Patent No. 7,072,667
`Petition For Inter Partes Review
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`APPLE INC.,
`Petitioner
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`v.
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`CORE WIRELESS LICENSING S.A.R.L.,
`Patent Owner
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`Patent No. 7,072,667
`_______________
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`Inter Partes Review No. ______
`____________________________________________________________
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`DECLARATION OF KEVIN S. JUDGE
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`Apple Inc. Exhibit 1002 Page 1
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`
`Petition For Inter Partes Review
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`APPLE INC.,
`Petitioner
`
`v.
`
`CORE WIRELESS LICENSING S.A.R.L.,
`Patent Owner
`
`Patent No. 7,072,667
`_______________
`
`Inter Partes Review No. ______
`____________________________________________________________
`
`DECLARATION OF KEVIN S. JUDGE
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`Apple Inc. Exhibit 1002 Page 1
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`Inter Partes Review of USP 7,072,667
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`Docket No. 106840000522
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`I, Kevin S. Judge, make this declaration in connection with the proceeding
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`identified above.
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`I.
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`INTRODUCTION
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`1.
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`I have been retained by counsel for Apple Inc. (“Petitioner”) as a
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`technical expert in connection with the proceeding identified above. I submit this
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`declaration in support of Apple, Inc.’s Petition for Inter Partes Review of United
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`States Patent No. 7,072,667 (“the ’667 patent”).
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`2.
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`I am being paid at an hourly rate for my work on this matter. I have
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`no personal or financial stake or interest in the outcome of the present proceeding.
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`II. QUALIFICATIONS
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`3.
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`I am currently employed as a senior engineer at John Deere in the
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`Advanced Engineering group designing the next generation of Global Navigation
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`Satellite System (GNSS) receivers for precision farming. I hold a Bachelor of
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`Science degree in Mathematics, and I am the owner of Judge Software Systems,
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`Inc., which provides consulting services for wireless communication and location.
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`4.
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`I have been designing and implementing systems for wireless
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`communication and location for the past 25 years.
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`5.
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`In particular, from 1987 to 1993 I was a programmer and analyst at
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`Magnavox Advanced Products Division, designing and implementing 1990’s core
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`GPS software. As part of my role, I worked on the navigation Kalman filter and
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`the receiver tracking control system.
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`6.
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`From 1993 to 1995, I was a software engineer and analyst at Interstate
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`Electronics Corporation, where I was responsible for the design and development
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`of the navigation processor for an aircraft navigation management system. My
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`responsibilities included writing the requirements for and participating in the
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`design, coding, and testing of all aspects of the GPS navigation code.
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`7.
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`From 2000 to 2004, I was the Senior Vice President of Software and
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`Systems at In-Sync Interactive Management Company, where I designed and
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`managed the creation of a complete wireless TDMA data network, including
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`Internet client/server software and the base station and endpoint modems. While at
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`Greenfield, I also designed the wireless protocol for robust communication.
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`8.
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`From 1996 to 2009, at Greenfield Associates, I designed and managed
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`the development of a GPS traffic preemption system, including the development of
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`a low cost differential base station and a TDMA scheme for data transfer. I also
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`implemented a precise golf ranging system using locally broadcast differential
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`corrections.
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`9.
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`From 2004 to 2009, I was an Engineering Manager at NorBelle, LLC,
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`where I designed and contributed to the implementation of a real time mobile-to-
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`mobile tracking application for assisted GPS mobile phones. The system included
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`an Internet-based back-end server over which a proprietary messaging system was
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`hosted. I designed the accuracy enhancing technology using GPS and cellular
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`trilateration critical to the usability of the application.
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`10. From 1999 to 2012, I represented SiRF Technology, Inc. in the 3GPP
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`and 3GPP2 standards committees helping to shape the standards for location
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`services in CDMA and GSM/UMTS. I also served as the chairman for the CDMA
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`Location Services standards committee. The 3GPP2 standards body, a sub-
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`working group for Location Services, is an international consortium of individuals
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`representing companies interested in developing standards for mobile location
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`technology. As chairman, I oversaw the development of the IS-801 A-1
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`specification used today by all CDMA mobile phones to receive location assistance
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`for both regulatory and commercial systems.
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`11. From 2008 to 2012, I was one of the three founding members of
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`Integrated Positioning, LLC, where I designed, built, and integrated a location
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`platform for a WiMax Network. I designed the backend systems to facilitate the
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`needs of the location platform to seed AGPS solutions for E-911 integration.
