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
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`University. In various positions at, among others, TRW and Toyota, I have been
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`responsible for research and development projects relating to, among others,
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`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. 8,719,037 (the “’037 patent”). I
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`have over 35 years of experience in fields relevant to the ’037 patent, including
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`telecommunications systems and navigation systems.
`
`2.
`
`I have reviewed the ’037 patent, as well as its prosecution history and the
`
`prior art cited during its prosecution. I have also reviewed U.S. Patent No.
`
`6,249,740 (“Ito”), 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”), European Patent Application Publication
`
`No. 0 829 704 (“Fujiwara”), U.S. Patent No. 5,274,560 (“LaRue”), U.S. Patent No.
`
`5,574,443 (“Hsieh”), and “Plaintiff and Counter-Defendant West View Research,
`
`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. 8,719,037 (the “’037 patent”). I
`
`have over 35 years of experience in fields relevant to the ’037 patent, including
`
`telecommunications systems and navigation systems.
`
`2.
`
`I have reviewed the ’037 patent, as well as its prosecution history and the
`
`prior art cited during its prosecution. I have also reviewed U.S. Patent No.
`
`6,249,740 (“Ito”), 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”), European Patent Application Publication
`
`No. 0 829 704 (“Fujiwara”), U.S. Patent No. 5,274,560 (“LaRue”), U.S. Patent No.
`
`5,574,443 (“Hsieh”), and “Plaintiff and Counter-Defendant West View Research,
`
`1
`
`VWGoA - Ex. 1002
`Volkswagen Group of America, Inc., Petitioner
`
`1
`
`
`
`LLC’s Revised Disclosure of Asserted Claims and Infringement Contentions,
`
`Pursuant to Patent L.R. 3.1 and the June 10, 2015 Court Order” (“Infringement
`
`Contentions”), dated June 26, 2015.
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`The ’037 Patent
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`3.
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`The ’037 patent describes an information system for use in an elevator,
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`although it states that the disclosed systems and methods may also be useful in
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`other similar types of personnel transport devices (i.e., devices that transport large
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`numbers of people and equipment between two locations on a routine basis) such
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`as trams, shuttles, and moving walkways. ’037 patent, col. 6, lines 44 to 45, col. 2,
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`lines 34 to 39, and col. 6, lines 34 to 39. The elevator information system is
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`responsive to verbal commands. ’037 patent, col. 6, lines 43 to 65. Signals
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`captured by a microphone 118 as part of a speech recognition module 104 are
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`digitized by an analog to digital converter 141 and processed using a speech
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`recognition algorithm to produce digital representations of the user’s speech. ’037
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`patent, col. 7, lines 30 to 34. The digital representations are compared to a speech
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`library to identify matching known words and the desired functionality is
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`implemented. ’037 patent, col. 7, lines 34 to 40.
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`4.
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`One function of the display device includes accessing a network via a
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`network interface 300 (such as an Internet or intranet data link) which permits the
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`user to rapidly access updated information on a variety of predetermined topics of
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`2
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`2
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`
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`interest. For example, URLs for news headlines, weather, sports scores, financial
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`data, directions to local airports or public transportation, etc., may be provided.
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`’037 patent, col. 11, lines 10 to 22.
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`
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`5.
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`The Disclosures of Ito and Lind – Claims 22, 37, 42, 48, 71, 72, and 77
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`Ito and Lind disclose display systems used in “a transport apparatus” (claims
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`22 and 42), a “land-mobile transport apparatus” (claim 37), and a “land-mobile
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`personnel transport device” (claims 48 and 77) “configured to transport one or
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`more persons from one location to another” as claimed in claims 22, 37, 42, 48,
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`and 77 of the ’037 patent. Ito specifically discloses a display used for navigation in
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`a vehicle, such as an automobile. Ito, col. 1, lines 19 to 21. Lind describes a display
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`system used in an automobile, in particular, the “Network Vehicle,” which it
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`characterizes as a “convergence of computers, the communications infrastructure,
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`and the automobile.” Lind, page I21-1.
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`6.
