DECLARATION OF SCOTT ANDREWS
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`I, Scott Andrews, declare as follows:
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`1.
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`I hold a B.Sc. degree in Electrical Engineering from University of
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`California–Irvine and a M.Sc. degree in Electronic Engineering from Stanford
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`University. In various positions at, among others, TRW and Toyota, I have been
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`responsible for research and development projects relating to, among others,
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`numerous remote vehicle control devices and vehicle information systems. My
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`qualifications are further set forth in my curriculum vitae (Exhibit A). I have been
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`retained by Volkswagen Group of America, Inc. in connection with its petition for
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`inter partes review of U.S. Patent No. 6,549,130 (“the ’130 patent”). I have over
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`25 years of experience in fields relevant to the ’130 patent, including remote
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`vehicle control systems.
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`2.
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`I have reviewed the ’130 patent, as well as its prosecution history and the
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`prior art cited during its prosecution. I have also reviewed the prosecution history
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`of the ex parte reexamination of the ’130 patent, Reexamination Control No.
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`90/013,301 (“the ’301 reexamination”), and
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`the prior art cited
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`in
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`the
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`reexamination. In addition, I have reviewed U.S. Patent No. 6,072,402 (“Kniffin”),
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`U.S. Patent No. 5,113,427 (“Ryoichi”), U.S. Patent No. 5,081,667 (“Drori”), U.S.
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`Patent No. 5,732,074 (“Spaur,”), U.S. Patent No. 5,726,984 (“Kubler,”), U.S.
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`Patent No. 5,808,566 (“Behr”), and U.S. Patent No. 4,602,127 (“Neely”).
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`VWGoA - Ex. 1002
`Volkswagen Group of America, Inc., Petitioner
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`1
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`The ’130 Patent
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`3.
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`The ’130 patent relates to a remote-controlled control, monitoring, and/or
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`security apparatus, linked to various vehicle systems like alarms, horns, power
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`door locks, video recording devices, phones, or vehicle recovery systems. Col. 4,
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`ll. 43-63. A remote transmitter system 2, such as a touch tone telephone, transmits
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`signals to a receiver 3, such as a beeper or pager system. Col. 18, l. 64-col. 19, l. 2;
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`col. 19, ll. 57-61; col. 19, l. 66–col. 20, l. 1. A CPU 4 receives signals from the
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`receiver 3 and controls vehicle systems by activating or deactivating the vehicle
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`systems. Col. 20, ll. 61–67; col. 21, l. 46–col. 22, l. 37; 24, l. 66–col. 25, l. 3.
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`4.
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`The claims of the ’130 patent describe the above-described sequence of
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`control among three devices. One control device is located at a vehicle, another
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`control device is located remote from the vehicle, and another control device is
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`located remote from the other remote control device and remote from the vehicle.
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`One of the remote control devices sends a control signal to the other remote control
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`device, which responds by sending a control signal to the control device in the
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`vehicle. In response, the control device in the vehicle activates or deactivates a
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`vehicle component.
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`5.
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`The claims of the ’130 patent recite the above-described sequence of control
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`signals among three control devices. The claims vary, however, in the naming of
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`the control devices. In claim 26, and its dependent claims, the “first control device”
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`2
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`is located in the vehicle, and is responsive to signals from the “second control
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`device,” which in turn is responsive to signals from the “third control device.” In
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`claim 42 and its dependent claims, however, the “third control device” is located at
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`the vehicle, responsive to signals from the “second control device,” which is
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`responsive to signals from the “first control device.” Claim 48, and its dependent
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`claims, describe a “first control device” located at the vehicle, responsive to signals
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`from the “second control device,” which in turn is responsive to signals from the
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`“first control device.” In claim 91, and its dependent claims, the “third control
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`device” is located at the vehicle, and is responsive to signals from the “first control
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`device,” which in turn in responsive to signals from the “second control device.” In
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`claim 138, and its dependent claims, the “third control device” is located at the
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`vehicle, responsive to signals from the “second control device,” which in turn is
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`responsive to signals from the “first control device.” Thus, my understanding of
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`the claims and the disclosure of the prior art documents is independent of these
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`naming conventions.
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`6.
