UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
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`VOLKSWAGEN GROUP OF AMERICA, INC.
`Petitioner,
`v.
`JOAO CONTROL & MONITORING SYSTEMS, LLC
`Patent Owner
`________________
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`Case IPR2015-01611
`Patent 6,549,130
`________________
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`PATENT OWNER’S RESPONSE TO PETITION
`FOR INTER PARTES REVIEW UNDER 37 C.F.R. § 42.107
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`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
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`VOLKSWAGEN GROUP OF AMERICA, INC.
`Petitioner,
`v.
`JOAO CONTROL & MONITORING SYSTEMS, LLC
`Patent Owner
`________________
`
`Case IPR2015-01611
`Patent 6,549,130
`________________
`
`
`
`PATENT OWNER’S RESPONSE TO PETITION
`FOR INTER PARTES REVIEW UNDER 37 C.F.R. § 42.107
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`Patent Owner’s Response to Petition
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`TABLE OF CONTENTS
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`I. INTRODUCTION ............................................................................................... 1
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`Page
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`II. BACKGROUND ................................................................................................. 1
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` A. Overview of the ‘130 Patent .......................................................................... 1
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` B. Prosecution History of the ‘130 Patent .......................................................... 2
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` C. Representative Claims .................................................................................... 3
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`III. CLAIM CONSTRUCTION ............................................................................. 11
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` A. Legal Standards ............................................................................................ 11
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` B. “control device” ............................................................................................ 14
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`IV. RESPONSE TO PROPOSED GROUNDS OF INVALIDITY ....................... 14
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` A. Ground 1 is Deficient ................................................................................... 14
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` 1. Kniffin fails to disclose an “A to B to C” system for controlling a vehicle
` system/component in response to a signal from a control device located
` remote from the vehicle .......................................................................... 15
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` 2. Kniffin fails to disclose transmitting a signal for controlling a vehicle
` system/component from a control device located remote from the vehicle
` to a control device located at the vehicle ................................................ 29
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` B. Ground 2 is Deficient ................................................................................... 31
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` E. Ground 5 is Deficient ................................................................................... 36
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`VII. CONCLUSION .............................................................................................. 36
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`ii ii
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` C. Ground 3 is Deficient ................................................................................... 35
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` C. Ground 4 is Deficient ................................................................................... 36
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`LIST OF EXHIBITS
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`Exhibit
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`EX2001
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`Description
`“Preliminary Remarks” filed by Applicant on November 26, 2006
`during prosecution of the patent application that issued as related U.S.
`Patent No. 7,277,010
`“Supplement to the Remarks for the Amendment filed on October 24,
`2007” filed on November 23, 2007 during prosecution of the patent
`application that issued as related U.S. Patent No. 7,397,363
`EX2003 Declaration of Steven W. Ritcheson
`EX2004 Transcript of April 21, 2016 Deposition of Scott Andrews
`“The Internet Report,” Morgan Stanley Global Technology Group,
`EX2005
`February 1996.
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`iii iii
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`EX2002
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`Patent Owner’s Response to Petition
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`I.
`INTRODUCTION
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`In response to the Petition for Inter Partes Review (“Petition”) filed by
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`Petitioner, the Board has instituted inter partes review (Paper 7, the “Decision”)
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`of claims 26, 31, 38, 42, 43, 48, 60, 63, 64, 73, 74, 85, 91, 92, 138, 139 and 143
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`(“Challenged Claims”) of U.S. Patent No. 6,549,130 (“the ‘130 Patent”) based on
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`the following grounds:
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`Ground
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`1
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`2
`3
`4
`5
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`claims
`26, 38, 42, 43,
`48, 63, 73, 74,
`91 and 138
`64, 85 and 92
`31
`60 and 139
`143
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`Proposed Rejections
`anticipated by Kniffin
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`obvious in view of Kniffin
`obvious in view of Kniffin and Ryoichi
`obvious in view of Kniffin and Drori
`obvious in view of Kniffin and Neely
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`The five proposed grounds of rejection are substantively flawed, in that
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`none of the cited references teach important properly construed claim limitations.
