Before the Patent Trial and Appeal Board
`________________
`
`NISSAN NORTH AMERICA, INC.
`Petitioner
`v.
`JOAO CONTROL & MONITORING SYSTEMS, LLC
`Patent Owner
`________________
`
`Case IPR2015-01585
`U.S. Patent No. 5,917,405
`
`Patent Owner’s Demonstrative Exhibits For Oral Hearing
`
`1 of 16
`
`JCMS - EXHIBIT 2007
`
`
`________________
`
`NISSAN NORTH AMERICA, INC.
`Petitioner
`v.
`JOAO CONTROL & MONITORING SYSTEMS, LLC
`Patent Owner
`________________
`
`Case IPR2015-01585
`U.S. Patent No. 5,917,405
`
`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 9.
`
`2
`
`2 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`Claim Construction: the signals
`
`• In litigation involving the ‘405 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 9.
`
`3
`
`3 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`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 8.
`Decision at 14.
`
`4
`
`4 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`Frossard: Petitioner’s Position
`
`Control
`Device A
`
`Control
`Device B
`
`Control
`Device C
`(at vehicle)
`
`Exh. 1005 (Frossard) at Fig. 4.
`Petition at 17, 19-20 and 22-25.
`
`5
`
`5 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`The Second Signal
`
`The ‘405 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 17-22.
`
`6
`
`6 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`Frossard and Simms Fail to Render Obvious
`Claim 3
`
`7
`
`7 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`Frossard and Simms Fail to Render Obvious
`Claim 3
`
`• A substantial redesign of the Frossard system would be required
`to add Simms’ functionality.
`
`• A positioning device would have to installed and integrated with
`the the rudimentary receiver/decoder circuit 4 of Frossard.
`
`• With regards to server 1 of Frossard, server 1 would 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 23-25.
`
`8
`
`8 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`Frossard and Shimizu Fail to Render Obvious
`Claim 11
`
`9
`
`9 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`Frossard and Shimizu Fail to Render Obvious
`Claim 11
`
`• Frossard is directed at a vehicle security system.
`
`• The use of a voice synthesizer (Shimizu) to provide
`voice messages indicative of the operation of the
`vehicle is completely inconsistent with the object of
`Frossard (a security system). There is absolutely no
`reason to provide this type of information to a car thief
`or other unauthorized individual.
`
`Patent Owner’s Response at 25-27.
`
`10
`
`10 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`Pagliaroli Fails to Disclose an A to B to C System
`as Required by Independent Claims 1 and 16
`
`Petitioner’s Position
`
`Control
`Device C
`(at vehicle)
`
`Control
`Device A
`
`Control
`Device B
`
`Exh. 1006 (Pagliaroli) at Fig. 1.
`Petition at 39, 42 and 44-50.
`
`11
`
`11 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`The Second Signal
`
`The ‘405 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 27-32.
`
`12
`
`12 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`Pagliaroli and Simms Fail to Render Obvious
`Claim 3
`
`13
`
`13 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`Pagliaroli and Simms Fail to Render Obvious
`Claim 3
`
`• 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 32-35.
`
`14
`
`14 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`Pagliaroli and Shimizu Fail to Render Obvious
`Claim 11
`
`15
`
`15 of 16
`
`JCMS - EXHIBIT 2007
`
`
`
`Pagliaroli and Shimizu Fail to Render Obvious
`Claim 11
`
`• Pagliaroli is directed to a system for the controlled
`shutdown of equipment in the event of theft or
`unauthorized access.
`
`• The use of a voice synthesizer to provide voice
`messages indicative of the operation of the vehicle is
`completely inconsistent with the object of the Pagliaroli
`system. There is absolutely no reason to provide this
`type of information to a car thief or other unauthorized
`individual.
`
`Patent Owner’s Response at 35-37.
`
`16
`
`16 of 16
`
`JCMS - EXHIBIT 2007
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
