UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`TRACBEAM, LLC,
`Patent Owner.
`
`Patent No. 7,525,484
`
`
`Inter Partes Review No. _____________
`
`
`PETITION FOR INTER PARTES REVIEW
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`UNDER 35 U.S.C. §§ 311-319 AND 37 C.F.R. § 42.100 ET SEQ.
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`Inter Partes Review of USP 7,525,484
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`Docket No. 106840000509
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`TABLE OF CONTENTS
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`I.  NOTICES AND STATEMENTS ...................................................................... 1 
`
`II. 
`
`INTRODUCTION ............................................................................................. 2 
`
`III.  DEVELOPMENT OF POSITION LOCATION TECHNOLOGY FOR
`CELLPHONES .................................................................................................. 3 
`
`IV.  THE ’484 PATENT ........................................................................................... 5 
`
`V.  CLAIM CONSTRUCTION............................................................................. 10 
`
`VI.  IDENTIFICATION OF CHALLENGE .......................................................... 12 
`
`A.  Statutory Ground for The Challenged Claims ......................................... 12 
`
`B.  Ground 1 – Obviousness of Claims 25, 26, 27, 31, 36, 37, 39, 40, 49, 51,
`56, 57, 60, 61, and 72 Based on Bruno ................................................... 13 
`
`C.  Ground 2 – Obviousness of Challenged Claims 38, 45, 50, and 63 Based
`on Bruno and LeBlanc ............................................................................. 26 
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`D.  Ground 3 – Obviousness of Claims 25-27, 31, 37-40, 49, 51, 57, 60-61,
`63, and 72 Based on Loomis ................................................................... 32 
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`E.  Ground 4 – Obviousness of Claims 38, 45, and 50 Based on Loomis in
`View of LeBlanc ...................................................................................... 47 
`
`F.  Ground 5 – Obviousness of Claim 56 Based on Loomis in View of
`Yokouchi ................................................................................................. 50 
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`VII.  CONCLUSION ................................................................................................ 51 
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`Inter Partes Review of USP 7,525,484
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`Docket No. 106840000509
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`Exhibit List for Inter Partes Review of U.S. Patent No. 7,525,484
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`Exhibit Description
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`Exhibit #
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`U.S. Patent No. 7,525,484 to Dupray et al. [referenced as “the ’484
`patent”]
`
`Declaration of Kevin S. Judge [referenced as “Judge Decl.”]
`(includes Mr. Judge’s CV as Appendix A thereto)
`
`PCT Application No. PCT/US97/15892, published on March 12, 1998
`as PCT Publication No. WO 98/10307 [referenced as “PCT ’307”]
`
`February 20, 2002 “Preliminary Amendment” in prosecution of the
`’484 patent
`*Note: this is a partial copy (missing pages 91-133) that is attached
`to a March 22, 2006 “Response to Office Action Dated February 8,
`2006” (and this exhibit contains these documents as they appear in
`the publicly available file history for the ’484 patent on PAIR, which
`is incomplete in many regards)
`
`Rappaport et al., “Position Location Using Wireless Communications
`on Highways of the Future,” IEEE Communications Magazine, pp.
`33-41 (Oct. 1996) [referenced as “Rappaport”]
`
`Krizman et al., “Wireless Position Location: Fundamentals,
`Implementation Strategies, and Sources of Error,” IEEE Vehicular
`Technology Conf., Phoenix, AZ (May 5-7, 1997) [referenced as
`“Krizman”]
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`U.S. Patent No. 5,604,765 to Bruno et al. [referenced as “Bruno”]
`
`U.S. Patent No. 5,936,572 to Loomis et al. [referenced as “Loomis”]
`
`U.S. Patent No. 5,602,903 to LeBlanc et al. [referenced as
`“LeBlanc”]
`
`1001
`
`1002
`
`1003
`
`1004
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`1005
`
`1006
`
`1007
`(prior art)
`
`1008
`(prior art)
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`1009
`(prior art)
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`U.S. Patent No. 4,903,212 to Yokouchi et al. [referenced as
`“Yokouchi”]
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`Docket No. 106840000509
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`1010
`(prior art)
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`Inter Partes Review of USP 7,525,484
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`Docket No. 106840000509
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`Petitioner Apple Inc. (“Petitioner”) respectfully petitions for inter partes
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`review of claims 25-27, 31, 36-40, 45, 49-51, 56-57, 60-61, 63 and 72 of U.S.
