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
`
`____________________
`
`GOOGLE INC.
`Petitioner
`
`v.
`
`SILVER STATE INTELLECTUAL TECHNOLOGIES, INC.
`Patent Owner
`
`____________________
`
`U.S. Patent No. 8,538,498
`____________________
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`DECLARATION OF DR. WILLIAM R. MICHALSON
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`Google Exhibit 1007
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`Page 1 of 135
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`By: Naveen Modi (Google-Silverstate-IPR@paulhastings.com)
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`Joseph E. Palys (Google-Silverstate-IPR@paulhastings.com)
`
`Daniel Zeilberger (Google-Silverstate-IPR@paulhastings.com)
`
`Paul Hastings LLP
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`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`GOOGLE INC.
`Petitioner
`
`v.
`
`SILVER STATE INTELLECTUAL TECHNOLOGIES, INC.
`Patent Owner
`
`____________________
`
`U.S. Patent No. 8,538,498
`____________________
`
`DECLARATION OF DR. WILLIAM R. MICHALSON
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`Google Exhibit 1007
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`Page 1 of 135
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`TABLE OF CONTENTS
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`Introduction ..................................................................................................... 1
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`
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`I.
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`II. Qualifications .................................................................................................. 1
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`III. Summary of Opinions ..................................................................................... 4
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`IV. Level of Ordinary Skill ................................................................................... 5
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`V.
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`The ’498 Patent ............................................................................................... 6
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`A. Overview of the ’498 Patent ................................................................. 6
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`B. General Background ........................................................................... 10
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`VI. Claim Construction ....................................................................................... 13
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`VII. The Prior Art Discloses All of the Features of Claims 1-24 the ’498
`Patent ............................................................................................................ 15
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`A. Overview of Maekawa ....................................................................... 15
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`B. Overview of Dickson .......................................................................... 22
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`C. Overview of Spiegel ........................................................................... 26
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`D.
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`E.
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`The Combination of Maekawa and Dickson Discloses the
`Features of Claims 1-4, 7-16, and 19-24 of the ’498 Patent .............. 27
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`The Combination of Maekawa, Dickson, and Spiegel Discloses
`the Features of Claims 5, 6, 17, and 18 of the ’498 Patent ................ 85
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`VIII. Conclusion .................................................................................................... 96
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`-i-
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`I, William R. Michalson, declare as follows:
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`I.
`
`INTRODUCTION
`1.
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`I have been retained by Google Inc. as an independent expert
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`consultant in this proceeding before the United States Patent and Trademark Office
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`(“PTO”) regarding U.S. Patent No. 8,538,498 (“the ’498 patent,” which I
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`understand is Ex. 1001 in this proceeding). I have been asked to consider whether
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`certain references disclose the features recited in claims 1-24 of the ’498 patent.
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`My opinions are set forth below.
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`2.
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`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.
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`II. QUALIFICATIONS
`3.
`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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`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).
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`7.
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`I have worked in the field of computer architecture and computer
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`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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`design. In addition, I teach classes in Electrical and Computer Engineering Design,
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`Foundations of Robotics and Robot Navigation. I have worked extensively in
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`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.
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`8.
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`GPS and GPS-related technologies have dominated the bulk of my
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`research since 1992. I have been involved in numerous academic and consulting
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`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
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`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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`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 ’498 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
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`during that time.
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`10. My curriculum vitae, which includes a more detailed summary of my
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`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
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`documents I reviewed, my knowledge and experience, and professional judgment.
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`In forming the opinions expressed in this Declaration, I reviewed the ’498 patent
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`(Ex. 1001), the prosecution file history for the ’498 patent (which I understand is
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`Ex. 1002 in this proceeding), U.S. Patent No. 6,040,824 to Maekawa et al.
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`(“Maekawa”) (which I understand is Ex. 1004 in this proceeding), U.S. Patent No.
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`6,574,603 to Dickson et al. (“Dickson”) (which I understand is Ex. 1005 in this
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`proceeding), U.S. Patent No. 6,629,079 to Spiegel et al. (“Spiegel”) (which I
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`understand is Ex. 1006 in this proceeding), and any other materials I refer to in this
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`declaration in support of my opinions, while drawing on my experience and
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`knowledge of communications systems and location-based 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 1-24 of the ’498 patent, as I
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`discuss in detail below.
