DECLARATION OF SCOTT ANDREWS
`
`I, Scott Andrews, declare as follows:
`
`I hold a B.Sc. degree in Electrical Engineering from University of California–
`
`
`
`1.
`
`Irvine and a M.Sc. degree in Electronic Engineering from Stanford University. In
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`various positions at, among others, TRW and Toyota, I have been responsible for
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`research and development projects relating to, among others, numerous vehicle
`
`navigation systems, information systems, and user interface systems. My qualifications
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`are further set forth in my curriculum vitae (Exhibit A). I have been retained by
`
`Volkswagen Group of America, Inc. in connection with its petition for inter partes
`
`review of U.S. Patent No. 7,917,285 (“the ’285 patent”). I have over 25 years of
`
`experience in fields relevant to the ’285 patent, including vehicle telecommunications
`
`systems, vehicle navigation systems, and telematics-aided vehicle navigation systems.
`
`2.
`
`I have reviewed the ’285 patent, as well as its prosecution history and the prior
`
`art cited during its prosecution, including U.S. Patent Application Publication No.
`
`2004/02284849
`
`(“Ishibashi”) and U.S. Patent Application Publication No.
`
`2004/0064245 (“Knockeart”). I have also reviewed U.S. Patent No. 6,526,335
`
`(“Treyz”), European Patent Application Publication No. 1 302 751 (“Demir”), U.S.
`
`Patent Application Publication No. 2003/0043019 (“Tanaka”), the Richard Lind et al.
`
`publication, The Network Vehicle – A Glimpse into the Future of Mobile Multi-Media, SAE
`
`Brasil 98, VII International Mobility Technology Conference & Exhibit (“Lind”), and
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`U.S. Patent No. 7,386,393 (“Zabel”).
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`- 1 -
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`VWGoA - Ex. 1002
`Volkswagen Group of America, Inc., Petitioner
`
`1
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`
`
`I, Scott Andrews, declare as follows:
`
`I hold a B.Sc. degree in Electrical Engineering from University of California–
`
`
`
`1.
`
`Irvine and a M.Sc. degree in Electronic Engineering from Stanford University. In
`
`various positions at, among others, TRW and Toyota, I have been responsible for
`
`research and development projects relating to, among others, numerous vehicle
`
`navigation systems, information systems, and user interface systems. My qualifications
`
`are further set forth in my curriculum vitae (Exhibit A). I have been retained by
`
`Volkswagen Group of America, Inc. in connection with its petition for inter partes
`
`review of U.S. Patent No. 7,917,285 (“the ’285 patent”). I have over 25 years of
`
`experience in fields relevant to the ’285 patent, including vehicle telecommunications
`
`systems, vehicle navigation systems, and telematics-aided vehicle navigation systems.
`
`2.
`
`I have reviewed the ’285 patent, as well as its prosecution history and the prior
`
`art cited during its prosecution, including U.S. Patent Application Publication No.
`
`2004/02284849
`
`(“Ishibashi”) and U.S. Patent Application Publication No.
`
`2004/0064245 (“Knockeart”). I have also reviewed U.S. Patent No. 6,526,335
`
`(“Treyz”), European Patent Application Publication No. 1 302 751 (“Demir”), U.S.
`
`Patent Application Publication No. 2003/0043019 (“Tanaka”), the Richard Lind et al.
`
`publication, The Network Vehicle – A Glimpse into the Future of Mobile Multi-Media, SAE
`
`Brasil 98, VII International Mobility Technology Conference & Exhibit (“Lind”), and
`
`U.S. Patent No. 7,386,393 (“Zabel”).
`
`- 1 -
`
`VWGoA - Ex. 1002
`Volkswagen Group of America, Inc., Petitioner
`
`1
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`
`
`
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`The ’285 Patent
`
`3.
`
`The ’285 patent describes remotely entering addresses into GPS devices. A user
`
`enters a location into a web browser in a computer 306, and the computer 306
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`transmits the location to a server 304. Col. 9, l. 67–col 10 20. The server 304 then
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`resolves the address and sends the resolved information to the GPS device 100. Col.