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`Accordingly, Joao Control & Monitoring Systems, LLC (“JCMS” or “Patent
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`Owner”) submits this Response to Petitioner’s Petition and the Board’s Decision.
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`II. BACKGROUND
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`A. Overview of the ‘130 Patent
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`1 1
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`The ‘130 Patent is directed to a novel and unconventional system for, inter
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`alia, remotely-controlling and/or monitoring systems located at vehicles and
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`premises. EX1001 at 23. The Challenged claims are directed to a specially
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`assembled and programmed distributed control system for vehicles, wherein
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`control functions for a vehicle or for a vehicle system, vehicle component,
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`vehicle device, vehicle equipment, vehicle equipment system, or vehicle
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`appliance, of a vehicle, can be distributed among three separate and distinct
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`control devices, each of which can generate or transmit a separate and distinct
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`signal in order to control a separate fourth device of or at the vehicle, which is the
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`respective vehicle system, vehicle component, vehicle device, vehicle equipment,
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`vehicle equipment system, or vehicle appliance.
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`A separate
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`interface device can be optionally used
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`to facilitate
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`communications between one of the control devices and the separate fourth
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`device of or at the vehicle, which is the respective vehicle system, vehicle
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`component, vehicle device, vehicle equipment, vehicle equipment system, or
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`vehicle appliance.
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`B.
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`Prosecution History of the ‘130 Patent
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`The patent application that issued as the ‘130 Patent was filed on March
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`29, 1999. EX1001. The ‘130 Patent issued on April 15, 2003. Id.
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`During prosecution of related U.S. Patent Applications that issued as U.S.
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`Patent Nos. 7,397,363 and 7,277,010 (hereinafter “the ‘363 Patent” and “the ‘010
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`Patent,” respectively), the Applicant chose to be his own lexicographer and
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`provided explicit definitions for, inter alia, the term “control device” in
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`“Preliminary Remarks” filed by Applicant on November 26, 2006 during
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`prosecution of the patent application that issued as the ‘010 Patent (see EX2001,
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`hereinafter “Preliminary Remarks”) and in “Supplement to the Remarks for the
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`Amendment filed on October 24, 2007” filed on November 23, 2007 during
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`prosecution of the patent application that issued as the ‘363 Patent (see EX2002,
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`hereinafter “First Remarks”).
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`C. Representative Claims
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`Claims 26, 42, 48, 91 and 138 are independent claims. They are
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`reproduced below:
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`26. A control apparatus, comprising:
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`a first control device, wherein the first control device at least one of
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`generates and transmits a first signal for at least one of activating, de-activating,
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`disabling, and re-enabling, at least one of a vehicle system, a vehicle component,
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`a vehicle device, a vehicle equipment, a vehicle equipment system, and a vehicle
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`appliance, of a vehicle, wherein the first control device is located at the vehicle,
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`wherein the first control device is responsive to a second signal, wherein the
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`second signal is at least one of generated by and transmitted from a second
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`control device, wherein the second control device is located at a location which is
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`remote from the vehicle, wherein the second signal is transmitted from the
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`second control device to the first control device, and further wherein the second
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`signal is automatically received by the first control device,
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`wherein the second control device is responsive to a third signal,
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`wherein the third signal is at least one of generated by and transmitted from a
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`third control device, wherein the third control device is located at a location
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`which is remote from the vehicle and remote from the second control device,
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`wherein the third signal is transmitted from the third control device to the second
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`control device, and further wherein the third signal is automatically received by
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`the second control device,
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`wherein the at least one of a vehicle system, a vehicle component, a
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`vehicle device, a vehicle equipment, a vehicle equipment system, and a vehicle
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`appliance, is at least one of a vehicle ignition system, a vehicle fuel pump system,
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`a vehicle alarm system, a vehicle door locking device, a vehicle hood locking
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`device, a vehicle trunk locking device, a wheel locking device, a brake locking
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`device, a horn, a vehicle light, a vehicle lighting system, a refrigerator, an air
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`conditioner, an oven, a vehicle window locking device, a video recording device,
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`an audio recording device, a camera, an intercom device, a microphone, a locking
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`device, a monitoring device for monitoring at least one of fuel supply, water or
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`coolant supply, generator operation, alternator operation, battery charge level,
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`and engine temperature, fire extinguishing equipment, radar equipment, hydraulic
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`equipment, pneumatic equipment, a winch, a self-defense system, a weapon
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`system, a gun, an electronic warfare system, a pumping device, sonar equipment,
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`a locking device for preventing unauthorized access to a vehicle compartment,
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`and landing gear.
