UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________
`
`
`
`
`
`T-Mobile US, Inc., T-Mobile USA, Inc., TeleCommunication Systems, Inc.,
`Ericsson Inc., and Telefonaktiebolaget LM Ericsson
`Petitioners,
`
`v.
`
`TracBeam, LLC,
`Patent Owner.
`
`__________________
`
`
`
`U.S. Patent No. 7,525,484
`
`Title: GATEWAY AND HYBRID SOLUTIONS FOR WIRELESS LOCATION
`
`__________________
`
`
`
`DECLARATION OF DR. WILLIAM R. MICHALSON
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`T-Mobile / TCS / Ericsson EXHIBIT 1006
`T-Mobile / TCS / Ericsson v. TracBeam
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`TABLE OF CONTENTS
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`Page
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`I.
`
`INTRODUCTION ........................................................................................... 1
`A.
`Compensation and Prior Testimony ...................................................... 1
`B.
`Background and Qualifications ............................................................. 2
`C. Materials Considered ............................................................................. 8
`LEGAL STANDARDS ................................................................................... 9
`II.
`III. THE ‘484 PATENT ....................................................................................... 11
`A. Overview ............................................................................................. 11
`B.
`Location Center of the Hybrid Location System ................................ 15
`1.
`Signal processing subsystem..................................................... 17
`2.
`Location Hypothesizing Models (FOMs) ................................. 18
`3.
`Hypotheses Evaluator ............................................................... 19
`4.
`Output Gateway ........................................................................ 20
`IV. PROSECUTION HISTORY OF THE ‘484 PATENT .................................. 20
`V.
`LEVEL OF ORDINARY SKILL IN THE ART ........................................... 21
`VI. CLAIM CONSTRUCTION .......................................................................... 21
`“mobile station,” “location technique(s)” (and related terms),
`A.
`“location estimating sources” (and related terms), “location
`determining sources” (and related terms), “geographical extent,” and
`“output criteria” .................................................................................. 22
`“location information” and related terms ............................................ 23
`B.
`order of claim elements ....................................................................... 24
`C.
`“obtained via/from transmissions” ...................................................... 27
`D.
`“gating module” and “communications controller” ............................ 29
`E.
`VII. STATE OF THE ART / TECHNOLOGY OVERVIEW .............................. 31
`A.
`Early applications of wireless location technologies .......................... 31
`B.
`Hybrid wireless location approaches .................................................. 32
`C.
`Fundamental location technologies ..................................................... 34
`1.
`Coverage Area ........................................................................... 34
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`2.
`Trilateration (time of arrival and signal strength) ..................... 35
`Time Difference of Arrival (TDOA) ........................................ 38
`3.
`Satellite-Based Location Technologies .................................... 40
`4.
`VIII. PRIOR ART ................................................................................................... 43
`Kauser.................................................................................................. 43
`A.
`Loomis ................................................................................................. 45
`B.
`C. Wortham .............................................................................................. 45
`IX. KAUSER COMBINATIONS ......................................................................... 47
`A. Overview ............................................................................................. 47
`B.
`Satellite / Non-Terrestrial GPS Technique ......................................... 49
`1.
`Satellite (non-terrestrial) technique .......................................... 49
`2.
`Satellite location information .................................................... 50
`3.
`Satellite signal measurements that are obtained by terrestrial
`transmissions (or “mobile-assisted GPS”) ................................ 51
`Differential GPS ........................................................................ 53
`4.
`Terrestrial Geometric Technique ........................................................ 56
`1.
`Terrestrial communication stations at fixed locations .............. 57
`2.
`Terrestrial location technique ................................................... 57
`3. Wireless signal measurements .................................................. 58
`Terrestrial Coverage Area Technique ................................................. 59
`Resulting Location Determination ...................................................... 60
`1.
`Determining resulting location information ............................. 60
`2.
`Likelihood indication ................................................................ 63
`Output of the Resulting Location Information .................................... 64
`F.
`G. Order of Location Techniques ............................................................. 65
`H. Other features ...................................................................................... 69
`1. Messages for Requesting Activation of One or More Mobile
`Station Location Estimators ...................................................... 69
`Geographic Extent..................................................................... 71
`Gating module and communications controller ........................ 72
`
`C.