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`Both Ito and Lind disclose automotive vehicles equipped with display
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`systems that provide drivers and/or passengers with various types of information,
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`including geographical information. Ito, col. 1, lines 19 to 21; Lind, page I21-1. Ito
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`and Lind specifically disclose a “computerized information and display apparatus
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`disposed at least partly within the passenger compartment” as claimed in claims
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`22, 37, 42, 48, and 77 of the ’037 patent. The computer and display disclosed in Ito
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`are “disposed at least partly within the passenger compartment.” The “processing
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`3
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`3
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`section 101” and the “display 106” are within the “vehicle navigation apparatus
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`100;” and the apparatus is both “computerized” and a “display apparatus.” Ito, col.
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`9, lines 51 to 67. The vehicle apparatus 100 is “mounted in a vehicle.” Id. at col. 8,
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`lines 11 to 16. Lind discloses an “on-board system” which includes a network
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`computer and a number of displays, and is located on-board the vehicle. The on-
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`board system is a “computerized information and display apparatus,” it is disposed
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`at least partly within the passenger compartment, and at least one display is located
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`in the center console. Lind, page I21-2.
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`7.
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`Ito and Lind disclose “a wireless network interface” as claimed in claims 22,
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`37, 42, and 48 of the ’037 patent and “a wireless network interface means” as
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`claimed in claim 77 of the ’037 patent. For example, Ito discloses a vehicle
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`apparatus 100 that wirelessly communicates with a base station using a
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`“transmitting and receiving section 108” that “includes devices such as a modem
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`and the like.” Ito, col. 10, lines 51 to 57. Ito discloses that this wireless connection
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`may “utilize systems such as car phones, portable phones PHS or the like.” Id.
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`These systems are wireless. Lind discloses a vehicle that includes “‘smart’
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`features” that “are enabled mainly because of the real-time data-streaming
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`capabilities over a wireless network.” Lind, page I21-2. Lind discloses that a
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`“wireless modem” is used as part of the system that connects to this wireless
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`network, as well as a “roof-mounted antenna.” Id.
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`4
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`4
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`8.
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`Ito and Lind disclose a “processing apparatus in data communication with
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`the network interface” as claimed in claims 22, 37, 42, and 48 of the ’037 patent
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`and a “processing means in data communication with the network interface for
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`processing data” as claimed in claim 77 of the ’037 patent. For example, Ito
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`discloses, in Figure 1, a “processing section 101,” which includes a CPU being
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`connected to and in data communication with the transmitting and receiving
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`section 108. Ito, col. 9, lines 51 to 67, Figure 1:
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`9.
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`Lind discloses
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`that
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`the Network Vehicle
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`includes,
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`for example,
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`“microprocessors.” Lind, page I21-1. Lind also discloses, in Figure 2, the “network
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`computer” being connected to and in data communication with, for example, the
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`DirecTV and DirecPC antennas:
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`5
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`5
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`10.
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`Ito and Lind disclose voice recognition systems, and Lind discloses a
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`“microphone” as claimed in claim 22 of the ’037 patent. For example, Ito describes
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`an input device that “us[es] voice recognition,” Ito, col. 10, lines 39 to 47, and
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`Lind discloses a speech recognition system that “allows the driver to access
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`virtually all the vehicle’s features through voice commands,” Lind, page I21-3.
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`Lind discloses that a “command and control application, … running on the
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`vehicle’s main processor, … controls devices such as … microphone, … and
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`controls vehicle software, such as the voice recognition … applications.” Lind,
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`page I21-6. As demonstrated, for example, by LaRue, at col. 5, line 17, voice
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`recognition systems rely on microphones for obtaining voice or speech input. It is
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`obvious from these disclosures that a microphone can be used to input a user’s
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`voice into an automotive voice recognition system, such as the navigation system
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`disclosed in Ito and the ViaVoice speech recognition system disclosed in Lind.
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`LaRue, col. 5, line 17.
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`6
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`6
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`11.
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`Ito and Lind disclose “a display device” as claimed in claim 22 of the ’037
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`patent, “a display device configured to be viewable by an occupant of the land-
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`mobile apparatus during use” as claimed in claims 37 and 48 of the ’037 patent, “a
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`display device configured to be viewable by an occupant of the transport apparatus
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`during use” as claimed in claim 42 of the ’037 patent, and a “display device means
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`configured to be viewable by an occupant of the land-mobile apparatus during use
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`for displaying information” as claimed in claim 77 of the ’037 patent. For example,
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`Ito discloses a display 106, equipped with a touch panel that is used to display
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`information, such as travel route and/or travel directions. Ito, col. 10, lines 48 to 50
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`and col. 15, lines 22 to 26. The display is viewable by an occupant, e.g., the driver.
