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. 5,917,405 (“the ’405 patent”). I have over
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`25 years of experience in fields relevant to the ’405 patent, including remote
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`vehicle control systems.
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`2.
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`I have reviewed the ’405 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 ’405 patent, Reexamination Control No.
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`90/013,300, and the prior art cited in the reexamination. In addition, I have
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`reviewed U.S. Patent No. 6,072,402 (“Kniffin”), U.S. Patent No. 4,897,642
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`(“DiLullo”), U.S. Patent No. 5,113,427 (“Ryoichi”), and U.S. Patent No. 5,223,844
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`(“Mansell”).
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`VWGoA - Ex. 1006
`Volkswagen Group of America, Inc., Petitioner
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`1
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`The ’405 Patent
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`3.
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`The ’405 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. 41-61. 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, ll. 58-63, col. 19,
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`ll. 8-10, 52-56, 63. A CPU 4 receives signals from the receiver 3 and controls
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`vehicle systems by activating or deactivating the vehicle systems. Col. 20, ll. 57-
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`62, col. 21, l. 42-col. 24, l. 67.
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`4.
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`The claims of the ’405 patent describe a sequence of control among three
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`control devices. One control device is located at a vehicle, another control device is
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`located remote from the vehicle, and another control device is located remote from
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`the other remote control device and remote from the vehicle. One of the remote
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`control devices sends a control signal to the other remote control device, which
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`responds by sending a control signal to the control device in the vehicle. In
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`response, the control device in the vehicle activates or deactivates a vehicle
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`component.
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`5.
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`The claims of the ’405 patent each describe the above-described sequence of
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`control signals among three control devices. The claims vary, however, in the
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`naming of the control devices. In claim 1, and its dependent claims, the “first
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`2
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`control device” is located at the vehicle, and is responsive to signals from the
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`“second control device,” which in turn is responsive to signals from the “third
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`control device.” In claim 12, and its dependent claims, however, the “third control
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`device” is located at the vehicle, responsive to signals from the “first control
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`device,” which is responsive to signals from the “second control device.” Claim
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`16, and its dependent claims, describe the “third control device” located at the
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`vehicle, responsive to signals from the “second control device,” which 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 ’405 patent, the
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`claims were initially filed with independent claims describing an apparatus and
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`method for controlling, monitoring, and securing a vehicle, having one or two
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`control devices generating signals for a vehicle device, and an activation device.
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`For example, claim 13 was initially filed as follows:
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`13. A remote-controlled control, monitoring and/or security
`apparatus, which comprises:
`a first control device;
`a second control device; and
`an activation device, wherein said activation device activates at
`least one of said first control device and said second control device,
`wherein one of said first control device and said second control
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`3
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`7.
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`device generates a signal for at least one of controlling, monitoring,
`securing, disabling and re-enabling at least one of a system,
`equipment and device for at least one of a vehicle, a marine vehicle,
`an aircraft, a recreational vehicle, a residential premises and
`commercial premises.
`After being rejected as anticipated by U.S. Patent No. 5,334,974 to Simms,
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`Joao amended the claims to add another control device, so that claim 13 now
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`included three control devices, and the activation device:
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`13. A [remote-controlled] control, monitoring and/or security
`system for a vehicle [apparatus], which comprises:
`a first control device;
`a second control device; and
`a third control device,
`[an activation device, wherein said activation device activates at
`least one of said first control device and said second control device,]
`wherein at least one of said first control device, [and] said second
`control device and said third control device generates a signal for at
`least one of controlling, monitoring, securing, disabling and re-
`enabling at least one of the vehicle and a vehicle one of component,
`device and subsystem [a system, equipment and device for at least one
`of a vehicle, a marine vehicle, an aircraft, a recreational vehicle, a
`residential premises and commercial premises].
`After again being rejected, as anticipated by U.S. Patent No. 5,557,254 to
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`8.