`
`D.
`E.
`
`2.
`3.
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`X.
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`D.
`
`E.
`
`GPS and geometric techniques provide different, independent
`location estimates ...................................................................... 75
`Requests for locations ............................................................... 78
`5.
`6. Mobile Phone Transmissions .................................................... 79
`Global Reasons to Modify and/or Combine ....................................... 80
`I.
`LOOMIS COMBINATIONS ......................................................................... 83
`A. Overview ............................................................................................. 83
`B.
`Two-Way Wireless Communication and Location Functionality ...... 85
`C.
`Satellite / Non-Terrestrial GPS Technique ......................................... 89
`1.
`Satellite (non-terrestrial) technique .......................................... 89
`2.
`Satellite signal time delay measurements ................................. 89
`3.
`Satellite location information .................................................... 91
`Terrestrial Radio Technique ................................................................ 92
`1.
`Terrestrial communication stations at fixed locations .............. 92
`2.
`Terrestrial location technique ................................................... 92
`3. Wireless signal measurements .................................................. 93
`4.
`Signal time delay measurements ............................................... 94
`Resulting Location Determination ...................................................... 97
`1.
`Determining resulting location information ............................. 97
`2.
`Likelihood indication ................................................................ 99
`Output of the Resulting Location Information ..................................101
`F.
`G. Order of Location Techniques ...........................................................101
`H. Other features ....................................................................................106
`1.
`Storing Data in Memory .........................................................106
`2.
`Location Information Determined According to Information
`Indicative of a Manner in Which an Application Prefers the
`Requested Location Information ............................................106
`Geographic Extent...................................................................107
`Plurality of Mobile Stations ....................................................109
`A Plurality of Requests for Information .................................111
`Different techniques that generate different estimates ...........112
`
`4.
`
`3.
`4.
`5.
`6.
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`7.
`8.
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`Application requests and preferences .....................................113
`Common standardized format & Common data representation
` .................................................................................................115
`Tracking a Mobile Wireless Device .......................................117
`9.
`Global Reasons to Modify and/or Combine .....................................119
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`I.
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`I, William R. Michalson, Ph.D., declare as follows:
`
`I.
`
`INTRODUCTION
`1. My name is William Michalson, Ph.D. I am over the age of eighteen
`
`(18) and otherwise competent to make this declaration.
`
`2.
`
`I have been retained as an expert witness on behalf of T-Mobile US,
`
`Inc. and T-Mobile USA, Inc. (“T-Mobile”), TeleCommunication Systems, Inc.
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`(“TCS”), and Ericsson Inc. and Telefonaktiebolaget LM Ericsson (“Ericsson”) to
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`provide my opinions regarding the validity of Claims 1, 2, 6, 24, 25, 27, 39, 51, 62,
`
`64, 67, 71, and 72 of U.S. Patent No. 7,525,484 (the “’484 Patent”). I am
`
`providing this declaration in connection with the inter partes review petitions for
`
`the ‘484 Patent that are being filed by the parties identified above.
`
`3.
`
`I am also providing separate declarations in connection with other
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`inter partes review petitions for three patents that are related to the ‘484 Patent:
`
`U.S. Patent Nos. 7,764,231 (the “’231 Patent”), 8,032,153 (the “’153 Patent”), and
`
`7,298,327 (the “’327 Patent”).
`
`A. Compensation and Prior Testimony
`4.
`I am being compensated for my time in connection with this matter at
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`my standard legal consulting rate of $500 per hour. I am also being reimbursed for
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`reasonable and customary expenses associated with my work and testimony in this
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`investigation. My compensation is not contingent on the outcome of this matter or
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`the specifics of my testimony.
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`5.
`
`I previously provided an expert declaration and expert testimony
`
`regarding invalidity of the ‘484 Patent (and the related ’231 Patent) in connection
`
`with TracBeam’s lawsuit against Google: TracBeam, LLC. v. Google, Inc., No.
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`6:13-cv-00093 (E.D. Tex.).
`
`6.
`
`In addition, I have also provided expert consulting services (including
`
`expert declarations and/or testimony) for various other patent disputes in both
`
`district court proceedings and inter partes review proceedings. My consulting
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`engagements are identified in my curriculum vitae (Ex. 1005).