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`12. From 2011 to 2013, at Level8, I designed, implemented, and
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`administered a Rails 3 server to facilitate a mobile-to-mobile tracking application.
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`13. From 2012 to 2014, I represented Broadcom in the Indoor Location
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`Alliance (ILA), 3GPP, and OMA, drafting the architecture for indoor location
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`standardization. I was elected to the board of directors for the ILA.
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`14. As discussed, I was recently a charter board member of the Indoor
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`Location Alliance, and in the early 2000's, I was the Chairman of the Location
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`Services sub-committee of the 3GPP2 telecommunications organization during the
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`drafting of the IS-801A-1 specification that defines how GPS and cellular location
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`operate on CDMA networks. I have also spent years as a contributing member of
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`location standards in the 3GPP organization that largely parallels 3GPP2, but for
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`GSM, UMTS, and now LTE networks. Attached as Appendix A is a copy of my
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`curriculum vitae.
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`III. MATERIALS CONSIDERED
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`15.
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`In preparing this declaration, I have reviewed, among other things, the
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`following materials: (a) the ’667 patent and its prosecution history; (b) U.S. Patent
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`No. 6,108,533 to Brohoff ; (c) U.S. Patent Application Publication No.
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`2002/0137530 to Karve; (d) U.S. Patent No. 7,444,156 to Boss et al.; (e) PCT
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`Publication No. WO 01/43482 to Garza; (f) GeePS.com Press Release, “Wireless,
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`Location-Based Shopping Portal Being Tested in New York City and San
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`Francisco by GeePS.com, Inc.” (Apr. 3, 2000); and (g) the Petition for Inter Partes
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`Review of the ’667 patent to which my declaration relates.
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`IV. DEFINITIONS AND STANDARDS
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`16.
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`I have been informed and understand that claims are construed from
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`the perspective of one of ordinary skill in the art at the time of the claimed
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`invention, and that during inter partes review, claims are to be given their broadest
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`reasonable construction consistent with the specification and the ordinary and
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`customary meaning given to the term by those of ordinary skill in the art at the
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`time of the invention. In analyzing the ’667 patent and the prior art, I have applied
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`meanings of claim terms according to this standard.
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`17.
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`I have also been informed and understand that the subject matter of a
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`patent claim is obvious if the differences between the subject matter of the claim
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`and the prior art are such that the subject matter as a whole would have been
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`obvious at the time the invention was made to a person having ordinary skill in the
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`art to which the subject matter pertains. I have also been informed that the
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`framework for determining obviousness involves considering the following
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`factors: (i) the scope and content of the prior art; (ii) the differences between the
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`prior art and the claimed subject matter; (iii) the level of ordinary skill in the art;
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`and (iv) any objective evidence of non-obviousness.
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`18.
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`I have been informed and understand that claimed subject matter
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`would have been obvious to one of ordinary skill in the art if, for example, it
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`results from the combination of known elements according to known methods to
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`yield predictable results, the simple substitution of one known element for another
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`to obtain predictable results, use of a known technique to improve similar devices
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`in the same way, applying a known technique to a known device ready for
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`improvement to yield predictable results, or pursuing known options within one’s
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`technical grasp in response to a design need or market pressure to solve a problem.
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`I have also been informed that the analysis of obviousness may include recourse to
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`logic, judgment, and common sense available to the person of ordinary skill in the
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`art that does not necessarily require explication in any particular reference.
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`19.
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`In my opinion, a person of ordinary skill in the art pertaining to the
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`’667 patent at the relevant date discussed below would have been a person with a
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`bachelor’s degree in mathematics, electrical engineering, computer engineering, or
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`computer science, and 3-5 years of experience with wireless location and/or
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`navigation systems. However, I recognize that someone with less technical
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`education but more experience, or more technical education but less experience,
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`could have also met this standard.
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`20.
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`I have been informed that the relevant date for considering the
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`patentability of the claims of the ’667 patent is December 31, 2001. Based on my
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`education and experience set forth above, I believe I am more than qualified to
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`provide opinions about how one of ordinary skill in the art in 2001 would have
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`interpreted and understood the ’667 patent and the prior art discussed below.
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`V.