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`13. Although this Declaration refers to selected portions of the cited
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`references for the sake of brevity, it should be understood that one of ordinary skill
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`in the art would view the references cited herein in their entirety and in
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`combination with other references cited herein or cited within the references
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`themselves. The references used in this Declaration, therefore, should be viewed as
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`being incorporated herein in their entirety.
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`IV. LEVEL OF ORDINARY SKILL
`14. Based on my knowledge and experience, I understand what a person
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`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
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`many such persons over the course of my career. My opinions herein are, where
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`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.
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`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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`’498 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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`5
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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.
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`V. THE ’498 PATENT
`A. Overview of the ’498 Patent
`16. The ’498 patent, entitled “Technique for Effective Navigation
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`Communications with, and Provision of Global Positioning System (GPS) Based
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`Advertising Information to, Automobiles,” issued on September 17, 2013, from
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`U.S. Application No. 11/445,685, which was filed on June 1, 2006. (Ex. 1001.) I
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`have been asked to assume for purposes of this proceeding that the effective date
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`of the ’498 patent is December 23, 1998, which is the filing date of a provisional
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`application to which the ’498 patent claims priority. I apply this understanding in
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`my analysis herein.
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`17. The ’498 patent discloses an information and control system for use in
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`a vehicle capable of communicating with remote servers through a
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`communications network. (Id. at 3:57-62, Fig. 1.) The system includes a user
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`interface having a display that presents several options on a main directory page,
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`including an option to view services or product providers (e.g., restaurants, gas
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`stations, department stores) within a selected distance of the vehicle’s current
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`location. (Id. at 10:56-60, 13:31-47, Fig. 6.)
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`18. Upon selection of, for example, the restaurant option, icons (also
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`called “tags”) representing location of restaurants around the vehicle’s current
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`location are displayed. (Id. at 13:48-14:5, Fig. 7.)
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`19. Further information about a particular restaurant is displayed when the
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`user selects a corresponding “tag.” (Id. at 15:11-14, 15:48-52, Fig. 9.) For example,
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`the restaurant’s business hours and phone number are displayed along with options
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`for obtaining directions to the restaurant (“NAVIGATE”) and the restaurant menu
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`(“RESTAURANT MENU”). (Id. at 16:3-6, 16:15-17, 16:30-35, Fig. 9.)
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`20. The user may select items from the restaurant menu and place a
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`corresponding order by selecting an “ORDER” key. (Id. at 16:28-41, Fig. 10.)
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`21. The ’498 patent includes two independent claims, claims 1 and 13.
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`Claims 2-12 depend directly or indirectly from claim 1, and claims 14-24 depend
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`directly or indirectly from claim 13.
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`B. General Background
`22. By the early 1990s, real-time information, geographic information
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`systems and databases became key components in the transportation industry,
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`specifically in the field of Intelligent Vehicle Highway Systems. Indeed, by that
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`time, there had been significant activity in the area of automobile navigation
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`systems. For instance, by 1987, “[a]utomobile navigation systems based on dead
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`reckoning, map matching, satellite positioning and other navigation technologies
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`[were] under active development.” (Ex. 1008, R.L. French, “Automobile
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`navigation: Where is it going?,” Aerospace and Electronic Systems Magazine, pp.
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`6-12, May 1987 at 6). Efforts were under way to make the user interface associated
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`with navigation systems more intuitive. For instance, it was recognized that the
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`“primary use of navigation systems is in finding the location of destinations,
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`usually specified by street address but also by street intersection or major
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`landmark.” (See Ex. 1009, White, Car Navigation Systems, Geographical
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`Information Systems: Principles and Applications, D.J. Maguire, et. al., eds., Vol.
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`2, pp. 115-125, Longman Group, 1991 at 121.) A disclosed user interface
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`“provided 12 buttons for input and the user only needs to enter a few characters
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`before selecting from a list of possible cities or street names.” (Id.) And the users
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`could also find “the nearest hardware store or service station.” (Id.)
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`23. Commercial embodiments of navigation systems had reduced to
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`practice the concept of providing an information rich vehicle navigation system.
