DECLARATION OF SCOTT ANDREWS
`
`I, Scott Andrews, declare as follows:
`
`I hold a B.Sc. degree in Electrical Engineering from University of
`
`
`
`1.
`
`California–Irvine and a M.Sc. degree in Electronic Engineering from Stanford
`
`University. In various positions at, among others, TRW and Toyota, I have been
`
`responsible for research and development projects relating to, among others,
`
`numerous vehicle navigation systems, information systems, and user interface
`
`systems. My qualifications are further set forth in my curriculum vitae (Exhibit A).
`
`I have been retained by Volkswagen Group of America, Inc. in connection with its
`
`petition for inter partes review of U.S. Patent No. 8,065,156 (the “’156 patent”). I
`
`have over 35 years of experience in fields relevant to the ’156 patent, including
`
`telecommunications systems and navigation systems.
`
`2.
`
`I have reviewed the ’156 patent, as well as its prosecution history and the
`
`prior art cited during its prosecution. I have also reviewed U.S. Patent No.
`
`6,202,023 (“Hancock”), the Richard Lind et al. publication, The Network Vehicle –
`
`A Glimpse
`
`into
`
`the Future of Mobile Multi-Media, 17th DASC, The
`
`AIAA/IEEE/SAE Digital Avionics Systems Conference – Bellevue, WA – Oct.
`
`31-Nov. 7, 1998 – Proceedings (“Lind”), U.S. Patent No. 6,401,112 (“Boyer”),
`
`U.S. Patent No. 6,230,132 (“Class”), Chapter 11 of the AUTOMOTIVE ELECTRONICS
`
`HANDBOOK, by Ronald Jurgen (ed.), U.S. Patent No. 5,274,560 (“LaRue”), and the
`
`1
`
`VWGoA - Ex. 1002
`Volkswagen Group of America, Inc. - Petitioner
`
`1
`
`
`
`I, Scott Andrews, declare as follows:
`
`I hold a B.Sc. degree in Electrical Engineering from University of
`
`
`
`1.
`
`California–Irvine and a M.Sc. degree in Electronic Engineering from Stanford
`
`University. In various positions at, among others, TRW and Toyota, I have been
`
`responsible for research and development projects relating to, among others,
`
`numerous vehicle navigation systems, information systems, and user interface
`
`systems. My qualifications are further set forth in my curriculum vitae (Exhibit A).
`
`I have been retained by Volkswagen Group of America, Inc. in connection with its
`
`petition for inter partes review of U.S. Patent No. 8,065,156 (the “’156 patent”). I
`
`have over 35 years of experience in fields relevant to the ’156 patent, including
`
`telecommunications systems and navigation systems.
`
`2.
`
`I have reviewed the ’156 patent, as well as its prosecution history and the
`
`prior art cited during its prosecution. I have also reviewed U.S. Patent No.
`
`6,202,023 (“Hancock”), the Richard Lind et al. publication, The Network Vehicle –
`
`A Glimpse
`
`into
`
`the Future of Mobile Multi-Media, 17th DASC, The
`
`AIAA/IEEE/SAE Digital Avionics Systems Conference – Bellevue, WA – Oct.
`
`31-Nov. 7, 1998 – Proceedings (“Lind”), U.S. Patent No. 6,401,112 (“Boyer”),
`
`U.S. Patent No. 6,230,132 (“Class”), Chapter 11 of the AUTOMOTIVE ELECTRONICS
`
`HANDBOOK, by Ronald Jurgen (ed.), U.S. Patent No. 5,274,560 (“LaRue”), and the
`
`1
`
`VWGoA - Ex. 1002
`Volkswagen Group of America, Inc. - Petitioner
`
`1
`
`
`
`article IBM’s Corporate High Flier, published in the Sydney Morning Herald on
`
`September 29, 1997.
`
`The ’156 Patent
`
`3.
