UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
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`NISSAN NORTH AMERICA, INC.
`Petitioner,
`v.
`JOAO CONTROL & MONITORING SYSTEMS, LLC
`Patent Owner
`________________
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`
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`Case IPR2015-01645
`Patent 7,397,363
`________________
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`PATENT OWNER’S RESPONSE TO PETITION
`FOR INTER PARTES REVIEW UNDER 37 C.F.R. § 42.107
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`Patent Owner’s Response to Petition
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`Case IPR2015-01645
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`TABLE OF CONTENTS
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`I. INTRODUCTION ............................................................................................... 1
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`Page
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`II. BACKGROUND ................................................................................................. 2
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` A. Overview of the ‘363 Patent .......................................................................... 2
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` B. Prosecution History of the ‘363 Patent .......................................................... 3
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` 1. Original prosecution ................................................................................... 3
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` 2. Reexamination of the ‘363 Patent .............................................................. 3
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` C. Exemplary Claim ............................................................................................ 4
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`III. CLAIM CONSTRUCTION ............................................................................... 6
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` A. Legal Standards .............................................................................................. 6
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` B. “interface device” ........................................................................................... 9
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` C. “processing device” ...................................................................................... 10
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` D. “first signal,” “second signal,” and “third signal” ....................................... 11
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` E. “the first processing device determines whether an action or an
` operation associated with information contained in the second
` signal, to at least one of activate, de-activate, disable, re-enable,
` and control an operation of, the at least one of a vehicle system,
` a vehicle equipment system, a vehicle component, a vehicle
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` device, a vehicle equipment, and a vehicle appliance, is an
` authorized or an allowed action or an authorized or an allowed
` operation” ..................................................................................................... 12
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`IV. DAVID McNAMARA’S DECLARATION IS FUNDAMENTALLY
` FLAWED ......................................................................................................... 14
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`
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` A. Mr. McNamara Did Not Review the Materials Required to Properly Reach
` His Conclusions and Opinions ..................................................................... 14
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` B. David McNamara has an Erroneous Understanding of the Standards to Use
` in Construing Patent Claims ........................................................................ 15
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` C. David McNamara Testimony Should Be Given Little or No Weight .......... 17
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` A. Ground 1 is Deficient ................................................................................... 17
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` 1. Frossard fails to teach the “first processing device” of claim 21 ............ 18
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`V. RESPONSE TO PROPOSED GROUNDS OF INVALIDITY ........................ 17
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` 2. Frossard fails to disclose the “A to B to C” control system of claim
` 21............................................................................................................. 22
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` 3. The combination of Frossard and Spaur fails to render obvious the
` subject matter of claims 21, 22, 24 and 25 ............................................. 25
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` B. Ground 2 is Deficient ................................................................................... 27
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` C. Ground 3 is Deficient ................................................................................... 30
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` D. Ground 4 is Deficient ................................................................................... 30
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` 1. Johnson fails to teach the “first processing device” and “second
` processing device” of claim 21 ................................................................ 31
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` 2. Rossmann fails to remedy the deficiencies in Johnson ............................ 36
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` 3. The combination of Johnson and Rossmann fails to render obvious the
` subject matter of claims 21, 22, 24, 25, 29 and 36 .................................. 39
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`VII. CONCLUSION .............................................................................................. 39
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`LIST OF EXHIBITS
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`Exhibit
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`EX2001
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`Description
`“Supplement to the Remarks for the Amendment filed on October 24,
`2007” filed on November 23, 2007 during prosecution of the patent
`application that issued as related U.S. Patent No. 7,397,363
`EX2002 Notice of Intent to Issue Ex Parte Reexamination Certificate
`“Petition for Inter Partes Review Under 35 U.S.C. §§ 311-319 and 37
`EX2003
`C.F.R. § 42.100 Et Seq.” filed by Nissan North America, Inc.
`EX2004 Declaration of Steven W. Ritcheson
`August 26, 2015 Opinion and Order Construing Disputed Claim Terms
`in the matter of JCMS v. Chrysler Group LLC, Case No. 13-cv-13957
`(E.D. Mich.)
`EX2006 Transcript of March 15, 2016 Deposition of David McNamara
`EX2007 Transcript of March 16, 2016 Deposition of David McNamara
`“The Internet Report,” Morgan Stanley Global Technology Group,
`EX2008
`February 1996.
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`iv iv
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`EX2005
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`Patent Owner’s Response to Petition
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`I.