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`42. A method for providing control, comprising:
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`transmitting a first signal from a first control device to a second
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`control device, wherein the first control device is located at a location remote
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`from a vehicle and remote from the second control device, and further wherein
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`the first signal is automatically received by the second control device;
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`transmitting a second signal from the second control device to a
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`third control device, wherein the third control device is located at the vehicle, and
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`further wherein the second control device is located at a location remote from the
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`vehicle, wherein the second signal is automatically received by the third control
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`devices;
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`generating a third signal with the third control device in response to
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`the second signal; and
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`at least one of activating, de-activating, disabling, and re-enabling, at
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`least one of a vehicle system, a vehicle component, a vehicle device, a vehicle
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`equipment, a vehicle equipment system, and a vehicle appliance, in response to
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`the third signal,
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`wherein the at least one of a vehicle system, a vehicle component, a
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`vehicle device, a vehicle equipment, a vehicle equipment system, and a vehicle
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`appliance, is at least one of a vehicle ignition system, a vehicle fuel pump system,
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`a vehicle alarm system, a vehicle door locking device, a vehicle hood locking
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`device, a vehicle trunk locking device, a wheel locking device, a brake locking
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`device, a horn, a vehicle light, a vehicle lighting system, a refrigerator, an air
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`conditioner, an oven, a vehicle window locking device, a video recording device,
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`an audio recording device, a camera, an intercom device, a microphone, a locking
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`device, a monitoring device for monitoring at least one of fuel supply, water or
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`coolant supply, generator operation, alternator operation, battery charge level,
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`and engine temperature, fire extinguishing equipment, radar equipment, hydraulic
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`equipment, pneumatic equipment, a winch, a self-defense system, a weapon
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`system, a gun, an electronic warfare system, a pumping device, sonar equipment,
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`a locking device for preventing unauthorized access to a vehicle compartment,
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`and landing gear.
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`48. A control apparatus, comprising:
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`a first control device, wherein the first control device is capable of at
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`least one of activating, de-activating, disabling, and re-enabling, one or more of a
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`plurality of at least one of a vehicle system, a vehicle component, a vehicle
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`device, a vehicle equipment, a vehicle equipment system, and a vehicle
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`appliance, of a vehicle, wherein the first control device at least one of generates
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`and transmits a first signal for at least one of activating, de-activating, disabling,
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`and re-enabling, the at least one of a vehicle system, a vehicle component, a
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`vehicle device, a vehicle equipment, a vehicle equipment system, and a vehicle
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`appliance, wherein the first control device is located at the vehicle, and further
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`wherein the first control device is responsive to a second signal, wherein the
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`second signal is at least one of generated by and transmitted from a second
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`control device,
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`wherein the second control device is located at a location which is
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`remote from the vehicle, and wherein the second signal is transmitted from the
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`second control device to the first control device, and further wherein the second
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`signal is automatically received by the first control device,
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`wherein the second control device is responsive to a third signal,
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`wherein the third signal is at least one of generated by and transmitted from a
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`third control device, wherein the third control device is located at a location
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`which is remote from the vehicle and remote from the second control device,
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`wherein the third signal is transmitted from the third control device to the second
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`control device, and further wherein the third signal is automatically received by
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`the second control device.
