UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`VOLKSWAGEN GROUP OF AMERICA, INC.
`
`Petitioner
`
`
`Patent No. 7,917,285
`Issue Date: March 29, 2011
`Title: DEVICE, SYSTEM AND METHOD FOR REMOTELY ENTERING,
`STORING AND SHARING ADDRESSES FOR A POSITIONAL
`INFORMATION DEVICE
`__________________________________________________________________
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 7,917,285
`PURSUANT TO 35 U.S.C. § 312 and 37 C.F.R. § 42.104
`
`Case No. IPR2015-00793
`__________________________________________________________________
`
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`

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`TABLE OF CONTENTS
`I.
`Mandatory Notices (37 C.F.R. § 42.8) ..................................................................... 1
`II. Grounds for Standing (37 C.F.R. § 42.104(a)) ....................................................... 2
`III.
`Identification of Challenge (37 C.F.R. § 42.104(b)(1)-(3)) and Relief
`Requested (37 C.F.R. § 42.22(a)(1)) ......................................................................... 2
`A.
`The ’285 Patent ............................................................................................... 2
`B.
`Prosecution History of the ’285 Patent ....................................................... 6
`C.
`Patents and Printed Publications Relied On ............................................... 9
`D.
`Statutory Grounds for Challenge (37 C.F.R. § 42.104(b)(1)-(2)) ............ 10
`E.
`Claim Construction (37 C.F.R. § 42.104(b)(3)) ......................................... 10
`IV. How Challenged Claims Are Unpatentable (37 C.F.R. § 42.104(b)(4)-(5)) ...... 11
`A.
`Claims 1–5, 9, and 10 are Obvious in View of the Combination of
`Knockeart and Treyz ................................................................................... 11
`1.
`Knockeart .......................................................................................... 12
`2.
`Treyz ................................................................................................... 15
`3.
`The Combination of Knockeart and Treyz ................................... 19
`Claims 6–8 are Obvious in View of the Combination of
`Knockeart, Treyz, and Demir ..................................................................... 48
`Claims 11 and 12 are Obvious in View of the Combination of
`Knockeart, Treyz, and Tanaka .................................................................... 54
`Conclusion ................................................................................................................ 60
`
`B.
`
`C.
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`
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`V.
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`-i-
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`TABLE OF AUTHORITIES
`
`Cases
`Concrete Appliances Co. v. Gomery,
`269 U.S. 177 (1925) .......................................................................................................... 48
`
`Geo. M. Martin Co. v. Alliance Machine Sys, Int’l, LLC,
`618 F.3d 1297 (Fed. Cir. 2010) ....................................................................................... 48
`
`Statutes
`
`35 U.S.C. § 102(a) ............................................................................................................... 6, 7
`
`35 U.S.C. § 102(b) ................................................................................................................. 10
`
`35 U.S.C. § 103........................................................................................................................ 2
`
`35 U.S.C. § 103(a) .......................................................................................................... passim
`
`35 U.S.C. § 314(a) ..................................................................................................... 48, 54, 60
`
`Rules
`
`37 C.F.R. § 42.100(b) ........................................................................................................... 10
`
`37 C.F.R. § 42.104(a) .............................................................................................................. 2
`
`37 C.F.R. § 42.104(b)(1)-(2) ................................................................................................. 10
`
`37 C.F.R. § 42.104(b)(1)-(3) ................................................................................................... 2
`
`37 C.F.R. § 42.104(b)(3) ....................................................................................................... 10