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`One such system was the TravTek system, which was a joint project between the
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`Federal Highway Administration, the Florida Highway Department, the American
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`Automobile Association, Oldsmobile, and Avis that was in public use from March
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`1992 to March 1993. (See Ex. 1010, TravTek Evaluation Rental and Local User
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`Study, Pub. No. FHWA-RD-96-028, March 1996 at 1.) The TravTek system
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`included a computer mounted within a car that displayed a map on a six-inch
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`touch-screen device showing the user’s current position and turn-by-turn directions
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`to a selected destination. The user could select to view the entire route on the
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`screen, or zoom in to display only the portion leading up to the next turn, as shown
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`in the figure below. (Id.)
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`24. A database was stored in the user’s device and updated from the
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`Traffic Management Center. The user could search the database for local
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`accommodations, restaurants, attractions, bank automatic teller machines, and then
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`display a selected item on the map or plot a route to a selected item, as shown
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`below. (Ex. 1010 at 5.)
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`25. While there had been significant advance in the interface design for
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`navigation systems, it was recognized that navigation systems need to be more
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`“information rich.” (Ex. 1011, Green, Potential Safety Impacts of Automotive
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`Navigation Systems, Proceedings of Automotive Land Navigation Conference,
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`June 18, 1997 at 5.) “At this time, navigation systems in the U.S. do not support
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`information retrieval. In Japan, systems tend to be more information rich, and
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`hence the use of the term ‘infomobile’ instead of ‘automobile.’ Data on the
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`potential tasks a driver might perform is lacking, but use of yellow page functions
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`to obtain information on potential destinations in great detail (even the menu for a
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`restaurant) is a possibility.” (Id.)
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`26. By the time Maekawa, Dickson, and Spiegel were filed in the mid-to-
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`late 1990s, there had been a significant advancement in the interface design for
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`navigation systems and efforts were under way to design information rich
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`navigation systems.
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`VI. CLAIM CONSTRUCTION
`27.
`I understand that a claim subject to inter partes review receives the
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`broadest reasonable interpretation in light of the specification and file history of
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`the patent in which it appears. I also understand that any term that is not construed
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`should be given its plain and ordinary meaning under the broadest reasonable
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`interpretation. I have followed these principles in my analysis. I discuss one claim
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`term below and what I understand to be Petitioner’s construction of this term,
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`which I apply in my analysis. The remaining claim terms in the ’498 patent are
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`13
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`given their plain and ordinary meaning under the broadest reasonable
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`interpretation, which I also apply in my analysis.
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`28.
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`I understand that Petitioner has proposed that the broadest reasonable
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`interpretation of the claimed term “selected status” is “a representation reflecting a
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`previous order of a product or service.” I agree with this construction based on the
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`claims and specification of the ’498 patent. For example, while the ’498 patent
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`does not use the term “selected status” anywhere in its specification, it discloses a
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`scenario in which a previously ordered menu item is “highlighted in a
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`distinguishable color.” (Ex. 1001 at 16:63-17:4.) According to the ’498 patent,
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`“such a color highlight advantageously triggers the user’s memory about the
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`selected items, and thereby helps him/her to decide whether or not to reselect the
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`same items.” (Id.) The construction is also consistent with my review of the file
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`history and how one of ordinary skill in the art would have understood the term in
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`context of the ’498 patent. I have applied this understanding in my analysis.
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`29.
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`I have been asked to assume that the broadest reasonable
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`interpretation of a “device” for sensing a location for the vehicle, as recited in
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`claim 13 is a “GPS receiver, or equivalents thereof.” I have been also asked to
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`assume that the broadest reasonable interpretation of a “processor” configured to
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`provide for display on the display element of the indication of the selectable option
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`to order, through a communications network, one or more of the plurality of
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`products or services based on the information, as recited in claim 13 is a
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`“processor, or equivalents thereof.” I have applied this understanding in my
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`analysis.
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`VII. THE PRIOR ART DISCLOSES ALL OF THE FEATURES OF
`CLAIMS 1-24 THE ’498 PATENT
`30.
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`I have reviewed several references, discussed further below, that I
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`understand are prior art to the ’498 patent. In my opinion, these references disclose
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`all features of claims 1-24 of the ’498 patent.
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`A. Overview of Maekawa
`31. Maekawa relates to “an information display system provided with a
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`touch panel suitable for a navigation system or the like.” (Ex. 1004 at 1:7-9.) In its
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`background, Maekawa discloses that “[i]n prior art information display systems
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`having touch panels, a variety of information such as menu items are displayed on
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`a display unit, and choices are input by manually touching selected items of the
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`displayed information through the touch panel.” (Id. at 1:11-15.)