`
`The ’156 patent describes an elevator information system, shown generally
`
`in Figs. 1 and 2. ’156 patent, col. 5, lines 39-40. The system 100 includes an input
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`device 102, a speech recognition (SR) module 104, and a central processor 106
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`with associated components. ’156 patent, col. 5, lines 41-49. In this system,
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`keypads 116 and/or touch sensitive displays 113 (Fig. 2) are disposed within an
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`elevator car 180 to facilitate “easy access and viewing by passengers.” ’156 patent,
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`col. 6, lines 47-50. The system also includes a central server 170 located remotely
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`from the elevator car and connects to the elevator car “clients” 180 via a local area
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`network. ’156 patent, col. 7, lines 39-42; Fig. 3. In an alternative embodiment, data
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`may be transferred between the elevator cars 180 and the remote server 170 via a
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`wireless interface 310. ’156 patent, col. 7, lines 51-58.
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`4.
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`According to the ’156 patent, the system 100 can include one or more data
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`terminals 702 which allow the user to plug in a personal electronic device (PED)
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`704 having a standardized interface into the system to obtain a download of
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`information. ’156 patent, col. 11, lines 9-15. A representation of this embodiment
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`is shown in Fig. 7:
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`2
`
`2
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`
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`5.
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`According to the ’156 patent, “the term ‘PED’ includes, but is not limited to,
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`personal digital assistants
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`(PDAs) such as
`
`the Apple Newton®, US
`
`Robotics/3COM PalmPilot®, or Palm III®, laptop computer, notebook computer,
`
`or the like.” ’156 patent, col. 11, lines 16-19. Furthermore, the data terminal, via
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`which the PED 704 may be plugged into to the system 100, “includes a connector
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`712 which is a 9-pin RS-232 serial connection of the type well known in the
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`electronic arts, although other types of connectors and protocols may be used.”
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`’156 patent, col. 11, lines 19-23.
`
`The Combination of Hancock and Lind – Claims 10, 15, 18, 20, 21, 22, and 23
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`6.
`
`The combination of Hancock and Lind describes all of the limitations of
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`claims 10, 15, 18, 20, 21, 22, and 23 of the ’156 patent.
`
`3
`
`3
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`
`
`Claim 10
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`7.
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`Hancock describes a remote database that can provide services over a
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`computer network, such as the Internet, to users in vehicles. Hancock, Abstract.
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`The remote database described in Hancock may be queried by the user of a vehicle
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`via, for example, a cellular base station. Hancock, Fig. 13.
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`8.
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`Lind describes an SUV, referred to as the “Network Vehicle,” containing
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`hardware and software that allows it to wirelessly connect to, for example, the
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`Internet. Lind, page I21-2. This allows the vehicle described in Lind to retrieve
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`information wirelessly. Lind, page I21-2 and Fig. 3. The system disclosed in Lind
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`can receive inputs from a user, via voice or via a touch screen, access a remote
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`server wirelessly based on that input, receive information responsive to the user’s
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`input, and implement the desired function. For example, the information requested
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`by the user may be a retrieval of e-mails, which may be displayed to the driver on
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`an LCD screen or read aloud. Lind, page I21-7.
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`9.
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`Lind also describes the use of an ad hoc communication link between the
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`vehicle’s computer and a user’s portable device, such as the IBM WorkPad PDA.
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`Lind, page I21-5. Further, e-mails that are retrieved from the Internet can be
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`downloaded to the IBM WorkPad PDA. Lind, page I21-7.
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`10. Hancock describes a computer readable apparatus comprising a storage
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`medium, including a “general or special purpose computer system” that includes a
`
`4
`
`4
`
`
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`CPU and various types of storage, including RAM and/or ROM. Hancock, col. 25,
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`lines 30-38. Additionally, Hancock describes that this storage medium contains a
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`computer program, as it uses “non-volatile program memory.” Hancock, col. 25,
`
`lines 30-38 (emphasis added). Therefore, Hancock discloses a “computer readable
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`apparatus comprising a storage medium, said storage medium comprising at least
`
`one computer program with a plurality of instructions,” as claimed in claim 10 of
`
`the ’156 patent.
`
`11.
`
`Lind discloses that the system makes use of software applications and
`
`microprocessors on-board the vehicle. Lind, pages I21-1, I21-2, I21-6. In order to
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`run software on a microprocessor, a storage medium such as a hard drive, RAM, or
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`ROM is used. Therefore, Lind discloses a “computer readable apparatus
`
`comprising a storage medium, said storage medium comprising at least one
`
`computer program with a plurality of instructions,” as claimed in claim 10 of the
`
`’156 patent.