`
`37 C.F.R. § 42.104(b)(4)-(5) ................................................................................................. 11
`
`37 C.F.R. § 42.22(a)(1) ........................................................................................................... 2
`
`37 C.F.R. § 42.8....................................................................................................................... 1
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`-ii-
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`
`Exhibit 1001
`
`Exhibit 1002
`
`Exhibit 1003
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`
`Exhibit 1004
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`
`Exhibit 1005
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`
`Exhibit 1006
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`
`Exhibit 1007
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`
`Exhibit 1008
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`
`Exhibit 1009
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`
`Exhibit 1010
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`Exhibit 1011
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`
`Exhibit 1012
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`
`Exhibit 1013
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`Exhibit 1014
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`
`
`
`LISTING OF EXHIBITS
`
`U.S. Patent No. 7,917,285 to Rothschild
`
`Declaration of Scott Andrews
`
`Non-Final Office Action, dated February 24, 2010, in U.S.
`Patent Application Serial No. 11/413,890
`
`U.S. Patent Application Publication No. 2004/0228489 to
`Ishibashi et al.
`
`U.S. Patent Application Publication No. 2004/0064245 to
`Knockeart et al.
`
`Amendment, dated July 26, 2010,
`Application Serial No. 11/413,890
`
`in U.S. Patent
`
`Final Office Action, dated October 13, 2010, in U.S. Patent
`Application Serial No. 11/413,890
`
`Amendment After Final Rejection, dated December 8,
`2010, in U.S. Patent Application Serial No. 11/413,890
`
`Notice of Allowance, dated February 11, 2011, in U.S.
`Patent Application Serial No. 11/413,890
`
`U.S. Patent No. 6,526,335 to Treyz et al.
`
`European Published Patent Application No. 1 302 751 to
`Demir et al., and a certified English translation
`
`U.S. Patent Application Publication No. 2003/0043019 to
`Tanaka et al.
`
`U.S. Patent No. 5,875,296 to Shi et al.
`
`U.S. Patent No. 7,114,006 to Colvig et al.
`-iii-
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`Exhibit 1015
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`
`Exhibit 1016
`
`
`
`
`Richard Lind et al., The Network Vehicle – A Glimpse into the
`Future of Mobile Multi-Media, SAE Technical Paper Series
`No. 982901
`
`U.S. Patent No. 7,386,393 to Zabel et al.
`
`
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`-iv-
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`I. Mandatory Notices (37 C.F.R. § 42.8)
`
`Real Party-in-Interest:
`
`Volkswagen Group of America, Inc., which is a subsidiary of Volkswagen AG.
`
`Related Matters:
`
`The following judicial matters may affect, or may be affected by, a decision in this
`
`inter partes review: Rothschild Location Technologies, LLC v. Volkswagen Group of America,
`
`Inc., No. 1:14-cv-01129 (D. Del.), in which Petitioner is the defendant; Rothschild
`
`Location Technologies, LLC v. Hyundai Motor America, No. 1:14-cv-01128 (D. Del.),
`
`Rothschild Location Technologies, LLC v. Volvo Case of North America LLC, No. 1:14-cv-
`
`01130 (D. Del.), Rothschild Location Technologies, LLC v. Nissan North America Inc., No.
`
`1:14-cv-00879 (D. Del.), Rothschild Location Technologies, LLC v. Calamp, Corp., No. 1:14-
`
`cv-00632 (D. Del.), Rothschild Location Technologies, LLC v. Fleetcor Techs. Inc., et al., No.
`
`1:14-cv-00634 (D. Del.), Rothschild Location Technologies, LLC v. Teletrac Inc., No. 1:14-
`
`cv-00639 (D. Del.), Rothschild Location Technologies, LLC v. American Honda Motor Co.,
`
`Inc., No. 1:14-cv-01351 (D. Del.), Rothschild GPS Sharing Innovations, LLC v. Nissan
`
`North America, Inc., No. 3:14-cv-00819 (S.D. Cal.), Qaxaz LLC v. Ford Motor Co.., et al.,
`
`No. 1:11-cv-00491 (D. Del.), and Qaxaz LLC v. Pioneer Electronics (USA) Inc., No. 1:11-
`
`cv-00492 (D. Del.).
`
`The following administrative matters may affect, or may be affected by, a decision
`
`in this inter partes review: U.S. Patent No. 8,606,503, which issued from U.S. Patent
`
`1
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`