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`Lind discloses display devices for use by the driver and additional display devices
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`for use by the vehicle passengers. According to Lind, the center console
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`additionally includes a touch-screen LCD display. Lind, pages I21-3, I21-4.
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`12.
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`Ito and Lind disclose “a storage apparatus comprising at least one computer
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`program” as claimed in claims 22, 37, and 42 of the ’037 patent, “computerized
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`logic” as claimed in claim 48 of the ’037 patent, and “computerized logic means”
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`as claimed in claim 77 of the ’037 patent. Ito discloses a “program storage section
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`102,” which serves as a memory for storing the programs that are executed by the
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`processing section 101. Ito, col. 9, lines 51 to 67. The program storage section 102
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`and processing section 101 described by Ito constitute a storage apparatus
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`7
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`7
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`
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`comprising at least one computer program, and also “computerized logic.” Ito and
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`Lind disclose voice recognition systems for inputting commands into the system.
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`Ito, col. 10, lines 39 to 47, Lind, page I21-1. As West View has acknowledged (and
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`I agree), “all speech recognition systems inherently digitize the speaker’s analog
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`voice” (Infringement Contentions, at 729), and the systems described by Ito and
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`Lind include a “speech recognition module.” Additionally, Ito describes a
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`processing section including a CPU as its main component. Ito, col. 9, lines 53 to
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`67. Lind also discloses a “main processor” that executes a command and control
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`application for managing various functions. Lind, page I21-6.
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`13.
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`Ito and Lind disclose at least one computer program configured to “obtain
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`digitized speech generated based on speech received from a passenger via the
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`microphone, the digitized speech comprising an affirmative request for desired
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`information which the passenger wishes to find via a network search, the desired
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`information relating to at least one of a plurality of predetermined topics of
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`interest” as claimed in claim 22 of the ’037 patent, “obtain digitized speech
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`generated based on speech received from the occupant, the digitized speech
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`comprising a request for desired information which the occupant wishes to obtain,”
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`as claimed in claim 37 of the ’037 patent, “obtain digitized speech generated based
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`on speech received from the occupant, the digitized speech comprising one or more
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`terms relating to a desired information which the occupant wishes to obtain” as
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`8
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`8
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`
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`claimed in claim 42 of the ’037 patent, and “obtain digitized speech generated
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`based on speech received from the occupant, the received speech comprising a
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`request for desired information which the occupant wishes to obtain” as claimed in
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`claims 48 and 77 of the ’037 patent. For example, Ito discloses that, among the
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`inputs the user may enter into the system, are “information about the destination,
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`such as the facility name, telephone number and address thereof, and a route search
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`request.” Ito, col. 15, lines 47 to 58. This input of information about the destination
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`is related to both a “request for desired information,” an “affirmative request for
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`desired information,” and also “one or more terms relating to desired information,”
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`with the desired information being, e.g., navigation data. The network search,
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`which Ito describes takes place when the system searches a remote database of
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`location data (Ito, col. 8, lines 28 to 40), is a search “relating to at least one of a
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`plurality of predetermined topics of interest,” such as the facility name. Lind also
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`discloses that the user may use voice commands to, e.g., “locate a restaurant or
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`hotel” and “ask for navigation help,” Lind, page I21-2, and to “request travel
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`directions and traffic updates from the Web or other sources,” Lind, page I21-3. As
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`discussed above, West View has also acknowledged (and I agree), “all speech
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`recognition systems inherently digitize the speaker’s analog voice.” Infringement
`
`Contentions, at 729.
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`9
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`9
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`14.
