Filed on behalf of: Google Inc.
`
`By: Naveen Modi (Google-Silverstate-IPR@paulhastings.com)
`
`Joseph E. Palys (Google-Silverstate-IPR@paulhastings.com)
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`Daniel Zeilberger (Google-Silverstate-IPR@paulhastings.com)
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`Paul Hastings LLP
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
`
`GOOGLE INC.
`Petitioner
`
`v.
`
`SILVER STATE INTELLECTUAL TECHNOLOGIES, INC.
`Patent Owner
`
`____________________
`
`U.S. Patent No. 7,650,234
`____________________
`
`DECLARATION OF DR. WILLIAM R. MICHALSON
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`Google Exhibit 1008
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`Page 1 of 123
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`TABLE OF CONTENTS
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`I.
`
`II.
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`III.
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`Introduction ..................................................................................................... 1
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`Qualifications .................................................................................................. 1
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`Summary of Opinions ..................................................................................... 4
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`IV. Level of Ordinary Skill ................................................................................... 5
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`V.
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`The ’234 Patent ............................................................................................... 6
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`A. Overview of the ’234 Patent ................................................................. 6
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`B.
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`General Background ............................................................................. 8
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`VI. Claim Construction ....................................................................................... 10
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`C.
`
`D.
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`VII. The Prior Art Discloses All of the Features of Claims 1-30 the ’234
`Patent ............................................................................................................ 13
`A. Overview of Xu .................................................................................. 13
`Overview of Golding .......................................................................... 18
`B.
`Overview of Trovato .......................................................................... 21
`Claims 1-7, 9-15, 17-21, 23-28, and 30 of the ’234 Patent ................ 23
`Xu Discloses the Features of Claims 1-7, 9-15, 17-21, 23-
`28, and 30 ................................................................................. 23
`The Combination of Xu and Golding Discloses the
`Features of Claims 1-7, 9-15, 17-21, 23-28, and 30 ................ 69
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`1.
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`2.
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`E.
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`1.
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`Claims 8, 16, 22, and 29 of the ’234 Patent ....................................... 75
`The Combination of Xu and Trovato Discloses the
`Features of Claims 8, 16, 22, and 29 ....................................... 75
`The Combination of Xu, Golding, and Trovato Discloses
`the Features of Claims 8, 16, 22, and 29 .................................. 82
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`2.
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`VIII. Conclusion .................................................................................................... 84
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`-i-
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`I, William R. Michalson, declare as follows:
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`I.
`
`INTRODUCTION
`1.
`
`I have been retained by Google Inc. as an independent expert
`
`consultant in this proceeding before the United States Patent and Trademark Office
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`(“PTO”) regarding U.S. Patent No. 7,650,234 (“the ’234 patent,” which I
`
`understand is Ex. 1001 in this proceeding). I have been asked to consider whether
`
`certain references disclose the features recited in claims 1-30 of the ’234 patent.
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`My opinions are set forth below.
`
`2.
`
`I am being compensated at my rate of $450 per hour for the time I
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`spend on this matter, and no part of my compensation is dependent on the outcome
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`of this proceeding. I have no other interest in this proceeding.
`
`II. QUALIFICATIONS
`3.
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`I received my Ph.D. in Electrical Engineering from Worcester
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`Polytechnic Institute in 1989, my Master of Science in Electrical Engineering from
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`Worcester Polytechnic Institute in 1985, and my Bachelor of Science in Electrical
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`Engineering from Syracuse University in 1981.
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`4.
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`I am currently a member of the faculty of the Electrical and Computer
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`Engineering Department at the Worcester Polytechnic Institute in Massachusetts
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`and have been a full-time faculty member there since 1991. I also have an
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`appointment as a Professor of Computer Science and I am a founding member of
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`1
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`the faculty of the Robotics Program. My emphasis at Worcester Polytechnic is on
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`teaching and conducting research on navigation, communications, and computer
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`system design.
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`5.
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`I was employed as an engineer at Raytheon Company from 1981 until
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`1991. During this period, I worked on a variety of projects which involved both
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`hardware and software design, including those relating to satellite, airborne, and
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`ground-based systems for navigation and communications. From 1985 until 1988, I
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`received a fellowship from Raytheon to pursue my Ph.D. degree and worked part-
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`time during this period. I returned to Raytheon full-time from 1988 until 1991.
