audi-9 at 99; Audi-10 at 97).
`(See, e.g., Exhibits Audi-1 at 92; Audi-2 at 105-06; Audi-3 at 96-97; Audi-4 at 99; Audi-5 at 90;
`
`
`
`
`
`
`
`Corresponding Element in Audi Vehicles
`
`Claim 17
`
`
`
`17F2. Audi Braking Guard:
`
`
`
`723
`
`

`
`71  
`
`
`
`Audi-6 at 116; Audi-7 at 130-34; Audi-9 at 105; Audi-10 at 100).
`(See, e.g., Exhibits Audi-1 at 98; Audi-2 at 109; Audi-3 at 100; Audi-4 at 102; Audi-5 at 96;
`
`
`
`
`
`(See, e.g., Exhibits Audi-1 at 194; Audi-5 at 192; Audi-9 at 196).
`
`17F3. Audi Side Assist:
`
`
`
`
`
`
`
`
`
`Corresponding Element in Audi Vehicles
`
`Claim 17
`
`
`
`724
`
`

`
`72  
`
`being operated at an excessive speed.
`subsystem, said upshift notification circuit issuing a notification that said engine of said vehicle is
`The accused Audi vehicles include an upshift notification circuit coupled to said processor
`
`See, e.g., citations for claim element 1F.
`
`
`
`
`
`supplied to said engine of said vehicle.
`subsystem, said fuel overinjection circuit issuing a notification that excessive fuel is being
`The accused Audi vehicles include a fuel overinjection circuit coupled to said processor
`(See, e.g., Exhibits Audi-1 at 194; Audi-5 at 192; Audi-9 at 196).
`
`See, e.g., citations for claim element 1E.
`
`
`
`
`
`
`
`
`
`
`
`
`
`being operated at an
`said engine of said vehicle is
`issuing a notification that
`upshift notification circuit
`processor subsystem, said
`circuit coupled to said
`17H. an upshift notification
`said vehicle;
`supplied to said engine of
`excessive fuel is being
`issuing a notification that
`fuel overinjection circuit
`processor subsystem, said
`circuit coupled to said
`17G. a fuel overinjection
`
`Corresponding Element in Audi Vehicles
`
`Claim 17
`
`
`
`725
`
`

`
`73  
`
`
`
`overinjection circuit, and when to activate said upshift notification circuit.
`subsystem, when to activate said vehicle proximity alarm circuit, when to activate said fuel
`based upon data received from said radar detector, said at least one sensor and said memory
`On information and belief, the accused Audi vehicles include a processor subsystem determining,
`
`
`
`See, e.g., citations for claim elements 1G, 17F.
`
`
`
`
`
`Corresponding Element in Audi Vehicles
`
`
`
`
`upshift notification circuit.
`and when to activate said
`fuel overinjection circuit,
`circuit, when to activate said
`vehicle proximity alarm
`when to activate said
`said memory subsystem,
`said at least one sensor and
`from said radar detector,
`based upon data received
`subsystem determining,
`17I. said processor
`excessive speed;
`
`Claim 17
`
`
`
`726
`
`

`
`74  
`
`
`
`The accused Audi vehicles  include at least one sensor further including a windshield wiper sensor
`
`See, e.g., citations for claim 17.
`
`
`
`the wipers are turned on.
`For example, the accused Audi vehicles include a windshield wiper sensor that determines when
`
`
`
`
`
`for indicating whether a windshield wiper of said vehicle is activated.
`
`to claim 17.
`The accused Audi vehicles include an apparatus for optimizing operation of a vehicle according
`
`Corresponding Element in Audi Vehicles
`
`
`
`
`
`vehicle is activated; and
`windshield wiper of said
`indicating whether a
`windshield wiper sensor for
`further includes a
`18B. said at least one sensor
`
`
`
`17 wherein:
`vehicle according to claim
`optimizing operation of a
`18A. Apparatus for
`Claim 18
`
`
`
`727
`
`