`
`12. At the time the ’156 patent was filed, it would have been understood that the
`
`computer programs disclosed in Hancock and Lind include “a plurality of
`
`instructions,” as claimed in claim 10 of the ’156 patent. Chapter 11 of the
`
`Automotive Electronics Handbook, for example, describes automotive computers
`
`and microcontrollers, as they existed in the mid-1990s. It was known, for example,
`
`in the mid-1990s that microcontrollers include an “instruction set,” which “consists
`
`5
`
`5
`
`
`
`of a set of unique commands which the programmer uses to instruct the
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`microcontroller on what operation to perform.” Jurgen, pages 11.12-11.13.
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`Additionally, the Automotive Electronics Handbook includes a discussion of the
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`common types of programming languages used in the automotive field, including
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`high level languages, such as C, and low level languages, such as assembly
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`language, each of which permit a microcontroller or CPU to execute machine
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`instructions. Jurgen, pages 11.15-11.17.
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`13. Hancock discloses a computerized information system disposed within a
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`transport apparatus that transports at least one person from one location to another,
`
`e.g., an automobile. For example, the “portable-computing device 1302” disclosed
`
`in Hancock is located inside a vehicle. Hancock, col. 23, lines 44-43. Therefore,
`
`Hancock discloses “the storage medium being part of a computerized information
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`system disposed on or within a transport apparatus configured to transport at least
`
`one person from one location to another,” as claimed in claim 10 of the ’156
`
`patent.
`
`14.
`
`Lind also discloses a computerized information system disposed within a
`
`transport apparatus that transports at least one person from one location to another.
`
`For example, Lind discloses an “on-board network,” including a network
`
`computer, which is located “on-board” the vehicle, in this case an SUV. Lind,
`
`Figures 1, 2. Therefore, Lind discloses “the storage medium being part of a
`
`6
`
`6
`
`
`
`computerized information system disposed on or within a transport apparatus
`
`configured to transport at least one person from one location to another,” as
`
`claimed in claim 10 of the ’156 patent.
`
`15. Hancock discloses that the computer program receives an input related to a
`
`desired function. For example, Hancock discloses a keypad device 1414 that is
`
`coupled to the portable-computing device 1302 for inputting data. Hancock, col.
`
`25, lines 43-45. Additionally, Hancock discloses the use of a speech interface 1418
`
`that accepts spoken commands. Hancock, col 25, lines 47-48. Therefore, Hancock
`
`discloses “said at least one program being configured to: receive an input from a
`
`user of the transport apparatus, the input relating to a desired function,” as claimed
`
`in claim 10 of the ’156 patent.
`
`16.
`
`Lind also discloses that the computer programs receive inputs relating to a
`
`desired function. For example, the ViaVoice program, which is one of the software
`
`programs described in Lind, receives voice inputs that can be used to check e-mail
`
`and voicemail. Lind, page I21-3. Therefore, Lind discloses “said at least one
`
`program being configured to: receive an input from a user of the transport
`
`apparatus, the input relating to a desired function,” as claimed in claim 10 of the
`
`’156 patent.
`
`17. Hancock discloses that the vehicle accesses a remote server via a wireless
`
`interface in order to access and receive information. For example, Hancock
`
`7
`
`7
`
`
`
`describes that a “wireless transceiver 1402 is used to send and receive data
`
`between the portable-computing device 1302 and other devices such as the servers
`
`1314 and 1315 coupled to the Internet 1318.” Hancock, col. 26, lines 8-11.
`
`Therefore, Hancock discloses “at least one program being configured to” (a)
`
`“cause access of a remote server via an associated wireless interface to access
`
`information relating to the desired function” and (b) “receive accessed information
`
`via the wireless interface,” as claimed in claim 10 of the ’156 patent.
`
`18.
`
`Lind also discloses that the vehicle accesses a remote server via a wireless
`
`interface in order to access and receive information. Lind describes an antenna,
`
`Lind, page I21-2, that connects the vehicle to the outside world using “high-
`
`bandwidth communications,” Lind, page I21-3. Lind describes that the vehicle can
`
`use the wireless interface to access an Internet service provider, and via the
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`Internet, can connect to, for example, an IBM web server or a home/office
`
`computer. Lind, Fig. 3. The system described in Lind may access information
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`related to the desired function, for example, checking e-mail, via Internet access to
`
`these servers. Therefore, Lind discloses “at least one program being configure to”
`
`(a) “cause access of a remote server via an associated wireless interface to access
`
`information relating to the desired function” and (b) “receive accessed information
`
`via the wireless interface,” as claimed in claim 10 of the ’156 patent.