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`6.
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`I hold eight patents in the fields of audio signal processing, indoor
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`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 am a Senior Member of the
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`Institute of Electrical and Electronics Engineers (IEEE).
`
`7.
`
`I have worked in the field of computer architecture and computer
`
`systems since I began employment at Raytheon in 1981. In addition, I teach classes
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`relating to computer architecture and design, and I also teach classes relating to
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`embedded system designs, advanced system architectures, and real-time system
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`designs. In addition, I teach classes in Electrical and Computer Engineering
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`2
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`Design, Foundations of Robotics and Robot Navigation. I have worked extensively
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`in software programming, including during my employment at Raytheon and in a
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`variety of projects relating to navigation and communications systems at Worcester
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`Polytechnic Institute.
`
`8.
`
`GPS and GPS-related technologies have dominated the bulk of my
`
`research since 1992. I have been involved in numerous academic and consulting
`
`projects involving navigation technologies and their association with geographic
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`information system technologies. Examples of academic projects include (1) a
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`container tracking system in 2003 which explored the application of tracking and
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`communications technologies to track shipping containers, (2) an automotive based
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`system in 2000 which combined GPS and map data in an automotive environment,
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`(3) a remote hazard detection system in 1996 that combined GPS and radio
`
`communications to remotely identify hazards to the engineer operating a freight
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`train, and (4) a differential GPS system in 1995 that combined GPS and radio
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`technologies to allow determining the precise path of vehicles operating off-road
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`during forest operations. As a consultant, I have worked with the combination of
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`GPS and radio communications in the context of space shuttle docking operations,
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`transfer of traffic information to GPS devices in a vehicle, combinations of GPS
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`and cellular communications for the tracking of individuals, and map-based
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`handheld tracking devices.
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`3
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`9.
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`Based on my experience and education, I believe that I am qualified to
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`opine as to knowledge and level of skill of one of ordinary skill in the art at the
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`time of the alleged invention of the ’234 patent (which I further describe below)
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`and what such a person would have understood at that time, and the state of the art
`
`during that time.
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`10. My curriculum vitae, which includes a more detailed summary of my
`
`background, experience, and publications, is attached as Appendix A.
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`III. SUMMARY OF OPINIONS
`11. All of the opinions contained in this Declaration are based on the
`
`documents that I reviewed, my knowledge and experience, and professional
`
`judgment. In forming the opinions expressed in this Declaration, I reviewed the
`
`’234 patent (Ex. 1001), the prosecution file history for the ’234 patent (which I
`
`understand is Ex. 1002 in this proceeding), U.S. Patent No. 6,401,027 to Xu et al.
`
`(“Xu”) (which I understand is Ex. 1004 in this proceeding), U.S. Patent No.
`
`5,835,881 to Trovato et al. (“Trovato”) (which I understand is Ex. 1005 in this
`
`proceeding), U.S. Patent No. 6,442,391 to Johansson et al. (“Johansson”) (which I
`
`understand is Ex. 1005 in this proceeding), U.S. Patent No. 5,933,100 to Golding
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`(“Golding”) (which I understand is Ex. 1006 in this proceeding), any other
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`materials I refer to in this declaration in support of my opinions, while drawing on
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`4
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`my experience and knowledge of communications systems and location-based
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`technology.
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`12. Based on my experience and expertise, it is my opinion that certain
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`references disclose all the features recited in claims 1-30 of the ’234 patent, as I
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`discuss in detail below.
`
`13. Although this Declaration refers to selected portions of the cited
`
`references for the sake of brevity, it should be understood that one of ordinary skill
`
`in the art would view the references cited herein in their entirety and in
`
`combination with other references cited herein or cited within the references
`
`themselves. The references used in this Declaration, therefore, should be viewed as
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`being incorporated herein in their entirety.
`
`IV. LEVEL OF ORDINARY SKILL
`14. Based on my knowledge and experience, I understand what a person
`
`of ordinary skill in the art would have known at the time of the alleged invention. I
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`have, for example, taught, participated in organizations, and worked closely with
`
`many such persons over the course of my career. My opinions herein are, where
`
`appropriate, based on my understandings as to one of ordinary skill in the art at
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`that time.
