UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`APPLE INC.,
`Petitioner,
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`v.
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`TRACBEAM, LLC,
`Patent Owner.
`
`Patent No. 7,298,327
`
`
`Inter Partes Review No. _____________
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`
`DECLARATION OF KEVIN S. JUDGE
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`
`
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`
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`Apple Inc. Exhibit 1002 Page 1
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`
`
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`TRACBEAM, LLC,
`Patent Owner.
`
`Patent No. 7,298,327
`
`
`Inter Partes Review No. _____________
`
`
`DECLARATION OF KEVIN S. JUDGE
`
`
`
`
`
`
`Apple Inc. Exhibit 1002 Page 1
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`
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`Inter Partes Review of USP 7,298,327
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`
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`Docket No.: 106840000507
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`
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`I, Kevin S. Judge, make this declaration in connection with the proceeding
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`identified above.
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`I.
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`INTRODUCTION
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`1.
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`I have been retained by counsel for Apple Inc. (“Petitioner”) as a
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`technical expert in connection with the proceeding identified above. I submit this
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`declaration in support of Apple, Inc.’s Petition for Inter Partes Review of United
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`States Patent No. 7,298,327 (“the ’327 patent”).
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`2.
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`I am being paid at an hourly rate for my work on this matter. I have
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`no personal or financial stake or interest in the outcome of the present proceeding.
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`II.
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`QUALIFICATIONS
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`3.
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`I am currently employed as a senior engineer at John Deere in the
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`Advanced Engineering group designing the next generation of Global Navigation
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`Satellite System (GNSS) receivers for precision farming. I hold a Bachelor of
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`Science degree in Mathematics, and I am the owner of Judge Software Systems,
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`Inc., which provides consulting services for wireless communication and location.
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`4.
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`I have been designing and implementing systems for wireless
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`communication and location for the past 25 years.
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`5.
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`In particular, from 1987 to 1993 I was a programmer and analyst at
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`Magnavox Advanced Products Division designing and implementing 1990’s core
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`GPS software. As part of my role I worked on the navigation Kalman filter and the
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`receiver tracking control system.
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`6.
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`From 1993 to 1995, I was a software engineer and analyst at Interstate
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`Electronics Corporation, where I was responsible for the design and development
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`of the navigation processor for an aircraft navigation management system. My
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`responsibilities included writing the requirements for and participating in the
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`design, coding, and testing of all aspects of the GPS navigation code.
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`7.
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`From 2000 to 2004, I was the Senior Vice President of Software and
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`Systems at In-Sync Interactive management Company, where I designed and
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`managed the creation of a complete wireless TDMA data network, including
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`Internet client/server software and the base station and endpoint modems. I also
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`designed the wireless protocol for robust communication.
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`8.
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`From 1996 to 2009, at Greenfield Associates, I designed and managed
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`the development of a GPS traffic preemption system, including the development of
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`a low cost differential base station and a TDMA scheme for data transfer. I also
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`implemented a precise golf ranging system using locally broadcast differential
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`corrections.
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`9.
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`From 2004 to 2009, I was an Engineering Manager at NorBelle, LLC,
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`where I designed and contributed to the implementation of a real time mobile-to-
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`mobile tracking application for assisted GPS mobile phones. The system included
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`an Internet based back-end server over which a proprietary messaging system was
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`hosted. I designed the accuracy enhancing technology using GPS and cellular
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`trilateration critical to the usability of the application.
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`10. From 1999 to 2012, I represented SiRF Technology, Inc. in the 3GPP
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`and 3GPP2 standards committees helping to shape the standards for location
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`services in CDMA and GSM/UMTS. I also served as the chairman for CDMA
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`location services standards committee. The 3GPP2 standards body, a sub-working
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`group for Location Services, is an international consortium of individuals
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`representing companies interested in developing standards for mobile location
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`technology. As chairman I oversaw the development of the IS-801 A-1
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`specification used today by all CDMA mobile phones to receive location assistance
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`for both regulatory and commercial systems.