`
`75  
`
`speed/stopping distance table.
`The accused Audi vehicles include a memory subsystem further storing a second vehicle
`Audi-6 at 54; Audi-7 at 63-64; Audi-9 at 52; Audi-10 at 49).
`(See, e.g., Exhibits Audi-1 at 48; Audi-2 at 53-54; Audi-3 at 49; Audi-4 at 56; Audi-5 at 48;
`
`On information and belief, the accused Audi vehicles store a second vehicle speed/stopping
`
`
`
`
`
`
`
`
`
`speed/stopping distance
`second vehicle
`subsystem further storing a
`18C. said memory
`
`Corresponding Element in Audi Vehicles
`
`Claim 18
`
`
`
`728
`
`

`
`76  
`
`
`
`The accused Audi vehicles  include a throttle controller for controlling a throttle of said engine of
`
`See, e.g., citations for claim 17.
`
`
`
`one sensor and said memory subsystem.
`selectively reduces said throttle based upon data received from said radar detector, said at least
`On information and belief, the accused Audi vehicles include a processor subsystem that
`See, e.g., citations for claim element 1B.
`
`See, e.g., citations for claim element 1G and 17E1.
`
`
`
`
`
`said vehicle.
`
`to claim 17.
`The accused Audi vehicles include an apparatus for optimizing operation of a vehicle according
`
`Corresponding Element in Audi Vehicles
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`Corresponding Element in Audi Vehicles
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`
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`See, e.g., citations for claim element 17E.
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`distance table.
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`memory subsystem.
`least one sensor and said
`said radar detector, said at
`upon data received from
`reducing said throttle based
`subsystem selectively
`19C. said processor
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`engine of said vehicle; and
`controlling a throttle of said
`19B. a throttle controller for
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`17 and further comprising:
`vehicle according to claim
`optimizing operation of a
`19A. Apparatus for
`Claim 19
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`
`
`Claim 18
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`table.
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`729
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`

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`77  
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`at 95; Audi-9 at 91; Audi-10 at 83).
`(See, e.g., Exhibits Audi-1 at 85; Audi-2 at 89; Audi-3 at 80; Audi-4 at 83; Audi-5 at 83; Audi-6
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`system is activated (e.g., as indicated by brake lights.)
`For example, the accused Audi vehicles include a brake sensor that determines when the brake
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`
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`a brake system of said vehicle is activated.
`to claim 19 wherein said at least one sensor further includes a brake sensor for indicating whether
`The accused Audi vehicles include an apparatus for optimizing operation of a vehicle according
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`Corresponding Element in Audi Vehicles
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`said vehicle is activated.
`whether a brake system of
`brake sensor for indicating
`sensor further includes a
`19 wherein said at least one
`vehicle according to claim
`optimizing operation of a
`20. Apparatus for
`Claim 20
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`730
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`

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`to claim 19 wherein said processor subsystem further comprises:
`The accused Audi vehicles include an apparatus for optimizing operation of a vehicle according
`
`Corresponding Element in Audi Vehicles
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`The accused Audi vehicles  include a means for counting a total number of vehicle proximity
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`See, e.g., citations for claims 1, 19.
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`alarms determined by said processor subsystem.
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`78  
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`processor subsystem;
`determined by said
`proximity alarms
`total number of vehicle
`21B. means for counting a
`comprises:
`subsystem further
`19 wherein said processor
`vehicle according to claim
`optimizing operation of a
`21A. Apparatus for
`Claim 21
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`731
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`79  
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`Corresponding Element in Audi Vehicles
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`21B1. Audi Adaptive Cruise Control:
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`Claim 21
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`732
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`(See, e.g., Exhibits Audi-1 at 194; Audi-5 at 192; Audi-6 at 110; Audi-9 at 196).
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`at 110; Audi-7 at 120-22; Audi-9 at 96; Audi-10 at 94).
`(See, e.g., Exhibits Audi-1 at 89; Audi-2 at 102; Audi-3 at 93; Audi-4 at 96; Audi-5 at 87; Audi-6
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`Corresponding Element in Audi Vehicles
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`80  
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`Claim 21
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`733
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`(See, e.g., Exhibits Audi-1 at 92; Audi-2 at 105-06; Audi-3 at 96-97; Audi-4 at 99; Audi-5 at 90;
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`81  
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`Corresponding Element in Audi Vehicles
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`21B2. Audi Braking Guard:
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`Claim 21
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`734
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`82  
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`(See, e.g., Exhibits Audi-1 at 194; Audi-5 at 192; Audi-6 at 110; Audi-9 at 196).
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`21B3. Audi Side Assist:
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`Corresponding Element in Audi Vehicles
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`Audi-6 at 113; Audi-7 at 127; Audi-9 at 99; Audi-10 at 97).
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`
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`Claim 21
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`735
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`