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`According to my understanding of the prosecution of the ’130 patent, the
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`initially filed claims recited the chain of three control devices. For example,
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`application claim 21 was initially filed as follows:
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`21. A control apparatus, comprising:
`a first control device, wherein said first control device one of
`generates and transmits a first signal for one of activating, de-
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`3
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`activating, enabling, and disabling, one of a premises and the premises
`one of system, subsystem, component, device, equipment, and
`appliance, wherein said first control device is located at the premises;
`wherein said first control device is responsive to a second signal,
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`wherein the second signal is one of generated by and transmitted from
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`a second control device, wherein the second control device is located
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`at a location which is remote from the premises, and further wherein
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`the second control device is responsive to a third signal, wherein the
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`third signal is one of generated by and transmitted from a third control
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`device, wherein the third control device is located at a location which
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`is remote from the premises and remote from the second control
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`device.
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`7.
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`The Examiner rejected this claim as anticipated by U.S. Patent No.
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`6,028,537 to Suman, but Joao convinced the Examiner that Suman does not qualify
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`as prior art. The Examiner then issued another Office Action, in which the claims
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`were rejected for obviousness-type double patenting in view of its parent patent,
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`U.S. Patent No. 5,917,405 (“the ’405 patent”). Joao thereafter submitted a
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`Terminal Disclaimer over the ’405 patent.
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`8.
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`A Notice of Allowance issued on June 4, 2001, in which the Examiner
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`provided the following reasons for allowance, identifying the chain of three control
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`devices:
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`9.
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`[T]here are no references teaching of a control apparatus for
`controlling of at least one activating, deactivating, enabling and
`disabling of at least one of a premises having at least one of system,
`subsystem, component, equipment and appliance. Wherein the first
`control device is responsive to a second signal and the second signal is
`at least generated by a a [sic] second control device which is located
`remote from the premises. And further wherein the second control
`device is responsive to a third control signal which is generated by a
`third control device which is located at a location remote from the
`premises and remote from the second control device.
`I further understand
`that
`the ’130 patent
`is currently subject
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`to
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`reexamination, and that during the reexamination, the Examiner determined that
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`substantial new questions of patentability affecting claim 48 are raised by Kniffin
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`and Ryoichi and by: U.S. Patent No. 5,070,320 to Ramono; U.S. Patent No.
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`5,276,728 to Pagliaroli; the combination either Ramono, Kniffin, Ryoichi, or
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`Pagliaroli with Drori; and the combination of either Ramono, Kniffin, Ryoichi, or
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`Pagliaroli with U.S. Patent No. 5,103,221 to Memmola. I further understand that
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`claim 48 currently stands rejected as anticipated by each of Ramono, Ryoichi, and
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`Pagliaroli.
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`Kniffin – Claims 26, 38, 42, 43, 48, 63, 73, 74, 91, and 138
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`10. Kniffin discloses all of the limitations of claims 26, 38, 42, 43, 48, 63, 73,
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`74, 91, 138, and 139, including the claimed sequence of control signals passed
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`among three control devices, which was the basis for allowance of the ’130 patent.
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`11. Kniffin describes a secure entry system 10, including telephone 22,
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`communications link 16, clearinghouse 18 connected to RF transmission system
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`26, and access control devices 12 or 64 having RF receiver 14. Col. 2, ll. 25-53,
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`col. 8, ll. 11-14.
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`12. The chain of three control devices described by Kniffin includes an access
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`control device 64 (located at the vehicle), clearinghouse 18 or 66 (located remote
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`from the vehicle), and communications link 16 and telephone 22 (located remote
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`from the vehicle and remote from the clearinghouse). A user may establish
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`communication via communications link 16, from a cellular telephone or
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`conventional telephone 22, to clearinghouse 18 or 66, and, after an authorization
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`check, the clearinghouse 18 or 66 transmits radio signals over RF transmission
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`system 26 to access control device 12 or 64, via RF receiver 14. Col. 2, ll. 25-53,
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`col. 8, ll. 11-14. In the vehicle embodiment, access control device 64 controls door
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`locks on a truck 62. Col. 8, ll. 11-14, 46-48; Fig. 4.
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`13.
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`In describing its system in the context of delivery truck 62, Kniffin describes
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`that a delivery company sends a schedule of deliveries to clearinghouse 66.