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`32. Maekawa discloses a vehicular navigation system that includes a
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`“display 12 . . . mounted in the instrument panel of the vehicle . . . .” (Id. at 4:34-
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`35, Fig. 1.)
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`(Id. at Fig. 1.) “The vehicular navigation system includes: an input/output unit 1
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`for inputting/outputting information on a route guide; a present position detecting
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`unit 2 for detecting information on the present position of a vehicle; an information
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`memory unit 3 having recorded navigation data necessary for calculating the route,
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`display/voice guide data necessary for providing guidance along the route, and
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`application and/or operating system (OS) programs; and a central processing unit 4
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`for controlling the entire system.” (Id. at 3:50-58.) “The display 12 is equipped
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`with the touch screen 11 having switch elements overlying the displayed function
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`buttons so that the input operations may be executed by touching the button.” (Id.
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`at 4:37-40.) “The present position detecting unit 2 detects or receives information
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`on the present position of the vehicle and includes . . . a GPS receiver utilizing the
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`satellite navigation system (GPS) . . . .” (Id. at 4:45-53.)
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`33.
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`“The information memory unit 3 is an external unit, for example a
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`CD-ROM, having stored programs and data necessary for navigation. . . . For
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`example, the stored data includes all the data necessary for the navigation system
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`such as files of map data, search data, guide data, map matching data, destination
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`data and registered point data.” (Id. at 4:60-5:8.) “The central processing unit 4
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`includes: a CPU 40 for executing a variety of processor or arithmetic operations
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`. . . .” (Id. at 5:8-10.)
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`34. Maekawa discloses with respect to FIG. 4, “a flowchart of the overall
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`operation of the navigation system of FIG. 1.” (Id. at 2:52-53.) During operation of
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`the system reflected in FIG. 4, Maekawa discloses that a peripheral map around a
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`present position of the vehicle and route information for a selected destination may
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`be displayed. (Id. at 6:44-62.) For example, Maekawa discloses that in step S2 of
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`the flowchart the present position of the vehicle is detected by a present position
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`detecting unit 2 of the vehicular navigation system and a peripheral map displayed
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`around the position. (Id. at 6:51-54.)
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`35.
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`“FIG. 5A shows a road map display screen around the present position
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`marker in the display unit provided with the touch panel. On the screen, several
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`touch buttons or switches are displayed in addition to an azimuth or direction
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`indicating mark and a distance scale unit. The displayed touch switches include a
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`peripheral search touch switch for initiating a search for the facilities around the
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`present position; a detail touch switch for displaying a detailed map; a whole route
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`touch switch for initiating a new search for a route to the destination; a re-search
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`touch switch for the starting a re-search by searching the periphery; a wide-range
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`touch switch for displaying a wide-range map; and a return switch for returning to
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`an initial screen for route guidance.” (Id. at 6:63-7:8.) “If the peripheral search
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`switch is touched as illustrated in FIG. 5B, the screen of FIG. 5C is displayed
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`wherein the lower portion of the screen shows facility selecting switches such as
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`switches for selecting a convenience store, a parking lot or garage, a gas station, a
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`family restaurant, a bank and so on.” (Id. at 7:9-14.)
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`(Id. at Figs. 5A, 5B, 5C.)
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`36.
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`“[I]f the switch convenience store is selected by touching as shown in
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`FIG. 5D, the screen of FIG. 6A is displayed to show landmarks of convenience
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`stores at their locations surrounding the present position.” (Id. at 7:14-17.)
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`(Id. at Figs. 5C, 5D, 6A.)
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`37. As shown in Fig. 6A above, indicators of landmarks such as
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`restaurants and convenience stores are displayed on the display unit and labelled
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`with letters, such as “D,” “F,” “G,” etc. (Id. at 7:25-27, “an ‘F mart’ as indicated by
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`the landmark F, is displayed in the road map”).
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`38. Maekawa discloses that when the displayed indicator of a landmark of
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`a service provider (e.g., a restaurant) is selected by the user, further information
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`(e.g., business hours, the business content and/or the telephone number) about the
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`service provider is displayed. (Id. at 7:23-45, explaining that when a landmark is
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`touched as shown in the Fig. 6B, “the screen of FIG. 7, may display the business
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`hours, the business content and/or the telephone number of the facility indicated by
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`the landmark F.”) An example of display of such additional information in
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`response to a user selection of the landmark indicators is shown in Fig. 13B, where
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`a landmark indicated by “Y” is selected. (Id. at 9:52-58.)