`
`B.
`7.
`
`Background and Qualifications
`
`I received my Ph.D. in Electrical Engineering from Worcester
`
`Polytechnic Institute in 1989, my Master of Science in Electrical Engineering from
`
`Worcester Polytechnic Institute in 1985, and my Bachelor of Science in Electrical
`
`Engineering from Syracuse University in 1981.
`
`8.
`
`I was employed as an engineer at Raytheon Company from 1981 until
`
`1991. During this period, I worked on a variety of projects which involved both
`
`hardware and software design and debugging. These projects involved developing
`
`computer systems and software for a variety of applications including: air traffic
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`display systems, signal and data processing systems, and communications systems.
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`During this time period, I was involved in hardware and software development that
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`included experience working with satellite, airborne, and ground-based systems for
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`navigation and communications. From 1985 until 1988, I received a fellowship
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`from Raytheon to pursue my Ph.D. degree and worked part-time during this period.
`
`I returned to Raytheon full-time from 1988 until 1991. I have been a full-time
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`faculty member at the Worcester Polytechnic Institute in Massachusetts since
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`1991. My emphasis at Worcester Polytechnic Institute is on teaching and
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`conducting research on navigation, communications, and computer system design.
`
`9.
`
`I hold eight patents in the fields of audio signal processing, indoor
`
`geolocation devices, and handheld GPS (Global Positioning System) mapping
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`devices. I have authored or co-authored over 100 original articles in the fields of
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`communications networks, precision location systems, and GPS, including more
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`than 15 journal papers and 90 conference papers. I have also authored one book
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`chapter relating to optical interconnect networks for massively parallel computers.
`
`I became a Senior Member of the Institute of Electrical and Electronics Engineers
`
`(IEEE) in 2003.
`
`10.
`
`I have worked in the field of computer architecture and computer
`
`systems since I began employment at Raytheon in 1981. In addition, I teach
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`classes relating to computer architecture and design, and I also teach classes
`
`relating to embedded system designs, advanced system architectures, and real-time
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`system designs, which relate to the design of computer systems, including real-
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`time operating systems and programming. I have worked extensively in software
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`programming, including during my employment at Raytheon and in a variety of
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`projects relating to navigation and communications systems at Worcester
`
`Polytechnic Institute.
`
`11. GPS and GPS-related technologies have dominated the bulk of my
`
`research since 1992, and at Worcester Polytechnic Institute, I direct the Center for
`
`Advanced Integrated Radio Navigation. I have been involved in numerous
`
`academic, consulting, and
`
`litigation-related projects
`
`involving navigation
`
`technologies. Examples of academic projects include (1) a container tracking
`
`system in 2003 which explored the application of tracking and communications
`
`technologies to track shipping containers, (2) an automotive based system in 2000
`
`which combined GPS and map data in an automotive environment, (3) a remote
`
`hazard detection system in 1996 that combined GPS and radio communications to
`
`remotely identify hazards to the engineer operating a freight train, and (4) a
`
`differential GPS system in 1995 that combined GPS and radio technologies to
`
`allow determining the precise path of vehicles operating off-road during forest
`
`operations. As a consultant, I have worked with the combination of GPS and radio
`
`communications in the context of space shuttle docking operations, transfer of
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`traffic information to GPS devices in a vehicle, combinations of GPS and cellular
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`communications for the tracking of individuals, and map-based handheld tracking
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`devices.
`
`12.
`
`I have extensive experience with the development and maintenance of
`
`the hardware and software associated with server computers, including server
`
`computers attached to the Internet. This experience includes the installation and
`
`maintenance of web servers and file servers, as well as the design, development,
`
`test, and maintenance of web based applications. These applications typically
`
`employ C/C++, Java, JavaScript, PHP, HTML, MySQL, and other applications,
`
`languages and/or utilities as might be appropriate for a given application.
`
`13.
`
`I have extensive experience with the design, implementation, and
`
`testing of computer hardware and software systems for a variety of military and
`
`non-military applications. This experience specifically includes the design,
`
`implementation, and testing of hardware and software systems used in navigation
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`systems and geographical information systems (GIS) as well as experience in the
`
`design, implementation, and testing of hardware and software systems in the
`
`context of a client-server computer architecture in which at least one client
`
`computer exchanges navigation and/or geographical information with at least one
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`server computer through a wired and/or wireless network.