`
`8
`
`8
`
`
`
`19. Hancock discloses that the desired function is implemented using the
`
`received information. For example, according to Hancock, “the process retrieves
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`the results from the database query and sends them to the client, as indicated by
`
`step 1620.” Hancock, col. 28, lines 6-8. Additionally, Hancock describes that the
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`received information, such as maps and driving directions, can be “presented to
`
`users.” Hancock, col. 32, lines 37-39. Therefore, Hancock discloses “at least one
`
`program being configured to” “implement the desired function using at least a
`
`portion of the received information,” as claimed in claim 10 of the ’156 patent.
`
`20.
`
`Lind also discloses that the desired function (receiving e-mail messages) is
`
`implemented using the information received via the wireless link. For example, the
`
`vehicle disclosed in Lind can read e-mail messages out loud or display a waiting e-
`
`mail indication on the heads-up display. Lind, pages I21-2, I21-3. Therefore, Lind
`
`discloses “at least one program being configured to” “implement the desired
`
`function using at least a portion of the received information,” as claimed in claim
`
`10 of the ’156 patent.
`
`21. As discussed above, the ’156 patent describes that a user can plug a personal
`
`electronic device (PED) into the system to obtain a download of information. ’156
`
`patent, col. 11, lines 13-16. Examples of these personal electronic devices (PEDs),
`
`according to the ’156 patent, include various PDAs and laptops, ’156 patent, col.
`
`11, lines 16-19 (“As used herein, the term ‘PED’ [personal electronic device]
`
`9
`
`9
`
`
`
`includes, but is not limited to, personal digital assistants (PDAs) such as the Apple
`
`Newton®, US Robotics/3COM PalmPilot®, or Palm III®, laptop computer,
`
`notebook computer, or the like.”), and the PED can be connected to the system
`
`using, e.g., an RS-232 serial connection. ’156 patent, col. 11, lines 19-23.
`
`22. Hancock describes that “[a]ny type of general or special purpose computer
`
`system can be used to implement the portable-computing device 1302,” Hancock,
`
`col. 25, lines 29-31, and that “[e]xamples of such devices include … personal
`
`digital assistant devices (PDAs),” Hancock, col. 25, lines 31-33. Hancock further
`
`describes that the portable-computing device 1302 may be coupled to external
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`devices, such an ALI (automatic location identifying) device 1406, e.g., a GPS
`
`device, and/or a wireless transceiver 1402, via external ports, e.g., RS-232 ports.
`
`Hancock, col. 25, lines 15-21.
`
`23.
`
`Lind discloses that the network computer, which includes software
`
`programs, establishes an ad hoc communication link with a portable computerized
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`device. According to Lind, a portable computerized device or “removable personal
`
`digital assistant (PDA)” (Lind, page I21-2), such as an IBM WorkPad (which is a
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`Palm device, like the PalmPilot and Palm III devices described in the ’156 patent
`
`as examples of a PED, and which is a personal digital assistant device (PDA), like
`
`that described by Hancock), can be placed in a slot built into the center console.
`
`Lind, page I21-5. Additionally, the diagram of the on-board network in Lind shows
`
`10
`
`10
`
`
`
`the “PDA Dock” for the WorkPad PDA being connected to the network computer
`
`via an RS-232 connection (which is identical to the type of connection described in
`
`the ’156 patent between the personal electronic device (PED) 704 and the system
`
`100, and to the type of connection described by Hancock between the portable-
`
`computing device 1302 and the ALI device 1406 and/or the wireless transceiver
`
`1402). Lind, page I21-2, Figure 2. Therefore, Lind discloses that “at least one
`
`program is … configured to: establish an ad hoc communication link with a
`
`portable computerized device of a user of the transport apparatus,” as claimed in
`
`claim 10 of the ’156 patent.
`
`24.