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`Ito and Lind disclose at least one computer program configured to “cause,
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`based at least in part on the digitized speech, search of a remote network entity to
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`cause retrieval of the desired information” as claimed in claim 22 of the ’037
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`patent, “cause, based at least in part on the digitized speech, access of a remote
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`network entity via the network interface to cause retrieval of the desired
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`information” as claimed in claim 37, 48, and 77 of the ’037 patent, “cause, based at
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`least in part on at least one of the one or more terms, access of a remote network
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`entity via the network interface to cause retrieval of the desired information” as
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`claimed in claim 42 of the ’037 patent, “receive the desired information via the
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`network interface” as claimed in claims 37, 42, and 48, and “receive the desired
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`information via the network interface means” as claimed in claim 77 of the ’037
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`patent. For example, Ito discloses that the user inputs, including one or more terms,
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`are used to search the database of navigation data which is located remotely from
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`the vehicle. Ito, col. 8, lines 28 to 50. The vehicle transmits location data as well as
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`the request for a route search to the base apparatus, which includes the database.
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`Id. at col. 10, line 64 to col. 11, line 30 and col. 15, lines 30 to 37. The map and
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`guidance data are transmitted via the network interface back to the navigation
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`apparatus. Id. Ito discloses both that the navigation database is “searched” for
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`navigation data, and also “accessed.” Id. Lind discloses that the driver can use the
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`10
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`10
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`
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`advanced speech recognition system of the Network Vehicle to “request travel
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`directions and traffic updates from the Web or other sources.” Lind, page I21-3.
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`15.
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`Ito and Lind disclose that an “apparatus is further configured to display
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`content on the display device, the content received via the network interface and
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`selected based at least in part on the digitized speech” as claimed in claim 22 of the
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`’037 patent, that “the apparatus is further configured to display at least a portion of
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`the desired information on the display device, the information received via the
`
`network interface and selected based at least in part on the digitized speech” as
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`claimed in claim 37 of the ’037 patent, that “the computerized information and
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`display apparatus is further configured to display at least a portion of the desired
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`information on the display device, the information received via the network
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`interface and selected based at least in part on the digitized speech” as claimed in
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`claim 42 of the ’037 patent, that “the information and display apparatus is further
`
`configured to display at least a portion of the desired information on the display
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`device, the information received via the network interface and selected based at
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`least in part on the digitized speech” as claimed in claim 48 of the ’037 patent, and
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`that “the information and display apparatus is further configured to display at least
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`a portion of the desired information on the display device means, the information
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`received via the network interface means and selected based at least in part on the
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`digitized speech” as claimed in claim 77 of the ’037 patent. For example, Ito
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`11
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`11
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`
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`discloses that the navigation information (“desired information” or “content”) is
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`received via the network interface and displayed on the display 106 as a
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`recommended route in the form of an outline map. Ito, col. 16, lines 21 to 27. Lind
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`also discloses that navigation information can be displayed on the display. Lind,
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`page I21-3 and Fig. 9.
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`16.
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`Ito and Lind disclose that “the desired information comprises at least one of
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`a map and/or directions to a particular organization or entity accessible by the
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`transport apparatus” as claimed in claim 37 of the ’037 patent, and that “the desired
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`information comprises at least one of a map and/or directions to a particular
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`organization or entity accessible by the occupant” as claimed in claim 48 of the
`
`’037 patent. For example, Ito discloses that a map and directions can be displayed
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`on the display device, in Figure 9(A). As one example of a possible destination, Ito
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`discloses “one’s own house.” Ito, col. 27, lines 6 to 9. One’s own house is
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`accessible by a transport apparatus (an automobile), by parking it in the garage.
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`One’s own house is also accessible by the occupant, by walking inside. According
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`to Lind, the Network Vehicle “can display the appropriate maps or simply provide
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`route directions on the head-up display, command console or as spoken
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`instructions.” Lind, page I21-7. Figure 9, for example, of Lind shows “an example
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`of such a display.”
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`12
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`12
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`17.
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`Ito and Lind disclose that “the desired information comprises at least one of
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`a map and/or directions to a particular organization or entity accessible by the
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`transport apparatus, the at least one map and/or directions comprising a graphical
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`representation of the organization or entity and its surroundings” as claimed in
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`claim 42 of the ’037 patent. For example, Ito discloses that the map displayed in
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`Figures 9(A), 40(C), and 44 include a “graphical representation of the entity and its
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`surroundings.” In addition to displaying a representation of the destination, Figures
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`9(A), 40(C), and 44 of Ito also display the roads and intersections that surround it.