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`(Id. at Fig. 13B.)
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`B. Overview of Dickson
`39. Dickson generally “relates to an in-vehicle interface allowing
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`occupants of the vehicle to place orders from within the vehicle for items provided
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`by a . . . restaurant . . . . Occupants in the vehicle are provided a menu on a display
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`of an in-vehicle interface. The occupants may select any number of desired items
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`to form an occupant order. The occupant order is stored and/or transmitted directly
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`or indirectly to the . . . restaurant for processing.” (Ex. 1005 at Abstract.)
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`40. Dickson discloses “a vehicle . . . equipped with an intelligent vehicle
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`controller (IVC) 1100 providing interactive multimedia access for the driver and
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`passengers of the vehicle. . . . The primary purpose of the IVC is to provide an
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`interactive communication medium allowing customers to interface remote
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`systems to 1) display menu information, 2) receive advertising, merchandising and
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`possibly menu indicia and, in return, 3) order and provide payment for selected
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`items from within the vehicle.” (Id. at 9:31-43.) The IVC 1100 is illustrated in
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`Figs. 4A and 4B.
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`(Id. at Figs. 4A, 4B.) “The IVC may also be associated with . . . a user input
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`means, such as a keypad, mouse or touch screen electronics 1120, a video display
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`1122, a card reader 1124, and a printer 1126. These features cooperate to provide a
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`Page 25 of 135
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`basic multimedia interface and means for paying for items ordered through the
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`IVC 1100.” (Id. at 10:21-25.)
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`41.
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`“In operation, the IVC is configured to 1) provide pre-stored or
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`downloaded information, such as menu information, to the occupants of the
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`vehicle, 2) receive order entries from one or more of the occupants, and 3) effect
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`transfer of the occupant order to the necessary communication electronics
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`associated in some manner with the QSR [quick-serve restaurant] to effect order
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`processing. With reference to FIGS. 11A-11C, a basic order entry, monitoring, and
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`receipt process is described.” (Id. at 18:15-23.)
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`Page 26 of 135
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`(Id. at Fig. 11A.)
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`42. Dickson explains that “[o]nce the occupant views the menu, the IVC
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`will receive occupant selections . . . and store these selections in the IVC as an
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`order . . . . Depending on the location of the vehicle and whether or not the vehicle
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`25
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`Page 27 of 135
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`is within communication range with the corresponding communication electronics
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`(. . . satellite, cellular or other), the information may be automatically transmitted
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`or transmitted upon receiving an occupant input to that effect.” (Id. at 18:41-48.)
`
`C. Overview of Spiegel
`43.
`Spiegel discloses “a computer system for conducting electronic
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`commerce.” (Ex. 1005 at Abstract.) In particular, Spiegel discloses a computerized
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`system and process for ordering products over a network. (See, e.g., id. at 4:3-27,
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`6:59-7:31.) Spiegel explains that the features of presenting a list of items for
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`purchase by a user and viewing, selecting, and ordering products over a network in
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`a computerized environment were conventional and known at least as early as June
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`25, 1998, the filing date of Spiegel. (See id. at 2:1-20, explaining how users could
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`electronically view a catalog of items to purchase (e.g., books, music, etc.), select
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`certain items, and order the items over a network.) Spiegel explains that the use of
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`electronic shopping carts to perform these conventional processes was also known.
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`(Id. at 2:21-34.) In Spiegel’s disclosed systems and processes, an electronic cart
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`displays “a current order box 201, the past order box 202, and a general
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`information box 203.” (Id. at 6:17-20.) (See also Fig. 2, illustrating such a cart.)
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`(Id. at Fig. 2.)
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`44.
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`Spiegel explains that “[t]he current order box contains information
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`relating to items currently in the shopping cart that have not yet been checked out.”
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`(Id. at 6:20-22.) “When the current order is checked out, it becomes a past order
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`and status information is displayed in the past orders box.” (Id. at 6:26-28.)
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`D. The Combination of Maekawa and Dickson Discloses the Features
`of Claims 1-4, 7-16, and 19-24 of the ’498 Patent
`In my opinion, the combination of Maekawa and Dickson discloses all
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`45.