`INTRODUCTION
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`In response to the Petition for Inter Partes Review (“Petition”) filed by
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`Petitioner, the Board has instituted inter partes review (Paper 11, the “Decision”)
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`of claims 21, 22, 24, 25, 29 and 36 (“Challenged Claims”) of U.S. Patent No.
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`7,397,363 (“the ‘363 Patent”) based on the following grounds:
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`Ground
`1
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`2
`3
`4
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`Claims
`21, 22, 24 and
`25
`29
`36
`21, 22, 24, 25,
`29 and 36
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`Proposed Rejections
`obvious over Frossard in view of Spaur
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`obvious over Frossard in view of Spaur and
`Simms
`obvious over Frossard in view of Pagliaroli
`obvious over Johnson in view of Rossmann
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`The four proposed grounds of rejection are substantively flawed, in that
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`none of the cited references disclose, teach, or suggest, important properly
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`construed claim limitations. For example, none of the cited references teach an
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`“A to B to C” control system/method, as required by the Challenged Claims, and
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`as will be explained in more detail below.
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`Further, as will be discussed below, it became apparent during cross-
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`examination that Petitioner’s expert, David McNamara: (1) did not review the
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`materials required to properly reach his conclusions and opinions; and (2) has an
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`erroneous understanding of the proper standards to use in construing patent
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`claims. For at least these reasons, the Board should give Mr. McNamara’s
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`testimony little or no weight.
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`Accordingly, Joao Control & Monitoring Systems, LLC (“JCMS” or
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`“Patent Owner”) submits this Response to Petitioner’s Petition and the Board’s
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`Decision.
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`II. BACKGROUND
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`A. Overview of the ‘363 Patent
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`The ‘363 Patent is directed to a novel and unconventional system for, inter
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`alia, remotely-controlling and/or monitoring systems located at vehicles and
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`premises. EX1001 at 26. The Challenged Claims are directed to a specially
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`assembled and programmed distributed control and monitoring system for
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`vehicles, wherein control functions for a vehicle or for a vehicle system, vehicle
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`equipment system, vehicle component, vehicle device, vehicle equipment, or
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`vehicle appliance, of a vehicle, can be distributed among three separate and
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`distinct processing devices, each of which can generate or transmit a separate and
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`distinct signal in order to control a separate fourth device of or at the vehicle,
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`which is the respective vehicle system, vehicle equipment system, vehicle
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`component, vehicle device, vehicle equipment, or vehicle appliance.
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`B.
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`Prosecution History of the ‘363 Patent
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`1.
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`Original prosecution
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`The U.S. Patent Application that issued as the ‘363 Patent was filed on
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`September 16, 2002. EX1001. The ‘363 Patent issued on July 8, 2008. Id.
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`During prosecution, the Applicant chose to be his own lexicographer and
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`provided explicit definitions for various terms, including “processing device,”
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`“remote” and “located at,” in “Supplement to the Remarks for the Amendment
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`filed on October 24, 2007” filed on November 23, 2007 during prosecution of the
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`patent application that issued as the ‘363 patent (see EX2001, hereinafter “First
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`Remarks”).
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`2.
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`Reexamination of the ‘363 Patent
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`Ex Parte Reexamination Control No. 90/013,303 (hereinafter “the ‘363
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`Reexam”) was requested by a third party on July 21, 2014, challenging claim 21
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`of the ‘363 Patent. Reexamination was ordered on September 17, 2014.
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`The Examiner issued a Notice of Intent to Issue Ex Parte Reexamination
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`Certificate on July 29, 2105 (EX2002, hereinafter “Notice”), in which original
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`claim 21 was confirmed as patentable over the prior art of record.
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`C.