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`18. As stated above, according to Lind, the Network Vehicle “can display the
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`appropriate maps or simply provide route directions on the head-up display,
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`command console or as spoken instructions,” Lind, page I21-7, and Figure 9 of
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`Lind, for example, shows “an example of such a display.”
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`19.
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`Ito discloses that “the desired information comprises a map and visual
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`directions to a particular organization or entity accessible by the transport device,
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`the visual directions comprising at least a visually differentiated line or arrow
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`showing a direction of travel from one location to the organization or entity via one
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`or more pre-established travel infrastructure” as claimed in claim 77 of the ’037
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`patent. For example, Ito discloses, in Figures 9(A) and 9(B), visually differentiated
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`lines and arrows showing the direction of travel between the departure and the
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`destination using pre-established travel infrastructure, or roads.
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`13
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`13
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`20. Lind discloses that “the display device is mounted substantially flush with a
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`surface of the interior of the passenger compartment so as to be visible by at least
`
`the occupant, yet mitigate incidental contact therewith” as claimed in claim 71 of
`
`the ’037 patent. For example, Lind discloses a touch screen display mounted in the
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`center console. Lind, page I21-3. This display is visible by an occupant, e.g., the
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`driver, in order to allow the occupant to view what it is displaying, and to utilize
`
`the touch screen. The display in the center console in Lind is “substantially flush”
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`with a surface of the passenger compartment, and to mount it in such a way would
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`mitigate incidental contact therewith as compared to locating it, e.g., on the
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`steering wheel or on top of the dashboard.
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`21.
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`Ito and Lind disclose “a plurality of doors which provide access to the
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`passenger compartment” as claimed in claim 72 of the ’037 patent. Automobiles
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`and other vehicles include one or more doors that provide access to the passenger
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`compartment. For example, Ito discloses “a moving body such as a vehicle, Ito,
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`col. 1, lines 9 to 17, and Lind discloses an SUV that includes multiple doors which
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`provide such access, Lind, pages I21-1, I21-5. Multiple doors are shown, for
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`example, in Figures 1 and 7 of Lind:
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`14
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`14
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`
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`The Level of Skill in the Art
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`22. Several years before the earliest filing date claimed as priority by the ’037
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`patent, as well as contemporaneously with filing of the application for the ’037
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`patent, other automotive industry companies had already developed, and were
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`developing, vehicles with Internet connectivity (allowing users to, for example,
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`retrieve information wirelessly from remote databases while inside their vehicles),
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`speech-recognition functionality, and navigation functionality.
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`23. As described by Lind, the Network Vehicle was designed and developed by
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`Delphi Delco Electronics Systems, IBM, Netscape Communication, and Sun
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`Microsystems. The Network Vehicle developers loaded several computing and
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`communications devices into a vehicle, to demonstrate that the technology could
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`successfully be used in a variety of ways. The Network Vehicle included a roof-
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`mounted antenna to provide a satellite connection to the Internet. Lind, page I21-2.
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`The system associated with the Network Vehicle included an off-board network
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`architecture, including, for example, a home/office computer and an IBM web
`15
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`15
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`
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`server. Lind, page I21-2. As described by Lind, the Network Vehicle developers
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`provided a Website for users of the Network Vehicle to remotely access the
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`computing systems located in the vehicle. The vehicle Website allowed users to
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`“plan trips on the vehicle web site, then download them to your vehicle.” Lind,
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`page I21-7.
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`24. Lind also describes systems in which a user can receive various types of
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`information inside the vehicle, including e-mail. The Network Vehicle was
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`demonstrated at the Computer Dealer’s Exhibits (COMDEX ’97) conference in
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`Las Vegas, Nevada on November 17-19, 1997. At this demonstration, the use of
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`the Network Vehicle Website described by Lind, as noted above, was
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`demonstrated to attendees of the conference.
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`25.
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`I have reviewed screenshots of the Network Vehicle Website; those
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`screenshots are attached as Exhibit B. I acquired these screenshots pursuant to my
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`work as an expert witness engaged by Volkswagen Group of America, Inc. in
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`connection with the litigation Affinity Labs of Texas, LLC v. BMW North America,
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`LLC, et al., Case No. 9:08-cv-00164 (E.D. Tex.).
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`26.