`

`
`
`Application Serial No. 12/882,754; and U.S. Patent Application Serial No.
`
`14/022,193.
`
`Counsel:
`
`Lead Counsel:
`
` Michael J. Lennon (Reg. No. 26,562)
`
`Backup Counsel: Clifford A. Ulrich (Reg. No. 42,194)
`
`Electronic Service: ptab@kenyon.com
`
`Post and Delivery: Kenyon & Kenyon LLP, One Broadway, New York NY 10004.
`
`Telephone: 212-425-7200 Facsimile: 212-425-5288
`
`II. Grounds for Standing (37 C.F.R. § 42.104(a))
`
`Petitioner certifies that U.S. Patent No. 7,917,285 (“the ’285 patent”) for which
`
`review is sought is available for inter partes review and that Petitioner is not barred or
`
`estopped from requesting an inter partes review challenging the patent claims on the
`
`grounds identified in this petition.
`
`III. Identification of Challenge (37 C.F.R. § 42.104(b)(1)-(3)) and Relief
`Requested (37 C.F.R. § 42.22(a)(1))
`
` Petitioner challenges claims 1–12 of the ’285 Patent under 35 U.S.C. § 103, and
`
`cancelation of those claims is requested.
`
`A. The ’285 Patent
`
`The ’285 patent issued on March 29, 2011 from the ’890 Application, filed April
`
`28, 2006. The ’285 patent includes 18 claims, of which claims 1 and 13 are
`
`independent. Independent claim 1 is reproduced below.
`
`2
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`

`

`
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`1. 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;
`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.
`
`The ’285 patent describes systems and methods for remotely entering, storing, and
`
`sharing addresses for Global Positioning Satellite (GPS) devices. Col 2, ll. 34–39. In
`
`its background, the ’285 patent describes GPS devices having three limitations relating
`
`to entry of addresses: first, each GPS device is configured to recognize addresses
`3
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`differently using different user interfaces; second, GPS devices do not share
`
`addresses, forcing users to enter destinations into each owned GPS device; third, GPS
`
`devices are difficult to program while driving. Col. 1, l. 43–col. 2, l. 13. The ’285
`
`patent notes the growing trend in automobile telematics, but observes the difficulty in
`
`programming GPS devices with destination information. Col. 2, ll. 14–30.
`
`To address these limitations, the ’285 patent describes a GPS device 100 in
`
`communication with a central server 304 via a telematics network. Col. 8, ll. 11–29. A
`
`user may program the GPS device 100 using a computer 306, coupled to
`
`communications network 302, such as the Internet. Col. 9, ll. 64–67; Fig. 3.
`
`The ’285 patent describes a user entering a location into the computer 306 using a
`
`client application program, such as a web browser, for transmission to the server 304.
`
`
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`4
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`Col. 9, l. 67–col 10 20. The user’s computer may identify the user to the server by
`
`transmitting an Internet cookie with the location information, so that the server can
`
`use a database lookup program to identify transmission information for the GPS
`
`device 100, such as a telephone number or IP address. Col. 10, ll. 21–33 (“The remote
`
`server then utilizes a standard database lookup program, based on the received
`
`identifier, to find out information on the user’s device including the transmission
`
`information for the device which may be the cellular telephone number of the device
`
`or a vehicle or the Internet address (e.g., the IP address) of the device or vehicle.”).
`
`Once it receives the information, the server 304 resolves the address into longitude or
`
`latitude coordinates using “standard computer processing power and computer
`
`programs”
`
`such
`
`as “teraserver.microsoft.com, geocorder.us,yahoo.com,
`
`and
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`maporama.com.” Col. 10, ll. 34–38. The server then sends the resolved information to
`
`the GPS device 100, which stores the information and uses “standard GPS computer
`
`processing power and systems” to provide route guidance to the user. Col. 10, ll. 38–
`
`49. See Andrews Declaration, Ex. 1002, ¶ 3.
`
`Thus, the ’285 patent describes (i) a web browser for transmitting a location and
`
`an Internet cookie from a computer to a server, (ii) the server using a database lookup
`
`program to determine the transmission information for a GPS device and to resolve
`
`an address into coordinates information, and (iii) the GPS device providing route
`
`guidance.
`
`5
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`
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`B. Prosecution History of the ’285 Patent
`
`The ’890 application (which issued as the ’285 patent) was filed with application
`
`claims 1-41, of which claims 1, 18, and 25 were independent. Claim 25, which would
`
`later issue as patent claim 1, is reproduced below (see Ex. 1002, ¶ 4):
`
`25. A system for entering location information into a positional
`information device, the system comprising:
`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.
`
`
`In an Office Action dated February 24, 2010 (Ex. 1003), claims 18-20, 22-26, 29-
`
`31, 35, 36, 38, 39, and 41 were rejected under 35 U.S.C. § 102(a) as anticipated by U.S.
`
`Patent Application Publication No. 2004/02284849 (“Ishibashi,” Ex. 1004), and
`
`claims 21, 27, 33, 34, and 40 were rejected under 35 U.S.C. § 103(a) as obvious over
`
`6
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`