`
`Lind discloses that a portion of the received information (e.g., e-mails) can
`
`be downloaded to the portable computerized device via communication link. Lind
`
`describes that “E-mails and appointments can be downloaded to the docked
`
`Workpad PDA, for review after leaving the vehicle.” Lind, page I21-7. Therefore,
`
`Lind discloses that “at least one program is … configured to” “download at least a
`
`portion of the received information to the portable computerized device via the
`
`communication link,” as claimed in claim 10 of the ’156 patent.
`
`Claim 15
`
`25. Hancock discloses that the database includes names of business entities, and
`
`is searchable by the name of a business entity. For example, the database can be
`
`searched by categories of interest, such as restaurants, banks, ATM machines, etc.
`
`11
`
`11
`
`
`
`The points of interest can be located by customers by common name, for example,
`
`“MacDonalds.” See, e.g., Hancock, col. 8, line 56-col. 9, line 17. Therefore,
`
`Hancock discloses that “said remote server is in communication with a database of
`
`business entities, said database being searchable at least by a name of a business
`
`entity,” as claimed in claim 15 of the ’156 patent.
`
`26.
`
`Lind also discloses that the driver may issue verbal commands to operate the
`
`vehicle. For example, Lind states that “voice recognition technology allows drivers
`
`and passengers to verbally request and listen to e-mail messages, locate a
`
`restaurant or hotel, ask for navigation help or for specific music or sports scores,
`
`and use voice-activated telephone services, all done safely without interfering with
`
`driving.” Lind, page I21-2. Lind further describes that the Network Vehicle’s
`
`advanced speech recognition system “allows the driver to access virtually all the
`
`vehicle’s features through voice commands” and that the “driver can: execute
`
`vehicle system commands such as … request travel directions and traffic updates
`
`from the Web or other sources, check e-mail and voicemail, request news, sports,
`
`and stock information.” Lind, page I21-3. It is well-known that in systems that
`
`accept voice commands, the speech input is digitized for analysis. For example,
`
`when using software to process speech, the speech is passed through a microphone,
`
`amplifier, and digital-to-analog converter in order to process and analyze the
`
`speech. LaRue, col. 5, lines 17-30. The speech recognition system described in
`
`12
`
`12
`
`
`
`Lind also includes a microphone. Lind, pages I21-3 and I21-6. Therefore, Lind
`
`discloses that “said input comprises a digitized representation of a speech input, the
`
`speech input being received via a microphone located within said transport
`
`apparatus, the speech comprising said name of said business entity,” as claimed in
`
`claim 15 of the ’156 patent.
`
`Claim 18
`
`27.
`
`Lind discloses that the desired function (e.g., the user receiving e-mails) can
`
`be implemented by “synthesizing speech for playout.” For example, Lind discloses
`
`that drivers and passengers can listen to e-mail messages, Lind, page I21-2, and
`
`also discloses that the ViaVoice system included in the Network Vehicle “enables
`
`the vehicle to talk back using synthesized speech,” Lind, page I21-3. Figure 2 of
`
`Lind discloses that the system includes amplifiers and speakers. Therefore, Lind
`
`discloses that “the implementation of the desired function comprises synthesizing
`
`speech for playout over one or more speakers disposed within said transport
`
`apparatus, the speech being synthesized based at least in part on said received
`
`information,” as claimed in claim 18 of the ’156 patent.
`
`Claim 20
`
`28. Hancock discloses that the received information can be configured into a
`
`“travel profile” specifically for the user. Hancock, col. 9, lines 48-64. For example,
`
`a user can select and sort the necessary data (such as destinations) to create a travel
`
`13
`
`13
`
`
`
`profile, which can be downloaded to the navigational unit. Hancock, col. 9, lines
`
`59-60. This pre-stored travel profile is “configured specifically for the user,” as
`
`claimed, because it is particular to user selections, and/or to preferences the user
`
`has stored in the central repository. Hancock, col. 9, lines 55-58. Therefore,
`
`Hancock discloses that “said received information is configured specifically for the
`
`user,” as claimed in claim 20 of the ’156 patent.
`
`29.