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`In 1997, I personally attended a demonstration of the Network Vehicle,
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`conducted by Delphi and a Delphi supplier, at Toyota’s headquarters in Toyota
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`City, Japan. At that event, the features of the Network Vehicle were demonstrated
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`and the system operation was explained.
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`16
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`16
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`27. Referring to Exhibit B, as illustrated on, e.g., the “Driver profile” page, the
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`Network Vehicle maintained a set of profiles for each driver, including personal
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`data, entertainment preferences, information preferences, vehicle preferences, and
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`a personal address book.
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`28. Referring to Exhibit C (VW is working on a multimedia car, Reuters AG,
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`April 22, 1996), Volkswagen had also designed a “multimedia car” and presented
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`an “Infotainment Car” at a conference in Hannover, Germany in 1996; the
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`Infotainment Car included, for example, a PC with Internet connectivity.
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`29.
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`In 1997, for example, in the Connected CarPC described in Exhibit D (In-
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`Car Computing and Communication Enables Entertainment, Productivity and
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`Information, Dedicated Conference on ATT/ITS Advances for Enhancing
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`Passenger, Freight & Intermodal Transportation Systems, p. 411-417 (1997)),
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`communication links were already available for use in automobiles to provide
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`traffic information, Internet access to find hotels, restaurants, and travel guides,
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`and to schedule maintenance, perform remote diagnostics and receive software
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`updates. The “Connected CarPC environment” at that time included both speech
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`recognition functionality and Internet access.
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`30. The Daimler-Benz Internet Multimedia on Wheels Concept Car, also
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`referred to as the Internet Car, and described in Exhibit E (Jameel et al., Internet
`
`Multimedia on Wheels: Connecting Cars to Cyberspace (IEEE 1998)) and Exhibit
`
`17
`
`17
`
`
`
`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
`
`included “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 also permitted 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.”
`
`31. Microsoft’s Auto PC, described in Exhibit G (Jost, The car as a mobile-
`
`media platform, Automotive Engineering International, pp. 49-53 (May 1998)),
`
`included “the benefits of interactive speech technology, connectivity, information
`
`on demand, and enhanced entertainment to the automobile.”
`
`32. Visteon’s ICES system, described in Exhibit G, included a voice-activated
`
`control system that permitted “drivers to control vehicle functions that are usually
`
`operated manually,” and “[t]hrough speech recognition, the driver can send e-mail,
`
`obtain turn-by-turn Global Positioning 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
`
`18
`
`18
`
`
`
`was included in Visteon’s ICES system and “used for vehicle-to-roadside
`
`assistance or to receive e-mail and Internet information.”
`
`Obviousness in View of Ito and Lind
`
`33. The systems described in claims 22, 37, 42, 48, 71, 72, and 77 of the ’037
`
`patent were obvious from the disclosures of Ito and Lind.
`
`34. Both Ito and Lind describe systems that provide information to the driver of
`
`an automobile. Lind, page I21-1; Ito, col. 2, lines 65 to 67 and col. 3, lines 2 to 3.
`
`Both of these systems also address problems related to providing a user of an
`
`automobile with navigation information, and displaying that information in a
`
`useful manner. Id. The ’037 patent purports to address problems related to
`
`“obtaining and displaying information” (’037 patent, Abstract) and to “allow the
`
`occupants of the elevator … to use their time more efficiently and obtain needed
`
`information” (Id. at col. 3, lines 36 to 41). Ito and Lind disclose the necessary
`
`hardware to receive voice inputs, wirelessly connect to a remote database, and
`
`retrieve navigation information including maps. Ito, col. 9, lines 51 to 67, col. 10,
`
`lines 51 to 57; Lind, pages I21-1 to I21-3, I21-7. Maps, such as those shown in
`
`Figures 9(A) and 9(b) of Ito, can be displayed in the Network Vehicle disclosed by
`
`Lind in order to address problems related to “obtaining and displaying
`
`information” as stated in the ‘037 patent. And selecting a destination that is
`
`accessible by the transport apparatus or accessible by the occupant is no more than
`
`19
`
`19
`
`
`
`a particular implementation of the geographic database disclosed in Ito, as well as
`
`the databases used in the automotive industry vehicles and systems that preceded
`
`the application for the ’037 patent.