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`11. From 2008 to 2012, I was one of the three founding members of
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`Integrated Positioning, LLC, where I designed, built, and integrated a location
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`platform for a WiMax Network. I designed the backend systems to facilitate the
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`needs of the location platform to seed AGPS solutions for E-911 integration.
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`12. From 2011 to 2013, at Level8, I designed, implemented, and
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`administered a Rails 3 server to facilitate a mobile-to-mobile tracking application.
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`13. From 2012 to 2014, I represented Broadcom in the Indoor Location
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`Alliance (ILA), 3GPP, and OMA, drafting the architecture for indoor location
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`standardization. I was elected to the board of directors for the ILA.
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`14. As discussed, I was recently a charter board member of the Indoor
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`Location Alliance, and in the early 2000’s, I was the Chairman of the location
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`services sub-committee of the 3GPP2 telecommunications organization during the
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`drafting of the IS-801A-1 specification that defines how GPS and cellular location
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`operate on CDMA networks. I have also spent years as a contributing member of
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`location standards in the 3GPP organization that largely parallels 3GPP2, but for
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`GSM, UMTS, and now LTE networks. Attached as Appendix A is a copy of my
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`curriculum vitae.
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`III.
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`MATERIALS CONSIDERED
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`15.
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`In preparing this declaration, I have reviewed, among other things, the
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`following materials: (a) the ’327 patent and its prosecution history; (b) U.S. Patent
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`No. 5,604,765 to Bruno et al.; (c) U.S. Patent No. 5,202,829 to Geier; (d) U.S.
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`Patent No. 5,564,079 to Olsson; (e) U.S. Patent No. 5,936,572 to Loomis et al.; (f)
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`U.S. Patent No. 5,418,843 to Stjernholm; and (g) the Petition for Inter Partes
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`Review of the ’327 patent to which my declaration relates.
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`IV.
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`DEFINITIONS AND STANDARDS
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`16.
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`I have been informed and understand that claims are construed from
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`the perspective of one of ordinary skill in the art at the time of the claimed
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`invention, and that during inter partes review, claims are to be given their broadest
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`reasonable construction consistent with the specification and the ordinary and
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`customary meaning given to the term by those of ordinary skill in the art at the
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`time of the invention.
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`17.
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`I have also been informed and understand that the subject matter of a
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`patent claim is obvious if the differences between the subject matter of the claim
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`and the prior art are such that the subject matter as a whole would have been
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`obvious at the time the invention was made to a person having ordinary skill in the
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`art to which the subject matter pertains. I have also been informed that the
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`framework for determining obviousness involves considering the following
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`factors: (i) the scope and content of the prior art; (ii) the differences between the
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`prior art and the claimed subject matter; (iii) the level of ordinary skill in the art;
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`and (iv) any objective evidence of non-obviousness.
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`18.
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`I have been informed and understand that the claimed subject matter
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`would have been obvious to one of ordinary skill in the art if, for example, it
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`results from the combination of known elements according to known methods to
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`yield predictable results, the simple substitution of one known element for another
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`to obtain predictable results, use of a known technique to improve similar devices
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`in the same way, applying a known technique to a known device ready for
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`improvement to yield predictable results, or pursuing known options within one’s
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`technical grasp in response to a design need or market pressure to solve a problem.
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`I have also been informed that the analysis of obviousness may include recourse to
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`logic, judgment, and common sense available to the person of ordinary skill in the
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`art that does not necessarily require explication in any particular reference.
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`19.
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`In my opinion, a person of ordinary skill in the art pertaining to the
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`’327 patent at the relevant date discussed below would have been a person with a
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`bachelor’s degree in mathematics, electrical engineering, computer engineering, or
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`computer science, and 3-5 years of experience with wireless location and/or
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`navigation systems. However, I recognize that someone with less technical
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`education but more experience, or more technical education but less experience,
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`could have also met this standard.
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`20.