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`THE ’667 PATENT
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`21. The ’667 patent generally relates to “a location information service for
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`a cellular telecommunications network, which enables individual mobile stations to
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`receive information about their location within the network.” (1:8-11.) A
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`“location message server” in the system includes a data store that contains location
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`information associated with the cells of the cellular network. A mobile station in
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`the network sends a request for location information as an SMS message, and the
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`system returns (as an SMS message) location information based on the cell in
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`which the mobile station is located. (Abstract, 1:52-63, 4:8-14.) The location
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`information can include, for example, information about restaurants as shown in
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`Table 1 and described at 4:5-8, and the provision of route guidance as described at
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`5:64-6:3. The system provides these features to the user without the need to pre-
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`register to the location information service. (Abstract, 1:63-2:2.)
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`VI. ANALYSIS OF THE PRIOR ART
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`A. U.S. Patent No. 6,108,533 to Brohoff (“Brohoff”)
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`22. Brohoff discloses a system in which a mobile station requests and
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`receives information from a “geographical database (GDB)” in a cellular
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`communication network. The geographic database contains information about
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`consumer services, geographic areas within the network, and which services are
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`available in the various geographic areas. (See, e.g., Abstract, 2:18-65, 3:66-4:11.)
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`Brohoff discloses that numerous different types of information can be requested
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`from the geographical database, including (1) “the position of one’s own mobile
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`station,” (2) “the position of another mobile station,” and (3) “information which is
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`associated with different search keys and with respect to the position of a mobile
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`station (either the inquiring MS or another MS).” (8:20-33; 9:30-10:5.) For
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`example, the user could enter the search term “food,” and the database would
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`return information about restaurants, including directions to the restaurants. (See,
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`e.g., 6:11-27.) Similarly, the user may, for example, request locations of stores and
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`restaurants in a shopping mall (5:66-6:27, FIG. 4), and the results may include
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`“how to get to each of the locations” (6:14-17) and “specific information with
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`respect to how to reach [a] particular establishment, i.e., the location within the
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`shopping mall where the establishment is located” (6:20-27).
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`23. The input to the geographic database typically includes “the
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`geographic location of a mobile station accessing the database” and “a possible
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`search key designating information a user desires to obtain from within the
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`database.” (4:12-17.) Thus, when a request is received from a mobile station, the
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`network determines the current geographic location of the mobile station. (See,
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`e.g., Abstract, 3:6-13.) Brohoff contemplates that there are many methods to
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`locate a mobile station with a cellular network, including using “knowledge as to
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`the existing location or registration facilities, i.e., cells or location areas . . . .”
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`(5:59-63, 4:17-29.)
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`B. U.S. Pat. App. Pub. No. 2002/0137530 to Karve (“Karve”)
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`24. Karve discloses a cellular telephone that allows received SMS
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`messages to be forwarded to another device. (Abstract.) The mobile phone in the
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`Karve system includes “program code for forwarding a received short message
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`from the telephone 10 to another device or telephone.” (See, e.g., [0029],
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`FIGS. 3, 4.)
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`C. U.S. Patent No. 7,444,156 to Boss et al. (“Boss”)
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`25. Boss discloses a cellular telephone positioning system that allows a
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`cell phone user to correlate a user-specified location name with a location among
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`one or more cells of a cellular network. (Abstract.) In the Boss system, the cell
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`phone “obtains a cell identification string corresponding to a cell of a cellular
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`telephone system with which cell the cellular telephone is in communication.” The
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`user provides a location name to be associated with the location corresponding to
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`that cell. (See, e.g., Abstract, 1:37-43.) This information can be sent to the cellular
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`telephone system and later used to provide a location information service.
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`Specifically, a cell phone user can send a location information request to the
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`location information service. For example, the user can enter an “I am lost”
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`command, which requests a description or name of the current location of the cell
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`phone, such as a street intersection or instructions on how to get to a destination
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`location. (7:21-8:16.)
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`26. A user of the Boss system can also send his or her location
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`information to others by sending location messages to other devices. (See, e.g.,
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`Abstract, 4:58-64.) The communications in the Boss system, including the
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`location information requests and responses and the location messages sent to other
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`devices, can be made using SMS. (See, e.g., 4:37-39, 4:55-64, 6:43-52, 6:37-42.)
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`D.
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`PCT Publication No. WO 01/43482 to Garza (“Garza”)
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`27. Garza discloses a system for communicating location-dependent
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`information from a telecommunications network to a mobile station based on
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`requests from the mobile station. (See, e.g., Abstract, 1:1-7, 3:1-15.) In the Garza
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`system, a mobile station sends a query related to goods or services to the network.
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`(3:1-15.) The network then determines the location of the mobile station
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`“according to the cell in which it is located, or according to geophysical
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`coordinates, for example.” (4:18-21, 3:1-15.)