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`Clearinghouse 66 verifies the schedule, and transmits the schedule to truck access
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`control device 64. The schedule is then stored in memory 68. Col. 8, ll. 15-24. That
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`is, the truck access control device 64, i.e., the first control device located at the
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`vehicle, is responsive to signals from clearinghouse 66, i.e., the second control
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`device located remote from the vehicle. See also, col. 8, ll. 61-67. The lock 12
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`includes a lock microprocessor CPU 30 that instructs a lock mechanism 32 to
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`unlock. Col. 8, ll. 46-48; col. 3, l. 64-col. 4, l. 3.
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`14. Because Kniffin describes a first device, located at a vehicle (access control
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`device 12 or 64), controlling a vehicle component (door lock or memory),
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`responsive to a signal from a second control device, located remote from the
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`vehicle (clearinghouse 18 or 66), which is in turn responsive to a signal from a
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`third control device (telephone 22 and communications link 16), located remote
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`from the vehicle and from the second control device, Kniffin addresses the
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`Examiner’s reasons for allowing the claims of the ’130 patent.
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`15. As noted above, the claims of the ’130 patent vary in naming the three
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`control devices. That is, the “first control device” in claim 26 corresponds to the
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`“third control device” in claims 42, 91, and 138, and to the “first control device” in
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`claim 48. The “second control device” recited by claim 26 corresponds to the
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`“second control device” in claims 42, 48, and 138, and to the “first control device”
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`in claim 91. Further, the “third control device” recited by claim 26 corresponds to
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`the “first control device” in claims 42 and 138, the “second control device” in
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`claim 91, and to the “third control device” in claim 48. As further noted above, my
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`understanding of the claims and the disclosure of the prior art documents is
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`independent of the naming conventions applied in the various claims.
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`16. Kniffin states that it is often desirable to confirm the entry of a person into a
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`secured area using a monitoring device, such as a sensor, and log this fact into an
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`access log memory. See col. 4, ll. 15-19. The lock 12 includes a memory 34 and a
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`sensor 36, and Kniffin describes forwarding access data in real-time or after a
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`threshold number of entries is reached using an RF transmission, a cellular
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`telephone service, or a paging service. Col. 2, ll. 46-51; col. 4, ll. 52-65. In the
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`vehicle embodiment, Kniffin describes the transmission of data by the access
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`control device identifying identification devices encountered by the truck so the
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`central station can track the truck through its route. Col. 9, ll. 5-8.
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`17. Further, Kniffin also includes a description of clearinghouse 66 relaying
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`status information regarding the presence of a person in the vicinity of the house,
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`or the presence of the truck access control device 64 at a delivery stop. Col. 2, l.
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`62-col. 3, l. 6, col. 8, ll. 25-27.
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`18.
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`In describing the communications link 16, Kniffin states that a cellular or
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`conventional telephone 22 may be provided. Col. 2, ll. 31-43.
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`19. Kniffin also describes a voice synthesizer that reports status information
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`regarding the lock to the user, including whether access permission has been
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`granted and time windows for access. Col. 2, ll. 54-61.
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`20. Kniffin further describes that the truck security system is integrated with a
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`satellite vehicle location system. Col. 9, ll. 1-4.
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`Kniffin – Claims 64, 85, and 92
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`21. Claims 64, 85, and 92 are obvious in view of Kniffin.
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`22. Kniffin describes an access control device 64 (the in-vehicle control device)
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`managing access to the doors of a delivery truck 62 based on a schedule received
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`from clearinghouse 66. Col. 3, l. 64-col. 4, l. 3; Ex. 1002, ¶¶ 11-13. Clearinghouse
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`66 includes a computer and an RF transmission system for transmitting the verified
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`schedule of stops to the access control device, and Kniffin discloses that this
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`transmission may be made by a paging system, and cellular telephone system or
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`other RF carrier depending upon the type of receiver equipped with the lock. Col.
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`2, ll. 35-38 and 44-51; col. 8, ll. 21-24 and 46-48.