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`I understand that the ’327 patent is a continuation of and claims
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`priority to Application No. 09/194,367, filed as Application No. PCT/US97/15892
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`on September 8, 1997. For purposes of this declaration I have not analyzed
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`whether the ’327 patent is entitled to this filing date, but I have analyzed
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`obviousness as of that date or somewhat before. I may refer to this time frame as
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`the “relevant date” or the “relevant time frame.”
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`21. Based on my education and experience in the field of wireless
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`location systems set forth above, I believe I am qualified to provide opinions about
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`how one of ordinary skill in the art by the relevant date would have interpreted and
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`understood the ’327 patent and the prior art discussed below.
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`V.
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`THE ’327 PATENT
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`22. The ’327 patent generally discloses a network-based system and
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`method for locating a wireless mobile station (e.g., a handset / mobile phone). The
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`system is intended to be readily incorporated into existing commercial wireless
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`telephony systems with few, if any, modifications to a typical infrastructure. As
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`described by the patent, the wireless network infrastructure includes a plurality of
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`mobile stations and a plurality of base stations. The system provides the mobile
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`station location capabilities using the measurements from wireless signals
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`communicated between mobile stations and a network of base stations. The
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`communication standard or protocol used for location is the same as that used by
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`the network of base stations for providing wireless communications with mobile
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`stations for other purposes such as voice communication.
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`23.
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`In the system and method disclosed in the ’327 patent, multiple
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`location estimates are obtained using different techniques, which the patent refers
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`to as “location hypothesizing first order models” or “FOMs.” The patent includes
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`descriptions of various types of first order models, including distance first order
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`models, coverage area first order models, location base station first order models,
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`stochastic first order models, statistically-based pattern recognition first order
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`models, and adaptive/trainable first order models. Using the multiple location
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`estimates obtained using the various first order models, a most likely mobile
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`station position estimate is determined.
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`VI.
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`CLAIM CONSTRUCTION
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`24.
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`I have been asked to provide my opinion on a phrase by discussing
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`what one of ordinary skill in the art at the time of the patent filing would regard as
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`the broadest reasonable interpretation consistent with the specification. In each
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`case, my opinion agrees with the position taken in the Petitioner’s Petition for Inter
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`Partes Review filed with this declaration.
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`25. Numerous terms in the claims of the ’327 patent appear to be directed
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`to the same meaning within the same context, and I am unable to find sufficient
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`support in the specification to provide these terms distinct meanings. Specifically,
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`it is my opinion that one of ordinary skill in the art at the time of filing would have
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`understood that the broadest reasonable interpretation of the following terms
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`consistent with the specification is that they simply mean information that pertains
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`to location: “geographic location information,” “actual geographic location,”
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`“geographical extent,” “potential geographic location,” “instance of the
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`geographical location or extent,” “geolocation indicative data,” “geographic
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`identifications,” and “location data derived from geographic identifications.”
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`VII.
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`ANALYSIS OF THE PRIOR ART
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`A. U.S. Patent No. 5,604,765 to Bruno et al. (“Bruno”)
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`26. Bruno discloses combining multiple location-detection techniques to
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`determine the location of a mobile unit. The different techniques are 1) measuring
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`a distance from a mobile unit to three base stations using cellular timing
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`measurements to locate the mobile unit, 2) GPS, and 3) short distance RF
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`“Signposts.” (See, e.g., 2:17-19, 4:1-36.)
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`27. The first technique involves a mobile unit determining a range to
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`multiple base stations. (See, e.g., 4:1-15.) The mobile unit receives a message
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`from each base station, which includes the time at which the message left the base
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`station. The mobile unit compares the time the message was sent with the time the
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`message was received. The time difference enables the mobile unit to determine
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`the range from the base station. This technique further involves correction data
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`that in order to ensure that the timings of the base station and mobile unit are
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`synched.
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`28. By this first technique, the mobile unit determines a range to multiple
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`base stations, for example three. (See, e.g., FIG. 3.) The mobile unit determines
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`the known locations of each base station, and then solves a series of equations to
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`determine its own location. In other words, the mobile unit is able to determine its
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`own location using the distance to three base stations, as well as the locations of
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`these base stations. (See, e.g., 4:16-37.)