`
`Lind also discloses that a user can use the system to “set up a profile,
`
`including preferences like radio stations, personalized audio content, service
`
`records, and emergency service numbers.” Lind, page I21-5. Therefore, Lind
`
`discloses that “said received information is configured specifically for the user,” as
`
`claimed in claim 20 of the ’156 patent.
`
`Claims 21 and 22
`
`30. Hancock discloses that the “travel profile,” which is configured specifically
`
`for the user, is based at least in part on data stored on a remote server that relates
`
`specifically to that user. For example, Hancock discloses that the personal
`
`configuration is based on “information in the central repository 65,” which is
`
`located on a remote server. Hancock, col. 9, lines 48-64. The data in the remote
`
`central repository, such as geographic data, is used to create the travel profile.
`
`Hancock, col. 9, lines 48-64. The central repository may also “store preferences for
`
`the user.” Hancock, col. 9, lines 58-59. Therefore, Hancock discloses that “said
`
`14
`
`14
`
`
`
`configuration specifically for the user is based at least in part on data stored on a
`
`remote server, the data relating specifically to that user,” as claimed in claim 21 of
`
`the ’156 patent, and that “said data stored on a remote server relating specifically
`
`to that user is based at least in part on one or more previously supplied user-
`
`selected configuration parameters,” as claimed in claim 22 of the ’156 patent.
`
`Claim 23
`
`31. Hancock discloses that the user may make an input to obtain information
`
`relating to a particular destination or entity. For example, Hancock describes that
`
`the user may conduct a database search for “restaurants that accept a particular
`
`type of credit card, have a particular dress code, or provide goods within a
`
`particular price range.” Hancock, col. 29, lines 2-5. These attributes of the various
`
`destinations constitute “information relating to a particular destination or entity.”
`
`Therefore, Hancock discloses that “said input relating to a desired function
`
`comprises an input to obtain information relating to a particular destination or
`
`entity,” as claimed in claim 23 of the ’156 patent.
`
`32.
`
`Lind also discloses that the user may use the system to obtain the location of
`
`a particular destination or entity, e.g., a restaurant or hotel, Lind, page I21-2, and
`
`that the driver can “request travel directions and traffic updates from the Web or
`
`other sources,” Lind, page I21-3. The location of a destination or entity is
`
`“information relating to” that destination or entity, and travel directions and traffic
`
`15
`
`15
`
`
`
`updates typically relate to particular destinations and entities. Additionally, Lind
`
`discloses that “[t]he driver can … check e-mail and voicemail, request news,
`
`sports, and stock information,” Lind, page I21-3, and that “[t]he Network Vehicle
`
`is an extension of your office, seamlessly offering access to … e-mail and address
`
`book,” Lind, page I21-7. E-mails, voicemails, news, sports, stock information, and
`
`address books relate to, for example, particular entities. Therefore, Lind discloses
`
`that “said input relating to a desired function comprises an input to obtain
`
`information relating to a particular destination or entity,” as claimed in claim 23 of
`
`the ’156 patent.
`
`Reasons to Combine Hancock and Lind
`
`33. At the time the ’156 patent was filed, it would have been obvious to combine
`
`Hancock and Lind to achieve the systems claimed in claims 10, 15, 18, 20, 21, 22,
`
`and 23 of the ’156 patent.
`
`34.
`
`For example, both Hancock and Lind describe systems that provide
`
`information conveniently and safely to the driver of an automobile. Lind, page I21-
`
`1; Hancock, col. 2, lines 54-56. Additionally both Hancock and Lind describe
`
`systems that obtain information from remote sources at the user’s or driver’s
`
`request and output the obtained information to the user or driver. Further, Lind
`
`states that the system could assist the user in locating a “restaurant or hotel.” Lind,
`
`page I21-2. Thus, the system in Lind is provided with navigation information, as
`
`16
`
`16
`
`
`
`also described in Hancock. It would have been obvious that different types of
`
`information could be downloaded to the Workpad PDA docked in the Network
`
`Vehicle, such as the navigation information that is provided to the car in Hancock.
`
`At the time of the alleged inventions of the claims of the ’156 patent, a person of
`
`ordinary skill in the art would have understood that digital data for providing
`
`information to the driver could have been supplied to the docked PDA, without any
`
`modification to the system of Lind.