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`23. Claim 64 describes that “the third control device [which is located remote
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`from the vehicle and remote from the second control device] at least one of
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`activates, de-activates, disables, re-enables, controls the operation of, and monitors
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`the operation of, 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, via the second control device and the first control device on or over at
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`least one of the Internet and the World Wide Web.” Claim 85 describes that “the
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`apparatus is utilized on or over at least one of the Internet and the World Wide
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`Web.” Claim 92 describes that “the first control device [which is remote from the
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`vehicle] is at least one of a server computer, a computer, and a network computer,”
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`“the second control device [which is remote from the vehicle and form the second
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`control device] is at least one of a stationary device, a portable device, a hand-held
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`device, a mobile device, a telephone, a cordless telephone, a cellular telephone, a
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`home computer, a personal computer, a personal digital assistant, a television, an
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`interactive television, a digital television, a personal communications device, a
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`personal communications services device, a display telephone, a video telephone, a
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`watch, and a two-way pager,” and “the apparatus is utilized on or over at least one
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`of the Internet and the World Wide Web.”
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`24. The use of the Internet or World Wide Web in vehicle control systems was
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`well-known at the time the ’130 patent was filed, as evidenced for example, by
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`Spaur, Behr, and Kubler.
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`25. Spaur describes communicating with a vehicle using a remote computer
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`terminal via the Internet and World Wide Web. Col. 2, ll. 42-48; col. 3, ll. 13-20;
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`col. 7, ll. 40-47; col. 12, ll. 51-54. For example, Spaur describes a CD-ROM unit as
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`a vehicle device 50 having an Internet Protocol (IP) address, which is recognized
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`by a controller 30 (the control device that is located at the vehicle). The controller
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`30 includes an applet associated with the IP address, and the controller 30 sends
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`this applet via the Internet 68 to a user’s web browser 72 on a computer terminal
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`60 (the control device that is remote from the vehicle and remote from the middle
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`control device). Col. 11, ll. 49-52. In Spaur’s system, a remote CDPD network
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`modem 76 constitutes the middle control device located remote from the vehicle;
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`the computer terminal 60 is remote from the CDPD network modem 76. See, e.g.,
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`Figure 2. Spaur states that the computer terminal 60 displays buttons representing
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`the CD-ROM unit’s controls and that the user can “click on” these buttons shown
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`on the computer terminal 60 to cause certain operations with the CD-ROM unit in
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`the vehicle. Col. 11, ll. 52-57. Spaur thus describes the chain of three control
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`devices as claimed in the ’130 patent.
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`26.
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`In addition, Behr describes an electronic navigation system in which a base
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`unit provides route guidance, tracking information, and other information to a
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`remote unit over wireless, wireline, or optical devices. Abstract, col. 1, ll. 19-26.
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`This communication may take place over one or more wireless or wireline
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`communication networks, such as CDPD (cellular digital patent data) or TCP/IP
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`(transmission control protocol/Internet Protocol). Col. 9, ll. 38-42. According to an
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`example in Behr, a mobile unit may be located in an armored vehicle transporting
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`valuables along a specified route. A control unit monitoring the mobile unit may
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`request tracking information from the base unit, and if the mobile unit in the
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`vehicle varies from the specified route by a predetermined amount, the control unit
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`can sound an alarm or trigger another action. Col. 9, ll. 48-56.
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`27. Further, Kubler describes a hierarchical communication system in which
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`wired and wireless networks, including the Internet, are used to communicate
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`between stationary and roaming devices, such as a vehicle-mounted computer
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`terminal. Abstract, col. 8, ll. 25-59.
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`28. At the time the ’130 patent was filed, the use of the Internet or World Wide
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`Web to communicate with a vehicle would have been obvious at least because the
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`Internet provides an infrastructure and signal transmission capabilities that are
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`superior to the RF transmission capabilities described by Kniffin.
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`The Combination of Kniffin and Ryoichi – Claim 31
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`29. The combination of Kniffin and Ryoichi discloses all of the limitations of
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`claim 31.
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`30. Ryoichi describes a vehicle device control system including a personal radio
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`paging unit 9 (located at the vehicle), a fixed radio station St (located remote from
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`the vehicle), and a telephone unit TEL (located remote from the vehicle and remote
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`from the fixed radio station St). Ryoichi provides for the control of an
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`“automobile-mounted device” in which the telephone unit sends information
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`related to controlling a device to a paging center, which subsequently sends paging
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`signals containing the control information over the paging network. These are
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`received by the paging unit in the vehicle, and are used to control various vehicle
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`components. As examples, Ryoichi describes the control of door locks, engine
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`ignition, headlights, etc. Abstract, col. 5, l. 16-col. 6, l. 9; col. 8, l. 1-col. 10, l. 27;
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`Figs. 5-7.