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`Patent No. 7,525,484 (“the ’484 patent” (Ex. 1001)) in accordance with 35 U.S.C.
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`§§ 311-319 and 37 C.F.R. § 42.100 et seq.
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`I.
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`NOTICES AND STATEMENTS
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`Pursuant to 37 C.F.R. § 42.8(b)(1), Apple Inc. is the real party-in-interest.
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`Pursuant to 37 C.F.R. § 42.8(b)(2), Petitioner identifies the following related
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`matters in which the ’484 patent is asserted: TracBeam, LLC v. Apple Inc., Case
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`No. 6:14-cv-680 (E.D. Tex.) (“the Apple case”) and TracBeam, LLC v. T-Mobile
`
`US, Inc., et al., Case No. 6:14-cv-678 (E.D. Tex.), both pending. The ’484 patent
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`was previously asserted in TracBeam, LLC v. AT&T, Inc. et al., Case No. 6:11-cv-
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`96 (E.D. Tex.) and TracBeam, LLC v. Google, Inc., Case No. 6:13-cv-93 (E.D.
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`Tex.), both dismissed. Petitioner is concurrently filing an additional petition for
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`inter partes review of the ’484 patent on separate grounds, as well as petitions on
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`the other patents asserted in the Apple case—U.S. Patent Nos. 7,764,231 (“the ’231
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`patent”), 7,298,327 (“the ’327 patent”), and 8,032,153 (“the ’153 patent”). On
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`August 11, 2015, T-Mobile US, Inc., T-Mobile USA, Inc., TeleCommunication
`
`Systems, Inc., Ericsson Inc., and Telefonaktiebolaget LM Ericsson filed three
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`petitions for inter partes review of the ’484 patent that have been assigned case
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`numbers IPR2015-01708, -01709, and -01711.
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`Docket No. 106840000509
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`Pursuant to 37 C.F.R. § 42.8(b)(3), Petitioner identifies the following
`
`counsel (and a power of attorney accompanies this Petition):
`
`Lead Counsel
`David L. Fehrman
`dfehrman@mofo.com
`Registration No.: 28,600
`MORRISON & FOERSTER LLP
`707 Wilshire Blvd., Suite 6000
`Los Angeles, CA 90017-3543
`Tel: (213) 892-5601
`Fax: (213) 892-5454
`
`Backup Counsel
`Martin M. Noonen
`mnoonen@mofo.com
`Registration No.: 44,264
`MORRISON & FOERSTER LLP
`707 Wilshire Blvd., Suite 6000
`Los Angeles, CA 90017-3543
`Tel: (213) 892-5764
`Fax: (213) 892-5454
`
`Pursuant to 37 C.F.R. § 42.8(b)(4), service information for lead and back-up
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`counsel is provided above. Petitioner consents to electronic service by email to
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`10684-TracBeam-IPR@mofo.com.
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`Pursuant to 37 C.F.R. § 42.104(a), Petitioner certifies that the ’484 patent is
`
`available for inter partes review and that Petitioner is not barred or estopped from
`
`requesting an inter partes review challenging the patent claims on the grounds
`
`identified in this Petition. Petitioner is the only defendant in the above-referenced
`
`Apple case, and was first served with a Complaint alleging infringement of the
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`’484 patent on August 12, 2014.
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`II.
`
`INTRODUCTION
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`The ’484 patent is directed to location determination for cellular phones. It
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`issued on April 28, 2009 from Appl. No. 09/770,838 (“’838 application”), which
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`was filed on January 26, 2001. The ’484 patent is a continuation of Appl. No.
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`09/194,367 (“’367 application”), filed on November 24, 1998 as the National Stage
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`of Int’l Appl. No. PCT/US97/15892 (“PCT ’892 application”), which was filed on
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`September 8, 1997, and later published as WO 98/10307 (“PCT ’307”; Ex. 1003).
`
`Through its parent application, the ’484 patent claims priority to the filing of three
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`provisional applications, the earliest of which was filed on September 9, 1996.
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`Section III of this Petition discusses the background and development of
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`position location technology for cellular telephones; as explained herein, the ’484
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`patent claims well-known techniques in the art of navigation for performing
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`location determination and is unpatentable as obvious in view of the prior art.