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`28. The network includes a database that stores physical locations related
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`to various providers of goods and services, and each location is associated with a
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`variety of corresponding “information segments,” such as “generic business names,
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`actual business names, physical addresses, descriptions of services, descriptions of
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`goods, certifications, fees, days of operation, employees, and/or hours of operation,
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`among others.” (4:12-18, 3:1-20.) The network searches the database for entries
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`that match information contained in the query from the mobile station. The
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`locations of the matching entries are then compared with the approximate location
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`of the mobile station, and a response is sent to the mobile station that includes
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`information associated with the most proximate locations. (3:1-15.) In addition to
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`the types of information identified above, the response can also include
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`entertainment or dining information (8:17-9:10), travel/route information or traffic
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`conditions (7:16-30, 9:5-10), and emergency services information such as the
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`nearest hospital (17:9-31, 21:15-20).
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`E. GeePS.com Press Release, “Wireless, Location-Based Shopping
`Portal Being Tested in New York City and San Francisco by
`GeePS.com, Inc.” (“GeePS”)
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`29. GeePS discloses a system that allows users of hand-held wireless
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`devices to “view the merchants in their vicinity as well as receive special
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`announcements and deals offered by these merchants.” (p. 1.) For example, the
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`press release discusses that business travelers can use the technology to get
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`information about businesses, such as restaurants, in towns they are unfamiliar
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`with. (p. 2) GeePS discusses that users of the system only receive location
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`information messages by request. (p. 2.) According to this press release, the
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`GeePS system’s business model is based on revenue sharing as well as advertising;
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`that is, businesses are listed for free and users do not have to pay to use the
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`service—instead merchants are charged on a per view basis. (p. 2.) GeePS also
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`discloses that registration is optional: “[r]egistration is only required when users
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`want access to more personalized services and messages.” (p. 2.)
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`F. Obviousness of Claims 12-14 Based on Brohoff
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`30. To the extent that Brohoff does not disclose the “without pre-
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`registering” limitation, implementation of this limitation in the system of Brohoff
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`would have been obvious to one of ordinary skill in the art at the time of the
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`claimed invention of the ’667 patent. In particular, one of ordinary skill in the art
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`would have understood that, as in the ’667 patent, there is nothing about the
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`technical implementation of the Brohoff system that would require any kind of pre-
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`registration. For example, Brohoff does not involve finding the location of people
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`in a pre-defined group, such as the prior art Finder system discussed in the
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`background section of the ’667 patent. In fact, Brohoff does not include any
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`discussion of requiring pre-registration or of any benefit to doing so, and one of
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`ordinary skill in the art would have understood a complete lack of discussion of
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`pre-registration to mean it is not required by the system disclosed.
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`31. Moreover, one of ordinary skill in the art would have been very
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`familiar with the numerous services available at the time of the invention that offer
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`requested information without pre-registration, such as MapQuest and various
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`internet search engines. It would have been obvious to one of ordinary skill in the
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`art to similarly implement Brohoff to not include pre-registration. This would have
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`been obvious to try as a matter of common knowledge of one ordinary skill in the
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`art at that time, as well as simply being the application of a known technique to
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`achieve a predictable result.
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`32. Further, Brohoff discusses providing various types of information in
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`the results sent to the mobile station that one of ordinary skill in the art would have
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`understood to typically not require pre-registration, such as emergency services
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`and location finding information (e.g., directions or a location in a mall). (6:17-27,
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`1:37-45, 2:7-12, 1:26-34.) For example, one of ordinary skill in the art would have
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`understood that location finding information and value-added services were often
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`available for free and without pre-registration, and that requiring pre-registration to
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`access such information and services would limit the number of customers the
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`information and value-added services may bring in, which is not in the financial
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`interest of the establishment providing the information and services.
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`33. Similarly, one of ordinary skill in the art would have been familiar
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`with emergency services then available and being developed at the time of the
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`claimed invention, such as the FCC’s E-911 regulations and related technologies.
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`One of skill in the art would have understood that these emergency services were
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`freely available to the public without pre-registration and that a goal of such
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`services was to provide emergency assistance to as many people as possible. Thus,
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`one of ordinary skill in the art would have understood that emergency services
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`typically would not require pre-registration and that doing so would have been
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`contrary to the intended purpose of the service being provided.
