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`Apple, Inc. Exhibit 1027 Page 1
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`Apple, Inc. Exhibit 1027 Page 1
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`In this case, TracBeam asserts two patents: U.S. Patent Nos. 7,764,231 (“Wireless
`Location Using Multiple Mobile Station Location Techniques”) and 7,525,484
`(“Gateway and Hybrid Solutions for Wireless Location”). The ‘484 patent issued
`first, on April 28, 2009, but was filed as a continuation of the ‘231 patent, which
`issued on July 27, 2010. Both patents claim their earliest priority to a September 9,
`1996 provisional application.
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`Generally, the patents disclose systems and methods of locating “mobile
`stations” (such as cell phones) using a plurality of location techniques (e.g., GPS or
`cell sector ID) and outputting reliable and accurate location estimates to the
`requesting sources (e.g., location based applications) according to specified criteria
`(e.g., the granularity of the location estimate).
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`Because it was the earlier filed patent, we cite to the ‘231 specification.
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`Apple, Inc. Exhibit 1027 Page 2
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`The patents disclose many innova4ve concepts and the claims use those concepts in
`different ways. There is no one claim that includes all of the concepts of the patents. We
`use claim 27 of the ‘484 patent to introduce some of the concepts and the terminology
`used by the patents.
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`Apple, Inc. Exhibit 1027 Page 3
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`The preamble explains that the claimed method is for loca4ng mobile sta4ons at unknown
`terrestrial loca4ons. Examples of where this method might be used would for the e911
`system (to locate a cell phone that is placing a 911 call), for naviga4on and direc4ons, or to
`locate family members.
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`Apple, Inc. Exhibit 1027 Page 4
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`Each asserted claim uses the term “mobile station.” In many asserted claims
`(but not ‘484 claim 27), an “M” abbreviation is also used to represent “each”
`mobile station of the entire set of mobile stations disclosed, or each mobile
`station of a subset of mobile stations.
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`Apple, Inc. Exhibit 1027 Page 5
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`In a moment, we will turn to step [1] of the claim. But first we introduce the diagram we
`use to depict Claim 27.
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`Apple, Inc. Exhibit 1027 Page 6
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`We will use a block diagram to depict components that are found in claim 27 and that
`interact with the system that performs the method of claim 27. We will start with a yellow
`block in the middle of the diagram. This block represents the system used to perform the
`claimed method. As will be seen, the other blocks that surround this system block iden4fy
`components the system will receive informa4on from or transmit informa4on to.
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`Apple, Inc. Exhibit 1027 Page 7
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`Turning to step [1] of the claim, the system receives an “input request.” This is indicated
`by the green arrow on the leV. The input request comes from a “loca4on reques4ng
`source.”
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`Apple, Inc. Exhibit 1027 Page 8
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`Examples of “loca4on reques4ng sources” include loca4on based applications, such as
`the e911, “Parent/Child Location,” and “Where Am I Applications” listed as “Location
`Applications 146” in Figure 8(4). Such applications might be running on a cell
`phone handset, a network server, or a desktop or portable computer.
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`Apple, Inc. Exhibit 1027 Page 9
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`The input request will relate to the loca4on for a “mobile sta4on” such as the mobile
`phone depicted above.
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`Apple, Inc. Exhibit 1027 Page 10
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`The system also receives requests from other loca4on reques4ng sources, such as the one
`depicted on the right side of the diagram above.
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`Apple, Inc. Exhibit 1027 Page 11
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`Step [1] also states that for each input request there is a “corresponding des4na4on for a
`responsive output,” as depicted in the diagram. This des4na4on may be the loca4on
`reques4ng source itself or the des4na4on may be elsewhere, as depicted above.
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`Apple, Inc. Exhibit 1027 Page 12
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`As an example, the des4na4on might be an e911 facility, an applica4on running on a cell
`phone handset, a network loca4on applica4on server, or a personal computer or laptop.
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`Apple, Inc. Exhibit 1027 Page 13
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`We now turn to step [2]. This step includes providing one or more loca4on requests to one
`or more loca4on determining sources. As depicted on the diagram, these sources will
`include one or more loca4on compu4ng modules. (Note that while the “loca4on request”
`may originate with the loca4on reques4ng source – e.g. as part of the “input request” from
`the loca4on reques4ng source – step [2] of the claim requires that the system perform the
`step of “providing” that loca4on request to a loca4on determining source).