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`31. The chain of three control devices described by Ryoichi includes: personal
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`radio paging unit 9 (located at the vehicle); fixed radio station St (located remote
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`from the vehicle); and telephone unit TEL (located remote from the vehicle and the
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`fixed radio station St).
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`32. To send a control signal to the vehicle, a user of Ryoichi’s system inputs the
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`telephone number for personal radio paging unit 9 in the telephone unit TEL. The
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`user then enters a number into the telephone key pad, the number operating as a
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`code corresponding to a particular control program that the user would like to
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`initiate in the vehicle. The telephone unit TEL communicates with radio station St,
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`and radio station St subsequently radiates a paging signal representing the coded
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`number. The radio paging unit 9 receives the radiated paging signals representing
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`the coded number. Col. 7, l. 60-col. 8, l. 1. In response to this signal, radio paging
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`unit 9, located in the vehicle, generates audible tones representing the coded
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`number, and those tones are detected by a sensor 10. As described by Ryoichi, the
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`sensor 10 converts the detected tones into an electric signal, a code converter 11
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`converts the signal into a digital code signal, and a control unit S reads the digital
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`code signal to execute a program corresponding to the coded number entered by
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`the user. Col. 8, ll. 1-22; see also col. 5, ll. 16-22, col. 4, l. 57-col. 5, l. 15; Fig. 2.
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`Ryoichi identifies several control programs, including unlocking the doors (col. 8,
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`l. 51-col. 9, l. 17), turning on the headlights (col. 9, ll. 18-64), or starting the engine
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`(col. 10, ll. 9-12), and further states that “various control programs for remotely
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`controlling other devices in the automobile” are possible (col. 10, ll. 22-27). That
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`is, radio paging unit 9, i.e., the first control device located at the vehicle, is
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`responsive to signals from fixed radio station St, i.e., the second control device
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`located remote from the vehicle, which is responsive to signals from the telephone
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`unit TEL, i.e., the third control device located remote from the vehicle and remote
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`form the second control device.
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`33. At the time the ’130 patent was filed, it would have been obvious to combine
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`the secure entry system of Kniffin with the vehicle control system of Ryoichi, at
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`least because both employ radio (i.e., wireless) signals to remotely control
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`programmable devices located on vehicles, e.g., the access control device 12 or 66
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`and the lock mechanism 32 of Kniffin, and the control unit S and actuators of
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`Ryoichi. In addition, Ryoichi describes an inexpensive, “small-size receiver unit
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`that can receive a calling signal from a general telephone unit,” that is easily
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`installed and cost-effective for equipping delivery trucks and “retrofitting into
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`existing applications and installations” as described by Kniffin. See Ryoichi, col. 2,
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`ll. 52-58; Kniffin, col. 8, ll. 11-14 and col. 9, ll. 49-52.
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`The Combination of Kniffin and Drori – Claims 60 and 139
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`34. The combination of Kniffin and Drori discloses all of the limitations of
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`claims 60 and 139.
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`35. Drori describes cellular telephone and automobile security systems,
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`including a system that allows for the installation of a cellular phone and a
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`controller in an automobile. Col. 1, ll. 12-14; col. 1, l. 67-col. 2, l. 5. As shown in
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`Figure 1 below, Drori describes a communications system 10 adapted for use with
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`a cellular telephone system 12, with the system 10 being interposed between the
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`handset unit 14 and the transceiver 16 of the telephone system 12. Col. 3, ll. 58-64.
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`According to Drori, inputs from a global positioning tracker, are received by the
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`system controller 20 via level conversion and filtering circuits 36. Col. 4, ll. 44-48.
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`Additionally, Drori discloses that the tracking data input is provided by a global
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`positioning system and that the system 10 can translate the tracking data input into
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`a location on map, when requested by a user or when the security system is tripped.
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`Col. 5, ll. 9-17.
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`36. Kniffin discloses that the truck security system may be integrated with a
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`satellite vehicle locator system. Col. 9, ll. 1-4. Drori describes a communications
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`system that receives tracking data from a global positioning system and translates
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`this data into a location on map. Col. 4, ll. 44-48; col. 5, ll. 9-17.