`
`Industry Activity
`
`35. Additionally, several years before the earliest filing date referred to on the
`
`face of the ’156 patent, as well as contemporaneously to the filing of the ’156
`
`patent, other companies developed, and were developing, vehicles with Internet
`
`connectivity (allowing users to, for example, retrieve information wirelessly from
`
`remote databases while inside their vehicles), speech-recognition functionality, and
`
`connectivity
`
`to portable electronic devices. This
`
`industry activity further
`
`demonstrates that the systems claimed in the ’156 patent would have been obvious
`
`to a person of ordinary skill in the art, and that it would have been obvious to
`
`combine Hancock and Lind.
`
`36.
`
`For example, as described by Lind, the Network Vehicle was developed by a
`
`group of companies including Delphi Delco Electronics Systems, IBM, Netscape
`
`Communication, and Sun Microsystems. The Network Vehicle developers loaded
`
`17
`
`17
`
`
`
`several computing and communications devices into a vehicle, to show that the
`
`technology could successfully be used in a variety of ways. The Network Vehicle
`
`included a roof-mounted antenna to provide a satellite connection to the Internet.
`
`Lind, page I21-2. The system associated with the Network Vehicle included an off-
`
`board network architecture, including, for example, a home/office computer and an
`
`IBM web server. Lind, page I21-2. As described by Lind, the Network Vehicle
`
`developers provided a web site for users of the Network Vehicle to remotely access
`
`the computing systems located in the vehicle. The vehicle web site allowed users
`
`to “plan trips on the vehicle web site, then download them to your vehicle.” Lind,
`
`page I21-7.
`
`37.
`
`Lind also describes systems in which a user can receive various types of
`
`information inside the vehicle, including e-mail. Lind states that the Network
`
`Vehicle was demonstrated at the Computer Dealer’s Exhibits (COMDEX ’97) in
`
`Las Vegas, Nevada on November 17-19, 1997. At this demonstration, the
`
`presenters of
`
`the Network Vehicle
`
`(Delphi,
`
`IBM, Netscape, and Sun
`
`Microsystems) presented the vehicle website that is described by Lind, as noted
`
`above.
`
`38.
`
`I have reviewed screenshots of the Network Vehicle web site; those
`
`screenshots are attached as Exhibit B. I acquired these screenshots pursuant to my
`
`work as an expert witness engaged by Volkswagen Group of America, Inc. in
`
`18
`
`18
`
`
`
`connection with Affinity Labs of Texas, LLC v. BMW North America, LLC, et al.,
`
`Case No. 9:08-cv-00164 (E.D. Tex.).
`
`39. Moreover, in 1997, I personally attended a demonstration of the Network
`
`Vehicle, conducted by Delphi and a Delphi supplier exhibition at Toyota’s
`
`headquarters in Toyota City, Japan. At that event, the developers of the Network
`
`Vehicle demonstrated its features to me, and explained the system operation.
`
`40. Referring to Exhibit B, as illustrated in, e.g., the “Driver profile” page, the
`
`vehicle maintains a set of profiles for each driver, including personal data,
`
`entertainment preferences, information preferences, vehicle preferences, and a
`
`personal address book. The Network Vehicle therefore demonstrates that it would
`
`have been obvious to configure the information specifically for the user.
`
`41. Additionally, referring to Exhibit C (VW is working on a multimedia car,
`
`Reuters AG, April 22, 1996), Volkswagen was working on a “multimedia car” and
`
`presented its “Infotainment Car,” in Hannover, Germany in 1996; the Infotainment
`
`Car included, for example, a PC with Internet connectivity.
`
`42.
`
`In the Connected CarPC, which is described, for example in Exhibit D (In-
`
`Car Computing and Communication Enables Entertainment, Productivity and
`
`Information, Dedicated Conference on ATT/ITS Advances for Enhancing
`
`Passenger, Freight & Intermodal Transportation Systems, p. 411-417 (1997)), in
`
`1997, communication links were being used in automobiles to provide, for
`
`19
`
`19
`
`
`
`example, traffic information, Internet access to find hotels, restaurants, and travel
`
`guides, and to schedule maintenance, perform remote diagnostics and receive
`
`software updates. The “Connected CarPC environment” provides, for example,
`
`speech recognition functionality and Internet access.
`
`43.