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`91. A control apparatus, comprising:
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`a first control device, wherein the first control device at least one of
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`generates and transmits a first signal for at least one of activating, de-activating,
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`disabling, and re-enabling, at least one of a vehicle system, a vehicle component,
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`a vehicle device, a vehicle equipment, a vehicle equipment system, and a vehicle
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`appliance, of a vehicle, wherein the first control device is located at a location
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`remote from the vehicle, and further wherein the first control device is responsive
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`to a second signal,
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`wherein the second signal is at least one of generated by and
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`transmitted from a second control device, wherein the second control device is
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`located at a location which is remote from the first control device and remote
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`from the vehicle, wherein the second signal is transmitted from the second
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`control device to the first control device, and further wherein the second signal is
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`automatically received by the first control device,
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`wherein the first signal is transmitted from the first control device to
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`a third control device, wherein the third control device is capable of at least one
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`of activating, de-activating, disabling, and re-enabling, one or more of a plurality
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`of the at least one of a vehicle system, a vehicle component, a vehicle device, a
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`vehicle equipment, a vehicle equipment system, and a vehicle appliance, and
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`wherein the third control device is located at the vehicle, and further wherein the
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`first signal is automatically received by the third control device, wherein the third
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`control device at least one of generates and transmits a third signal for at least
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`one of activating, de-activating, disabling, and re-enabling, the at least one of a
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`vehicle system, a vehicle component, a vehicle device, a vehicle equipment, a
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`vehicle equipment system, and a vehicle appliance.
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`138. A method for providing control, comprising:
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`transmitting a first signal from a first control device to a second
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`control device, wherein the first control device is located at a location remote
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`from a vehicle and remote from the second control device, and further wherein
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`the first signal is automatically received by the second control device;
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`transmitting a second signal from the second control device to a
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`third control device, wherein the third control device is located et the vehicle, and
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`further wherein the second control device is located at a location remote from the
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`vehicle, wherein the second signal is automatically received by the third control
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`device, and further wherein the third control device is capable of at least one of
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`activating, deactivating, disabling, and re-enabling, one or more of a plurality of
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`at least one of a vehicle system, a vehicle component, a vehicle device, a vehicle
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`equipment, a vehicle equipment system, and a vehicle appliance;
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`generating a third signal with the third control device in response to
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`the second signal; and
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`at least one of activating, de-activating, disabling, and re-enabling,
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`the at least one of a vehicle system, a vehicle component, a vehicle device, a
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`vehicle equipment, a vehicle equipment system, and a vehicle appliance.
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`III. CLAIM CONSTRUCTION
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`Legal Standards
`A.
`The ‘130 Patent is expired. Claim terms in an expired patent are generally
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`given their “ordinary and customary meaning” as understood by a person of
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`ordinary skill in the art in question at the time of the invention. Phillips v. AWH
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`Corp., 415 F.3d 1303,1327 (Fed. Cir. 2005). However, it is important to note that
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`the Manual of Patent Examining Procedure (MPEP) and controlling case law
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`make it clear that the determination of the ordinary and customary meaning of a
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`term or phrase does not occur in a vacuum, but instead it must be made in light of
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`the patent’s specification and the intrinsic evidence. MPEP §2111.01 is clear and
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`unequivocal on this point. The pertinent portion of the MPEP §2111.01 recites:
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`The ordinary and customary meaning of a term may be
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`evidenced by a variety of sources, including “the words
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`of
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`the claims
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`themselves,
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`the remainder of
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`the
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`specification, the prosecution history, and extrinsic
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`evidence concerning relevant scientific principles, the
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`meaning of technical terms, and the state of the art.”