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`15.
`
`In my opinion, based on the materials and information that I have
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`reviewed, and on my extensive experience in the technical areas relevant to the
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`5
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`’234 patent, a person of ordinary skill in the art would have been an engineer
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`having at least a bachelor’s degree in electrical engineering, computer science, or a
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`degree in a related field, with approximately two or more years of experience in the
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`design and implementation of navigation systems and/or routing. I apply this
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`understanding in my analysis herein.
`
`V. THE ’234 PATENT
`A. Overview of the ’234 Patent
`16. The ’234 patent, entitled “Technique for Effective Navigation Based
`
`on User Preferences,” issued on January 19, 2010, from U.S. Application No.
`
`11/971,193, which was filed on January 8, 2008. (Ex. 1001.) I have been asked to
`
`assume for purposes of this proceeding that the effective date of the ’234 patent is
`
`October 19, 1999, which is the filing date of a provisional application to which the
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`’234 patent claims priority. I apply this understanding in my analysis herein.
`
`17. The ’234 patent is directed to a navigation system (e.g., “navigator
`
`arrangement 100”) that “may be ‘docked’ or connected to another device or system
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`to enhance its functionality, which may include a terminal, workstation, computer
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`system, or an automobile system.” (Id., 3:29-33.) The “navigator arrangement 100
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`includes processor 103, memory 108, display driver 111, display 113, user
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`interface 115, external interfaces 117, GPS receiver 119, communication unit 120.”
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`(Id., 3:36-39.) While databases in navigator arrangement 100 may be “pre-
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`populated with data” (id., 4:30-32), data may also be downloaded “from a remote
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`source to supplement and update the databases in arrangement 100, and to provide
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`thereto just-in-time information, including, e.g., latest traffic, weather, map and
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`other information” (Id., 4:33-37).
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`18. Navigator arrangement 100 includes a “NAVIGATE option 657.”
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`(Id., 9:56-57.) The NAVIGATE option provides the user with an interface to enter
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`an origination and destination address, with the user’s current location being the
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`default origination. (Id., 10:5-10.) According to the ’234 patent, “[a]fter learning
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`the origination address and destination address . . . processor 103 determines
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`whether” a geographic area called the “navigation coverage” “includes the
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`origination and destination addresses, and whether the stored map and related
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`information is fresh.” (Id., 10:27-34.) “If the navigation coverage includes the
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`origination and destination addresses in question . . . processor 103 at step 1006
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`selects the route from the origination address to the destination address which is
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`the most time-efficient, i.e., fastest by automobile in this instance, taking into
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`account the relevant weather, traffic, and road conditions along the selected route,
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`together with any roadblocks set up by the user in a manner to be described.” (Id.,
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`10:35-46.) On the other hand, if the “navigation coverage” area “does not cover the
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`origination and/or destination address in question, and/or if the map and related
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`information is not fresh, processor 103 . . . establishes a communication connection
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`to navigation server 630 [and] causes a transmission of a request for fresh map and
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`related information for an appropriate navigation coverage through the established
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`connection.” (Id., 10:55-61.)
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`19. The ’234 patent includes four independent claims, claims 1, 9, 17, and
`
`24. Claims 2-8 depend directly or indirectly from claim 1, claims 10-16 depend
`
`directly or indirectly from claim 9, claims 18-23 depend directly or indirectly from
`
`claim 17, and claims 25-30 depend directly or indirectly from claim 24.
`
`20.
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`In my opinion, as explained further below, the features recited in
`
`claims 1-30 characterize conventional features of vehicle navigation systems
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`known prior to the time of the alleged invention for the ’234 patent, e.g., as
`
`disclosed in Xu, Golding, and Trovato.
`
`B. General Background
`21. Route planning based on road conditions, such as traffic and weather
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`information, has been a well-known feature of vehicle navigation systems since at
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`least the early 1980s. For instance, by 1980, it was already recognized that
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`“searching [for a route] can be carried out very quickly and at any time before or
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`during a journey to meet changed or changing conditions, as forecast or actually
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`met on the roads.” (Ex. 1009, UK Patent Application GB 2079453A at 7:40-42.)