`
`14. Since 1992, I have not only been involved with the development of
`
`GIS related software for evaluating various aspects of GPS performance, but I have
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`also used a number of commercial GPS and GIS products. GPS products I am
`
`familiar with include products produced by GEC Plessey, Motorola, Rockwell,
`
`Trimble, Novatel, Magellan, Garmin, and others. GIS products I am familiar with
`
`include products such as ArcView/ArcGIS, GeoRover, and Navtech, as well as
`
`various data sets made available by government agencies (for example, USGS
`
`topographical maps, Digital Elevation Models, marine and aviation charts, and the
`
`like). I am also familiar with numerous GIS and mapping products that existed in
`
`the market since the late 1980s, including systems and software developed by Etak,
`
`Microsoft, DeLorme, AutoMap, and others. In the conduct of my research and
`
`other work, I have routinely used database systems such as Microsoft Access,
`
`Borland Paradox, Oracle, SQL and others.
`
`15.
`
` I teach undergraduate and graduate classes relating to computer
`
`systems and engineering design. I have taught computer architecture classes
`
`(undergraduate and graduate), in which I cover memory hierarchies, caching, and
`
`communications/networking. I also teach classes relating to embedded system
`
`designs, advanced system architectures, real-time system design, communication
`
`systems, navigation and robotics. Some of my classes address network protocols
`
`at the hardware level (i.e., the low-level hardware interfaces necessary for
`
`performing computer communications), while other classes address networking at
`
`the architectural level and cover layered protocol models, such as the OSI
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`reference model developed by the International Standards Organization (ISO). In
`
`addition to the classes listed in my curriculum vitae (Ex. 1005), I have also taught
`
`a number of guest lectures in the areas of satellite navigation, systems engineering,
`
`and engineering design. In addition, I teach classes in the Fundamentals of Robot
`
`Systems and courses in navigation, both of which cover radiolocation, inertial
`
`navigation, and other means of navigating as well as using position information for
`
`purposes of guidance, mapping, navigation and path planning.
`
`16. Other projects that I worked on and supervised involved public safety
`
`radio systems, aircraft laser communications, and railroad communications
`
`between locomotives and railway switches. Many of the projects that I worked on
`
`and supervised involved the use of existing communications protocols such as File
`
`Transfer Protocol (FTP), Transmission Control Protocol (TCP), and Internet
`
`Protocol (IP), while other projects required the design of new communications
`
`protocols for data exchange between computers.
`
`17.
`
`In my research, I have done extensive work in communications and
`
`networking system design, and have worked with all of the digital, analog and
`
`software components needed to build communications and navigation systems.
`
`My work with communications and networking protocols began in the mid-1980s
`
`with TCP/IP over packet radio. I have used these and other communications and
`
`networking protocols extensively in conducting my research. In addition, my work
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`on GPS
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`and navigation
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`systems
`
`involved
`
`implementing
`
`low-latency
`
`communications to support differential techniques that allow a GPS receiver to
`
`provide more accurate positioning information.
`
`18.
`
`In writing this declaration, I have considered my own knowledge and
`
`experience, including my work experience in the fields of electrical engineering,
`
`computer engineering, networking, wireless location technologies, wireless
`
`communication technologies, and navigation and GIS systems; my experience in
`
`teaching those subjects; and my experience in working with others involved in
`
`those fields.
`
`19. A copy of my curriculum vitae, which further describes my
`
`qualifications, has been provided as Ex. 1005.
`
`C. Materials Considered
`20.