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`Section IV summarizes the ’484 patent, while Section V discusses claim
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`construction. Section VI sets forth the detailed grounds for unpatentability in view
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`of certain prior art (Exs. 1007-1010). This showing is accompanied by the
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`Declaration of Kevin S. Judge (“Judge Decl.”; Ex. 1002). Accordingly, Petitioner
`
`respectfully requests a Decision to institute inter partes review.
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`III. DEVELOPMENT OF POSITION LOCATION TECHNOLOGY FOR
`CELLPHONES
`
`Prior to the ’484 patent, a number of different position location technologies
`
`already existed. An overview of some of these technologies is provided in
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`Rappaport et al., “Position Location Using Wireless Communications on Highways
`
`of the Future,” IEEE Communications Magazine, pp. 33-41 (Oct. 1996) (Ex.
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`1005). The technologies described in Rappaport include (1) Global Positioning
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`System (“GPS”) using time-of-arrival measurement of signals received from plural
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`satellites, (2) Signpost Navigation using beacon transmitters, and (3) cellular
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`geolocation, which uses the existing cellular infrastructure and provides position
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`estimates of mobile units as they transmit over standard frequencies. (Id. at 34.)
`
`According to the Rappaport article, “[g]eolocation offers some advantages to
`
`GPS since it concentrates cost at each base station and allows position location to
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`be performed without the need of GPS at the mobile. Thus, standard cellular
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`phones, including handheld portables, may be tracked.” (Id.) Rappaport further
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`explained that position location systems may be either “unilateral” (in which a
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`mobile unit forms an estimate of its own position) or “multilateral” (in which an
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`estimate of the mobile location is based on a signal transmitted by the mobile unit
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`and received at multiple fixed base stations, and the position estimate is formed by
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`the network, rather than by the mobile unit itself). (See id. at 35.)
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`Location methods then included angle-of-arrival (“AOA”) and time-of-
`
`arrival (“TOA”) techniques, as well as combined (or hybrid) techniques. (See id.
`
`at 35-36.) Rappaport reiterated that cellular geolocation has advantages over GPS
`
`including compatibility with existing phones for E911, and noted that “[p]lacing
`
`the responsibility of position location at the base station alleviates the difficulties
`
`of integrating GPS in the handheld subscriber unit.” (Id. at 39.)
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`Additional background regarding wireless position location technology is
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`provided
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`in Krizman et al., “Wireless Position Location: Fundamentals,
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`Implementation Strategies, and Sources of Error,” IEEE Vehicular Technology
`
`Conf., Phoenix, AZ (May 5-7, 1997) (Ex. 1006). Krizman reviewed basic position
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`location techniques then feasible for cellular wireless system providers. The
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`described methods in Krizman included beacon location techniques, direction-
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`finding techniques, and time-difference-of-arrival (“TDOA”) techniques.
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`IV. THE ’484 PATENT
`The ’484 patent discloses a network-based location system employing
`
`cellular geolocation. As stated in the “Summary of the Invention,” an objective is
`
`to accurately locate people and/or objects in a cost-effective manner and to:
`
`provide such location capabilities using the measurements from
`wireless signals communicated between mobile stations and a network
`of base stations, wherein the same communication standard or
`protocol is utilized for location as is used by the network of base
`stations for providing wireless communications with mobile stations
`for other purposes such as voice communication[.]
`
`(’484 (Ex. 1001) at 7:66-8:9.) Related objectives are listed in the Summary at
`
`sections (1.1)-(1.6) and include, inter alia, providing a system requiring few if any
`
`modifications to a typical telephony infrastructure which can use the native
`
`electronics of commercially available telephony wireless mobile stations (e.g.,
`
`handsets) as location devices. (Id. at 8:13-33.) As set forth in the Summary at
`
`sections (2.1)-(2.6), another objective is to provide a location system that uses a
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`plurality of location techniques for increasing location accuracy. (Id. at 9:1-22.)
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`FIG. 4 of the ’484 patent (reproduced below) is an overview of a wireless
`
`location network architecture. In the below figure, mobile stations (“MS”) 140 are
`
`highlighted in yellow, and various different types of base stations (including
`
`infrastructure base stations 122, mobile base stations 148, and location base
`
`stations 152) are highlighted in pink. (See, e.g., ’484 at 24:36-25:17.)