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`of the features recited in claims 1-4, 7-16, and 19-24 of the ’498 patent.
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`27
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`Page 29 of 135
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`46. As described below, the combination of Maekawa and Dickson
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`discloses the features of claim 1:
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`Claim Language
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`Maekawa and Dickson
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`La: A method for Maekawa discloses a method for use in a system in a vehicle,
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`use in a System in
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`the Vehicle including a display element.
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`a vehicle, the
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`_
`_
`_
`Maekawa discloses a method with respect to FIG. 4, which
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`vehicle including
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`_
`_
`_
`_
`“is a flowchart of the overall operation of the navigation
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`a display element,
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`_
`_
`system of FIG. l.” (Ex. 1004 at 2:52-53.) The navigation
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`the method
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`comprising:
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`_
`_
`_
`_
`_
`system of FIG- 1 1S disclosed as a vehicular navigation
`system, which is a “system in a vehicle.” (Id. at 3:48-49.)
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`Maekawa also discloses that the Vehicular navigation system
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`and hence, the vehicle, includes a “display 12 .
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`.
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`. mounted in
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`the instrument panel of the vehicle .
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`.
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`.
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`(Id. at 4:34-35; Fig.
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`1.) The display 12 is a “display element,” which is sometimes
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`referred to by Maekawa as a “display unit.” (See, e.g., id. at
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`6:64, 10:9-15; see also id. at Figs. 5A-9B; my analysis and
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`citations above in VH.A; my analysis and citations below for
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`the remaining elements of this claim.)
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`Maekawa discloses sensing a locationofthevehicle.
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`Page 30 of 135
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`Claim Language
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`Maekawa and Dickson
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`location of the
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`For example, Maekawa discloses that the disclosed method of
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`vehicle;
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`Fig. 4 includes a step S2 in which the present position of the
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`vehicle is detected by a present position detecting unit 2 of
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`the Vehicular navigation system. (Ex. 1004 at 6:51-54; see
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`also id. at 3:50-53, “vehicular navigation system includes .
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`.
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`.
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`a present position detecting unit 2 for detecting information
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`on the present position of a Vehicle-”) (See also id. at Fig. 2,
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`4:45-53, 6:44-54, Fig. 4.) Fig. 6A, for example, shows the
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`sensed location of the vehicle.
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`Page 31 of 135
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`29
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`Claim Language
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`Maekawa and Dickson
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`(Id. at Fig. 6A.)
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`Therefore, Maekawa discloses sensing a location of the
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`vehicle. (See also my analysis and citations above in VII.A.)
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`1.c: showing, on
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`the display
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`element, at least
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`Maekawa also discloses showing, on the display element, at
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`least one indicator indicating a location of at least one
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`product or service provider in relation to the sensed location
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`one indicator
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`of the Vehicle.
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`indicating a
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`location of at least
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`one product or
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`service provider
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`in relation to the
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`sensed location of
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`the vehicle;
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`For example, Maekawa discloses that a road map is displayed
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`in Fig. 5A “around the present position marker in the display
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`unit,” which corresponds to the claimed “display element.”
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`(Ex. 1004 at 6:63-65, emphasis added.) When the “peripheral
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`search switch” on the display unit “is touched as illustrated in
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`FIG. 5B, the screen of FIG. 5C is displayed wherein the
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`lower portion of the screen shows facility selecting switches
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`such as switches for selecting a convenience store, a parking
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`lot or garage, a gas station, a family restaurant, a bank and so
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`on. For example if the switch convenience store is selected
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`by touching as shown in FIG. 5D, the screen of FIG. 6A is
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`Page 32 of 135
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`30
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`Claim Language
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`Maekawa and Dickson
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`displayed to show landmarks of convenience stores at
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`their locations surrounding the present position.” (Id. at
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`7:9—16, emphasis added; see also id. at Figs. 5A, 5B, 5C, 5D,
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`6A.)
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`As shown in Fig. 6A above, indicators of landmarks such as
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`restaurants and convenience stores (“at least one product or
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`service provider”) are displayed on the display unit and
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`Page 33 of 135
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`31
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`Claim Language
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`Maekawa and Dickson
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`labelled with letters, such as
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`etc. (Id. at 7:25-
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`27, “an ‘F mart’ as indicated by the landmark F, is display
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