`
`Such changes could be initiated “[i]n the event that the driver finds that road,
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`weather, or other conditions are undesirably impeding his progress along the
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`route,” with a new route determined “avoiding the road sections ahead on which
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`travelling difficulties are known (for example, from a broadcast traffic news
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`bulletin) to exist.” (Id. at 7:1-6).
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`22. By the late 1980s, systems were being developed that addressed the
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`need to make route changes based on traffic congestion. “These systems [could]
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`respond to traffic conditions, help drivers avoid incidents and traffic congestion
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`and guide them to their precise destination.” (Ex. 1010, Wootton, J.; Ness, M.;
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`“The experience of developing and providing driver route information systems,”
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`IEEE 1989 Vehicle Navigation and Information Systems Conference, pp. 71-75,
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`Toronto, Ont., Canada, 11-13 Sep 1989 at 74). “If information can be obtained in
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`real time, for example on traffic incidents or congestion, then drivers might be
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`advised of new routes to follow to their destination with the consequent reduced
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`travel times.” (Id., 71).
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`23. Likewise, systems were developed in which “an alternative route is
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`calculated and displayed if signals from an IB (information beacon) advise of
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`congestion or closure of the planned route.” (Ex. 1011, Saito, T.; Shima, J.;
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`Kanemitsu, H.; Tanaka, Y.; “Automobile navigation system using beacon
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`information,” IEEE 1989 Vehicle Navigation and Information Systems
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`Conference, pp. 139-145, Toronto, 11-13 Sep 1989 at 142). “IB (information
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`beacon) data concerning congestion is expressed as a congestion factor
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`(corresponding to link flow rate). When such information is received, the shortest
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`route from the preceding node to D is calculated (as above) in terms of total link
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`cost (distance x congestion factor) and displayed on the CRT.” (Id., 143).
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`24. By the time Xu, Golding, and Trovato were filed in the mid-to-late
`
`1990s, route planning based on road conditions for vehicle navigation systems was
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`well established and well known to those of ordinary skill in the art.
`
`VI. CLAIM CONSTRUCTION
`25.
`I understand that a claim subject to inter partes review receives the
`
`broadest reasonable interpretation in light of the specification and file history of
`
`the patent in which it appears. I also understand that any term that is not construed
`
`should be given its plain and ordinary meaning under the broadest reasonable
`
`interpretation. I have followed these principles in my analysis. I discuss certain
`
`claim terms below and what I understand to be Petitioner’s construction of these
`
`terms, which I apply in my analysis. The remaining claim terms in the ’234 patent
`
`are given their plain and ordinary meaning under the broadest reasonable
`
`interpretation, which I also apply in my analysis.
`
`26.
`
`I understand that Petitioner has proposed that the broadest reasonable
`
`interpretation of the claimed term “searching the database” is “analyzing data from
`
`the database.” I agree with this construction based on the claims and specification
`
`of the ’234 patent. For example, while the ’234 patent does not define or even use
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`
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`10
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`the term “searching” anywhere in its specification, it does disclose a scenario in
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`which a server analyzes data from a database (Ex. 1001 at 8:26-55), and a scenario
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`in which data is transmitted from a database of a server to a processor of a
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`“navigator arrangement” and then the data from the database is analyzed at the
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`“navigator arrangement” (id., 10:27-11:14). The common factor in both scenarios
`
`is that data from a database is analyzed. The construction is also consistent with
`
`my review of the file history and how one of ordinary skill in the art would have
`
`understood the term in context of the ’234 patent. I have applied this understanding
`
`in my analysis.
`
`27.
`
`I understand that Petitioner has proposed that the broadest reasonable
`
`interpretation of the claimed term “navigation coverage” is “the geographic area
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`over which the navigation system operates.” I agree with this construction based on
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`the claims and specification of the ’234 patent. For example, the ’234 patent
`
`describes a scenario in which “processor 103 determines whether the navigation
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`coverage based on the map layer corresponding to automobile travel . . . includes
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`the origination and destination addresses in question.” (Ex. 1001 at 10:30-35
`
`(emphasis added).) If so, “processor 103 . . . selects [a] route from the origination
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`address to the destination address.” (Id., 10:35-42.) However, “if the stored map
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`. . . does not cover the origination and/or destination address in question . . .