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`and associated text relating to the expression programmed in the Processor Subsystem 12.
`alarms determined by said processor subsystem” are described in, for example, Figures 1 and 2
`materials(s) that perform the claimed function of “counting a total number of vehicle proximity
`To the extent that 35 U.S.C. §112(6) applies to this claim limitation, the structure(s), act(s), or
`
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`(See, e.g., Exhibits Audi-1 at 194; Audi-5 at 192; Audi-9 at 196).
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`On information and belief, the accused Audi vehicles  include a means for selectively reducing
`
`said throttle based upon said total number of vehicle proximity alarms.
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`materials(s) that perform the claimed function of “counting a total number of vehicle proximity
`To the extent that 35 U.S.C. §112(6) applies to this claim limitation, the structure(s), act(s), or
`
`83  
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`See, e.g., citations for claim element 21B.
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`Audi-6 at 116; Audi-7 at 130-34; Audi-9 at 105; Audi-10 at 100).
`(See, e.g., Exhibits Audi-1 at 98; Audi-2 at 109; Audi-3 at 100; Audi-4 at 102; Audi-5 at 96;
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`Corresponding Element in Audi Vehicles
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`vehicle proximity alarms.
`upon said total number of
`reducing said throttle based
`21C. means for selectively
`
`Claim 21
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`736
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`to claim 17 and further comprising:
`The accused Audi vehicles include an apparatus for optimizing operation of a vehicle according
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`Corresponding Element in Audi Vehicles
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`See, e.g., citations for claim 17.
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`
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`The accused Audi vehicles  include a downshift notification circuit coupled to said processor
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`84  
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`received from said plurality of sensors, when to activate said downshift notification circuit.
`The accused Audi vehicles include a processor subsystem that determines, based upon data
`
`See, e.g., citations for claim elements 1B, 1G.
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`
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`vehicle is being operated at an insufficient engine speed.
`subsystem, said downshift notification circuit issuing a notification that said engine of said
`
`See, e.g., citations for claim element 7F.
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`circuit.
`said downshift notification
`sensors, when to activate
`from said plurality of
`based upon data received
`subsystem determining,
`22C. said processor
`and
`an insufficient engine speed;
`vehicle is being operated at
`that said engine of said
`circuit issuing a notification
`said downshift notification
`to said processor subsystem,
`notification circuit coupled
`22B. a downshift
`17 and further comprising:
`vehicle according to claim
`optimizing operation of a
`22A. Apparatus for
`Claim 22
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`and associated text relating to the expression programmed in the Processor Subsystem 12.
`alarms determined by said processor subsystem” are described in, for example, Figures 1 and 2
`
`Corresponding Element in Audi Vehicles
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`Claim 21
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`737
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`