`

`
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`Ishibashi in view of U.S. Patent Application Publication No. 2004/0064245
`
`(“Knockeart,” Ex. 1005). In the Response filed on July 26, 2010 (Ex. 1006), Applicant
`
`canceled claims 1-24 and 37, added claims 42-44, and amended claim 25, as follows
`
`(see Ex. 1002, ¶ 5):
`
`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
`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.
`
`In a Final Office Action issued on October 13, 2010 (Ex. 1007), the Examiner
`
`rejected claims 25-31, 34, and 38-44 under 35 U.S.C. § 102(a) as anticipated by
`
`7
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`

`

`
`
`Knockeart, determining that Knockeart describes a server configured to receive a
`
`request for an address of at least one location not already stored in the positional
`
`information device (in-vehicle database and point of interest and address input of
`
`Figures 4B, 11, and 14), determining and transmitting the address (route planning in
`
`the vehicle and server of Figures 15A and 15B), the positional information device
`
`including a locational information module, a communication module, a processing
`
`module to determine route guidance, and a display module (in-vehicle system of
`
`Figure 2, including GPS receiver 252, cellular transceiver 254, processor 212, and
`
`display 242), and a communications network for coupling the positional information
`
`device to the server (telephone network 350 and PSTN network 340 of Figure 3). Ex.
`
`1007 at 2–3. The Examiner indicated that claim 33 included allowable subject matter:
`
`“wherein the server is configured to determine a second identifier for the positional
`
`information device based on the received first identifier of the remote computer.” See
`
`Ex. 1002, ¶ 7.
`
`In Response, on December 8, 2010, Applicant made no arguments against the
`
`pending rejection. Instead, Applicant opted for the subject matter indicated to be
`
`allowable, incorporating claims 30, 31, and 33 into claim 25. Ex. 1008; see Ex. 1002, ¶
`
`6.
`
`25. A system for remotely entering location information into a
`positional information device, the system comprising:
`
`8
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`

`

`
`
`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;
`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.
`
`A Notice of Allowance issued on February 11, 2011 (Ex. 1009), and the
`
`’285 patent issued on March 29, 2011.
`
`C. Patents and Printed Publications Relied On
`
`U.S. Patent Appl. Pub. No. 2004/0064245 (“Knockeart,” Ex. 1005), published
`
`April 1, 2004, constitutes prior art against the ’285 patent under 35 U.S.C. § 102(b).
`
`9
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`