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`Exemplary Claim
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`Claim 21 is the only independent claim being challenged. It is reproduced
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`below:
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`21. An apparatus, comprising:
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`a first processing device, wherein the first processing device at least
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`one of generates a first signal and transmits a first signal for at least one of
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`activating, deactivating, disabling, re-enabling, and controlling an operation of, at
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`least one of a vehicle system, a vehicle equipment system, a vehicle component, a
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`vehicle device, a vehicle equipment, and a vehicle appliance, of or located at a
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`vehicle, wherein the first processing device is associated with a web site, and
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`further wherein the first processing device is located at a location remote from
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`the vehicle,
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`wherein the first processing device at least one of generates the first
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`signal and transmits the first signal in response to a second signal, wherein the
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`second signal is a at least one of generated by a second processing device and
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`transmitted from a second processing device, wherein the second processing
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`device is located at a location which is remote from the first processing device
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`and remote from the vehicle, wherein the first processing device determines
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`whether an action or an operation associated with information contained in the
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`second signal, to at least one of activate, de-activate, disable re-enable, and
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`control an operation of, the at least one of a vehicle system, a vehicle equipment
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`system, a vehicle component, a vehicle device, a vehicle equipment, and a
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`vehicle appliance, is an authorized or an allowed action or an authorized or an
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`allowed operation, and further wherein the first processing device at least one of
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`generates the first signal and transmits the first signal to a third processing device
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`if the action or the operation is determined to be an authorized or an allowed
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`action or an authorized or an allowed operation, wherein the third processing
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`device is located at the vehicle,
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`wherein the second signal is transmitted to the first processing
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`device via, on, or over, at least one of the Internet and the World Wide Web, and
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`further wherein the second signal is automatically received by the first processing
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`device, wherein the first signal is transmitted to and automatically received by the
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`third processing device, wherein the third processing device at least one of
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`generates a third signal and transmits a third signal for at least one of activating,
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`de-activating, disabling, re-enabling, and controlling an operation of, the at least
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`one of a vehicle system, a vehicle equipment system, a vehicle component, a
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`vehicle device, a vehicle equipment, and a vehicle appliance, in response to the
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`first signal.
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`III. CLAIM CONSTRUCTION
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`Legal Standards
`A.
`The Board concluded that the term of the ‘363 Patent will expire prior to
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`the end of the one-year period allotted for an inter partes review, and thus the
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`Board is treating the ‘363 Patent as expired for purposes of claim interpretation.
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`Decision at 6. Claim terms in an expired patent are generally given their
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`“ordinary and customary meaning” as understood by a person of ordinary skill in
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`the art in question at the time of the invention. Phillips v. AWH Corp., 415 F.3d
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`1303,1327 (Fed. Cir. 2005).
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`However, it is important to note that the Manual of Patent Examining
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`Procedure (MPEP) and controlling case law make it clear that the determination
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`of the ordinary and customary meaning of a term or phrase does not occur in a
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`vacuum, but instead it must be made in light of the patent’s specification and the
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`intrinsic evidence. MPEP §2111.01 is clear and unequivocal on this point. The
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`pertinent portion of the MPEP §2111.01 recites:
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`The ordinary and customary meaning of a term may be
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`evidenced by a variety of sources, including “the words
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`of
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`the claims
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`themselves,
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`the remainder of
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`the
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`specification, the prosecution history, and extrinsic
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`evidence concerning relevant scientific principles, the
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`meaning of technical terms, and the state of the art.”
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`Phillips v. AWH Corp., 415 F.3d at 1314, 75 USPQ2d
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`at 1327. If extrinsic reference sources, such as
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`dictionaries, evidence more than one definition for the
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`term, the intrinsic record must be consulted to identify
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`which of the different possible definitions is most
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`consistent with Applicant’s use of the terms. Brookhill-
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`Wilk 1, 334 F.3d at 1300, 67 USPQ2d at 1137; see also
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`Renishaw PLC v. Marposs Societa' per Azioni, 158
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`F.3d 1243, 1250, 48 USPQ2d 1117, 1122 (Fed. Cir.
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`1998) (“Where there are several common meanings for
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`a claim term, the patent disclosure serves to point away
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`from the improper meanings and toward the proper
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`meanings.”) and Vitronics Corp. v. Conceptronic Inc.,
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`90 F.3d 1576, 1583, 39 USPQ2d 1573, 1577 (Fed. Cir.
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`1996) (construing the term “solder reflow temperature”
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`to mean “peak reflow temperature” of solder rather than
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`the “liquidus temperature” of solder in order to remain
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`consistent with the specification.). (Emphasis added).
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`“[A] patentee may choose to be his own lexicographer” and assign special
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`definitions to the words in the claim, as long as those definitions are clearly
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`stated in the patent specification or file history. Vitronics Corp. v. Conceptronic,
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`Inc., 90 F.3d 1576, 1582 (Fed. Cir. 1996) (citing Hoechst Celanese Corp. v. BP
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`Chems. Ltd., 78 F.3d 1575, 1578 (Fed. Cir. 1996)). Therefore, “it is always
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`necessary to review the specification to determine whether the inventor has used
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`any terms in a manner inconsistent with their ordinary meaning. The
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`specification acts as a dictionary when it expressly defines terms used in the
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`claims or when it defines terms by implication.” Id. Because the specification
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`must contain a description sufficient to those of ordinary skill in the art to make
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`and use the invention, the specification “is the single best guide to the meaning of
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`a disputed claim term.” Id.