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`10, ll. 34–38. The GPS device uses the information to provide route guidance. Col. 10,
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`ll. 38–49. To identify both the user and the user’s GPS device, the system described in
`
`the ’285 patent uses an Internet cookie and a database of GPS device transmission
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`information. The user’s computer transmits an Internet cookie to the server to
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`identify the user, and the server utilizes a database to identify a telephone number or
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`IP address for use in transmitting information to the GPS device 100. Col. 10, ll. 21–
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`33.
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`4.
`
`According to my understanding of the prosecution of the ’285 patent, claim 1
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`was granted on an application claim, i.e., application claim 25, which described a
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`system for entering location information into a positional information device
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`including a server that is configured to receive a request for a location, to determine
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`coordinates of the location, and to transmit the coordinates to the positional
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`information device, as follows:
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`25. A system for entering location information into a positional information
`device, the system comprising:
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`- 2 -
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`2
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`
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`a server configured to receive a request for at least one location, determine
`coordinates of the least one requested location and to transmit the determined
`coordinates to the device;
`the positional information device including
`a locational information module for determining location information of the
`device;
`a communication module for receiving coordinates of the at least one location
`from the server;
`a processing module configured to receive the coordinates from the
`communication module and determine route guidance based on the location of
`the device and the received coordinates; and
`a display module for displaying the route guidance; and
`a communications network for coupling the positional information device to
`the server.
`After being rejected as anticipated by Ishibashi, this claim was amended to
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`5.
`
`describe “remotely” entering location information and to change “coordinates” to
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`“address, ” as follows:
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`25. A system for remotely entering location information into a
`positional information device, the system comprising:
`a server configured to receive a request for an address of at least one
`location not already stored in the positional information device, to
`determine coordinates the address of the least one requested location
`and to transmit the determined coordinates address to the positional
`information device;
`the positional information device including
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`3
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`
`
`a locational information module for determining location information
`of the positional information device;
`a communication module for receiving the determined coordinates
`address of the at least one location from the server;
`the determined
`a processing module configured
`to receive
`coordinates address from the communication module and determine
`route guidance based on the location of the positional information
`device and the received determined coordinates address; and
`a display module for displaying the route guidance; and
`a communications network for coupling the positional information
`device to the server.
`After again being rejected, as anticipated by Knockeart, this claim was further
`
`6.
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`amended to describe that “the request is received from a remote computer with a first
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`identifier and the server being configured to determine a second identifier for
`
`identifying the positional information device based on the received first identifier,” as
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`follows:
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`25. A system for remotely entering location information into a
`positional information device, the system comprising:
`a server configured to receive a request for an address of at least one
`location not already stored in the positional information device, to
`determine the address of the least one location and to transmit the
`determined address to the positional information device,
`wherein the request is received from a remote computer with a first
`identifier and the server being configured to determine a second
`identifier for identifying the positional information device based on the
`received first identifier;
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`4
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`
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`the positional information device including
`a locational information module for determining location information
`of the positional information device;
`a communication module for receiving the determined address of the
`at least one location from the server;
`a processing module configured to receive the determined address
`from the communication module and determine route guidance based
`on the location of the positional information device and the determined
`address; and
`a display module for displaying the route guidance; and
`a communications network for coupling the positional information
`device to the server.
`According to the Office Action dated October 13, 2010, the Examiner
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`7.
`
`concluded that Knockeart disclosed all of the limitations of application claim 25,
`
`except for the limitation that “the server being configured to determine a second
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`identifier for identifying the positional information device based on the received first
`
`identifier.” As discussed below, however, this limitation of claim 1 of the ’285 patent,
`
`as well as the remaining limitations of claims 1 through 12 of the ’285 patent, are
`
`described in the prior art. In my opinion, a person of ordinary skill in the art, at the
`
`time of the filing of the application for the ’285 patent, would have found the systems
`
`described in claims 1 through 12 obvious in view of the prior art.