`

`
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`U.S. Patent No. 6,526,335 (“Treyz,” Ex. 1010), issued February 25, 2003,
`
`constitutes prior art against the ’285 patent under 35 U.S.C. § 102(b).
`
`European Pub. Patent Appl. No. 1 302 751 (“Demir,” Ex. 1011, including a
`
`certified English translation), published April 16, 2003, constitutes prior art against
`
`the ’285 patent under 35 U.S.C. § 102(b).
`
`U.S. Patent Appl. Pub. No. 2003/0043019 (“Tanaka,” Ex. 1012), published March
`
`6, 2003, constitutes prior art against the ’285 patent under 35 U.S.C. § 102(b).
`
`D. Statutory Grounds for Challenge (37 C.F.R. § 42.104(b)(1)-(2))
`
` Cancelation of claims 1–12 is requested on the following grounds:
`
`A.
`
`B.
`
`C.
`
`Claims 1–5, 9, and 10 are obvious under 35 U.S.C. § 103(a) over the
`combination of Knockeart and Treyz
`
`Claims 6–8 are obvious under 35 U.S.C. § 103(a) over the combination
`of Knockeart, Treyz, and Demir
`
`Claims 11 and 12 are obvious under 35 U.S.C. § 103(a) over the
`combination of Knockeart, Treys, and Tanaka
`
`
`
`E. Claim Construction (37 C.F.R. § 42.104(b)(3))
`
`The claim terms should be given their broadest reasonable construction in view of
`
`the specification. 37 C.F.R. § 42.100(b). The claim terms are generally presumed to
`
`take on their ordinary and customary meaning. The specification of the ’285 patent
`
`does not present any special definition for any claim term, and the prosecution history
`
`of the ’285 patent does not include any claim construction arguments.
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`10
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`
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`IV. How Challenged Claims Are Unpatentable (37 C.F.R. § 42.104(b)(4)-(5))
`
`As described above, during the original prosecution of the ’285 patent, the
`
`Examiner initially rejected application claim 25 as anticipated by Knockeart, but
`
`indicated that the subject matter of dependent claim 33 was allowable. The Applicant
`
`chose to incorporate the subject matter of dependent claim 33 into independent claim
`
`25, without disputing the findings of the Examiner. Thus, during prosecution, it was
`
`undisputed that Knockeart describes all of the limitations of claim 1, except for the
`
`limitation that led to allowance, i.e., “the server being configured to determine a
`
`second identifier for identifying the positional information device based on the
`
`received first identifier.” As discussed below, the prior art, (e.g., Treyz), describes this
`
`additional claim limitation, so that claims 1–12 of the ’285 patent are unpatentable.
`
`A. Claims 1–5, 9, and 10 are Obvious in View of the Combination of
`Knockeart and Treyz
`Claims 1–5, 9, and 10 are obvious under 35 U.S.C. § 103(a) in view of the
`
`combination of Knockeart and Treyz. As stated above, during prosecution of the ’285
`
`patent, the Examiner initially rejected the claims as anticipated by Knockeart, and
`
`Applicant amended the claims to include limitations that the Examiner indicated to be
`
`allowable. Treyz was not cited by the Examiner or the Applicant during prosecution
`
`of the ’285 patent.
`
`11
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`
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`1. Knockeart
`Knockeart, assigned to Siemens Automotive Corp., describes a vehicle information
`
`system including an in-vehicle system 105 in communication with a centralized server
`
`125, used to provide route planning. Abstract; ¶¶ 9, 73. The operator of the vehicle
`
`inputs a desired destination into the in-vehicle system 105, which uploads the desired
`
`destination to the server system 125. The server system determines a route plan and
`
`sends the plan to the in-vehicle system 105, which performs route guidance. ¶ 74; see
`
`Ex. 1002, ¶ 9. Figure 1, reproduced below, illustrates the system.
`
`
`
`
`
`Figure 2, reproduced below, depicts a block diagram of in-vehicle system 105,
`
`including onboard computer 210, processor 212, GPS antenna 253 and receiver 252,
`
`cellular transceiver 254, and display 242. The operator enters a desired destination in
`
`12
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`
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`input device 244, and GPS receiver 252 determines the current location of the vehicle
`
`to be used as the starting point in determining a route. ¶¶ 113–123; see Ex. 1002, ¶ 10.
`
`
`
`Once the operator has entered destination information into the in-vehicle system
`
`105, the in-vehicle system 105 sends the entered information to the server 125 over
`
`cellular telephone network 350 and PSTN 340. ¶¶ 125–127. The server system 125
`
`then determines a route from the current location to the desired destination, and
`
`sends the route to the in-vehicle system 105 along with spot maps of the current
`
`location and destination. ¶¶ 73–74, 183–185. In-vehicle system 105 uses the
`
`13
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`
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`downloaded route to provide route guidance, both in executing the route provided by
`
`the server system 125, and in re-planning the route if the vehicle goes off-course. ¶¶
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`73–74 (“After planned route information is downloaded to the vehicle from the
`
`server system, the in-vehicle system does not require further interaction with the
`
`server system to operate in its autonomous route guidance mode. While in the
`
`autonomous route guidance mode the in-vehicle system can recover from an operator
`
`going off the planned route without necessarily requiring further communication with
`
`the server system.”), 103–104, 151. See Ex. 1002, ¶ 10.
`
`The server 125 compares the entered desired destination to a database, to either
`
`determine the address of the desired destination (¶ 168–169, 236) or validate the
`