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`processor 103 causes a transmission of a request for fresh map and related
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`information for an appropriate navigation coverage.” (Id., 10:55-62 (emphasis
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`added).) In other words, in the ’234 patent, maps associated with an appropriate
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`navigation coverage are selected to conform to the geographic area over which the
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`navigation system operates. The construction is also consistent with my review of
`
`the file history and how one of ordinary skill in the art would have understood the
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`term in context of the ’234 patent. I have applied this understanding in my
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`analysis.
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`28.
`
`I understand that Petitioner has proposed that the broadest reasonable
`
`interpretation of the claimed term “coverage area” is “the geographic area that the
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`vehicle is located in, which is a subset of the geographic area over which the
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`navigation system operates.” I agree with this construction based on the claims and
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`specification of the ’234 patent. The term “coverage area” does not appear in the
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`specification of the ’234 patent. However, in the context of claims 1, 9, 17, and 24,
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`“coverage area” is a subset of the navigation coverage, which is addressed above.
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`For example, claim 1 refers to a “coverage area including the location of the
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`navigation device.” (Id., 13:65-67.) Claim 1 also characterizes a scenario in which
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`“the coverage area is different from one or more areas in navigation coverage
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`defined by the origination and destination,” suggesting that the “coverage area” is a
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`subset of the overall navigation coverage. (Id., 14:3-5.) Claims 9, 17, and 24
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`characterize the “coverage area” in substantively the same manner. The
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`construction is also consistent with my review of the file history and how one of
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`ordinary skill in the art would have understood the term in context of the ’234
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`patent. I have applied this understanding in my analysis.
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`29.
`
`I have been asked to assume that the broadest reasonable
`
`interpretation of the “processing unit for searching the database for traffic
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`information specific to a coverage area including the location of the vehicle”
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`recited in claim 17, and the “processing unit for searching the database for weather
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`information specific to a coverage area including the location of the vehicle”
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`recited in claim 24, includes “a server, a processor of a navigation device, or
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`equivalents thereof.” I have applied this understanding in my analysis.
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`VII. THE PRIOR ART DISCLOSES ALL OF THE FEATURES OF
`CLAIMS 1-30 THE ’234 PATENT
`30.
`
`I have reviewed several references, discussed further below, that I
`
`understand are prior art to the ’234 patent. In my opinion, these references disclose
`
`all features of claims 1-30 of the ’234 patent.
`
`A. Overview of Xu
`31. Xu relates to “traffic data collection and intelligent routing systems for
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`highway vehicles,” including a “system and method for remotely collecting real-
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`time traffic data and providing traffic forecasts and travel guidance for drivers of
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`vehicles equipped to utilize the system.” (Ex. 1004 at 1:6-11.) Figure 1, which I
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`show below, illustrates one example of a “traffic data remote collection and
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`13
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`intelligent vehicle highway system” that performs a method for navigation. (Id.,
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`6:26-28.)
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`
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`(Id., 6:26-28, Fig. 1.)
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`32. The traffic data remote collection and intelligent vehicle highway
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`system includes a “group of vehicles 20 [that] travel a roadway system 10.” (Id.,
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`6:28-29.) An example of the roadway system 10 is shown in Figure 4:
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`(Id., 8:40-50, Fig. 4.) Figure 5 depicts an example of a digitized road network
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`representing roadway system 10:
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`(Id., 8:50-52, Fig. 5.)
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`33.
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`“Each vehicle 20 is equipped with an in-vehicle device 21.” (Id., 6:31-
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`32, Fig. 2 (reproduced below).)
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`(Id., Fig. 2.) The in-vehicle device 21 has a “vehicle support sub-system 30,”
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`which “includes a road network locator 32 (hereinafter locator 32) and a road
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`explorer 34.” (Id., 7:21-23.) The in-vehicle device 21 also has a “computer system
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`26 for operating the sub-systems and storing the digitized road network map,” as
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`well as a “mobile radio sub-system 24 . . . for exchanging radio frequency data
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`with [a] traffic service center 60,” and a “driver interface 28 . . . to permit drivers
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`to interact with the in-vehicle device 21.” (Id., 7:23-31.)