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`5
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`The Combination of Knockeart and Treyz – Claims 1 to 5, 9, and 10
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`8.
`
`In my opinion, it would have been obvious to combine the teachings of
`
`Knockeart and Treyz, as discussed below, to achieve the system claimed in the ’285
`
`patent. The combination of Knockeart and Treyz describes all of the limitations of
`
`claims 1 through 5, 9, and 10 of the ’285 patent, including the limitation which was
`
`the basis for the allowance of the ’285 patent, i.e., “wherein the request is received
`
`from a remote computer with a first identifier and the server being configured to
`
`determine a second identifier for identifying the position information device based on
`
`the received first identifier.”
`
`9.
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`Knockeart, assigned to Siemens Automotive Corp., published on April 1, 2004.
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`Knockeart describes a vehicle information system including an in-vehicle system 105
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`in communication with a centralized server 125, used to provide route planning.
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`Abstract; ¶¶ 9, 73. The operator of the vehicle inputs a desired destination into the in-
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`vehicle system 105, which uploads the desired destination to the server system 125.
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`The server system determines a route plan and sends the plan to the in-vehicle system
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`105, which performs route guidance. ¶ 74.
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`10.
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`In-vehicle system 105 includes onboard computer 210, processor 212, GPS
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`antenna 253, GPS receiver 252, cellular transceiver 254, and display 242. The vehicle
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`operator enters a desired destination into the in-vehicle system, which sends the
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`information, along with the current location of the vehicle, to the server system 125
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`over cellular telephone network 350 and PSTN 340. ¶¶ 113–127. The server system
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`6
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`determines a route from the current location of the vehicle to the desired destination,
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`and transmits that route information to the vehicle along with spot maps of the
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`current location and destination. The in-vehicle system 105 uses the information to
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`provide route guidance. ¶¶ 73–74, 183–185.
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`11. The server system 125 uses the desired destination input by the vehicle
`
`operator to validate the destination, or determine the street address of the desired
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`destination. For example, as described by Knockeart, the server system 125 is used to
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`validate a desired destination entered by the vehicle operator if the destination is
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`outside of the geographic range of data stored in the in-vehicle system. ¶ 239. As a
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`further example, the server system 125 executes a navigation application 512 to
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`determine the address of a desired destination by comparing an entered telephone
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`number to a yellow pages database 520. ¶¶ 168–169, 236. Knockeart recognizes that
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`the in-vehicle database may not include all possible yellow page listings and that only
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`categories of listings may be included in the in-vehicle database. ¶ 230. An operator is
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`presented with a list of categories and may select a category from the list. Id. Once the
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`operator selects a yellow page category, a communication session between the in-
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`vehicle system and the server system is established, and the specific listings, i.e., street
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`addresses, in the selected category are downloaded from the server system to the in-
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`vehicle system, and the operator can select a particular destination from the
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`downloaded list. ¶ 231. Furthermore, in implementing a “reverse” telephone
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`directory, Knockeart describes that the “operator can specify a destination by
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`7
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`specifying the telephone number of the destination” and that the “server system
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`receives the telephone number and looks in [sic] up in a ‘reverse’ telephone directory
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`to determine the street address of the destination.” ¶ 236.
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`12. Treyz describes a networked personal computer for a vehicle. The automobile
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`computer system communicates over the Internet using remote wireless links, and
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`may be controlled by a user using a service provider. Col. 2, ll. 5–8, 44–45; Col. 19, ll.
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`33–45; Fig. 13.
`
`
`13. Treyz describes numerous functions of the automobile personal computer 14.
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`Several of those functions require a system for verifying a user identity before
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`providing access to a user. A user registers user identification information (a first
`
`identifier), such as a name, password, or personal identification number (PIN). Col.
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`8
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`30, ll. 25–32, 54–60. The user may then also register an automobile personal computer
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`to be associated with that user’s identification information. Automobile personal
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`computers are identified by an identification number or a communications address (a
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`second identifier). Col. 42, ll. 10–25. In addition, a manufacturer may maintain a
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`database of the identification information of automobile personal computers and their
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`users. Col. 32, ll. 28–54.