`entered destination (¶ 239). Knockeart describes various systems for determining the
`
`address of a desired destination. For example, the operator enters a telephone number
`
`in the in-vehicle system for transmission to the server system 125, which runs
`
`navigation application 512 to determine the address of the desired destination, using
`
`server map database 520 and yellow pages database 520. ¶ 168–169 (“Navigation
`
`application 512 also makes use of a yellow pages database 522 that it uses to convert
`
`the telephone number of a desired destination to a street address in a ‘reverse’ number
`
`lookup.”); ¶ 236 (“An operator can specify a destination by specifying the telephone
`
`number of the destination . . . . The server system receives the telephone number and
`
`looks in [sic] up in a ‘reverse’ telephone directory to determine the street address of
`
`the destination.”). As a further example, the operator may be presented with
`14
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`categories of listings stored on the in-vehicle database 432, without street addresses,
`
`for selection. The operator selects a category, initiating a communication session with
`
`the server system 125, which downloads the specific listings, i.e., street addresses, of
`
`the selected category to the in-vehicle system for the operator to select for route
`
`guidance. ¶¶ 230–231 (“The in-vehicle system presents a list of categories to the
`
`operator and the operator selects from the list. Note that the destination is not
`
`completely specified at this point since a particular destination (i.e., a street address)
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`has not yet been determined. After the communication session with the server is
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`established, the server downloads the specific listings in the selected yellow pages
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`category to the in-vehicle system.”); see Ex. 1002, ¶ 11.
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`Knockeart therefore teaches the claimed server (server system 125), receiving a
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`request from a computer (in-vehicle system 105 with onboard computer 210),
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`determining an address for a location (navigation application 512 and yellow pages
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`database 522, ‘reverse’ telephone directory) and transmitting the determined address
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`to a positional information device (in-vehicle system 105).
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`2. Treyz
`Treyz describes an automobile personal computer system, located in a vehicle and
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`wirelessly communicating over local or remote wireless links. Col. 1, ll. 25–36. For
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`example, users may control the automobile personal computer from remote
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`computing devices, using a service provider. Col. 2, ll. 5–8, 44–45. As illustrated in
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`Figure 13 (reproduced below), automobile personal computer 14 and home electronic
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`device 313 may be connected over the communications network 314, such as the
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`Internet, to download information to the automobile personal computer 14. Col. 19,
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`ll. 33–45; see Ex. 1002, ¶ 12.
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`
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`As described by Treyz, users may require authentication before being permitted
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`access to the automobile personal computer. A user may therefore create a personal
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`identification number (PIN), password, or other user identifier, used to verify the
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`user’s identity. Col. 30, ll. 25–32, 54–60 (“At step 466, the PIN, password, voiceprint,
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`fingerprint, or other information used to identify the user is used to verify the user’s
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`identity. The user’s identity may be verified, for example, when the user is using the
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`16
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`automobile personal computer 14 or when the user is selecting options or modifying
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`settings related to the operation of automobile 12.”); see Ex. 1002, ¶¶ 13–14.
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`Treyz teaches that a user’s identifying information is used to identify the user’s
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`automobile personal computer 14. For example, a user registers a user ID and an
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`identification number for the automobile personal computer with a service provider.
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`Col. 42, ll. 10–25 (“For example, the user may register by supplying the service
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`provider with an identification number that is associated with the automobile personal
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`computer 14 and that uniquely identifies a communications address for automobile
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`personal computer 14. The user may also provide user information such as the user's
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`password or user ID, or other information that may be used to verify the user's