`
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`This system includes “a location center 142 which is required for
`
`determining a location of a target MS 140 using signal characteristic values for this
`
`target MS” (id. at 25:8-10). The Location Center 142 interfaces with the mobile
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`switching center (“MSC”) 112 of the wireless network via a signal processing
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`system 1220, as shown below in FIG. 5 of the patent (where the mobile station 140
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`and various base stations are again respectively highlighted in yellow and pink):
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`In operation, the signal processing subsystem 1220 receives measurements
`
`from the MSC 112 of signals communicated between the MS 140 and base stations
`
`122 (BS), 148 (MBS), and 152 (LBS). (See, e.g., id. at 28:60-29:37.)
`
`The ’484 patent discloses a network-based system which uses measurements
`
`of signals transmitted between a mobile station to be located and base stations to
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`determine position location. In the patent, plural location estimates are obtained
`
`from such signals using different techniques. These techniques are referred to as
`
`location hypothesizing first order models (“FOMs”), shown at box 1224 in FIG. 5.
`
`The basic operation of the FOMs is outlined in (4.1)-(4.4) of the Summary
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`(’484 patent at 12:27-13:30). As noted at 12:55-58 of the patent, “the signal data
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`measurements are ensembles of samples from the wireless signals received from
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`the target MS by the base station infrastructure[.]” Those signal characteristic
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`values are provided to one or more MS hypothesizing “first order models” or
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`“location estimating models.” (Id. at 12:64-67.)
`
`First order models for providing initial position location estimates are
`
`described initially at 51:14-54:67 of the ’484 patent, and then in more detail at
`
`62:54-82:17. First order models include distance model FOMs (id. at 51:40-52:21;
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`62:58-64:22), statistically-based models using a “location signature” database of
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`verified wireless signal measurements of an MS at different locations (id. at 52:22-
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`40; 65:57-66:67), adaptive learning models such as an artificial neural net (id. at
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`52:41-58; 53:35-40; 67:1-74:62), a location base station model using low-cost base
`
`stations 152 (id. at 52:59-53:28; 65:17-56), a coverage area first order model (id. at
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`64:23-65:16), a mobile base station model generated from target MS location data
`
`received from the mobile base station 148 (id. at 53:29-32), and a distributed
`
`antenna model (id. at 53:41-62).
`
`With respect to the mobile base station first order model, the mobile base
`
`station location subsystem is described at 100:5-112:52 and in Appendix A to the
`
`’484 patent. After obtaining location estimates using the various first order
`
`models, the location estimates may be adjusted or modified, and a most likely MS
`
`location estimate is determined, as shown at box 1228 in FIG. 5 (see also ’484
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`patent at 13:12-30; 13:52-14:26; 55:3-57:12).
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`As noted above, the ’484 patent issued as a continuation of the PCT ’892
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`application, which was filed on September 8, 1997 and published as PCT ’307 (Ex.
`
`1003) on March 12, 1998. As filed, the parent application highlighted
`
`“fundamental problems” with the use of GPS in handsets (see Ex. 1003 at 2:10-
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`12). Notwithstanding this recognition, on February 20, 2002, the Applicants
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`submitted an amendment during the prosecution of the ’484 patent that introduced
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`substantial new matter to the specification that suddenly embraced GPS (see Ex.
`
`1004); the 51 pages of amendments to the specification (submitted about 4.5 years
`
`after the original parent application was filed) included the entirety of objectives
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`(1.7)-(1.9) (corresponding to 8:34-67 of the issued ’484 patent) and voluminous
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`additions to the “Summary Discussion” (such as the entirety of 10:35-12:18 of the
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`issued ’484 patent).1
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`1 The prosecution history of the ’484 patent and its parent application is detailed in
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`Petitioner’s concurrently filed Petition for Inter Partes Review of this same patent.
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`While Petitioner contends that the ’484 patent (and its related patents) are not
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`entitled to their claimed earlier priority dates, the prior art used in this Petition
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`predates the claimed September 9, 1996 date.
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`V. CLAIM CONSTRUCTION
`A claim of an unexpired patent is given the “broadest reasonable
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`construction in light of the specification” in inter partes review. See 37 C.F.R.
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`§ 42.100(b).2 Petitioner submits that the terms of the challenged claims of the ’484
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`patent should be accorded their broadest reasonable interpretation as understood by
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`one of ordinary skill in the art and consistent with the disclosure.