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`14. Once the user identification information and automobile personal computer
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`identification number or communications address are registered with the server, the
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`information can be used to determine the automobile personal computer associated
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`with a particular user. For example, if a user logs in to a service provider server to
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`remotely control the automobile personal computer, the user’s identification
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`information will allow the server to identify the corresponding automobile personal
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`computer according to its identification number or communications address. Col. 42,
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`ll. 38–44. As another example, if a user wants to locate a vehicle, a user may provide
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`user identification information to a kiosk, which will contact the database to
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`determine the communications address of the associated automobile personal
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`computer, and will allow the system to contact the automobile personal computer to
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`determine its location. Col. 32, ll. 28–66. Further still, a user can request the street
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`address associated with the current location of the vehicle, and the system will
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`perform a database look-up operation in a remote database to determine the street
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`address and transmit the street address to the user. Col. 44, ll. 27–42.
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`9
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`15. Treyz therefore describes the claimed server (service provider server or third
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`party database), receiving a request from a remote computer (home device or kiosk)
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`including a first identifier (user identification information, e.g., name, PIN, or
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`password), determining a second identifier for identifying a position information
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`device (automobile personal computer 14) based on the received first identifier
`
`(determining
`
`the automobile personal computer
`
`identification number or
`
`communications address), and transmitting information to the positional information
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`device (control commands or request for location).
`
`16.
`
`In my opinion, it would have been obvious to combine the teachings of
`
`Knockeart and Treyz to achieve the systems claimed in the ’285 patent.
`
`17.
`
`For example, both Knockeart and Treyz describe systems that transmit
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`requests from a remote computer to a server requesting information, and the server
`
`transmitting the requested information to a navigation unit in a vehicle. More
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`specifically, Knockeart describes that a server determines an address of a location in
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`response to the user’s request, and transmits the address information to the vehicle
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`computer system. In the system described by Knockeart, the in-vehicle system guides
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`the operator along a calculated route to the determined address and also replans a new
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`route to the destination if the vehicle deviates from a planned route. Treyz specifically
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`describes transmitting a request from a remote computer, along with a first identifier,
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`to the server, and the server using the first identifier to determine a second identifier
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`for
`
`identifying the positional
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`information device to receive the determined
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`10
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`
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`information from the server, by describing user identification information to match an
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`associated automobile personal computer.
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`18. According to Treyz, the first and second identifiers are provided for security
`
`purposes in remotely communicating with a vehicle, including verifying a user’s
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`identity. See, e.g., col. 2, ll. 44–47, col. 30, l. 25–col. 31, l. 15.
`
`19. At the time that the ’285 patent was filed, it would have been obvious to
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`modify the vehicle information system taught by Knockeart to include the automobile
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`remote control and user authentication system taught by Treyz for greater
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`functionality in the automobile computer system, and for security purposes in
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`remotely communicating with a vehicle, including verifying a user’s identity, as taught
`
`by Treyz.
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`20. Additionally, several years before the filing of the ’285 patent, as well as
`
`contemporaneously to the filing of the ’285 patent, other companies developed
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`vehicles with networked connectivity, allowing users to interact with their vehicles
`
`remotely. This industry activity further supports my opinion that the system claimed
`
`in the ’285 patent would have been obvious to a person of ordinary skill in the art,
`
`and that it would have been obvious to combine the teachings of Knockeart and
`
`Treyz.
`
`21.
`
`For example, as described by Lind, the Network Vehicle was developed by a
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`group of companies including Delphi Delco Electronics Systems, IBM, Netscape
`
`Communication, and Sun Microsystems. The Network Vehicle developers loaded
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`11
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`several computing and communications devices into a vehicle, to show that the
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`technology could successfully be used in a variety of ways. The Network Vehicle
`
`included a roof-mounted antenna to provide a satellite connection to the Internet. p.