`
`The Daimler-Benz Internet Multimedia on Wheels Concept Car, also
`
`referred to as the Internet Car, which is described, for example, in Exhibit E
`
`(Jameel et al., Internet Multimedia on Wheels: Connecting Cars to Cyberspace
`
`(IEEE 1998)) and Exhibit F (Jameel et al., Web on Wheels: Toward Internet-
`
`Enabled Cars (IEEE January 1998)), included “an on-board, integrated wireless
`
`communication system and the computing infrastructure to provide Internet
`
`connectivity from the car to any specific server on the Internet while stationary or
`
`in motion.” The Internet Car allows for “Personal device (smart cards, HPCs) [to]
`
`be used to personalize car seats, climate, phone numbers, Internet services
`
`bookmarks, and computing man machine interface.” The Internet Car allows
`
`drivers to “access … voice-mail, e-mail, and travel-related information such as
`
`restaurant guides and movie theater locations” “in a hands-free, eyes-free manner
`
`through voice commands and speech technology.” The Internet Car also allows
`
`drivers and passengers to “use their personal devices like Smart Phones, Personal
`
`Digital Assistants (PDAs), Hand-held PCs (HPCs), etc., in an integrated fashion.”
`
`20
`
`20
`
`
`
`Figure 1, reproduced below, illustrates a PDA among “Personal Devices” that may
`
`be connected to the Internet Car via an IrDA (infrared) transceiver.
`
`44. Microsoft’s Auto PC, which is described, for example, in Exhibit G (Jost,
`
`The car as a mobile-media platform, Automotive Engineering International, pp.
`
`49-53 (May 1998)), “brings the benefits of interactive speech technology,
`
`connectivity, information on demand, and enhanced entertainment to the
`
`automobile.” The system is designed so that “users can share information between
`
`their Auto PC and Handheld and Palm PCs.”
`
`45. Visteon’s ICES system, which is also described in Exhibit G, includes a
`
`voice-activated control system that “allows drivers to control vehicle functions that
`
`are usually operated manually.” Using the Visteon ICES system, “[t]hrough speech
`
`recognition, the driver can send e-mail, obtain turn-by-turn Global Positioning
`
`21
`
`21
`
`
`
`Satellite (GPS)-based navigation to a specific destination, ask for traffic and
`
`weather conditions, locate a restaurant or hotel, or change the musical selection on
`
`the stereo.” Wireless Internet connectivity “can be used for vehicle-to-roadside
`
`assistance or to receive e-mail and Internet information.” Additionally, the Visteon
`
`ICES system includes an infrared data link to connect to Windows CE-based
`
`devices, “such as Handheld and Palm PCs or another personal handheld Digital
`
`Assistant, for transferring data to and from the vehicle.”
`
`The Combination of Hancock, Lind, and Boyer – Claim 11
`
`46. Boyer (assigned on its face to Palm, Inc.) discloses a PDA docking system
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`that allows connection and synchronization with a personal computer. Boyer, col.
`
`2, lines 55-59. As described in Boyer, the synchronization program is “resident on
`
`the portable device.” Boyer, col. 2, lines 55-59.
`
`47.
`
`This synchronization of information is initiated by the software resident on
`
`the portable device, as claimed in claim 11 of the ’156 patent. As described in
`
`Boyer, the PDA (the “portable computer system 160”) is docked in a cradle, and
`
`the user presses a synchronization button 185 on the cradle to activate a
`
`synchronization program called “HotSync.” Figure 1B, reproduced below, shows
`
`that “[t]he synchronization cradle 180 has a button 185 that activates a
`
`synchronization Program (HotSync) 161 in the portable computer system 160.”
`
`Boyer, col. 3, lines 2-5. As shown in Figure 1B, the synchronization program (the
`
`22
`
`22
`
`
`
`HotSync Program 161) is resident “in the portable computer system 160.” The
`
`synchronization of the two devices involves transfer of data to and from both
`
`devices. Boyer, col. 2, lines 59-61. Therefore, data is downloaded to the PDA
`
`during this synchronization.
`
`48. Once the button is pressed, indicating that the synchronization should begin,
`
`the HotSync software resident on the PDA initiates the synchronization process,
`
`which includes a download of information to the PDA. Boyer, col. 3, lines 2
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