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`37. At the time the ’130 patent was filed, it would have been obvious to combine
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`the secure entry system described by Kniffin with the cellular telephone and
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`automobile security systems described by Drori, to provide “a versatile cellular
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`security system which is compatible with a wide variety of cellular telephones”
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`(Drori, col. 1, ll. 62-64) and to provide “a secure entry system” that “makes use of
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`radio transmissions” using “a paging system, a cellular telephone system, or any
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`other RF carrier” (Kniffin, Abstract). Further, Kniffin discloses equipping delivery
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`trucks and “retrofitting [access control devices] into existing applications and
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`installations,” and Drori’s system “interfaces between a variety of vehicle security
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`systems and most cellular communication systems whether already sold and
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`installed in vehicles or yet to be marketed.” Kniffin, col. 8, ll. 11-14 and col. 9, ll.
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`49-52; Drori, col. 1, l. 67-col. 2, l. 3.
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`The Combination of Kniffin and Neely – Claim 143
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`38. The combination of Kniffin and Neely discloses all of the limitations of
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`claim 143.
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`39. Neely describes a vehicular diagnostic system employing a portable
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`communications control station. Col. 1, ll. 12-15. As shown in Figure 1 below, the
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`diagnostic system 10 generally comprises a portable communications control
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`station 12 and remote data processing station 14. The control station 12 is adapted
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`to be employed in connection with a vehicle 16 having an on-board computer 17
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`with access to one or more of the operating parameters. Col. 3, ll. 40-66. The
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`control station 12 also includes a telephone 36, which permits both voice and data
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`communication between the control station 12 and the data processing station 14,
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`and the use of the telephone system allows for the diagnosis of a vehicle at any
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`location remote from the station 14. Col. 4, l. 42-col. 5, l. 10. The diagnostic
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`system further includes a call indicator light 70 used to switch between data
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`communication and voice communication, which, according to Neely, is
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`advantageous because it permits the station operator to convey the diagnosis of a
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`vehicle problem immediately after the data parameter has been analyzed. Col. 6, ll.
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`44-56.
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`40. As noted above, Kniffin states that the clearinghouse 18 can relay any status
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`information regarding the lock 12 to the user through the communications link 16,
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`and that the truck access control device 64 monitors for the presence or absence of
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`identification devices 70 at delivery locations. Col. 2, l. 62-col. 3, l. 6; col. 8, ll. 25-
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`27 and 40-43. In addition, Neely describes a vehicular diagnostic system using a
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`telephone for voice and data communication to convey diagnostic information.
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`Col. 4, l. 42-col. 5, l. 10; col. 6, ll. 44-56.
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`41. At the time the ’130 patent was filed, it would have been obvious to combine
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`the secure entry system described by Kniffin with the vehicular diagnostic system
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`described by Neely, at least because both describe the communication of
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`information regarding the operation of vehicle components from the vehicle to
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`remotely located devices, and Neely describes a system for voice and data
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`communication of the status information relayed by Kniffin. Kniffin, col. 2, l. 62-
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`col. 3, l. 6; Neely, col. 4, l. 42-col. 5, l. 10; col. 6, ll. 44-56. In addition, Kniffin
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`discloses equipping delivery trucks and “retrofitting [access control devices] into
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`existing applications and installations,” and Neely’s portable communications
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`control station is “capable of servicing a variety of vehicle models over a number
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`of model years.” Kniffin, col. 8, ll. 11-14 and col. 9, ll. 49-52; Neely, col. 2, ll. 31-
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`34.
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`I declare that all statements made herein of my own knowledge are true and
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`that all statements made on information and belief are believed to be true, and
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`further that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under §1001 of Title 18 of the United States Code.
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`Dated:
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`7/31/2015
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`Scott Andrews
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`2020
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`EXHIBIT A
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`EXHIBIT AEXHIBIT A
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`20
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`

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`(650) 279-0242
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`
`Scott Andrews
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`915 Western Ave.
`Petaluma, CA 94952
`
`Summary
`Creative, energetic, and innovative internationally recognized executive experienced in
`general management, systems engineering, advanced product development, advanced
`technology, business development, strategic planning, and program management
`
` •
`
` Vehicle Electrical/Electronics Systems
`• Vehicle Information Systems
`• Communications Systems
`• ITS and Related Industries
`• Program and Project Management
`
`
`• Enterprise Software
`• Multimedia/Internet Computing
`• Vehicle Safety and Control Systems
`• Spacecraft Electronics
`• Mobile Information Technology
`
`Experience
`
`Consultant
`12/2001-Present
`Systems engineering, business development and technical strategy consulting supporting
`automotive and information technology.