`
`2. The system associated with the Network Vehicle included an off-board network
`
`architecture, including a home/office computer and an IBM web server, among
`
`others. p. 2. As described by Lind, the Network Vehicle developers provided a web
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`site for users of the Network Vehicle to remotely access the computing systems
`
`located in the vehicle. The vehicle web site allowed users to “plan trips on the vehicle
`
`web site, then download them to your vehicle.” p. 4.
`
`22. The Lind article also describes systems in which a user can remotely enter
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`information into a positional information device in a vehicle. Lind states that the
`
`Network Vehicle was demonstrated at the Computer Dealer’s Exhibits (COMDEX
`
`‘97) in Las Vegas, Nevada, on November 17–19, 1997, nine years before the filing of
`
`the ’285 patent. At this demonstration, the presenters of the Network Vehicle
`
`(Delphi, IBM, Netscape, and Sun Microsystems) presented the vehicle website that is
`
`described by Lind, as noted above.
`
`23.
`
`I have reviewed screenshots of the Network Vehicle web site, and attached
`
`those screenshots as Exhibit B. I acquired these screenshots pursuant to my work as
`
`an expert witness engaged by Volkswagen Group of America, Inc. in connection with
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`Affinity Labs of Texas, LLC v. BMW North America, LLC, et al., Case No. 9:08-cv-00164
`
`(E.D. Tex.).
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`12
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`24. Moreover, in 1997, I personally attended a demonstration of the Network
`
`Vehicle, conducted by Delphi at a Delphi supplier exhibition at Toyota’s headquarters
`
`in Toyota City, Japan. At that event, the developers of the Network Vehicle
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`demonstrated its features to me, and explained the system operation.
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`25. Referring to Exhibit B, as illustrated in, e.g., the “Member Home” page, once a
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`user logged in to the web site as an owner of the Network Vehicle, the Vehicle ID
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`(“J3792X04128”) was displayed. The next page, the “Travel Itinerary” web page,
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`shows entry of origin and destination cities, route, origin, and destination maps that
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`can be selected and downloaded to the Network Vehicle identified by the Vehicle ID.
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`The Network Vehicle, and its associated off-board network architecture and web site,
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`therefore demonstrate that it would have been obvious to provide a first identifier (a
`
`user’s log-in information) to determine a second identifier identifying the positional
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`information device (the Vehicle ID).
`
`26. As a further example, Zabel describes BMW’s “Google Send to Car” project, in
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`which destination information could be transmitted to a vehicle over a network. Using
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`a remote computer, a user could perform online searches for destination information,
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`and have the resulting information sent to their vehicle. The server 150 compares the
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`user’s identification information to a vehicle database 170 to identify an associated
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`vehicle and the communication information of the in-vehicle navigation system 140.
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`Once the vehicle and its communication information has been identified, the server
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`150 sends the requested information to that in-vehicle navigation system 140. Col. 1,
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`13
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`
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`ll. 62–66; col. 2, l. 53–col. 3, l. 8; col. 3, l. 57–col. 4, l. 10. In my opinion, Zabel also
`
`demonstrates the obviousness of the system claimed in the ’285 patent.
`
`27. The use of Internet cookies to identify a user of a web browser to a server was
`
`well known in 2006, when the ’285 patent was filed. For example, in 1999, seven years
`
`before the ’285 patent was filed, IBM received a patent describing web server user
`
`authentication using Internet cookies, U.S. Patent No. 5,875,296.
`
`It is a further object of the invention to provide a distributed file system
`authentication scheme for Web browsing that only requires passing of a
`user id and password when the user initially logs in to the file system
`through a Web server. On subsequent requests, a secret handle stored in
`a ‘cookie’ is passed from the Web browser to the Web server.
`
`Col. 2, ll. 29–34;
`
`In response to receipt by the Web server of a user id and password from
`the Web client, a login protocol is executed with the security service. If
`the user can be authenticated, a credential is stored in an in-memory
`credential database of credentials associated with authenticated users.