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`The prosecution history of the patent is also important to a proper claim
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`construction. As a complete record of proceedings before the U.S. Patent and
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`Trademark Office, it may contain representations made by the applicant
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`regarding the scope of the claims. Vitronics, 90 F.3d at 1582. “The patentee is
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`bound by representations made and actions that were taken in order to obtain the
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`patent.” Phillips, 415 F.3d at 1317 (quoting Chimie v. PPG Indus., Inc., 402 F.3d
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`1371, 1384 (Fed. Cir. 2005)). The prosecution history limits the meaning of
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`claim terms “so as to exclude any interpretation that was disclaimed during
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`prosecution.” Southwall, 54 F.3d at 1576. Prior art, some of which may be
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`contained in the file history, is also important because a valid claim cannot read
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`on, or cover within its scope, what is disclosed in the prior art. See General
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`American Transportation Corp. v. Cryo-Trans, Inc., 93 F.3d 766, 771 (Fed. Cir.
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`1996).
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`B.
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`“interface device”
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`Petitioner offered a construction for this term in a petition Petitioner filed
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`in related Inter Partes Review No. IPR2015-01509 (see EX2003, hereinafter “the
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`‘1509 Petition”).
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`In the ‘1509 Petition, Petitioner’s proposed construction for “interface
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`device” is “a device that allows components connected via the interface
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`device to work together.” EX2003 at 14-15. Patent Owner agreed with this
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`proposed construction, and submits that this construction is useful in the present
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`proceedings to distinguish a “processing device” from an “interface device.”
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`C.
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`“processing device”
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`The term “processing device” appears in independent claim 21 and its
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`construction is necessary to interpret the meaning of the claims. Petitioner has
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`offered no construction for this key term.
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`As discussed supra, Applicant chose to be his own lexicographer and
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`provided an explicit definition for the term “processing device” in the First
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`Remarks. EX2001 at 9-10. Accordingly, the term “processing device” should be
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`construed as “a device or a computer, or that part of a device or a computer,
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`which performs an operation, an action, or a function, or which performs a
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`number of operations, actions, or functions.” This proposed construction is
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`consistent with Applicant’s definition of the term “processing device” in the First
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`Remarks, and is also supported by and is consistent with the Specification of the
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`‘363 Patent, including the written description, the drawings and the claims.
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`D.
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`“first signal,” “second signal,” and “third signal”
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`JCMS respectfully submits that construction of these terms is necessary at
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`this time, as will become apparent below.
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`In litigation involving the ‘363 Patent, the U.S. District Court for the
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`Eastern District of Michigan issued an Opinion and Order Construing Disputed
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`Claim Terms in which they construed the terms “first signal,” “second signal,”
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`and “third signal” as follows:
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`“The Court does, however, find that Defendant’s
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`proposed alternative constructions are consistent with
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`the normal understanding of the claim terms. In fact,
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`the parties agree that the “first signal” is a signal sent
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`by the first device, the “second signal” is sent by the
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`second device, and the “third signal” is sent by the
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`third device.” EX2005 at 23. (emphasis added).
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`JCMS respectfully submits that, for purposes of this proceeding, these
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`constructions should be adopted, as they are required to evaluate the merits of
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`Petitioner’s arguments, namely:
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`• “first signal” is “a signal sent by a first device”
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` •
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` “second signal” is “a signal sent by a second
` device”
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` •
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` “third signal” is “a signal sent by a third
` device”
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`E.
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`“the first processing device determines whether an action or an
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` operation associated with information contained in the second
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` signal, to at least one of activate, de-activate, disable, re-enable,
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` and control an operation of, the at least one of a vehicle system,
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` a vehicle equipment system, a vehicle component, a vehicle
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` device, a vehicle equipment, and a vehicle appliance, is an
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` authorized or an allowed action or an authorized or an allowed
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` operation”
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`The phrase appears in independent claim 21, and Petitioner has proposed
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`the following construction: “the first processing device determines whether an
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`action or an operation associated with information contained in the second
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`signal is allowed or authorized, wherein the action or operation is to at least
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`one of activate, de-activate, disable, re-enable, and control an operation of,
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`the at least one of a vehicle system, a vehicle equipment system, a vehicle
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`component, a vehicle device, a vehicle equipment, and a vehicle appliance.”
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`Paper 3 at 9.