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`29. The second technique is GPS. (See, e.g., 2:20-24.) This technique is
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`well-known and understood in the art of location detection. Using the GPS
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`technique, the mobile unit communicates with multiple satellites to determine its
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`location. The mobile unit may experience some difficulty communicating with
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`satellites that do not have clear line-of-sight—such as downtown and indoor areas.
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`(See, e.g., 2:41-47.) If a line of sight to a satellite is available, the mobile unit
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`measures timing information from messages received from satellites to determine
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`its own location.
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`30. The third technique is called RF signposting. This technique involves
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`a short-range broadcast, approximately 100 feet, of a location identifier. (See, e.g.,
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`2:53-59.) If a mobile unit receives a broadcast with specific location information,
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`then the mobile unit knows that it is within approximately 100 feet of the location.
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`For example, the RF signpost may indicate to the mobile device that it is within a
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`certain store in a shopping mall. (See, e.g., 2:59-63.)
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`31. Bruno discloses that these three techniques can be used together, or in
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`combination. This is shown in Fig. 9, reproduced below:
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`32. The mobile unit receives cellular signals for location determination
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`along path A (red), GPS signals along path B (blue), and RF signpost signals along
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`path C (green). (See, e.g., 8:54-9:2.) Component 9-13 determines a pseudo range
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`measurement for each technique. Component 9-14 then estimates a position of the
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`mobile unit based on one or more of the techniques. (See, e.g., 8:55-62, 9:2-14.)
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`33. Moreover, Bruno states that the cellular ranging and RF signpost
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`techniques can be used to supplement or replace the GPS technique when the GPS
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`signal is weak or unavailable. (See, e.g., 2:41-48, 10:8-11; 9:38-56.)
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`Alternatively, Bruno’s mobile unit will use GPS when the cellular ranging
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`technique is not available. (See, e.g., 9:8-14.)
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`34. Once the mobile unit in Bruno determines its location, it outputs the
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`location to one or more of a variety of applications. (See, e.g., 9:57-10:6.) For
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`example, the mobile unit can output its location to the communications system,
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`which can either route the call appropriately based on the location, or provide the
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`location to a call destination. (See, e.g., 9:57-64.) For example, the
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`communication system could route the call to a particular E-911 operator that is
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`closest to the mobile unit, and also provide the E-911 operator with the location.
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`The mobile unit may also send its location directly to the destination once a call to
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`the destination is connected. (See, e.g., 9:64-66.) Bruno discloses that the mobile
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`unit can send its position to any one of a variety of applications, including E-911,
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`roadside assistance, fleet management, and tracking to reduce theft, fraud and
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`abuse. (See, e.g., 9:67-10-6.)
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`B. U.S. Patent No. 5,202,829 to Geier (“Geier”)
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`35. Geier discloses estimating the location of a ship using GPS
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`techniques. (Abstract.) Geier’s system includes multiple GPS receivers, each of
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`which calculate pseudo ranges (PRs) for a ship. (Id.) Geier discloses performing
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`statistical analysis to determine a weight for each of the PRs, weighting each PR,
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`and combining the weighted PRs to determine an approximation of the ships
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`location. (2:26-29, 2:36-38, 4:19-26, 7:5-22.) The ship’s location would also be
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`displayed on a map using an “error ellipse”, as shown in Fig. 14 (below, cropped).
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`C. U.S. Patent No. 5,564,079 to Olsson (“Olsson”)
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`36. Olsson discloses using prior wireless signal measurements to identify
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`the location of a mobile device. In Olsson, a measuring mobile 2 (“MM”)
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`equipped with GPS traverses various roadways covered by a cellular network of
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`base stations. (2:31-36, Fig. 1.) This is shown in Fig. 1, reproduced below.