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`In prac4ce, the loca4on determining source (and its loca4on compu4ng module) might be
`a chip (integrated circuit) on a cellphone handset that collects informa4on from satellite
`signals or terrestrial signals, or an applica4on running on a cell phone, network server, or
`other computa4onal machinery.
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`Apple, Inc. Exhibit 1027 Page 14
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`As we just men4oned, Claim 27 uses the phrase “loca4on determining sources” and (later)
`“loca4on compu4ng module.” Other claims use phrases such as “computa4onal
`machinery” or “computa4onal equipment” to iden4fy hardware that performs relevant
`loca4on compu4ng.
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`Apple, Inc. Exhibit 1027 Page 15
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`The term “computational machinery” was described during the prosecution as
`follows:
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`“the terms ‘computational equipment’ and ‘computational machinery’ added to the
`claims refer to (or include) one or more particularly configured computational
`machines such as: one or more particularly programmed computers, and/or one or
`more hardware devices having access to instructions (e.g., via software, firmware,
`or otherwise) for performing the functions and algorithms disclosed in the claims
`and the specification.” Exh. 4 to TracBeam’s Amended Opening Brief (AVer-‐
`allowance Amendment (March 15, 2010) in ‘231 prosecu4on) at TB2361.
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`Apple, Inc. Exhibit 1027 Page 16
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`Depending on the claim and the context, the computational machinery may
`reside in the mobile station (e.g. a mobile handset), a networked server, a
`laptop computer, a desktop computer, or any of the above.
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`Apple, Inc. Exhibit 1027 Page 17
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`Next we turn to step [3]. Step [3] relates to “loca4on informa4on” that is received from a
`source as depicted on the diagram.
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`Apple, Inc. Exhibit 1027 Page 18
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`The claims of the patent use the phrase “location information, “ or “location related
`information,” or “location related response information” to refer to information
`related to a location, but not necessarily information that describes a particular
`geographical location. By contrast, the claims use more specific terms when
`referring to particular geographical location, such as “representation of a
`geographical location.”
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`An example of “location information” might be data including the time that a satellite
`message was received by a GPS receiver installed in a cell phone, the time that the
`message was transmitted by the satellite, and the position of the satellite at the time
`of transition. This data is “location information” because the data is related to the
`location of the cell phone (the “mobile station”), and can be used (along with other
`information) in calculating a geographical location for the cell phone.
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`Apple, Inc. Exhibit 1027 Page 19
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`Another example of “location information” could be time or distance data from
`signals from cell towers.
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`Apple, Inc. Exhibit 1027 Page 20
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`Another example of location information would be the coordinates of cell antennae
`serving the cell phone.
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`Apple, Inc. Exhibit 1027 Page 21
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`Regarding the “loca4on compu4ng module,” this structure may be located within the
`mobile sta4on or at some distant loca4on, such as on a network server. For example,
`depicted above is a loca4on compu4ng module that is providing loca4on informa4on
`based on GPS wireless loca4on techniques. The module may be located inside of the cell
`phone or it may be located on a network server, in which case it will receive signals data
`that is transmiced from the cell phone and thereaVer make computa4ons.
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`Apple, Inc. Exhibit 1027 Page 22
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`Now we turn to step [4]. This step is a determina4on made by the system as to what data
`to output to the specific “corresponding des4na4on.”
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`Apple, Inc. Exhibit 1027 Page 23
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`This step requires that the output will include a representa4on iden4fying a geographical
`loca4on. An example of such a representa4on might be a street address, la4tude and
`longitude coordinates, or a depic4on of a loca4on or area on a map.
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`Apple, Inc. Exhibit 1027 Page 24
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`In this step, the system determines this geographical representa4on using “loca4on
`informa4on” provided by one or more sources.
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`For example, the loca4on informa4on from one source might be 4me and ephemeris data
`determined by a GPS receiver chip on a mobile phone. From another source, it might be
`4me and distance data based on signals from a terrestrial sta4on. Or it might be a specific
`address or set of map coordinates. Or, one loca4on determining source might report that
`no determina4on is available, requiring the system to rely upon loca4on informa4on
`provided by the alternate.