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`Johnson, Joao canceled all claims and added new claims. The new claims describe
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`a control, monitoring, and/or security system for a vehicle, having two or three
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`4
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`control devices. For example, the system of claim 34 includes a first control device
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`located at the vehicle, a second control device located at a central location, and a
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`third control device located remote from both the vehicle and the central location.
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`The second and third control devices control the operation of the first, in-vehicle,
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`device:
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`34. A control, monitoring and/or security system for a vehicle,
`which comprises:
`a first control device for one of controlling and monitoring one of
`the operation and status of one of the vehicle and a vehicle one of
`component, device, system and subsystem, wherein said first control
`device is located at the vehicle;
`a second control device for one of controlling and monitoring one
`of the operation and status of one of the system, the vehicle and a
`vehicle one of component, device, system and subsystem, wherein
`said second control device is located at a central location;
`a third control device for one of controlling and monitoring one of
`the operation and status of one of the system, the vehicle and the
`vehicle one of component, device, system and subsystem, wherein
`said third control device is located at a location which is remote from
`the vehicle and remote from the central location;
`wherein one of said second control device and said third control
`device one of controls, monitors and activates an operation of said
`first control device, and further wherein said first control device
`generates a signal for at least one of controlling, monitoring, securing,
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`5
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`9.
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`disabling and re-enabling at least one of the vehicle and the vehicle
`one of component, device, system and subsystem.
`After another rejection, as anticipated by U.S. Patent No. 5,081,667 to Drori,
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`Joao canceled all claims and added new claims. The new claims describe a control
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`apparatus for a vehicle, all claims having three control devices, and now including
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`a sequence of control signals from the remote devices to the in-vehicle device:
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`44. A control apparatus for a vehicle, which comprises:
`a first control device, wherein said first control device one of
`generates and
`transmits a first signal for one of activating,
`deactivating, enabling, and disabling, one of a vehicle component, a
`vehicle device, a vehicle system, and a vehicle subsystem, wherein
`said first control device is located at the vehicle;
`wherein said first control device is responsive to a second signal,
`wherein the second signal is one of generated by and transmitted from
`a second control device, wherein the second control device is located
`at a location which is remote from the vehicle, and further wherein the
`second control device is responsive to a third signal, wherein the third
`signal is one of generated by and transmitted from a third control
`device, wherein the third control device is located at a location which
`is remote from the vehicle and remote from the second control device.
`10. The claims were thereafter allowed in a Notice of Allowance on October 29,
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`1998, and the Examiner relied on the three control devices, with the particular
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`chain of command among those control devices, as the reasons for allowance:
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`6
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`11.
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`Examiner’s primary reason for allowance is in the environment of a
`control apparatus for a vehicle comprising, ‘a first control device,
`located at a vehicle, for generating and transmitting a control signal,
`first control device is responsive to a second signal, second signal is
`generated and transmitted by a second control device remote from
`first control device and second control device is responsive to a third
`signal, third signal is generated and transmitted by a third control
`device, third control device is at a location remote from vehicle and
`second control device, in that signals are sequentially relayed from
`outside control devices to a control device within the vehicle’.
`I further understand
`that
`the ’405 patent
`is currently subject
`
`to
`
`reexamination, and that during the reexamination, the Examiner determined
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`substantial new questions of patentability affecting claim 1 are raised by Kniffin
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`and Ryoichi and also 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 of either Ramono, Kniffin, Ryoichi, or
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`Pagliaroli with U.S. Patent No. 5,081,667 to Drori; and the combination of either
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`Ramono, Kniffin, Ryoichi, or Pagliaroli with U.S. Patent No. 5,103,221 to
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`Memmola. I further understand that claim 1 currently stands rejected as anticipated
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`by each of Ramono, Kniffin, Ryoichi, and Pagliaroli.
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`Kniffin – Claims 2, 7, 8, 11, 14, 17, 19, and 20
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`12. Kniffin discloses all of the limitations of claims 2, 7, 8, 11, 14, 17, 18, and
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`21, including the sequence of control signals passed among three control devices,
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`which was the basis for allowance of the ’405 patent.