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`Phillips v. AWH Corp., 415 F.3d at 1314, 75 USPQ2d
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`at 1327. If extrinsic reference sources, such as
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`dictionaries, evidence more than one definition for the
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`term, the intrinsic record must be consulted to identify
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`which of the different possible definitions is most
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`consistent with Applicant’s use of the terms. Brookhill-
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`Wilk 1, 334 F.3d at 1300, 67 USPQ2d at 1137; see also
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`Renishaw PLC v. Marposs Societa' per Azioni, 158
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`F.3d 1243, 1250, 48 USPQ2d 1117, 1122 (Fed. Cir.
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`1998) (“Where there are several common meanings for
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`a claim term, the patent disclosure serves to point away
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`from the improper meanings and toward the proper
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`meanings.”) and Vitronics Corp. v. Conceptronic Inc.,
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`90 F.3d 1576, 1583, 39 USPQ2d 1573, 1577 (Fed. Cir.
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`1996) (construing the term “solder reflow temperature”
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`to mean “peak reflow temperature” of solder rather than
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`the “liquidus temperature” of solder in order to remain
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`consistent with the specification.). (Emphasis added).
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`“[A] patentee may choose to be his own lexicographer” and assign special
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`definitions to the words in the claim, as long as those definitions are clearly
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`stated in the patent specification or file history. Vitronics Corp. v. Conceptronic,
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`Inc., 90 F.3d 1576, 1582 (Fed. Cir. 1996) (citing Hoechst Celanese Corp. v. BP
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`Chems. Ltd., 78 F.3d 1575, 1578 (Fed. Cir. 1996)). Therefore, “it is always
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`necessary to review the specification to determine whether the inventor has used
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`any terms in a manner inconsistent with their ordinary meaning. The
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`specification acts as a dictionary when it expressly defines terms used in the
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`claims or when it defines terms by implication.” Id. Because the specification
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`must contain a description sufficient to those of ordinary skill in the art to make
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`and use the invention, the specification “is the single best guide to the meaning of
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`a disputed claim term.” Id.
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`B.
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`“control device”
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`For purposes of its Decision, the Board adopted the express definition of
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`“control device” provided during prosecution of the patent application that issued
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`as related U.S. Patent No. 7,397,363, which is “a device or a computer, or that
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`part of a device or a computer, which performs an operation, an action, or a
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`function, or which performs a number of operations, actions, or functions.”
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`Decision at 7.
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`JCMS respectfully submits that this construction should be adopted for the
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`remainder of this IPR.
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`IV. RESPONSE TO PROPOSED GROUNDS OF INVALIDITY
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`A. Ground 1 is Deficient
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`Ground 1 alleges that claims 26, 38, 42, 43, 48, 63, 73, 74, 91 and 138 are
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`anticipated by Kniffin. However, Patent Owner respectfully submits that Kniffin
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`fails to disclose every claimed element and feature of claims 26, 38, 42, 48, 63,
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`73, 74, 91 and 138, as required under § 102, and therefore, Kniffin does not
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`anticipate claims 26, 38, 42, 48, 63, 73, 74, 91 and 138.
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`At the outset, Patent Owner disagrees with the Petitioner’s interpretation of
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`“control device” that would allow the “access control device 64” of Kniffin to
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`serve as the “first control device” of claims 26 and 48 and the “third control
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`device” of claims 42 and 138. Patent Owner maintains that the “access control
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`device 64” is the vehicle system being controlled and not a “control device.”
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`Petitioner’s arguments and the constructions and interpretations that have been
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`adopted by the Board, notwithstanding, Petitioner’s arguments with respect to
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`Kniffin still fail with regards to each of independent claims 26, 42, 48, 91 and
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`138.
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`Kniffin fails to disclose an “A to B to C” system for
`1.
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` controlling a vehicle system/component in response to a
` signal from a control device located remote from the vehicle
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`Independent claim 26 recites, inter alia, “a first control device . . . [that] at
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`least one of generates and transmits a first signal for at least one of activating, de-
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`activating, disabling, and re-enabling, at least one of a vehicle system, a vehicle
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`component, a vehicle device, a vehicle equipment, a vehicle equipment system,
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`and a vehicle appliance, of a vehicle, wherein the first control device is located at
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`the vehicle [and] is responsive to a second signal [that] . . . is at least one of
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`15 15
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`generated by and transmitted from a second control device [that] is located at a
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`location which is remote from the vehicle . . .” (emphasis added).”