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`Within the challenged claims of the ’484 patent that are charted against the
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`prior art in Section VI below, numerous claim terms of similar wording appear to
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`be directed to the same meaning within the same context. Specifically, each of
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`“information
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`related
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`to
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`the
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`location,” “position
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`information,” “location
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`information,” “geographical information,” “location estimate,” “location data,”
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`“geographical approximation,” and “geographical location approximation” as
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`recited in the challenged claims should be similarly construed.
`
`The above-listed terms were added to different claims at different times via a
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`series of claim amendments filed throughout the prosecution of the ’484 patent
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`(whose file history runs over 2,200 pages) and its parent application (which
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`2 The “broadest reasonable construction” standard applies in this IPR proceeding,
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`but claim construction before the district court may differ, as the standards differ.
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`generated a file history of almost 3,000 pages).3 The written description of the
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`’484 patent does not support ascribing meanings to these similarly-themed terms
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`that are materially distinct from each other. Accordingly, as interpreted under the
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`“broadest reasonable construction” standard, these terms simply mean information
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`that pertains to location. (See Judge Decl., ¶ 25.)
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`Claims 36 and 61 of the ’484 patent recite the term “granularity” as a
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`criterion by which location estimate is to be provided or determined. Under the
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`“broadest reasonable construction” standard, “granularity” should be construed to
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`encompass precision in either location or time. (See Judge Decl., ¶ 26.)
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`Finally, each of the challenged claims contains recitations regarding the use
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`of more than one location technique or “evaluator” that uses input data of wireless
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`signal measurements to determine the position of a mobile station. While certain
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`claims (such as claims 39 and 72), recite the use of signals from non-terrestrial
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`transmitters (i.e., satellites) to determine the location of a mobile station, other
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`claims do not limit the location techniques to non-terrestrial sources. Under the
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`3 Because Petitioner is not relying on the prosecution for claim construction,
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`Petitioner is not submitting the voluminous file history of the ’484 patent or its
`
`parent as exhibits to this Petition (other than the published parent application (Ex.
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`1003) and the amendment referenced above in Section IV (Ex. 1004)).
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`“broadest reasonable construction” standard, such claim language encompasses
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`reception of satellite signals at the mobile station for purposes of location
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`determination.
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`VI.
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`IDENTIFICATION OF CHALLENGE
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`Pursuant
`
`to 37 C.F.R. § 42.104(b), Petitioner respectfully requests
`
`cancellation of claims 25-27, 31, 36-40, 45, 49-51, 56-57, 60-61, 63, and 72 of the
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`’484 patent based on the grounds of unpatentability set forth in this Petition. On
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`June 23, 2015, the above-identified claims were asserted by Patent Owner against
`
`Petitioner in the Apple case.
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`Statutory Ground for The Challenged Claims
`
`A.
`The statutory grounds for the challenge of each claim are set forth below:
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`Grounds based upon U.S. Patent No. 5,604,765 to Bruno (“Bruno”):
`
`Ground 1 – Obviousness under 35 U.S.C. § 103(a) of claims 25, 26, 27, 31, 36,
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`37, 39, 40, 49, 51, 56, 60, 61, and 72 based on U.S. Patent No
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`5,604,765 to Bruno et al.
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`Ground 2 – Obviousness under 35 U.S.C. § 103(a) of claims 38, 45, 50, 57,
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`and 63 based on Bruno in view of U.S. Patent No. 5,602,903 to
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`LeBlanc et al.
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`Grounds Based Upon U.S. Patent No. 5,936,572 to Loomis (“Loomis”):
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`Ground 3 – Obviousness under 35 U.S.C. § 103(a) of claims 25-27, 31, 36, 37,
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`39, 40, 49, 51, 57, 60-61, 63, and 72 based on U.S. Patent No.
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`5,936,572 to Loomis et al.
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`Ground 4 – Obviousness under 35 U.S.C. § 103(a) of claims 38, 45, and 50
`
`based on Loomis in view of LeBlanc
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`Ground 5 – Obviousness under 35 U.S.C. § 103(a) of claim 56 based on
`
`Loomis in view of U.S. Patent No. 4,903,212 to Yokouchi et al.
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`Set forth below is a discussion of how the claims are unpatentable under the
`
`statutory grounds raised (pre-AIA), including claim charts specifying where each
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`element of a challenged claim is met by the prior art. 37 C.F.R. § 42.104(b)(4).