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`7
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`13. Kniffin describes a secure entry system 10, including telephone touch pad
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`22, communications link 16, clearinghouse 18 connected to RF transmission
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`system 26, and access control devices 12 or 64 having RF receiver 14. Col. 2, ll.
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`25-53, col. 8, ll. 11-14.
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`14. The chain of three control devices described by Kniffin includes an access
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`control device 64 (located in 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 the clearinghouse). A user may establish communication via
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`communications link 16, from a cellular telephone or conventional telephone 22, to
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`clearinghouse 18 or 66, and, after an authorization check, the clearinghouse 18 or
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`66 transmits radio signals over RF transmission system 26 to access control device
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`12 or 64, via RF receiver 14. Col. 2, ll. 25-53, col. 8, ll. 11-14. In the vehicle
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`embodiment, access control device 64 controls door locks on a truck 62. Col. 8, ll.
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`11-14, 46-48; Fig. 4.
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`15.
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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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`8
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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.
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`16. 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 ’405 patent.
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`17. As noted above, the claims of the ’405 patent vary in naming the three
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`control devices. That is, the “first control device” of claim 1 corresponds to the
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`“third control device” in claims 12 and 16, the “second control device” of claim 1
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`corresponds to the “first control device” of claim 12 and the “second control
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`device” of claim 16, and the “third control device” of claim 1 corresponds to the
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`“second control device” of claim 12 and the “first control device” of claim 16. As
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`further noted above, my understanding of the claims and the disclosure of the prior
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`art documents is independent of the naming conventions applied in the various
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`claims.
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`18. Kniffin further describes a monitoring device for monitoring at least one of
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`several identified vehicle systems, including the vehicle itself, or activity outside of
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`the vehicle, in its description of clearinghouse 66 relaying status information
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`regarding the presence of a person in the vicinity of the house, or the presence of
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`the truck access control device 64 at a delivery stop. Col. 2, l. 62-col. 3, l. 6, col. 8,
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`ll. 25-27.
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`19. Kniffin further describes examples of vehicle component, device, system, or
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`subsystem, including, for example, a vehicle electro-mechanical system or
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`component, a vehicle anti-theft system, a vehicle door lock system, in its
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`description of electronic access control device 64 as an electromechanical vehicle
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`system component, a vehicle anti-theft system, and a vehicle door lock system.
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`Col. 8, ll. 11-14, 21-24, and 46-48.
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`20. Kniffin further describes that the operation of the apparatus or first control
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`device is programmed, automatically activated, or self-activating, in its description
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`of the programming of the truck access control device 64 by the clearinghouse 66.
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`Col. 8, ll. 21-33, 65-67.
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`21. Kniffin further describes a voice synthesizing device for generating a voice
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`message indicative of an operation of the apparatus, first control device, or
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`operation of the vehicle, in its description of a voice synthesizer reporting whether
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`access permission is granted. Col. 2, ll. 54-61.
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`22. Kniffin further describes determining an operational status of the vehicle
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`component, device, system, or subsystem, in its description of clearinghouse 66
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`relaying status information regarding the presence of a person in the vicinity of the
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`house, or the presence of the truck access control device 64 at a delivery stop. Col.
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`2, l. 62-col. 3, l. 6, col. 8, ll. 25-27.
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`23. Kniffin further describes examples of the “first control device” of claim 16,
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`including a hand-held device, a mobile device, a telephone, and a cellular
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`telephone, in its description of a cellular telephone or conventional telephone 22.
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`Col. 2, ll. 31-43.
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`The Combination of Kniffin and DiLullo – Claim 3
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`24. The combination of Kniffin and DiLullo discloses all of the limitations of
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`claim 3, and it would have been obvious to combine Kniffin and DiLullo to
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`achieve the apparatus claimed in claim 3.
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`25. Kniffin states that the described truck security system may be integrated
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`with a satellite vehicle locator system, and identifies DiLullo as a patent describing
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`one such satellite vehicle locator system.