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`Independent claim 42 recites, inter alia, “transmitting a second signal from
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`[a] . . . second control device to a third control device . . .located at the vehicle . .
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`. generating a third signal with the third control device in response to the second
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`signal . . . and . . . activating, de-activating, disabling, and re-enabling, at least
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`one of a vehicle system, a vehicle component, a vehicle device, a vehicle
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`equipment, a vehicle equipment system, and a vehicle appliance, in response to
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`the third signal . . .” (emphasis added). Claim 42 also recites, inter alia, that “the
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`second control device is located at a location remote from the vehicle . . .”
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`(emphasis added).
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`Independent claim 48 recites, inter alia, “a first control device . . . [that] at
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`least one of generates and transmits a first signal for at least one of activating, de-
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`activating, disabling, and re-enabling, the at least one of a vehicle system, a
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`vehicle component, a vehicle device, a vehicle equipment, a vehicle equipment
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`system, and a vehicle appliance, wherein the first control device is located at the
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`vehicle [and] is responsive to a second signal [that] . . . is at least one of
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`generated by and transmitted from a second control device [that] is located at a
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`location which is remote from the vehicle . . .” (emphasis added).”
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`Independent claim 138 recites, inter alia, “transmitting a second signal
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`from [a] . . . second control device to a third control device . . .located at the
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`vehicle . . . generating a third signal with the third control device in response to
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`the second signal . . . and . . . at least one of activating, de-activating, disabling,
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`and re-enabling, the at least one of a vehicle system, a vehicle component, a
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`vehicle device, a vehicle equipment, a vehicle equipment system, and a vehicle
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`appliance, in response to the third signal . . .” (emphasis added). Claim 138 also
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`recites, inter alia, that “the second control device is located at a location remote
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`from the vehicle . . .” (emphasis added).
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`Kniffin fails to disclose, teach or suggest at least the above features of each
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`of claims 26, 42, 48 and 138, as required under 35 U.S.C. § 102.
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`Petitioner asserts that the “first control device” of claims 26 and 48, and
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`the “third control device” of claims 42 and 138, are satisfied by Kniffin’s “access
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`control device 64.” See Paper 1 at 15-16 and 22-23. Petitioner further asserts that
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`the “clearinghouse” of Kniffin (element 18 in Fig. 1 of Kniffin and element 66 in
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`Fig. 4 of Kniffin) corresponds to the claimed “second control device” of claims
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`17 17
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`26, 42, 48 and 138, and that the combination of the telephone 22 and
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`communications link 16 of Kniffin (shown in Fig. 1 of Kniffin) corresponds to
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`the claimed “third control device” of claims 26 and 48, and the claimed “first
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`control device” of claims 42 and 138. Id. At 16-17 and 23-24. Figs. 1 and 4 of
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`Kniffin are reproduced below:
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`Kniffin states that the access control device 64 in Fig. 4 can take the form
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`as the lock 12 in Fig. 1. EX1010 at 8:45-48 (“[a]lthough the access control device
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`64 is not particularly detailed in FIG. 4, it can take the same form as lock 12 of
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`FIG. 1 (but with a lock mechanism adapted to secure the doors of a delivery
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`truck)”).
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`In their analysis of claim 26, Petitioner asserts that:
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`“[t]he access control device 64 is adapted to secure the
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`doors of the truck 62 and guard against unauthorized
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`opening. Col. 8, ll. 11-14 and 46-48. Kniffin states that
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`the access control device 64 includes a lock mechanism
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`adapted to secure the doors of the truck as in Figure 1,
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`and as shown in Figure 1, the lock 12 includes a lock
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`microprocessor CPU 30 that instructs (the first signal) a
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`lock mechanism 32 to unlock (activating a vehicle
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`component). Col. 8, ll. 46-48; col. 3, l. 64-col. 4, l. 3;
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`EX.1002,¶¶ 11-13.” Petition at 15. (citations in original).