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`However, Petitioner goes on to state that “[t]his construction emphasizes
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`that the action or operation is what activates, deactivates, disables, re-enables, or
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`controls.” Id. (emphasis in original). This is a misleading statement. Patent
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`Owner submits that the “action” or “operation” is not “what activates,
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`deactivates, disables, re-enables, or controls.” Rather, the “action” or “operation”
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`being allowed or authorized is the so-called action or operation of activating, de-
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`activating, disabling, re-enabling, or controlling an operation of . . . ,” which is
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`performed by the third processing device as the result of the third processing
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`device generating or transmitting the third signal.
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`Accordingly, Patent Owner agrees with Petitioner’s construction only to
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`the extent that it means that the “action” or “operation” being “authorized” or
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`“allowed” is the action or the operation “to at least one of activate, de-activate,
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`disable, re-enable, and control an operation of, the at least one of a vehicle
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`Patent Owner’s Response to Petition
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`system, a vehicle equipment system, a vehicle component, a vehicle device, a
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`vehicle equipment, and a vehicle appliance . . . ,” which is performed by the third
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`processing device as the result of the third processing device generating or
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`transmitting the third signal.
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`IV. DAVID McNAMARA’S DECLARATION IS FUNDAMENTALLY
` FLAWED
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`A. Mr. McNamara did not Review the Materials Required to
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` Properly Reach his Conclusions and Opinions
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`
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`During David McNamara’s cross-examination, it became apparent that Mr.
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`McNamara had not reviewed the materials required for him to properly reach his
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`conclusions and opinions. In his Declaration, Mr. McNamara indicated that he
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`“read” the prosecution history of the ‘363 Patent, as is required in order to
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`properly construe the claims. EX1003 at ¶ 13. Yet, during cross-examination, Mr.
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`McNamara testified that, in fact, he did not review the prosecution history of the
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`‘363 Patent, as evidenced by the following exchange:
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`EX2006 at 153
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`Q: You have testified previously, I think, that you did
` not review the prosecution histories for the four
` JCMS patents at issue correct?
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`A: That’s correct.
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`Case IPR2015-01645
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`Patent Owner’s Response to Petition
`Patent 7,397,363
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`Q: Is it necessarily true, then, that you, in reaching the
` conclusions or opinions expressed in Exhibits 1
` through 4, you did not apply the, any definitions that
` may have been provided by Mr. Joao during
` prosecution of those patents, correct?
`
`A: That’s correct.
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` B. David McNamara has an Erroneous Understanding of the
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` Standards to Use in Construing Patent Claims
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`
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`Mr. McNamara is not at all versed in the proper standards to use when
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`construing patent claims. For example, Mr. McNamara admitted during cross-
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`examination that he used the wrong standard when construing the Challenged
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`Claims in the present IPR, as evidenced by the following exchange:
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`EX2006 at 151-152
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`Q: . . . With respect to the '363 patent, if you turn
` to that declaration which should be Exhibit 4,
` you have Paragraph 9 that the, you identify
` the claim construction, or the, it states the
` following, "The claim of an unexpired patent
` is to be given the broadest reasonable
` construction in light of the specification of the
` patent in which it appears, which is what I
` have done when performing my analysis in
` this declaration." Do you see that?
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`A: Which paragraph are we reading?
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`
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`Q: I am at paragraph 9 of Exhibit 4?
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`Case IPR2015-01645
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`. . .
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`Q: Okay. Are you aware that the PTAB has indicated or
` stated that that is, in fact, the wrong standard for the
` ‘363 patent and that, in fact, the standard is the
` standard that you articulated in the, for example, in
` Exhibit 1?
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`A: I’m recently aware of that, yes.
`
`Q: Okay. How does the use of the wrong claim
` construction standard affect your opinions in this
` case?
`
`A: I don't think I used the wrong standard because I used
` the same standard through all of the four patents. I
` used the one of ordinary and customary
` understanding. (emphasis added)
`
`Q: Is that notwithstanding the fact that you say in
` Paragraph 9 that you used a different standard? Is that
` incorrect?
`
`A: Well, I think that the, put it this way, I can’t
` personally differentiate between broadest and
` ordinary and customary. I guess that is the simple
` answer. (emphasis added).
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`
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`Thus, by Mr. McNamara’s own testimony, he admitted that he cannot tell
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`the difference between the standards used to construe claims in expired and
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`unexpired patents, and so he simply uses the same standard regardless of whether
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`the patent is expired or not. Specifically, Mr. McNamara testified that he uses the
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`“plain and ordinary meaning” standard for all patents, although, given his
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`testimony, it is not clear that he even knows what this standard is or should be.