`Current Engagements:
`• Technical consultant to ARINC for connected vehicle application systems
`engineering and development of high precision connected vehicle test bed for
`FHWA (Federal High Way Admin.)
`• Technical consultant to Booz Allen for connected vehicle performance measures
`development project for NHTSA (National Highway Traffic Safety Admin.)
`• Technical consultant to Booz Allen for connected vehicle standards for FHWA
`• Technical consultant to American Association of State Highway Transportation
`Officials (AASHTO) for connected vehicle deployment analysis and strategy
`• Technical consultant to Michigan State DOT (Enterprise Pooled Fund) to develop
`a system architecture and deployment strategy for Rural ITS
`• Expert witness for Toyota in a case brought by American Vehicular Sciences
`(AVS)
`• Expert witness for Toyota in a patent case brought by Affinity Labs
`• Expert Witness for TomTom in a patent case brought by AVS
`• Expert witness for Liberty Mutual, Geico and Hartford in a patent case brought by
`Progressive Insurance
`• Expert witness for Ford in a patent case brought by Medius.
`• Expert witness for Ford in a patent inventorship case brought by Berry.
`• Expert witness for Ford and GM in a patent case brought by Affinity Labs
`• Expert witness for M/A Com in a patent case against Laird
`• Expert witness for VW/Audi in a patent case brought by Velocity
`• Expert witness for VW/Audi in a case brought by Beacon, GmbH.
`• Expert witness for Wasica in a patent case against Shrader and Continental
`
`Recent Engagements:
`• Expert Witness for Samsung, Nokia, ZTE and Sony in an ITC patent case brought
`by Pragmatus
`• Expert Witness for TomTom in a case brought by AOT/Adolph
`• Expert Witness for TomTom in a case brought by Cuozzo
`• Expert Witness for Navico in a case brought by Honeywell
`Scott Andrews
`
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`Page 1
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`21
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`

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`• Expert witness for Bentley in a case brought by Cruise Control Technologies.
`• Expert witness for Google in a case brought by Walker Digital
`• Expert witness for Emtrac in a case brought by GTT (3M)
`• Expert witness for Motorola in a case brought against Microsoft
`• Co-Principal investigator for Integrated Advanced Transportation System;
`research program funded by FHWA
`• Expert Witness for Volkswagen/Sirius-XM in patent infringement case relating to
`traffic information systems
`• Expert Witness for Pioneer in patent infringement related International Trade
`Commission matter
`• Expert Witness for Volkswagen in patent infringement case relating to the iPod
`interface
`• Chief System Architect for the Vehicle Infrastructure Integration (VIIC) program
`(BMW, Chrysler, Daimler Benz, Ford, GM, Honda, Nissan, Toyota, VW);
`• Expert Witness for Honda in patent infringement lawsuit); 14 asserted patents
`dealing with telematics equipment interfaces and functions
`• Expert Witness for Alpine, Denso and Pioneer Corporation in patent infringement
`related International Trade Commission matter relating to navigation systems
`• Telematics delivery architecture development for a Fortune 100 service provider
`• Technical consultant to the Vehicle Safety Consortium developing Dedicated
`Short Range Communications (DSRC) standards for safety systems;
`• Expert Witness for BMW in patent infringement lawsuit (American CalCar, Inc. v
`BMW) included prior art search, invalidity & non-infringement reports, rebuttals
`reports, depositions, etc for 12 patents with 200+ asserted claims.
`• Toyota Motor Sales – 10 year technology survey;
`• Connected Vehicle Trade Association- Transferred AMI-C specifications to ISO
`TC 22, TC 204 AND OSGi. Developed OSGi Vehicle Interface Specification;
`• Personal navigation device product feature and opportunity analyses for Thales-
`Magellan and Rand McNally
`
`
`4/2000 to 12/2001 Cogenia, Inc.
`President and Chief Executive Officer, Founder
`Founded company in 2000 to develop enterprise class data management software system.
`Responsibilities
`included development of business concept and plan, corporate
`administration including financial and legal management, leadership of executive team in
`product development, fundraising, business development, organizational development,
`and investor relations. Raised $2.2M between 8