Before the Patent Trial and Appeal Board
`________________
`
`NISSAN NORTH AMERICA, INC.
`Petitioner
`v.
`JOAO CONTROL & MONITORING SYSTEMS, LLC
`Patent Owner
`________________
`
`Case IPR2015-01645
`U.S. Patent No. 7,397,363
`
`Patent Owner’s Demonstrative Exhibits For Oral Hearing
`
`1 of 13
`
`JCMS - EXHIBIT 2009
`
`
`________________
`
`NISSAN NORTH AMERICA, INC.
`Petitioner
`v.
`JOAO CONTROL & MONITORING SYSTEMS, LLC
`Patent Owner
`________________
`
`Case IPR2015-01645
`U.S. Patent No. 7,397,363
`
`Patent Owner’s Demonstrative Exhibits For Oral Hearing
`
`1 of 13
`
`JCMS - EXHIBIT 2009
`
`
`
`Claim Construction: the signals
`
`• “first signal” is: “a signal sent by a first device”
`
`• “second signal” is: “a signal sent by a second device”
`
`• “third signal” is: “a signal generated by a third
`device”
`
`Patent Owner’s Response at 11-12.
`
`2
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`2 of 13
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`Claim Construction: the signals
`
`• In litigation involving the ‘363 Patent, the U.S.
`District Court for the Eastern District of Michigan
`adopted the same constructions proposed by Patent
`Owner.
`
`Patent Owner’s Response at 11-12.
`
`3
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`3 of 13
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`JCMS - EXHIBIT 2009
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`
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`Frossard: Petitioner’s Position
`
`Second
`Processing
`Device
`
`First
`Processing
`Device
`
`Third
`Processing
`Device
`(at vehicle)
`
`Exh. 1005 (Frossard) at Fig. 4.
`Petition at 14-22.
`
`4
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`4 of 13
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`
`
`The Second Signal: Frossard Fails to Disclose,
`Teach or Suggest an A to B to C System
`
`The ‘363 Patent: A to B to C System
`
`Second
`Processing
`Device
`
`First
`Processing
`Device
`
`Frossard: A to B to C to D System
`
`Third
`Processing
`Device
`(At Vehicle)
`
`Minitel
`Telephone
`
`Server
`1
`
`Resource
`2
`
`Receiver-
`Decoder Circuits
`4
`(At Vehicle)
`
`Exh. 1005 (Frossard) at Fig. 4.
`Patent Owner’s Response at 22-25.
`
`5
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`5 of 13
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`Frossard & Spaur Fail to Disclose, Teach or Suggest the
`“First Processing Device” of Claim 21
`
`Claim 21 recites, inter alia, “a first processing device
`[that] is associated with a web site” and that “is
`located at a location remote from the vehicle.”
`
`Exh. 1001 at claim 21.
`Patent Owner’s Response at 18.
`
`6
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`6 of 13
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`Frossard Fails to Disclose, Teach or Suggest the
`“First Processing Device” of Claim 21
`
`Second
`Processing
`Device
`
`First Processing
`Device (Not
`Associated with a
`Web Site)
`
`Third
`Processing
`Device
`(at vehicle)
`
`Exh. 1005 (Frossard) at Fig. 4.
`Patent Owner’s Response at 18-22.
`
`7
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`7 of 13
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`Spaur Fails to Remedy the Deficiencies in
`Frossard
`
`Controller (Located at
`Vehicle)
`
`Web Server (Located
`at Vehicle)
`
`Exh. 1016 (Spaur) at Fig. 2.
`Patent Owner’s Response at 18-22.
`
`8
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`8 of 13
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`Johnson and Rossman Fail to Disclose, Teach or
`Suggest the “First Processing Device” and “Second
`Processing Device” of Claim 21
`
`Claim 21 recites, inter alia, “a first processing device
`[that] is associated with a web site” and that “is
`located at a location remote from the vehicle” and a
`“second processing device . . . located at a location
`which is remote from the first processing device and
`remote from the vehicle” that transmits a “second
`signal . . . to the first processing device via, on or over,
`at least one of the Internet and the World Wide Web.”
`
`Exh. 1001 at claim 21.
`Patent Owner’s Response at 31.
`
`9
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`Johnson and Rossman Fail to Disclose, Teach or
`Suggest the “First Processing Device” and “Second
`Processing Device” of Claim 21
`
`Johnson
`
`First Processing
`Device (Not
`Associated with a
`Web Site)
`
`Second
`Processing
`Device
`
`No disclosure, teaching or
`suggestion as to the use of the
`Internet or the World Wide Web as
`the communication medium.
`
`Exh. 1008 (Johnson) at Fig. 6.
`Patent Owner’s Response at 31.
`Petition at 40-42.
`
`10
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`10 of 13
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`Johnson and Rossman Fail to Disclose, Teach or
`Suggest the “First Processing Device” and “Second
`Processing Device” of Claim 21
`
`• Because both the computer system 601 and the operator console
`605 of Johnson are located at a common location, there is no need
`to connect them via the Internet, nor is there any need to associate
`the computer system 601 with a web site.
`
`• The client-server relationship between the computer system 601
`and the operator console 605 is more simply implemented with a
`closed network, such as a local area network, because there is
`absolutely no teaching by Johnson that anyone outside of the
`central monitoring station 103 is given access to the computer
`system 601.
`
`Patent Owner’s Response at 33-34.
`
`11
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`11 of 13
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`Johnson and Rossman Fail to Disclose, Teach or
`Suggest the “First Processing Device” and “Second
`Processing Device” of Claim 21
`
`• Petitioner’s analysis as to how Rossmann remedies the deficiencies in
`Johnson lacks an articulated reasoning with some rational underpinning.
`
`• Because both the computer system 601 and the operator console 605 of
`Johnson are located at a common location, there is no need to connect
`them via the Internet and there is no need to associate the computer system
`601 with a web site.
`
`• The client-server relationship between the computer system 601 and the
`operator console 605 is more simply implemented with a closed network,
`such as a local area network, because there is absolutely no teaching by
`Johnson that anyone outside of the central monitoring station 103 is
`provided with access to the computer system 601.
`Patent Owner’s Response at 37.
`
`12
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`12 of 13
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`Johnson and Rossman Fail to Disclose, Teach or
`Suggest the “First Processing Device” and “Second
`Processing Device” of Claim 21
`
`• Conventional wisdom at the time of the effective filing date of the
`Challenged Claims of the ‘363 Patent was that the Internet was not secure,
`as evidenced by Morgan Stanley’s “Internet Report” in 1996.
`
`• Thus, not only would a POSITA not be motivated to modify Johnson so
`as to utilize the Internet or the World Wide Web at the time of the
`invention of the Challenged Claims, conventional wisdom at the time of
`the invention of the subject matter the Challenged Claims of the ‘363
`Patent would have actually taught away from the use of the Internet or the
`World Wide Web.
`
`Patent Owner’s Response at 34.
`Exh. 2008 at 24 and 109.
`
`13
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`13 of 13
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`JCMS - EXHIBIT 2009
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