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`The showing in these sections establishes a reasonable likelihood of prevailing as
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`to each ground of invalidity with respect to the challenged claims as to that ground.
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`This showing is accompanied by the Judge Declaration (Ex. 1002) as noted above.
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`B. Ground 1 – Obviousness of Claims 25, 26, 27, 31, 36, 37, 39, 40,
`49, 51, 56, 57, 60, 61, and 72 Based on Bruno
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`U.S. Patent No 5,604,765 to Bruno et al. (“Bruno”; Ex. 1007), entitled
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`“Position Enhanced Communication System Including System for Embedding CDMA
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`Navigation Beacons Under
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`the Communications Signals of a Wireless
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`Communication System,” issued from an application filed on December 23, 1994,
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`and qualifies as prior art to the ’484 patent under at least 35 U.S.C. § 102(e). Like
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`the ’484 patent, Bruno discloses combining multiple location-detection techniques
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`to determine the location of a mobile unit. The different techniques are
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`(1) measuring a distance from a mobile unit to three base stations using cellular
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`timing measurements to locate the mobile unit, (2) GPS, and (3) short distance RF
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`“Signposts.” (Ex. 1007 at 2:17-19, 4:1-36.) As shown in Fig. 9 of Bruno,
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`reproduced below, the three techniques can be combined to locate the mobile unit:
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`The mobile unit of Bruno 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 id. at 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. (Id. at 8:55-62, 9:2-14.)
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`Petitioner believes that Bruno discloses all elements of claims 25, 26, 27, 31,
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`36, 37, 39, 40, 49, 51, 56, 57, 60, 61, and 72 of the ’484 patent. However, in view
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`of the extremely lengthy claim limitations that set forth techniques that are well
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`known in the art, Petitioner relies on obviousness under 35 U.S.C. § 103 for all
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`claims, as Bruno does not explicitly disclose every specific detail of such
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`techniques.
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` For example, claim 39 describes GPS in terms of “signal
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`transmissions to the first mobile station from non-terrestrial transmitters above and
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`not supported on the Earth’s surface.” Although Bruno discloses GPS, it does not
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`describe in detail the well-known techniques for implementing GPS as recited in
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`the claims. One of ordinary skill in the art would have recognized that the
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`recitations are directed to commonly known techniques. (See Judge Decl., ¶ 41.)
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`Thus, to the extent that Patent Owner attempts to distinguish over Bruno using
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`claimed techniques that were well-known in the art, these techniques would have
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`been obvious.
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`Moreover, claims 27, 31, and 36, as discussed below, would have been
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`obvious in view of Bruno standing alone. These claims recite output criteria,
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`including a frequency of providing a location estimate depending on the output
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`application. Bruno discloses the provision of various output applications, such as
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`E-911 services, roadside assistance services, fleet management services, theft
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`recovery, etc. (See Ex. 1007 at 1:15-23, 1:33-34, 9:57-10:6.) It would have been
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`obvious to a person of ordinary skill to provide location estimates at a given
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`frequency depending on the application. (See Judge Decl., ¶ 42.) For example,
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`certain applications, like roadside assistance, need infrequent updating, because an
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`operator with a disabled vehicle is unlikely to move. (Id.) Less frequent updating
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`of a roadside assistance application would satisfy the application and require less
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`processing power. (See Judge Decl., ¶ 43.) In contrast, in other applications, such
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`as fleet management, there would be a greater need for frequent updating, because
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`delivery vehicles are often on the move. (Id.) Therefore, claims 27, 31, and 36 are
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`obvious in view of Bruno alone.
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`The below claim chart shows where the elements of claims 25, 26, 27, 31,
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`36, 37, 39, 40, 49, 51, 56, 57, 60, 61, and 72 are disclosed in Bruno:
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`Challenged Claim of ’484 Patent
`25. A method for estimating, for each mobile
`station M of a plurality of mobile stations, an
`unknown terrestrial location (LM) for M using
`wireless signal measurements obtained via
`transmissions between said mobile station M
`and a plurality of fixed location terrestrial
`communication stations, wherein each of said
`communications stations is substantially co-
`located with one or more of a transmitter and a
`receiver for wirelessly communicating with
`said mobile station M, comprising:
`initiating a plurality of requests for information
`related to the location of said mobile station M,
`the requests provided to each of at least two
`mobile station location evaluators, wherein
`there is at least a first of the requests provided
`to a first of the location evaluators and a second
`of the requests, different from the first request,
`provided to a second of the location evaluators,
`such that when said location evaluators are
`supplied with corresponding input data having
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`Prior Art Disclosure
`Bruno discloses a method of
`locating a mobile terminal
`having 2-way communication
`with base stations, using wireless
`measurements from multiple
`base stations. See 2:35-41, 3:52-
`4-16, 8:48-50, 10:34-37, 11:14-
`17, Figs. 1, 9.