`In formulating my opinion, I have considered the following materials:
`
`Number
`
`Description
`
`1001
`
`1002
`
`1003
`
`1004
`
`1007
`
`1008
`
`1009
`
`U.S. Patent No. 7,764,231
`
`U.S. Patent No. 7,525,484
`
`U.S. Patent No. 8,032,153
`
`U.S. Patent No. 7,298,327
`
`U.S. Patent No. 5,724,660 to Kauser
`
`U.S. Patent No. 5,936,572 to Loomis
`
`U.S. Patent No. 6,748,226 to Wortham
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`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`1016
`
`1017
`
`1018
`
`International PCT Application No. PCT/US93/12179
`Schuchman
`
`to
`
`U.S. Patent No. 5,327,144 to Stilp
`
`FAA Advisory Circular 20-101C, Airworthiness Approval of
`Omega/VLF Navigation Systems For Use in the U.S. National
`Airspace System (NAS) and Alaska (Sep. 12, 1988)
`
`FAA Advisory Circular 20-130A, Airworthiness Approval of
`Navigation or Flight Management Systems Integrating Multiple
`Navigation Sensors (Jun. 14, 1995)
`
`FCC Notice of Proposed Rulemaking for Locating Wireless 911
`Callers (Released Oct. 19, 1994)
`
`TR45 Joint Experts Meeting (JEM) for Emergency Services (Aug.
`18, 1994)
`
`C.J. Driscoll & Associates, Survey of Location Technologies to
`Support Mobile 9-1-1, July 1994
`
`Claim Construction Order (MetroPCS and TCS lawsuits)
`
`Supplemental Claim Construction Order
`
`
`II. LEGAL STANDARDS
`21. This section provides my understanding of the applicable legal
`
`principles regarding the standards for patentability, which I have used in forming
`
`my opinions regarding the invalidity of the ‘484 Patent.
`
`22.
`
`I understand that the petitioners have the burden to prove that the
`
`claims challenged in its inter partes review petitions are not patentable by a
`
`preponderance of the evidence. I understand “preponderance of evidence” to be
`
`just enough evidence to make it more likely than not that their position is correct.
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`23.
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`I understand that patentability of each claim challenged in the
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`petitions is assessed based on documents that predate the ‘484 Patent, such as other
`
`patents and printed publications, which are referred to as “prior art.”
`
`24.
`
`It is my understanding that a claim is not patentable if it is directed to
`
`subject matter that is not new or if the subject matter recited in the claim would be
`
`obvious to a person of ordinary skill in the art in the field of the invention at the
`
`time of the invention. I understand that an obviousness analysis involves a
`
`consideration of (1) the scope and content of the prior art; (2) the differences
`
`between the claimed invention and the prior art; (3) the level of ordinary skill in
`
`the pertinent field; and (4) secondary considerations of non-obviousness. I
`
`understand that secondary considerations of non-obviousness include failure of
`
`others, copying, unexpectedly superior results, perception in the industry,
`
`commercial success, and long-felt but unmet need. It is also my understanding that
`
`obviousness can be established by combining or modifying the teachings of the
`
`prior art to produce the claimed invention where there is some teaching,
`
`suggestion, or motivation to do so. Additionally, it is my understanding that
`
`obviousness can be established when the claimed invention is considered to be
`
`predictable based on the prior art.
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`25.
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`I understand that obviousness is determined based on the point of
`
`view of a person of ordinary skill in the art. I also understand that the person of
`
`ordinary skill in the art has ordinary creativity.
`
`26.
`
`I understand that, in an inter partes review proceeding, the claims
`
`must be given their broadest reasonable interpretation in view of the specification.
`
`After interpreting the claims in this manner, the claims can then be compared to the
`
`prior art.
`
`III. THE ‘484 PATENT
`A. Overview
`27. As the first sentence under the “Summary Discussion” section states:
`
`“The present invention relates to a wireless mobile station location system, and in
`
`particular, various subsystems related thereto such as a wireless location gateway,
`
`and the combining or hybriding of a plurality of wireless location techniques.”1
`
`28. The ‘484 Patent lists various objectives the inventors were trying to
`
`achieve, including:
`
`1. To provide a system and method for wireless telecommunication
`systems to accurately locate people and/or objects in a cost effective
`manner;
`
`2. To provide such location capabilities using the measurements from
`wireless signals communicated between mobile stations and a network
`of base stations; and
`
`
`1 Ex. 1002 (‘484 Patent) at 10:33-37.