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`37. MM2 collects GPS location and cellular reference data, and supplies
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`this information to a neural network. The cellular reference data and the GPS
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`location are used to train the neural network . (3:1-10.) During training, the neural
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`network calculates the position of MM2 based on the cellular reference data, and
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`compares the calculated position with a GPS estimate. (3:36-45.) If there is a
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`difference, the neural network trains itself by adjusting certain weightings that are
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`used to determine a location from cellular reference data. (3:43-45.)
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`38. At some later point in time, a mobile device may seek to determine its
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`own location. When the mobile station establishes a call, it connects to a base
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`station, and sends cellular reference data, as a measurement report. (3:27-33.) The
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`neural network accesses the data from the measurement report, and applies its
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`weightings to solve patterns in the report and to estimate a location of the mobile
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`device. (3:45-4:2.)
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`D. U.S. Patent No. 5,936,572 to Loomis et al. (“Loomis”)
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`39. Loomis discloses a hybrid location system for locating a mobile or
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`portable device that uses two or more location determination (“LD”) systems
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`embodied in the mobile device. (See, e.g., 4:39-5:13.) One location determination
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`system, which Loomis calls the “outdoor LD system,” may be “a GPS, GLONASS
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`or other satellite-based positioning system (SATPS) or a ground-based system such
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`as Loran, Omega, Tacan, Decca, JTIDS Relnav or PLRS.” The other location
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`determination system, which Loomis calls the “radio LD system,” uses analysis of
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`radio signals transmitted between terrestrial transmitter and the mobile device to
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`determine the location of the mobile device. (See, e.g., Loomis at Abstract, 4:39-
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`5:13; and Figs. 1-3, 6, 8, 9.)
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`40.
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`In the Loomis system, the location determination processing can be
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`done at the mobile device or, alternatively, the wireless signal measurements
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`received at the mobile device can be transmitted to a central processing station,
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`which uses the signals to determine the mobile station location, including at
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`different time intervals. (See, e.g., 8:26-42.) Further, the Loomis system can use
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`threshold error and accuracy indicators to select which location determination from
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`the multiple systems it will use to determine the location estimate. (See, e.g.,
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`12:47-58). The Loomis system can also combine measurements from the different
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`location determination systems using, for example, a Kalman filter to determine a
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`location estimate. (See, e.g., 15:39-46).
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`E. U.S. Patent No. 5,418,843 to Stjernholm (“Stjernholm”)
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`41. Stjernholm discloses a method for estimating traffic density in a
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`mobile telephone network by compiling mobile station signal measurements at
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`multiple locations, and storing each signal measurement with its associated
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`location. (See, e.g., Abstract, 1:28-49.) A position of an individual mobile station
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`is then estimated by, first, training a pattern-recognizing neural network using the
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`previously-stored pairs of signal measurements and locations. (See, e.g., 2:29-35.)
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`Then, signal from the mobile station to be located is measured, and the location of
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`the mobile station is generated from the measurements with the aid of the trained
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`neural network. (See, e.g., 2:36-57.)
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`F. Obviousness of Claims 1-4, 17-19, 60, 61, 67, 72, and 76 Based on
`Bruno and Geier
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`42.
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`It would have been obvious to a person of ordinary skill in the art to
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`combine the disclosures of weighting various estimates and showing an error
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`ellipse in Geier with the hybrid system of Bruno. Geier’s weighting technique
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`increases accuracy of a location estimate (Geier, 4:31-35), and the error ellipses
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`have the advantage of “rapidly convey[ing] statistical information to users about
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`the quality of the position information being viewed.” (Id, 2:32-35.) Similarly,
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`Bruno discloses a hybrid approach to increase the accuracy of location detection
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`techniques. (Bruno, 3:52-56, 10:8-11.) Therefore, it would have been obvious to a
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`person of ordinary skill to modify Bruno in view of Geier to improve the accuracy
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`of a location estimate, and to allow a user to quickly and easily understand the
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`level of accuracy of a location estimate. A person of ordinary skill in the art would
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`further understand that both systems take measures to increase the accuracy of the
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`location estimate, and thus it would have been obvious to improve the Bruno
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`system by further including the weighting technique and error ellipses from Geier.