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`34. The “locator 32 computes the geographical location of the vehicle,
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`using data received from [a] GPS receiver 22, and converts it to a position on the
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`digitized road network map, which is broadcast from the traffic service center 60
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`via the communication station 50 and stored in the computer system 26.” (Id.,
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`7:32-37; see also id., Fig. 3 (depicting the traffic service center 60).)
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`17
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`(Id., Fig. 3.)
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`35. The digitized road network map provided by traffic service center 60
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`includes “nodes 14 and links 16 indicating a traffic direction. The node 14 may
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`represent an intersection of two or more roads, an entry to a parking lot, a junction
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`of a highway with an entry or exit ramp, a starting or an endpoint of a bridge, a
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`tunnel, an overpass or an arbitrary location on a road. A link 16 represents a road
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`segment with an orientation indication, which connects two nodes 14 of the road
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`network.” (Id., 8:58-65.)
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`B. Overview of Golding
`36. Golding discloses a “route planning and navigation system,” an
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`example of which is shown in Figure 1:
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`(Id., 4:31-33, Fig. 1.) The route planning and navigation system includes a vehicle
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`navigation system 1, which is “located on each automobile within the system,” and
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`a central database 2. (Id., 4:31-34.) Golding explains that data collector 12 of
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`navigation system 1 collects travel time information for various street segments,
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`which is transmitted by wireless communication device 14 to central database 2 for
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`storage. (Id., 3:33-37, 5:5-58.)
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`(Id., 4:26-27, 6:11-27, Fig. 2 (depicting an example of the data stored by central
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`database 2).)
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`37. Route advisor 13 of vehicle navigation system 1 is configured to
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`determine a “best route from a starting point to a destination location.” (Id., 4:49-
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`50.) To do so, route advisor 13 uses travel time information available at central
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`database 2 to determine a route having minimum travel time. (See, e.g., id., 3:29-
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`31.) Golding explains, however, that “in order to limit the required memory, the
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`route advisor [13] can have travel time information for only a portion of the map
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`database in which the automobile is presently located. The route advisory could
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`then obtain any additional travel time information from the central database, as
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`needed.” (Id., 4:53-58.) For example, “[w]hen planning a route, the route advisor
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`13 can contact the central database 2 to obtain updated information for the
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`locations of interest.” (Id., 6:32-34.)
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`C. Overview of Trovato
`38. Trovato discloses a “travel direction speaking system.” (Ex. 1005 at
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`Abstract.) In Trovato, a “computer determines a route between an origin and a
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`destination using an electronic map,” along with “driving instructions” associated
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`with turns that a driver will need to make. (Id., 2:6-11.) A driving instruction is
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`output when a GPS reading is within a specified range of the position associated
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`with the driving instruction. (Id., 2:11-16.) A driving instruction is output using a
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`“text to voice unit that converts the text driving instructions into a voice signal.”
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`(Id., 2:34-35.)
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`(Id., Fig. 1 (depicting the GPS unit 118 and text to voice converter 120).)
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`(Id., 5:64-67, Fig. 4 (depicting the process that is performed in determining which
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`direction to issue and when to issue the direction).)
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`39. Trovato selects the “specified range” at which the driving instruction
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`is output in a manner that can ensure “there is enough time to speak the directions
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`sufficiently in advance of the turn to allow the driver to make the turn.” (Id., 1:58-
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`60; see also id., 2: 16-27.)
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`D.
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`Claims 1-7, 9-15, 17-21, 23-28, and 30 of the ’234 Patent
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`1.
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`Xu Discloses the Features of Claims 1-7, 9-15, 17-21, 23-28,
`and 30
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`40.
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`In my opinion, Xu discloses all of the features recited in claims 1-7, 9-
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`15, 17-21, 23-28, and 30 of the ’234 patent.
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`41. As described below, Xu discloses the features of claim 1:
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`La: A method for
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`Xu discloses a method for navigation using a navigation
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`navigation using a
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`device (in-vehicle device 21) which includes a location-
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`navigation device
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`sensing element (locator 32 and GPS receiver 22). (See my
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`which includes 3
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`analysis and citations above in VII.A.)