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`The system uses such “loca4on informa4on” to determine “output loca4on data” that will
`include a geographical representa4on of a loca4on (depic4on on a map, longitude and
`la4tude, address, etc.) for the first mobile sta4on.
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`Apple, Inc. Exhibit 1027 Page 25
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`This step also requires that when the system determines what the output data should be,
`the system should do so according to an “output criteria.” Several claims of the patents
`include examples of output criteria. For example, claim 61 of the ‘484 patent describes “a
`transmission protocol” that is to be used as one example of output criteria.
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`Apple, Inc. Exhibit 1027 Page 26
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`Another example of output criteria is a “granularity” by which a loca4on es4mate is to be
`provided. For example, the criteria may require specifying the degree of accuracy, such as
`within 50 meters.
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`Apple, Inc. Exhibit 1027 Page 27
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`Another output criteria might be the frequency (or minimum or maximum 4me interval)
`with which loca4on es4mates are to be reported.
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`Apple, Inc. Exhibit 1027 Page 28
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`Next we turn to step [5]. The first part of this step is analogous to step [3], except that this
`is done for a second request and a second mobile sta4on. In this step, the system receives
`at least one instance of loca4on informa4on related to the second mobile sta4on
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`Apple, Inc. Exhibit 1027 Page 29
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`Step [5] includes a “wherein” clause that requires that the techniques for determining the
`loca4on informa4on make use of “the signal measurements,” which the preamble
`iden4fies as being from terrestrial sta4ons. In other words, while the first loca4on
`informa4on may make use of either satellite or terrestrial signals, the second loca4on
`informa4on does not use satellite signal measurements.
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`Apple, Inc. Exhibit 1027 Page 30
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`In addition to the structures recited by ‘484 claim 27, the asserted claims recite that
`the mobile stations communicate with (for example) one or more of the following
`structures: “communication stations” (‘231 claims 1, 7, 10, 36, 67, and 106)),
`“communication stations at terrestrial locations” (‘231 claim 36), “terrestrial
`communication stations” (‘231 claims 1, 36), “terrestrial stations” (‘484 claim 51),
`“communication stations supported on the Earth” (‘231, claim 162), “terrestrially
`based stationary location communication stations” (‘231 claim 185), “transmitting
`stations above and not supported on the Earth’s surface” (‘231 claim 185), “non-
`terrestrial wireless transmitters, not supported on the Earth’s station” (‘231 claim 1).
`These structures generally fall into one of two categories: (1) those that are
`terrestrial (located on or supported by the Earth) and (2) those that are not (such as
`space satellites).
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`Apple, Inc. Exhibit 1027 Page 31
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`Step [5] of Claim 27 also includes a second “wherein” clause. This clause specifies that the
`second loca4on informa4on is determined without using at least one of the loca4on
`compu4ng modules that is used to determine the first loca4on informa4on. In effect, this
`wherein clause means that the process used to obtain the first loca4on informa4on will
`differ in some way from the process used to determine the second loca4on informa4on.
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`Apple, Inc. Exhibit 1027 Page 32
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`Next we turn to step [6]. This step is analogous to step [4], except that it is done for the
`second request that is related to the second mobile sta4on. In this step, the system uses
`loca4on informa4on to determine what data will be output, and the output will include a
`geographical loca4on for the second mobile sta4on.
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`Apple, Inc. Exhibit 1027 Page 33
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`AVer step [6], there is an addi4onal wherein clause. This wherein clause relates to the
`output criteria discussed earlier. In effect this wherein clause requires that not all output
`criteria will be the same all the 4me for every request.
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`Apple, Inc. Exhibit 1027 Page 34
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`We now turn to the two final steps, [7] and [8]. These two steps include transmidng the
`first output loca4on data to its des4na4on, and the second output loca4on data to its
`loca4on. We use the red arrows at the top of the slide to point to the relevant por4ons of
`the diagram.
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`Apple, Inc. Exhibit 1027 Page 35
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`That concludes our overview of claim 27.
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`36
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`Apple, Inc. Exhibit 1027 Page 36
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`37
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`Apple, Inc. Exhibit 1027 Page 37
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