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`26. DiLullo describes a vehicle monitoring system that is based on satellite
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`communications technology. The vehicle monitoring system includes a mobile
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`satellite transmitter (MST), located in a vehicle, such as a tractor-trailer. The MST
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`is used to transmit status information from the tractor-trailer to the status
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`monitoring system. The MST may include a position locating unit, so that the
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`11
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`status information may include vehicle position data. Col. 2, ll. 30-33, col. 5, ll. 56-
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`66.
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`27. At the time that the ’405 patent was filed, it would have been obvious to
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`combine Kniffin’s system with the mobile satellite transmitter of DiLullo, at least
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`because Kniffin expressly states that the satellite vehicle locator system of DiLullo
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`may be integrated with Kniffin’s security system. Col. 9, ll. 1-4.
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`Ryoichi – Claims 2, 7, 8, 11, 14, 17, 19, and 20
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`28. Ryoichi discloses all of the limitations of claims 2, 7, 8, 11, 14, 17, 18, and
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`21, including the sequence of control signals passed among three control devices,
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`which was the basis for allowance of the ’405 patent.
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`29. 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 from
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`the fixed radio station St). Ryoichi provides for the control of an “automobile-
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`mounted device” in which the telephone unit sends information related to
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`controlling a device to a paging center, which subsequently sends paging signals
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`containing the control information over the paging network. These are received by
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`the paging unit in the vehicle, and are used to control various vehicle components.
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`As examples, Ryoichi describes the control of door locks, engine ignition,
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`12
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`headlights, etc. Abstract, col. 5, l. 16-col. 6, l. 9; col. 8, l. 1-col. 10, l. 27; Figs. 5-
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`7).
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`30. 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
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`remote from the fixed radio station St).
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`31. 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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`13
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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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`32. Because Ryoichi describes a first control device, located at a vehicle (radio
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`paging unit 9), controlling a vehicle component (e.g., door locks, headlights,
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`engine), responsive to a signal from a second control device, located remote from
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`the vehicle (radio station St), which is in turn responsive to a signal from a third
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`control device (telephone unit TEL), located remote from the vehicle and from the
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`second control device, Ryoichi addresses the Examiner’s reasons for allowing the
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`claims of the ’405 patent.
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`33. As noted above, the claims of the ’405 patent vary in naming the three
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`control devices. That is, the “first control device” of claim 1 corresponds to the
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`“third control device” in claims 12 and 16, the “second control device” of claim 1
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`corresponds to the “first control device” of claim 12 and the “second control
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`14
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`device” of claim 16, and the “third control device” of claim 1 corresponds to the
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`“second control device” of claim 12 and the “first control device” of claim 16. As
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`further noted above, my understanding of the claims and the disclosure of the prior
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`art documents is independent of the naming conventions applied in the various
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`claims.
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`34. Further, I understand that Joao has argued, during the reexamination of the
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`’405 patent, that the signal from telephone unit TEL to the radio station St is
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`merely relayed, unchanged, when it is radiated in its radio wave form to radio
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`paging unit 9. First, based on my understanding of the claims of the ’405 patent,
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`none of the claims require that a signal communicated between the three control
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`devices is modified in some way from the signals to which it is responding.
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`Second, Ryoichi describes the input to the telephone unit TEL as dialing the
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`“pushbuttons of a general wire telephone.” Col. 7, ll. 60-64. Such a general wire
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`telephone sends wired signals to radio station St, as illustrated in Figure 1, below.
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`The wired signals received by the radio station St are changed at least in that the
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`wired signals are converted to radio waves, transmitted through the air. Moreover,
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`the radio paging unit 9 generates acoustic signals in response to radio signals
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`received from the paging system. Col. 5, ll. 16-25.