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`3. To provide a low cost location system and method, adaptable to
`wireless telephony systems, for using simultaneously a plurality of
`location techniques for increasing location accuracy and consistency.2
`29. To achieve these objectives, the ‘484 Patent discloses the use of a
`
`combination of prior art wireless location technologies that locate mobile stations
`
`using measurements from wireless signals communicated between the mobile
`
`station and the base stations.3 The use of multiple location technologies (each of
`
`which by itself is known in the art) and then selecting or combining the results of
`
`the different technologies is the advertised inventive aspect of the ‘484 Patent:
`
`[A] fundamental aspect of the present invention is to use a plurality
`MS location techniques for generating location estimates and to
`analyze the generated estimates (likely after being adjusted) to detect
`patterns of convergence or clustering amongst the estimates.4
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`30.
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`In particular, the limitations of the various prior art location
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`technologies were recognized by the inventors and are discussed in the background
`
`section of the ‘484 Patent:
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`Systems have been proposed that rely upon signal strength and
`trilateralization techniques to permit location [determinations]….
`Furthermore, the systems are generally only effective in line-of-sight
`conditions, such as rural-settings. Radio wave surface reflections,
`
`
`2 Ex. 1002 (‘484 Patent) at 7:65-9:27.
`3 Ex. 1002 (‘484 Patent) at 12:1-10, 12:62-13:30.
`4 Ex. 1002 (‘484 Patent) at 66:45-49 (emphasis added).
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`in
`refractions and ground clutter cause significant distortion,
`determining the location of a signal source in most geographical areas
`that are more than sparsely populated.
`
`GPS is impractical in many applications. The signal power levels
`from the satellites are low and the GPS receiver requires a clear, line-
`of-sight path to at least three satellites above a horizon of about 60
`degrees for effective operation. Accordingly, inclement weather
`conditions, such as clouds, terrain features, such as hills and trees, and
`buildings restrict the ability of the GPS receiver to determine its
`position.5
`
`31. The inventors sought to overcome the limitations of any single
`
`location technology using a hybrid location solution:
`
`The present invention relates to a wireless mobile station location
`system, and in particular, various subsystems related thereto such as a
`wireless location gateway, and the combining or hybriding of a
`plurality of wireless location techniques.
`
`Yet another objective is to provide a low cost location system and
`method, adaptable
`to wireless
`telephone systems,
`for using
`simultaneously a plurality of location techniques for synergistically
`increasing MS [mobile station] location accuracy and consistency.6
`
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`5 Ex. 1002 (‘484 Patent) at 1:43-54 and 2:2-9.
`6 Ex. 1002 (‘484 Patent) at 10:33-37 and 9:1-5 (emphasis added).
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`32. Figure 4 illustrates a high level diagram of the hybrid location
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`solution described by the ‘484 Patent, which includes a plurality of mobile devices
`
`(referred to as “mobile stations” by the patent); a plurality of base stations and
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`mobile base stations; a mobile switching center; and a public switched telephone
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`network, or PSTN.
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`
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`33. Each mobile station is connected to the wireless network through one
`
`
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`of the base stations, and the base stations are connected to the public switched
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`telephone network through the mobile switching center. The base stations may
`
`either be typical stationary base stations or may be mobile base stations. Mobile
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`base stations are vehicles equipped with base station equipment to provide the
`
`functionality of a stationary base station but with the ability to change locations.
`
`34. Figure 4 also features a location center and location applications. The
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`location applications use the location of mobile stations to provide services.
`
`Examples of services disclosed in the ‘484 Patent include 911 emergency response
`
`services, taxi services, vehicle navigation services, and stolen vehicle tracking
`
`services.7 In order to provide these services, the location applications submit
`
`location requests to the location center. The location center then activates various
`
`different location technologies to obtain multiple location estimates for the target
`
`mobile station. After obtaining location estimates from the various technologies,
`
`the location center provides a “most likely” location estimate of the target mobile
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`station by selecting or combining the various location estimates from each location
`
`technology.
`
`B.
`Location Center of the Hybrid Location System
`35. This section provides an explanation of the “location center” used in
`
`the hybrid location system of the ‘484 Patent.
`
`36. Figure 5 illustrates a more detailed diagram of the location center,
`
`which includes, among other components: a signal processing subsystem; location
`
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`7 Ex. 1002 (‘484 Patent) at 8:52-55.
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`hypothesizing models, which the patent also refers to as “First Order Models,” or
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`FOMs; a hypothesis evaluator; and an output gateway.
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