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`This is the simple use of a known technique to improve a similar system in the
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`same way and achieve predictable results.
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`43. Moreover, both Bruno and Geier are in the same field. They both
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`relate to location detection by combining multiple techniques. Geier’s technique
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`of weighting multiple measurements of GPS signals would be readily applicable to
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`Bruno, because Bruno employs a GPS back-end for estimating a location based on
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`either GPS-like measurements on a cellular frequency, or actual GPS
`
`measurements as transmitted directly from GPS satellites; applying a weight to the
`
`measurements of GPS or GPS like signals would have been obvious. (Bruno, 9:2-
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`8.) Thus, although Geier is directed to ship-based applications, its technique of
`
`weighting and combining location estimates can be used by Bruno’s system.
`
`Therefore, the combination of Bruno with Geier would have been obvious to a
`
`person of ordinary skill, and would have yielded predictable results.
`
`G. Obviousness of Claims 6, 24, 25, 47, 50, 54, 62, and 69 Based on
`Bruno, Geier, and Olsson.
`
`44.
`
`It would have been obvious to a person of ordinary skill to add the
`
`neural network and pattern recognition of Olsson to Bruno, as modified by Geier.
`
`Bruno discusses employing a hybrid approach by “supplementing” and
`
`“augment[ing]” GPS solutions to increase the accuracy of location determination.
`
`(Bruno, 3:52-56, 10:8-11.) Using the neural network and pattern matching features
`
`of Olsson as one of the hybrid techniques of Bruno would allow for increased
`
`
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`17
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`Apple Inc. Exhibit 1002 Page 18
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`accuracy for Bruno’s system. (Olsson, 1:61-67) Thus, it would have been obvious
`
`to one of ordinary skill in the art to combine Olsson’s neural network and pattern
`
`recognition with Bruno’s hybrid approach to further improve accuracy. Doing so
`
`is simply use of a known technique to improve a similar system in the same way,
`
`as well as applying a known technique to a known system ready for improvement
`
`to yield predictable results.
`
`H. Obviousness of Claims 1-4, 6, 17-19, 47, 50, 54, 60-62, 67, 69, 72,
`and 76 Based on Loomis
`
`45. Loomis discloses each element of claims 1-4, 6, 17-19, 47, 50, 54, 60-
`
`62, 67, 69, 72, and 76 of the ’327 patent, as set forth in the claim charts in the
`
`Petition. However, the claim recitations are lengthy and include specifics of
`
`various location techniques that Bruno does not explicitly disclose. It is my
`
`opinion that one of ordinary skill in the art would be very familiar with the
`
`techniques recited in these claims, and that Loomis renders each of the claims
`
`obvious when considered with the knowledge of one of ordinary skill in the art.
`
`One of ordinary skill in the art would immediately recognize that the claims of the
`
`’327 patent are directed to commonly known techniques. For some limitations that
`
`are not present in Loomis, it would be obvious to modify and/or supplement
`
`Loomis, as set forth in the remainder of this section.
`
`46. Claim 1 recites “locating communication devices in a plurality of
`
`geographically spaced apart locations.” To the extent that term is understood to
`
`
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`18
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`mean simply that the communication device can be located in various different
`
`locations, it would have been obvious to one of ordinary skill in the art that mobile
`
`communication devices by definition are mobile and can be located at various
`
`different locations.
`
`47. Further, it would have been obvious to one of ordinary skill in the art
`
`that Loomis discloses use of three or more location determination techniques. In
`
`particular, Loomis explicitly states that it provides a system for location
`
`determination that combines “two or more” location determination techniques.
`
`(See, e.g., 4:39-42.) In addition to the traditional GPS technique (the “outdoor LD
`
`unit” and the TDOA technique using terrestrial wireless signals (the “indoor LD
`
`unit,” as discussed above, Loomis also discloses a hybrid technique that
`
`determinates “displacement coordinates” by comparing the differences in radio
`
`signal phase information as received by the “outdoor LD system” and by the “radio
`
`LD system.” (See, e.g., 16:4-23.) It would have been obvious to one of ordinary
`
`skill in the art that determination of such “displacement coordinates” is a third
`
`technique of location determination that is distinct from the GPS location
`
`technique and TDOA location technique.