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`In their analysis of claim 42, Petitioner similarly asserts that:
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`“Kniffin describes that the access control device 64 (the
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`in-vehicle control device) can include a lock mechanism
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`adapted to secure the doors of the truck 62 and that the
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`lock 12 includes a lock microprocessor CPU 30 that
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`instructs a lock mechanism 32 to unlock (the third
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`signal). Col. 8, ll. 46-48; col. 3, l. 64-col. 4, l. 3.” Id. at
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`17. (citations in original).
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`In their analysis of claim 48, Petitioner similarly asserts that:
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`“[t]he access control device 64
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`includes a
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`lock
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`mechanism adapted to secure the doors of the truck 62,
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`and, Kniffin states that the lock 12 includes a lock
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`microprocessor CPU 30 that instructs a lock mechanism
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`32 to unlock (the first signal). Col. 3, l. 64-col. 4, l. 3; Ex.
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`1002, ¶¶ 11-13.” Id. at 22. (citations in original).
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`In their analysis of claim 138, Petitioner similarly asserts that:
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`“As noted above, Kniffin describes an access control
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`device 64 (the in-vehicle control device) managing
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`access to the doors of a truck 62 based on a schedule
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`received from clearinghouse 66 (the middle device). Col.
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`8, ll. 21-24, 46-48; col. 2, ll. 31-51; Ex. 1002, ¶¶ 11-13.”
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`Id. at 27. (citations in original).
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`However, what Petitioner fails to mention is that the access control device
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`64 of Kniffin does not generate a signal (the claimed “first signal” in claims 26
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`and 48, and the claimed “third signal” in claims 42 and 138) for instructing the
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`lock mechanism 32 to unlock the doors in response to a signal from the
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`clearinghouse 66 (which Petitioner asserts corresponds to the claimed “second
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`control device”). The signal from the clearinghouse 66 is a signal that contains
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`information regarding an authorized schedule of stops for the truck. EX1010 at
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`8:15-24. This information regarding the authorized schedule of stops does not
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`trigger the transmission of a signal from the access control device 64 for
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`unlocking the lock mechanism 12, but rather this information regarding the
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`schedule of stops is stored in memory 68. Id. at 8:21-24 (“[a]fter suitable
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`verification checks, the clearinghouse transmits to the targeted truck access
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`control device 64 the authorized schedule of stops, which data is received and
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`stored in memory 68).
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`In fact, the signal that triggers the access control device 64 of Kniffin to
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`generate a signal for instructing the lock mechanism 32 to unlock the doors is a
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`signal from an “identification device 70” that is present at one of the authorized
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`locations stored in memory 68. Id. at 8:25-33. When the truck arrives at a stop,
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`the signal from the “identification device 70” is received by the sensor 36 of
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`Kniffin. If the truck has stopped at an authorized destination (as determined by
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`the information regarding the authorized schedule of stops stored in memory 68),
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`then the signal from the identification device 70, which is received by sensor 36,
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`will cause the sensor to trigger (by sending another signal) the access control
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`device 64 to generate a signal for unlocking the lock mechanism 12. Id.
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`Kniffin explains this functionality unequivocally:
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`“when the truck arrives at its first delivery stop, the truck
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`access control device 64 senses this fact by detecting an
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`identification device 70 maintained at that location. The
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`identification device may be a proximity card mounted at
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`the loading dock, or may be an electronic key carried by
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`a manager employed at the first delivery stop. If the
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`detected identification device corresponds to the first
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`expected stop that had been earlier programmed, the
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`truck access control device unlocks, permitting access to
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`the truck’s contents.” Id. At 8:25-33.
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