`The Web server then returns to the Web client a persistent client state
`object having a unique identifier therein. This object, sometimes referred
`to as a cookie, is then used to enable the Web client to browse Web
`documents in the distributed file system. In particular, when the Web
`client desires to make a subsequent request to the distributed file system,
`the persistent client state object including the identifier is used in lieu of
`the user’s id and password, which makes the session much more secure.
`
`
`Col. 2, l. 66–col. 3, l. 12.
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`14
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`28. The use of IP addresses to identify a device for sending or receiving
`
`information over the Internet was also well known in 2006, when the ’285 patent was
`
`filed. For example, in 2003, IBM filed a patent application describing the use of
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`Internet Protocol (“IP”) addresses, which eventually issued as U.S. Patent No.
`
`7,114,006.
`
`In the most widely installed level of the Internet Protocol (“IP”) today,
`an IP address is a 32-bit number that identifies each sender or receiver
`of information that is sent in packets across the Internet. When a user
`requests an HTML page, the Internet Protocol part of TCP/IP includes
`the user's IP address in the message (actually, in each of the packets if
`more than one is required) and sends it to the IP address that is obtained
`by looking up the domain name in the Uniform Resource Locator
`(“URL”) requested. At the other end, the recipient can see the IP
`address of the Web page requestor and can respond by sending another
`message using the IP address it received.
`
`Col. 1, ll. 56–67.
`
`
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`The Combination of Knockeart, Treyz, and Demir – Claims 6 to 8
`
`29.
`
`In my opinion, it would have been obvious to combine the teachings of
`
`Knockeart, Treyz, and Demir, as discussed below, to achieve the system described in
`
`claims 6 through 8 of the ’285 patent. As described above, the combination of
`
`Knockeart and Treyz describes all of the limitations of claim 1 of the ’285 patent,
`
`including the limitation which was the basis for the allowance of the ’285 patent, i.e.,
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`15
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`
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`“wherein the request is received from a remote computer with a first identifier and the
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`server being configured to determine a second identifier for identifying the position
`
`information device based on the received first identifier.” Demir describes the
`
`limitations of claims 6 through 8, and it would have been obvious to combine the
`
`teachings of Demir with the combination of Knockeart and Treyz.
`
`30. Demir describes another system for entering destination information into a
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`navigation unit of a vehicle. The user transmits an address to a server (service control
`
`point 6), which generates destination information suitable for the on-vehicle
`
`navigation system associated with the transmitted address. Abstract. As relevant to
`
`claim 6 of the ’285 patent, the service control point 6 assigns geographical coordinates
`
`to the address before transmitting that information to the operating unit 3 in the
`
`navigation system of a vehicle. Abstract, ¶ 41 (“In a second step, destination
`
`recognition means 7 assigns geographical coordinates to a specified and clearly
`
`identified destination address.”). As relevant to claims 7 and 8, a user specifies a
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`destination address according to conventional address format, including the name or
`
`street. ¶ 9 (“In one advantageous specific embodiment, the destination address is
`
`specified by the user as the complete, conventional address, for instance, in the
`
`format: first name, last name, street name, house number, place of residence.”).
`
`31. At the time that the ’285 patent was filed, it would have been obvious to
`
`combine the teachings of Knockeart and Treyz with the teachings of Demir for a
`
`system for specifying a destination address. Demir teaches that the system for
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`16
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`specifying a destination address provides “a convenient and accurately addressed
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`destination selection of the navigation system at all times,” and a “simplification of
`
`the destination selection [which] increases the readiness for using the navigation
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`system, and thus enables a convenient, reliable and stress-free trip to the travel
`
`destination.” Demir, ¶ 10. For at least these reasons, it is my opinion that a person of
`
`ordinary skill in the art, at the time that the ’285 patent was filed, would have found it
`
`obvious to combine the teachings of Demir with the teachings of Knockeart and
`
`Treyz.
`
`
`
`The Combination of Knockeart, Treyz, and Tanaka – Claims 11 and 12
`
`32.