`
`48. Additionally, Loomis discusses use of a variety of other location
`
`techniques for determining the location of mobile devices. (See, e.g., 18:33-36;
`
`18:53-55.) It would have been obvious to one of ordinary skill in the art to have
`
`
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`19
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`incorporated these additional location techniques in the system of Loomis, as one
`
`of ordinary skill in the art would have understood that different location techniques
`
`offer different advantages in different situations. Further, one of ordinary skill in
`
`the art would have understood that use of multiple techniques would, for example,
`
`improve accuracy and add versatility and redundancy to a location system in
`
`situations where one or more of the other location techniques should become
`
`unavailable. Finally, including additional location techniques in Loomis is simply
`
`the combining of prior art elements according to known methods to yield
`
`predictable results, as well as the use of a known technique to improve a similar
`
`system in the same way.
`
`49. Loomis discloses using an estimated overall inaccuracy indicator that
`
`is representative of a “position dilution of precision.” (20:53-55.) It would have
`
`been obvious to one of ordinary skill in the art that an accuracy indicator, as
`
`disclosed by Loomis, necessarily represents a likelihood that a communication
`
`device is within a particular geographic location or extent.
`
`I.
`
`Obviousness of Claims 6, 24, and 25 Based on Loomis and
`Stjernholm
`
`50. Claims 6, 24, and 25 of the ’327 patent would have been obvious to
`
`one of ordinary skill in the art based on Loomis in view of Stjernholm. In
`
`particular, it would have been obvious to one of ordinary skill in the art to include
`
`the pattern-recognition location technique from Stjernholm as one of the multiple
`
`
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`20
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`Apple Inc. Exhibit 1002 Page 21
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`Inter Partes Review of USP 7,298,327
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`location techniques used in Loomis. Given Loomis’s teaching of using multiple
`
`location technique, and further teaching that various known location techniques
`
`may be substituted into the disclosed system (see 18:33-36; 18:53-55), substituting
`
`Stj ernholm’s pattern—recognition location technique for one of the techniques in
`
`Loomis’s system is merely a combination of familiar elements according to known
`
`methods which yields predictable results.
`
`*>I<*
`
`I declare that all statements made herein of my own knowledge are true and
`
`that all statements made on information and belief are believed to be true, and that
`
`these statements were made with knowledge that willful false statements and the
`
`like so made are punishable by fine or imprisonment, or both, under section 1001
`
`of Title 18 of the United States Code.
`
`Dated: August 12, 2015 .
`
`Kevin S. Judge
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`21
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`Apple Inc.
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`Exhibit 1002
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`Page 22
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`Apple Inc. Exhibit 1002 Page 22
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`Kevin S. Judge
`
`4028 Via Gavilan
`
`Palos Verdes Estates, CA 90274
`
`(310) 850-5936 - kjudge@judgesoftwaresystems.com
`
`Kevin S. Judge
`• Over twentyfive years experience in systems design, management and implementation of
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`wireless location systems.
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`• Over ten years experience architecting, managing and implementing software systems in a
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`variety of fields and languages including C, C++, Java, and Ruby.
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`• Holder of multiple patents in positioning and wireless technologies.
`
`
`
`Judge Software Systems (1999 – Present)
`Professional Experience
`Confidential
`
`
`
`
`
`2011-2015
`
`North America
`
`Designed and implemented a GNSS phase differential heading sensor. Dual GNSS receivers
`
`are used to provide phase measurements for GPS and GLONASS satellites. The system
`
`integrated a magnetometer, gyro and accelerometer to provide continuous location, speed and
`
`heading information. Managed the entire system development and was the primary design
`
`and implementation engineer for the real-time embedded software.
`
`2012-2014
`
`Broadcom
`
`
`
`
`
`
`
`
`
`
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`
`
`Irvine, CA
`
`Represent Broadcom in the Indoor
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