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`85  
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`sensors.
`pressure set point, an RPM set point, and present and prior levels for each one of said plurality of
`said memory subsystem storing therein a first vehicle speed/stopping distance table, a manifold
`The accused Audi vehicles include a memory subsystem, coupled to said processor subsystem,
`See, e.g., citations for claim element 1C.
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`each one of said plurality of sensors, to receive data therefrom;
`The accused Audi vehicles include a processor subsystem, coupled to said radar detector and
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`having an engine and another object in front of the accused vehicles.
`The accused Audi vehicles include a radar detector that determines a distance separating a vehicle
`See, e.g., citations for claims 1, 17.
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`The accused Audi vehicles include an apparatus for optimizing operation of a vehicle.
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`Corresponding Element in Audi Vehicles
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`See, e.g., citations for claim element 17B.
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`speed sensor, and engine speed sensor, a manifold pressure sensor and a throttle position sensor
`said plurality of sensors, which collectively monitor operation of said vehicle, including a road
`The accused Audi vehicles include a plurality of sensors coupled to a vehicle having an engine,
`
`See, e.g., citations for claim element 1B.
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`distance table, a manifold
`first vehicle speed/stopping
`subsystem storing therein a
`subsystem, said memory
`coupled to said processor
`23E. a memory subsystem,
`receive data therefrom;
`said plurality of sensors, to
`detector and each one of
`coupled to said radar
`23D. a processor subsystem,
`throttle position sensor;
`pressure sensor and a
`speed sensor, a manifold
`speed sensor, and engine
`vehicle, including a road
`monitor operation of said
`sensors, which collectively
`an engine, said plurality of
`coupled to a vehicle having
`23C. a plurality of sensors
`vehicle;
`object in front of said
`having an engine and an
`distance separating a vehicle
`radar detector determining a
`23B. a radar detector, said
`vehicle, comprising:
`optimizing operation of a
`23A. Apparatus for
`Claim 23
`
`
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`738
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`

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`being operated at an excessive speed.
`subsystem, said upshift notification circuit issuing a notification that said engine of said vehicle is
`The accused Audi vehicles include an upshift notification circuit coupled to said processor
`
`
`
`See, e.g., citations for claim element 1F.
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`
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`The accused Audi vehicles include a vehicle proximity alarm circuit coupled to said processor
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`86  
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`to activate said upshift notification circuit.
`received from said plurality of sensors, when to activate said fuel overinjection circuit and when
`The accused Audi vehicles include a processor subsystem that determines, based upon data
`
`See, e.g., citations for claim element 1G.
`
`
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`excessive fuel is being supplied to said engine of said vehicle.
`processor subsystem, said fuel overinjection notification circuit issuing a notification that
`The accused Audi vehicles include a fuel overinjection notification circuit coupled to said
`
`See, e.g., citations for claim element 1E.
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`Corresponding Element in Audi Vehicles
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`See, e.g., citations for claim element 17E.
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`23I. a vehicle proximity
`circuit;
`said upshift notification
`circuit and when to activate
`said fuel overinjection
`sensors, when to activate
`from said plurality of
`based upon data received
`subsystem determining,
`23H. said processor
`excessive speed;
`being operated at an
`said engine of said vehicle is
`issuing a notification that
`upshift notification circuit
`processor subsystem, said
`circuit coupled to said
`23G. an upshift notification
`engine of said vehicle;
`fuel is being supplied to said
`notification that excessive
`notification circuit issuing a
`said fuel overinjection
`to said processor subsystem,
`notification circuit coupled
`23F. a fuel overinjection
`said plurality of sensors;
`prior levels for each one of
`set point, and present and
`pressure set point, an RPM
`
`Claim 23
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`739
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`

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`87  
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`activate said vehicle proximity alarm circuit.
`received from said radar detector, said at least one sensor and said memory subsystem, when to
`The accused Audi vehicles includes a processor subsystem that determines, based upon data
`
`See, e.g., citations for claim element 17I.
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`
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`said object.
`subsystem, said vehicle proximity alarm circuit issuing an alarm that said vehicle is too close to
`
`Corresponding Element in Audi Vehicles
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`See, e.g., citations for claim 17F.
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`circuit.
`vehicle proximity alarm
`when to activate said
`said memory subsystem,
`said at least one sensor and
`from said radar detector,
`based upon data received
`subsystem determining,
`23J. said processor
`said object;
`said vehicle is too close to
`circuit issuing an alarm that
`vehicle proximity alarm
`proce