`
`In my opinion, it would have been obvious to combine the teachings of
`
`Knockeart, Treyz, and Tanaka, as discussed below, to achieve the system described in
`
`claims 11 and 12 of the ’285 patent. As described above, the combination of
`
`Knockeart and Treyz describes all of the limitations of claim 1 of the ’285 patent,
`
`including the limitation which was the basis for the allowance of the ’285 patent, i.e.,
`
`“wherein the request is received from a remote computer with a first identifier and the
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`server being configured to determine a second identifier for identifying the position
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`information device based on the received first identifier.” Tanaka describes the
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`limitations of claims 11 and 12, and it would have been obvious to combine the
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`teachings of Tanaka with the combination of Knockeart and Treyz.
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`33. Knockeart describes downloading “spot maps as small graphs around the
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`starting location or the selected maneuver points” from the server system to the in-
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`vehicle system. ¶ 257.
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`34. Tanaka, assigned to Hitachi, Ltd., published on March 6, 2003. Tanaka
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`describes a system for remotely controlling on-vehicle devices, such as a navigation
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`apparatus, allowing a user to enter a request for information associated with a
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`particular location, e.g., an address, into a remote computer (stationary computer
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`terminal 301 or mobile device 302) as control content, and to transmit the request to a
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`server (service center 10) with a user identifier. ¶¶ 38, 42–44, 57, 60; Fig. 1. The server
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`(service center 10) stores the user identifier and the control content in control
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`information database 105, and produces “control information” used to cause an on-
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`vehicle navigation apparatus to execute, e.g., navigation. ¶¶ 44–47.
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`35. As described by Tanaka, a vehicle transmits the user identifier to the server,
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`and the server responds with all of the control information stored on the server
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`associated with that user identification. ¶¶ 96–100. The control information may
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`include commands for the navigation apparatus of the on-vehicle equipment 20, so
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`that route guidance may be processed and displayed. ¶¶ 68–72.
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`36. Tanaka therefore describes the claimed server (service center 10), receiving a
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`request from a remote computer (terminals 301 or 302), determining an address for a
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`location (searching point information database 108) and transmitting the determined
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`address to a positional information device (on-vehicle navigation apparatus 20). The
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`request includes a first identifier (ID information), and the server determines which
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`position information device to send the information when the user later submits the
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`ID information from the on-vehicle equipment.
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`37. Tanaka describes a map information request from the on-vehicle equipment 20
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`to map information database 106 of service center 10. ¶ 58. If the necessary map
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`information is not included in the on-vehicle equipment’s map information database
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`205, the on-vehicle equipment 20 requests the map information from the map
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`information database 106, and the map information database 106 transmits the
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`requested map information to the on-vehicle equipment 20. ¶ 110.
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`38. At the time that the ’285 patent was filed, it would have been obvious to
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`combine the teachings of Knockeart and Treyz with the teachings of Tanaka for
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`acquiring map information from a database on a server. The prior art teaches that
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`- 19 -
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`19
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`system for acquiring map information from remote databases advantageously avoid
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`requiring an on-vehicle database to store large quantities of map information. See, e.g.,
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`Tanaka, ¶ 110; Knockeart, ¶ 11 (“An advantage of the invention is that the vehicle
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`does not have to have a prestored map to plan a route to a destination.”); Demir, ¶ 11
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`(“it is possible to access a particularly voluminous and current data base . . . no
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`memory is required in the motor vehicle for the complete storage of all destination
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`addresses of the navigation system.”). For at least these reasons, it is my opinion that
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`a person of ordinary skill in the art, at the time that the ’285 patent was filed, would
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`have found it obvious to combine the teachings of Tanaka with the teachings of
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`Knockeart and Treyz.
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`I declare that all statements made herein of my own knowledge are true and
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`that all statements made on information and belief are believed to be true, and further
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`that these statements were made with the knowledge that willful false statements and
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`the like so made are punishable by fine or imprisonment, or both, under §1001 of
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`Title 18 of the United States Code.
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`Dated: 1/21/2014
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`Scott Andrews
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