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`15
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`35. Ryoichi further describes a monitoring device for monitoring at least one of
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`several identified vehicle systems, including the vehicle, vehicle operation status,
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`vehicle operation, a vehicle device, or activity inside of the vehicle, in its
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`description of remote control condition detectors, such as brake lever operation
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`detector K1, shift lever/parking position detector K2, engine operation detector K3,
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`door handle operation detector K6, and vehicle speed sensor 36, detecting
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`conditions of the vehicle devices. Col. 6, ll. 20-31, col. 1, ll. 16-20, col. 12, ll. 66-
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`68; Fig. 2.
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`36. Ryoichi further describes examples of vehicle component, device, system, or
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`subsystem, including, for example, a vehicle ignition system, a vehicle electro-
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`mechanical system or component, a vehicle light system, a vehicle anti-theft
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`16
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`system, or a vehicle door lock system, in its description of control programs for
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`controlling door locks, headlights, and engines. Col. 8, ll. 51-55, col. 9, ll. 18-64,
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`col. 10, ll. 9-12, col. 10, ll. 13-27.
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`37. Ryoichi further describes that the operation of the apparatus or first control
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`device is programmed, automatically activated, or self-activating, in its description
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`of the personal radio paging unit 9 responding to signals from the radio station St
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`by generating a calling sound for detection by sensor 10, automatically activating
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`the paging unit 9. Col. 8, ll. 1-22.
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`38. Ryoichi further describes a voice synthesizing device for generating a voice
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`message indicative of an operation of the apparatus, first control device, or
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`operation of the vehicle, in its description of transmitter 52 transmitting tones
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`produced by synthesizer 55, including a voice signal from handset 57. Col. 15, l.
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`58-col. 16, l. 26.
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`39. Ryoichi further describes determining an operational status of the vehicle
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`component, device, system, or subsystem, in its description of remote control
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`condition detectors, such as brake lever operation detector K1, shift lever/parking
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`position detector K2, engine operation detector K3, door handle operation detector
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`K6, and vehicle speed sensor 36, detecting operational status of the vehicle
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`devices. Col. 6, ll. 20-31, col. 1, ll. 16-20, col. 12, ll. 66-68; Fig. 2.
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`17
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`40. Ryochi further describes examples of the first control device of claim 16,
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`including a hand-held device, a mobile device, a telephone, and a cellular
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`telephone, in its description of a telephone TEL as a general wire telephone unit.
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`Col. 7, l. 60-col. 8, l. 1.
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`The Combination of Ryoichi and Mansell – Claim 3
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`41. The combination of Ryoichi and Mansell discloses all of the limitations of
`
`claim 3, and it would have been obvious to combine Ryoichi and Mansell to
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`achieve the apparatus claimed in claim 3.
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`42. Mansell describes a vehicle tracking and security system, operating via
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`Mobile Units installed in hidden locations of a vehicle. Abstract. As described by
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`Mansell, each Mobile Unit 100 “preferably includes means for determining the
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`present location of the vehicle 102 in which it is installed.” Mansell specifically
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`identifies a Global Positioning System (GPS) receiver as a preferred mechanism
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`for determining the location, because it is accurate and free of cost. Col. 7, ll. 19-
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`26.
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`43. At the time that the ’405 patent was filed, it would have been obvious to
`
`combine the vehicle control system of Ryoichi with the vehicle tracking and
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`security system of Mansell, at least because both systems are designed to remotely
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`control vehicle components located in the vehicle, such as the control unit S and
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`actuators described by Ryoichi, and the Mobile Units 100 described by Mansell,
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`and further to “provid[e] a highly accurate, real-time vehicle tracking system.”
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`Mansell, col. 6, ll. 40-47.
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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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`- 19 -
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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
`
`
`Scott Andrews
`
`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
`
`
`Page 1
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`21
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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 8/00 and 5/01 from individuals and funds;
`
`1996 to 4/2000 Toyota Motor Corporation, Japan
`Project General Manager, R&D Management Division
`Responsibilities included the conceptualization and development of multimedia and new
`technology products and services for Toyota's future generations of passenger ve