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`G. Obviousness of Claims 12-14 Based on Brohoff and GeePS
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`34. Additionally, it would have been obvious to one of ordinary skill in
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`the art to not require any pre-registration, as disclosed in GeePS, in the Brohoff
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`system. As discussed above, GeePS explicitly discloses that users were not
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`required to pre-register with the GeePS system. The GeePS and Brohoff systems
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`both provide location-based information to users of mobile devices, and each
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`reference contemplates providing a mobile user with location finding information
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`such as finding restaurants. (GeePS at pp. 1-2; Brohoff at 1:46-58, 5:66-6:27.)
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`Accordingly, including the lack of pre-registration as disclosed in GeePS in the
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`Brohoff system would simply have applied a known technique to similar systems
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`to yield a predictable result. Further, one of ordinary skill in the art would have
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`recognized that not requiring pre-registration would not only simplify the technical
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`implementation of the system, it would also have provided the advantage of
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`making the services, such as locating restaurants, accessible to more potential
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`customers.
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`H. Obviousness of Claim 15 Based on Brohoff and Karve
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`35.
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`It would have been obvious to one of ordinary skill in the art to
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`include the SMS message forwarding feature of Karve in the Brohoff system. As
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`discussed above, Brohoff discloses that the mobile station may receive the
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`requested information as a text message. Because Brohoff and Karve are similar
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`systems that both involve sending text messages over a cellular communication
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`network, including Karve’s SMS message forwarding feature in Brohoff would
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`have simply constituted the use of a known technique to improve similar systems
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`in the same way.
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`36.
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`In particular, Karve discusses that SMS messaging is routinely used to
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`deliver a wide range of information to mobile phone users, such as stock share
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`prices, sports scores, weather, flight information, and news headlines—much of
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`which is location dependent. ([0012].) Karve also discusses that SMS messaging
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`is routinely used by people to, for example, arrange a meeting or to tell someone
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`something. Thus, just as Karve contemplates that users may want to forward a
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`received message to another device to share information with another person, one
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`of ordinary skill in the art would have understood that users of the Brohoff system
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`may similarly desire to forward information about their location received from the
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`geographical database to another user. For example, a user might want to share his
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`or her current location, food or store options, or directions. Doing so could, for
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`example, further facilitate arranging a meeting.
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`37. Similarly, Karve discusses that typing a message on a phone keypad
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`can be quite time consuming, and thus a benefit of message forwarding is that it
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`allows a received message to be sent without requiring re-typing of the message.
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`One of ordinary skill in the art would have immediately understood that this same
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`improvement would have been equally beneficial in the Brohoff system.
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`I.
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`Obviousness of Claim 15 Based on Brohoff, Karve, and GeePS
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`38. For the same reasons discussed in Section VII.G with respect to
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`Brohoff and GeePS, it would have been obvious to one of ordinary skill in the art
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`to include the lack of pre-registration disclosed in GeePS in the Brohoff/Karve
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`system. That is, it would have been obvious to one of ordinary skill in the art to
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`implement the Brohoff/Karve system as discussed in Section VII.H, and it would
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`have been obvious to further include the GeePS lack of pre-registration in the
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`Brohoff/Karve system for the reasons discussed in section VII.G.
`
`J.
`
`Obviousness of Claims 12-15 Based on Boss
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`39. To the extent that Boss does not disclose the “without pre-registering”
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`limitation, it would have been obvious to one of ordinary skill in the art to
`
`implement this limitation in the system disclosed by Boss. Again, one of ordinary
`
`skill in the art would have been very familiar with the numerous services available
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`at the time that offered requested information without pre-registration, such as
`
`MapQuest and various internet search engines. It would have been obvious to one
`
`of ordinary skill in the art to similarly implement Boss to not include pre-
`
`registration. This would have been obvious to try as a matter of common
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`
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`16
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`Apple Inc. Exhibit 1002 Page 17
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`Inter Partes Review of USP 7,072,667
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`knowledge of one ordinary skill in the art at the time, as well as simply being the
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`application of a known technique to achieve a predictable result.
`
`40. Not requiring pre-registration in Boss would have been particularly
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`obvious because Boss does not include any specific discussion of requiring pre-
`
`registration or any benefit to doing so. Boss instead discusses services that one of
`
`ordinary skill in the art would have understood to not require pre-registration. For
`
`example, Boss discusses the use of the location information service for “an
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`emergency (e.g., 911) service.” (8:32-40) One of ordinary skill in the art would
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`have been familiar with emergency services available and being developed at the
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`time of the claimed invention, such as the FCC’s E-911 regulations and related
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`technologies. Again, one of skill in the art would have understood that these
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`emergency services were freely available to the public without pre-registration and
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`that a goal of the services was to provide emergency assistance to as many people
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`as possible. Thus, one of ordinary skill in the art would have understood that
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`emergency services typically do not require pre-registration and that doing so
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`would have been contrary to the intended purpose of the service being provided.
