Before the Patent Trial and Appeal Board
`________________
`
`NISSAN NORTH AMERICA, INC.
`Petitioner
`v.
`JOAO CONTROL & MONITORING SYSTEMS, LLC
`Patent Owner
`________________
`
`Case IPR2015-01508
`U.S. Patent No. 6,542,076
`
`Patent Owner’s Demonstrative Exhibits For Oral Hearing
`
`1 of 16
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`JCMS - EXHIBIT 2007
`
`
`________________
`
`NISSAN NORTH AMERICA, INC.
`Petitioner
`v.
`JOAO CONTROL & MONITORING SYSTEMS, LLC
`Patent Owner
`________________
`
`Case IPR2015-01508
`U.S. Patent No. 6,542,076
`
`Patent Owner’s Demonstrative Exhibits For Oral Hearing
`
`1 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`Claim Construction: the signals
`
`• “first signal” is: “a signal sent by a first device”
`
`• “second signal” is: “a signal sent by a second device”
`
`• “third signal” is: “a signal generated by a third
`device”
`
`Patent Owner’s Response at 12.
`
`2
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`2 of 16
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`Claim Construction: the signals
`
`• In litigation involving the ‘076 Patent, the U.S.
`District Court for the Eastern District of Michigan
`adopted the same constructions proposed by Patent
`Owner.
`
`Patent Owner’s Response at 11.
`
`3
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`3 of 16
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`Claim Construction: “control device”
`
`• The Board adopted the express definition of this term provided
`during prosecution of a related patent application.
`
`• “control device” means: “a device or a computer, or that part
`of a device or a computer, which performs an operation, an
`action, or a function, or which performs a number of
`operations, actions, or functions .”
`
`Patent Owner’s Response at 11.
`Decision at 14.
`
`4
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`4 of 16
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`Frossard: Petitioner’s Position
`
`Control
`Device A
`
`Control
`Device B
`
`Control
`Device C
`(at vehicle)
`
`Exh. 1005 (Frossard) at Fig. 4.
`Petition at 10, 14 and 17-19.
`
`5
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`The Second Signal
`
`The ‘076 Patent: A to B to C System/Method
`
`Control
`Device A
`
`Control
`Device B
`
`Control
`Device C
`(At Vehicle)
`
`Frossard: A to B to C to D System
`
`Minitel
`Telephone
`
`Server
`1
`
`Resource
`2
`
`Receiver-
`Decoder Circuits
`4
`(At Vehicle)
`
`Exh. 1005 (Frossard) at Fig. 4.
`Patent Owner’s Response at 16-22.
`
`6
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`Frossard and Drori Fail to Render Obvious
`Claim 93
`
`7
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`Frossard and Drori Fail to Render Obvious
`Claim 93
`
`• A substantial redesign of the Frossard system would be required
`to add Drori’s functionality of sending the on/off status of the
`engine to a user of the Frossard system.
`
`• The rudimentary receiver/decoder circuits 4 of Frossard would
`have to be redesigned so as to provide communication of the
`engine’s on/off status to a remote user, since the receiver/decoder
`circuits 4 of Frossard, as their name implies, are designed to only
`receive signals and decode those signals.
`
`Patent Owner’s Response at 22-24.
`
`8
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`Frossard and Simms Fail to Render Obvious
`Claim 108
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`9
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`Frossard and Simms Fail to Render Obvious
`Claim 108
`
`• A complete redesign at the vehicle of Frossard would be required,
`where a positioning device would have to installed and integrated
`with the rudimentary receiver/decoder circuits 4.
`
`• Server 1 of Frossard would also have to be redesigned to turn
`server 1 into a manned central station which is equipped with
`displays for allowing an individual operator or operators to view
`and monitor vehicle position or location on a digitized map.
`
`Patent Owner’s Response at 24-27.
`
`10
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`Pagliaroli Fails to Disclose an A to B to C System
`as Required by Independent Claims 3, 73 and 205
`
`Petitioner’s Position
`
`Control
`Device C
`(at vehicle)
`
`Control
`Device A
`
`Control
`Device B
`
`Exh. 1006 (Pagliaroli) at Fig. 1.
`Petition at 36-40, 42-43 and 45-46.
`
`11
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`11 of 16
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`The Second Signal
`
`The ‘076 Patent: A to B to C System
`
`Control
`Device A
`
`Control
`Device B
`
`Control
`Device C
`(At Vehicle)
`
`Pagliaroli: A to B to C to D System
`
`Telephone
`48
`
`Signal
`Transmitter
`46
`
`Receiver
`14
`(at the vehicle)
`
`Control Unit
`16
`(At Vehicle)
`
`Exh. 1006 (Pagliaroli) at Fig. 1.
`Patent Owner’s Response at 28-34.
`
`12
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`Pagilaroli Fails to Disclose a “First Control Device”
`that Determines an “Operating Status” as Required by
`Claim 93
`
`13
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`Pagilaroli Fails to Disclose a “First Control Device”
`that Determines an “Operating Status” as Required by
`Claim 93
`
`• Based on Petitioner’s own anticipation
`arguments with regards to independent
`claim 73, the devices that must determine
`an operating status are the “receiver 14”
`and “control unit 16” of Pagliaroli,
`because these are the devices that
`Petitioner alleges correspond to the
`claimed “first control device.”
`
`• The device in Pagliaroli that determines
`whether the vehicle is being stolen is the
`“theft sensor 12.” The “theft sensor” 12 is
`not the device that Petitioner alleges is the
`claimed “first control device.”
`
`Control
`Device C
`(at vehicle)
`
`Control
`Device A
`
`Control
`Device B
`
`Exh. 1006 (Pagliaroli) at Fig. 1.
`Patent Owner’s Response at 34-35.
`
`14
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`Pagliaroli and Simms Fail to Render Obvious
`Claim 108
`
`15
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`Pagliorili and Simms Fail to Render Obvious
`Claim 108
`
`• A substantial redesign at the Pagliaroli mobile telephone signal
`transmitter 46 and at the vehicle is required in order to combine the
`teachings of Pagliaroli and Simms.
`
`• The vehicle of Pagliaroli and, in particular, the receiver 14 of Pagliaroli,
`would have to be modified in a similar manner as the vehicle in Frossard
`in order to provide position determining functionality.
`
`• A positioning device would have to be installed and integrated with the
`receiver 14, and at the mobile telephone signal transmitter 46, which
`would require that the mobile telephone signal transmitter 46 be turned
`into a manned central station equipped with displays for allowing an
`individual operator or operators to view and monitor vehicle position or
`location on a digitized map.
`
`Patent Owner’s Response at 36-40.
`
`16
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`16 of 16
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`JCMS - EXHIBIT 2007
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