`
`
`
`The Disclosures of Ito, Lind, and Fujiwara – Claim 1
`
`35. Fujiwara discloses that “the computerized information and display apparatus
`
`is further configured to display advertising content on the display device, the
`
`content received via the network interface and selected based at least in part on the
`
`digitized speech” as claimed in claim 1 of the ’037 patent. For example, Fujiwara
`
`discloses the display of advertising content, such as information relating to the
`
`hotel “H&H Tokyo,” such as room rates, vacancy information, and a free sauna, in
`
`Figure 22 and at 5:53-6:2.
`
`36. This advertising information is displayed on a display device, and also
`
`received via a network interface. Fujiwara, col. 4, lines 14 to 22 and col. 5, line 53
`
`
`
`to col. 6, line 7.
`
`20
`
`20
`
`
`
`37. The system claimed in claim 1 of the ’037 patent is obvious from the
`
`disclosures of Ito, Lind, and Fujiwara. It is obvious that advertising information, as
`
`disclosed by Fujiwara, can be used in the systems of Ito and Lind, to “provide a
`
`navigation system, by which much information is capable to be accessed so as to
`
`suitably control the amount of information to be communicated and the received
`
`information is capable to be displayed intelligibly.” Fujiwara, col. 1, line 55 to col.
`
`2, line 2. Modifying the systems of Ito and Lind, which already transmit map and
`
`navigation information to the vehicle, and display map and navigation information
`
`in the vehicle, to also transmit the advertising information disclosed in Fujiwara,
`
`would require no structural modifications of the system and would not provide
`
`unexpected results. Providing advertising information, as disclosed by Fujiwara, in
`
`the systems of Ito and Lind benefits the user by providing useful information, such
`
`as room rates, vacancy information, etc., such that users can be alerted of services
`
`of which they might not otherwise be aware.
`
`
`
`The Disclosures of Ito, Lind, and Hsieh – Claims 73 and 75
`
`38. The systems claimed in claims 73 and 75 of the ’037 patent are obvious
`
`from the disclosures of Ito, Lind, and Hsieh.
`
`39.
`
`It is obvious that the CCD video cameras of Hsieh may be placed in data
`
`communication with the processing apparatuses disclosed in Ito or Lind. Hsieh
`
`discloses a “video data apparatus in data communication with the processing
`
`21
`
`21
`
`
`
`apparatus and configured to enable video data to be generated and displayed on the
`
`display device, the video data generated by one or more cameras associated with
`
`the personnel transport device so as to enable monitoring of one or more portions
`
`of an area surrounding the personnel transport device” as claimed in claim 73 of
`
`the ’037 patent. Hsieh discloses CCD video cameras that are mounted on the rear
`
`of a car, and a control system connected to those cameras. Hsieh, page 2, line 7,
`
`lines 18 to 20, and lines 60 to 62. The video data generated by these cameras is
`
`displayed on a display device (Hsieh, page 1, lines 7 to 11) and is used to monitor
`
`an area behind the car in order to prevent a collision when backing up the car
`
`(Hsieh, page 1, lines 12 to 13). These video cameras are also the same type as
`
`those described in the specification of the ’037 patent (see ’037 patent, col. 17,
`
`lines 4 to 32).
`
`40.
`
`It is obvious that the vehicle monitoring apparatus, rear view camera, and
`
`television disclosed by Hsieh may be used in the systems described in Ito and Lind
`
`to “provide a vehicle monitoring apparatus” to display a picture on a television
`
`placed inside the vehicle (Hsieh, page 1, lines 39 to 53), e.g., a backup camera.
`
`Providing a known backup camera as disclosed in Hsieh in the computerized
`
`information and display systems disclosed in Ito and Lind would have required no
`
`major modifications to those systems, because they already included displays
`
`22
`
`22
`
`
`
`capable of displaying videos generated by CCD cameras and would have provided
`
`only expected results.
`
`41. Lind discloses “a communication apparatus configured to enable at least
`
`voice communication by a passenger with a remote monitoring station while the
`
`transport device is in operation” as claimed in claim 75 of the ’037 patent. Lind
`
`discloses, for example, that the Network Vehicle includes cell phone and in-vehicle
`
`audio system that is used as a speakerphone, allowing hands-free communication,
`
`Lind, page I21-7, and that a customer service representative can be contacted using
`
`the Networ
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