`
`K. Obviousness of Claims 12-14 Based on Garza
`
`41. Based on its disclosure, the apparent goal of the Garza system is to
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`improve upon traditional directory services by providing an automated system that
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`returns location-based information about goods or services based on a query from a
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`17
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`Apple Inc. Exhibit 1002 Page 18
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`Inter Partes Review of USP 7,072,667
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`mobile station. As discussed, the results can include emergency services
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`information and information concerning safety or health service providers, such as
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`the nearest hospital, the police, the fire department, or an ambulance. (See, e.g.,
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`2:4-8, 9:5-24, 13:22-29, 17:9-32, 21:15-20.)
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`42. One of ordinary skill in the art would have understood that such
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`directory services and emergency services were (and are) typically free of charge
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`and do not require pre-registration. For example, as discussed above, one of
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`ordinary skill in the art would have been familiar with the FCC’s E-911 regulations
`
`and related technologies and the fact the e-911 systems proposed and being
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`developed at the time did not require pre-registration; again, pre-registration is
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`inconsistent with the goal of providing emergency services to as many users as
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`possible. Additionally, Garza contemplates using the system to contact the police,
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`the fire department, or an ambulance. One of ordinary skill in the art would have
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`immediately recognized that such services do not require pre-registration.
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`Similarly, one of ordinary skill in the art would also have immediately recognized
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`that the directories contemplated in Garza (e.g., a local telephone directory) are
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`generally freely available to the public and do not require pre-registration.
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`Accordingly, to the extent it is found that Garza does not disclose the “without pre-
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`registering” limitation, it would have been obvious to one of ordinary skill in the
`
`art.
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`
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`18
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`Apple Inc. Exhibit 1002 Page 19
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`Inter Partes Review of USP 7,072,667
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`Docket No. 106840000522
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`43. Further, one of ordinary skill in the art would have been very familiar
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`with the numerous services available at the time that offered requested information
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`without pre-registration, such as those discussed in Garza, MapQuest, and various
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`internet search engines. It would have been obvious to one of ordinary skill in the
`
`art to similarly implement Garza to not include pre-registration. This would have
`
`been obvious to try as a matter of common knowledge of one ordinary skill in the
`
`art at the time, as well as simply being the application of a known technique to
`
`achieve a predictable result.
`
`44. Not requiring pre-registration in Garza would have been particularly
`
`obvious because Garza does not include any specific discussion of requiring pre-
`
`registration or any benefit to doing so. This would have been further obvious
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`because, as discussed above, the Garza system provides services that one of
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`ordinary skill in the art would have understood to not require pre-registration.
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`L. Obviousness of Claim 15 Based on Garza and Karve
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`45.
`
`It would have been obvious to one of ordinary skill in the art to
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`include the SMS message forwarding feature of Karve in the Garza system. As
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`discussed above, Garza discloses that the mobile station may receive the requested
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`information as an SMS message. Because Garza and Karve are similar systems
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`that both involve sending SMS messages over a cellular communication network,
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`
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`19
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`Apple Inc. Exhibit 1002 Page 20
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`Inter Partes Review of USP 7,072,667
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`including Karve’s SMS message forwarding feature in Garza would simply use a
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`known technique to improve similar systems in the same way.
`
`46.
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`In particular, Karve discusses that SMS messaging is routinely used to
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`deliver a wide range of information to mobile phone users, such as stock share
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`prices, sports scores, weather, flight information, and news headlines—much of
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`which is location dependent. ([0012].) Karve also discusses that SMS messaging
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`is routinely used by people to, for example, arrange a meeting or to tell someone
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`something. Thus, just as Karve contemplates that users may want to forward a
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`received message to another device to share information with another person, one
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`of ordinary skill in the art would have understood that users of the Garza system
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`may similarly desire to forward information about their location received from the
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`geographical database to another user. For example, a user might want to share
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`information about the local entertainment or restaurant options, or directions to a
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`location. Doing so could, for example, further facilitate arranging a meeting.
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`47. Similarly, Karve discusses that typing a message on a phone keypad
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`can be quite time consuming, and thus a benefit of messag
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