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`identity and authorization to remotely control automobile 12.”). Later, when a user
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`seeks to remotely control the automobile personal computer, the user enters his
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`password or other verifying information, and the server identifies the associated
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`automobile personal computer and sends control commands. Col. 42, ll. 38–44 (“To
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`verify the user’s identity at the service provider server, the user device may
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`communicate with the server. After the user’s identity has been verified, control
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`commands for the selected option are transmitted to automobile personal computer
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`14 from the server at step 614.”); see Ex. 1002, ¶¶ 13–14.
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`Additionally, Treyz teaches a system for locating a parked car, in which a user at a
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`kiosk enters user identification information, and a database correlates the user
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`identification to an automobile personal computer communications address, such as
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`an email or “general purpose address or identifier.” Col. 32, ll. 28–54 (“The
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`manufacturer or a third party may maintain a database that correlates user names (for
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`example) with automobile personal computer communications addresses. The user’s
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`user ID or password may also be used to identify automobile personal computer 14 to
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`kiosk 486. Such information may also be used to verify the user’s identity.”). The
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`system will then establish a link with the automobile personal computer according to
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`the communications address, and obtain GPS information about the automobile. Col.
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`32, ll. 55–66; see Ex. 1002, ¶ 14.
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`Further, Treyz teaches a system for determining a street address associated with
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`the location of a parked automobile, and sending that street address to a user’s
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`personal device, such as a home computer or a mobile device. Col. 44, ll. 27–42 (“At
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`step 642, the user device or the automobile personal computer accesses a map or
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`address database that is remote from automobile 12. A database look-up operation
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`may be performed on the remote database at step 642 to determine the contextual
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`location (e.g., the street address, etc.) of automobile 12 based on the coordinates
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`supplied at step 638 and to supply this information to the user device.”). Treyz also
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`describes automobile personal computer 14 connecting to a GPS system to determine
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`the location of the vehicle, and further being capable of calculating and displaying
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`route guidance. Col. 11, ll. 38–42; col. 86, ll. 47–59; see Ex. 1002, ¶ 14.
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`Treyz therefore teaches the claimed server (service provider server or third party
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`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 positional information
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`device (automobile personal computer 14) based on the received first identifier
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`(communications address for automobile personal computer), and transmitting
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`information to the positional information device (control commands or request for
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`location). See Ex. 1002, ¶ 15. The first identifier (user identification information, e.g.,
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`name, PIN, or password) and the second identifier (communications address for
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`automobile personal computer) are provided, according to Treyz, for security
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`purposes, for ensuring that purchases made through the automobile personal
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`computer are authorized, and for verifying a user’s identity. See col. 30, l. 25–col. 31, l.
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`15; Ex. 1002, ¶ 18.
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`3. The Combination of Knockeart and Treyz
`The combination of Knockeart and Treyz renders obvious claims 1–5, 9, and 10 of
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`the ’285 patent.
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`Claim 1 is directed to a “system for remotely entering location information into a
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`positional information device.” Both Knockeart and Treyz describe remotely entering
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`information from a centr