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`C. David McNamara’s Testimony Should Be Given Little or No
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` Weight
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`
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`The Board should give Mr. McNamara’s testimony little or no weight
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`because, as discussed in detail above: (1) despite his statements in his sworn
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`Declaration to the contrary, he did not even review the materials required to
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`properly reach his conclusions and opinions; and (2) he has an erroneous
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`understanding of the proper standards to use in construing patent claims.
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`V. RESPONSE TO PROPOSED GROUNDS OF INVALIDITY
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`
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`A. Ground 1 is Deficient
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`Ground 1 alleges that claims 21, 22, 24 and 25 are obvious over Frossard
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`in view of Spaur. However, Patent Owner respectfully submits that the asserted
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`combination of Frossard and Spaur fails to disclose, teach, or suggest, every
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`claimed element and feature of claims 21, 22, 24 and 25 when the claim elements
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`are properly construed.
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`At the outset, JCMS disagrees with the Petitioner’s interpretation of
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`“processing device” that would allow the receiver/decoder circuits 4 of Frossard
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`to serve as the “third processing device” of claim 21. Patent Owner maintains
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`that the receiver/decoder circuits 4 of Frossard are merely an interface device as
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`taught by the specification of the ‘363 Patent, and not a “processing device.”
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`Petitioner’s arguments and the constructions and interpretations that have been
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`adopted by the Board, notwithstanding, Petitioner’s arguments with respect to
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`Frossard still fail with regards independent claim 21.
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`1.
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`Frossard fails to teach the “first processing device” of claim
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` 21
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`As discussed supra, Claim 21 recites, inter alia, “a first processing device
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`[that] is associated with a web site” and that “is located at a location remote
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`from the vehicle.” (emphasis added). Claim 21 also recites a “second processing
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`device . . . located at a location which is remote from the first processing device
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`and remote from the vehicle” that transmits a “second signal . . . to the first
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`processing device via, on, or over, at least one of the Internet and the World Wide
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`Web.” The “first processing device,” in turn, transmits a “first signal” to a “third
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`processing device” that is located at the vehicle.
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`Thus, the apparatus of claim 21 is an “A to B to C” system. Critically, the
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`claimed “first processing device” is the intermediate processing device in this “A
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`to B to C” system. This intermediate processing device (“first processing device”)
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`sends a signal (“first signal”) to the final processing device in the chain (“third
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`processing device”) in response to a signal (“second signal”) from another
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`processing device (“second processing device”). It is the claimed intermediate
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`device (“first processing device”) that is required to be “associated with a web
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`site.”
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`Petitioner looks to Spaur to remedy the fact that Frossard does not disclose,
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`teach, or suggest, a “first processing device” that is “associated with a web site,”
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`as claim 21 requires. In its Decision, the Board stated:
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`“Petitioner points to the computer terminal at the ‘remote
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`site’ (not the vehicle) that has a “world wide web browser.”
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`Pet. 14, 15 (citing EX. 1016, 1:7-8, 5:40-6:22, Fig. 1, 2:25-
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`34, Ex. 1003, 46). Thus, we agree that Spaur teaches a
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`computer terminal at a remote site (remote from the vehicle)
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`that includes a web browser. Id. At 15. Petitioner argues that
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`one of ordinary skill in the art would understand that Spaur
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`discloses using a web site at the remote site. Id. (citing Ex.
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`1003, 46).” Decision at 12. (citations in original).
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`However, the “World Wide Web Browser” present on the computer
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`terminal of Spaur simply means that it can access a web site that is hosted at
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`some remote web server. In fact, it accesses a web server that is hosted at the
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`controller 30, which is located at the vehicle.
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`
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`Indeed, the only device in Spaur that is “associated with a web site” is the
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`controller 30, which is shown in Figure 2 of Spaur as including a web server 102.
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`See EX1016 at Figure 2 and Col. 8, lines 24-45. However, Spaur clearly and
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`unequivocally teaches that the controller 30, and the web server, must be located
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`at the vehicle. For example, Spaur specifically states:
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`“The wireless device 18 bi-directionally communicates with
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`a controller 30 contained in the vehicle through a network
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`protocol converter 26 using a wireless device interface 22 . .
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`. [i]n the embodiment to be described in greater detail
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`herein, the network protocol converter 26 includes a TCP/IP
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`stack which can be part of the cont