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`location-sensing
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`_
`.
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`For example, Xu discloses that in-vehicle device 21 has a
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`element therein, the
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`“vehicle support sub—system 30,” which “includes a road
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`method comprising:
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`network locator 32 (hereinafter locator 32) and a road
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`explorer 34-” (Ex. 1004 at 7:21-23.) The in-vehicle device
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`21 also has a “computer system 26 for operating the sub-
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`systems and storing the digitized road network map,” as
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`well as a “mobile radio sub—system 24 .
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`.
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`. for exchanging
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`Claim Language
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`Xu
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`radio frequency data with [a] traffic service center 60,”
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`and a “driver interface 28 .
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`.
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`. to permit drivers to interact
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`with the in—vehicle device 2 1
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`(Id., 7:23-31.)
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`The “locator 32 computes the geographical location of the
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`vehicle, using data received from [a] GPS receiver 22, and
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`converts it to a position on the digitized road network map,
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`which is broadcast from the traffic service center 60 via
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`the communication station 50 and stored in the computer
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`system 26.” (Id., 7:32-37; see also id., Fig. 3 (depicting the
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`traffic service center 60).)
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`Lb: forming a
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`Xu discloses forming a database storing traffic information
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`database storing
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`for extraction thereof with respect to areas.
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`traffic information
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`_
`_
`_
`_
`The traffic data remote collection and intelligent vehicle
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`for extraction thereof
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`_
`_
`_
`_
`highway system in IQ: includes a “traffic service center
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`with respect to areas;
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`_
`_
`_
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`60,” as shown in Figure 3, which includes collections of
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`data that disclose the claimed “database.”
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`Claim Language
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`Xu
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`Traffic
`Forecaster
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`9313
`EX°l‘39°
`Interface
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`EPD
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`(Ex. 1004 at Fig. 3.)
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`The traffic service center 60 includes “[a] data exchange
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`interface 62
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`provided for connection of the
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`communication station 50 for receiving the vehicle
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`position data and sending data respecting the digitized
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`road network maps and real-time traffic forecast data
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`which are to be broadcast.” (Id., 8: 19-23 (emphasis
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`added).) In addition, “[a]n external party interface 64 is
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`provided to connect the external party data sources 70 to
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`receive real-time information about weather or road
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`conditions. The real-time information is processed by an
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`Claim Language
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`Xu
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`external party data integrator 65 for incorporation into
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`real-time traffic forecasts.” (Id., 8:23-28 (emphasis
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`added).) In other words, traffic service center 60 receives
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`data relating to traffic information from both vehicles and
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`external party data sources.
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`Traffic service center 60 uses the received data to form
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`collections of data relating to traffic information for
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`extraction thereof with respect to areas. For example, Xu
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`explains that “traffic forecasts are computed by a traffic
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`forecaster 68 using the collected vehicle position data
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`for normal road conditions. The collected vehicle position
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`data received from the data exchange interface 62 is stored
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`in a database 66 to be processed by the traffic forecaster
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`68.” (Id., 8:28-33 (emphasis added).) With respect to how
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`traffic forecaster 68 computes the traffic forecasts, Jfil
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`explains that the “traffic forecaster 68 retrieves traffic data
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`for two adjacent nodes from the database 66, and
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`determines a time at which the vehicle was on the source
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`Claim Language
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`Xu
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`node of the link and a time the vehicle was on the sink
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`node of the link,” wherein the “travel time of the vehicle
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`for the link is determined by calculating a difference
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`between the two times” and the “travel speed for the link is
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`determined by dividing a length of the link by the travel
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`time.” (Id., 11:50-57; see also id., 11:57-60 (“The data
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`including the travel time, or vehicle travel speed for each
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`link are computed from time to time from each vehicle 20
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`to provide a database for forecasting traffic conditions
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`for the roadway system 10.”) (emphasis added).)
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`InXu, a “link” (e.g., with respect to the “links” discussed
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`above) represents “a road segment with an orientation
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`indication, which connects two nodes 14 of the road
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`network,” wherein a “node” (e.g., with respect t