`
`Bruno discloses receiving
`estimated location information
`from software instances using
`GPS, broadcast signals, and RF
`signpost techniques, which are
`independent and use wireless
`signal measurements between
`the mobile terminal and a
`communication station. See
`2:17-63, 3:52-56, 4:1-67, 8:48-
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`values obtained using wireless signal
`measurements obtained via two way wireless
`communication between said mobile station M,
`and the communication stations, each of said
`first and second location evaluators determine
`corresponding location information related to
`LM, and
`wherein for at least one location L of one of the
`mobile stations, said first location evaluator
`and said second location evaluator output,
`respectively, first and second position
`information related to the one mobile station
`being at L wherein neither of the first and
`second position information is dependent upon
`the other;
`
`obtaining a first collection of location
`information of said mobile station M, wherein
`the first collection includes first location
`information from the first location evaluator,
`and second location information from the
`second location evaluator;
`
`determining resulting information related to the
`location LM of the mobile station M, wherein
`the resulting information is dependent on
`geographical information in each of the first
`and second location information; and
`transmitting, to a predetermined destination via
`a communications network, the resulting
`information.
`
`26. The method of claim 25, further including
`the following steps:
`second obtaining, from an additional one or
`more of the location evaluators, additional
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`9:4, 10:8-11, Fig. 2, (Nos. 17,
`18, 20), Fig. 9.
`
`Bruno discloses receiving
`estimated location information
`from software instances using
`GPS, broadcast signals, and RF
`signpost techniques, which are
`independent and use wireless
`signal measurements between
`the mobile terminal and a
`communication station. See
`2:17-63, 3:52-56, 4:1-67, 8:48-
`9:4, 10:8-11, Fig. 2, (Nos. 17,
`18, 20), Fig. 9.
`Bruno discloses determining a
`location by combining estimates
`from the GPS, broadcast signals,
`and RF signposts techniques.
`See 2:41-44, 3:52-56, 8:48-50,
`10:8-11, 9:40-46, 9:57-10:6,
`10:34-37, item 14, Fig. 9.
`See above. Bruno discloses
`determining a resulting location
`by combining estimates from the
`GPS, broadcast signals, and RF
`signposts techniques. See 9:9-56.
`Bruno discloses transmitting
`location information to
`destinations. See 2:35-41, 9:57-
`10:6, Fig. 1.
`See claim 25.
`
`Bruno discloses receiving
`estimated location information
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`location information using values obtained
`from wireless signal measurements for a time
`different from a time of the communications
`between the mobile station M and the
`communication stations for obtaining the first
`collection;
`
`determining, as part of said resulting
`information, a resulting location estimate of the
`mobile station M, wherein said resulting
`location estimate is dependent upon a value
`obtained from said additional location
`information.
`
`27. A method for locating mobile stations at
`one or more unknown terrestrial locations
`using wireless signal measurements obtained
`via transmissions between said mobile stations
`and a plurality of fixed location terrestrial
`communication stations, wherein each of said
`communications stations includes one or more
`of a transmitter and a receiver for wirelessly
`communicating with said mobile stations,
`comprising:
`receiving, from a plurality of location
`requesting sources, a plurality of input requests
`for locations of the mobile stations, wherein for
`each of the input requests there is a
`corresponding destination for a responsive
`output;
`for each of the input requests, providing one or
`more location requests for location
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`from software instances using
`GPS, broadcast signals, and RF
`signposts techniques, which are
`independent and use wireless
`signal measurements between
`the mobile terminal and a
`communication station. See
`2:17-63, 3:52-56, 4:1-67, 8:48-
`9:4, 10:8-11, Fig. 2, (Nos. 17,
`18, 20), Fig. 9. Bruno further
`discloses receiving
`measurements from multiple
`base stations at different times.
`See 4:1-37.
`See above. Bruno discloses
`determining a location by
`combining estimates from the
`