DECLARATION OF SCOTT ANDREWS
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`I, Scott Andrews, declare as follows:
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`I hold a B.Sc. degree in Electrical Engineering from University of
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`1.
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`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
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`systems. My qualifications are further set forth in my curriculum vitae (Exhibit A).
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`I have been retained by Volkswagen Group of America, Inc. in connection with its
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`petition for inter partes review of U.S. Patent No. 8,706,504 (“the ’504 patent”). I
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`have over 35 years of experience in fields relevant to the ’504 patent, including
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`telecommunications systems and navigation systems.
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`2.
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`I have reviewed the ’504 patent, as well as its prosecution history and the
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`prior art cited during its prosecution. I have also reviewed U.S. Patent No.
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`6,249,740 (“Ito”), the Richard Lind et al. publication, The Network Vehicle – A
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`Glimpse
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`into
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`the Future of Mobile Multi-Media, 17th DASC, The
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`AIAA/IEEE/SAE Digital Avionics Systems Conference – Bellevue, WA – Oct.
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`31-Nov. 7, 1998 – Proceedings (“Lind”), European Patent Application Publication
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`No. 0 829 704 (“Fujiwara”), U.S. Patent No. 5,274,560 (“LaRue”), and “Plaintiff
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`and Counter-Defendant West View Research, LLC’s Revised Disclosure of
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`VWGoA - Ex. 1002
`Volkswagen Group of America, Inc., Petitioner
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`Asserted Claims and Infringement Contentions, Pursuant to Patent L.R. 3.1 and the
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`June 10, 2015 Court Order” (“Infringement Contentions”), dated June 26, 2015.
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`The ’504 Patent
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`3.
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`The ’504 patent describes an information system for use in an elevator,
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`although the ’504 patent states that the disclosed systems and methods may also be
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`useful in other similar types of personnel transport devices (i.e., devices that
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`transport large numbers of people and equipment between two locations on a
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`routine basis) such as trams, shuttles, and moving walkways. ’504 patent, col. 6,
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`lines 20 to 21; col. 2, lines 34 to 40; col. 6, lines 9 to 15. The elevator information
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`system is responsive to verbal commands. Id. at col. 6, lines 20 to 41. 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. Id. at
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`col. 7, lines 6 to 10. The digital representations are compared to a speech library to
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`identify matching known words and the desired functionality is implemented. Id. at
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`col. 7, lines 10 to 13.
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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. The ’504 patent also discloses that the
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`elevator display devices “may be programmed to provide adaptive advertising or
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`information.” ’504 patent, col. 20, lines 60 to 62. Based on voice commands
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`(which the system may simply overhear, or be prompted to obtain), the system
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`accesses a building directory file to “obtain pertinent advertising information.” Id.
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`at col. 21, lines 2 to 58; col. 22, lines 20 to 47. The “Adaptive Advertising Sub-
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`System” is described at col. 20, line 56 to col. 24, line 67 of the ’504 patent.
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`The Disclosures of Ito and Lind – Claims 43, 44, 45, 46, and 48
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`5.
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`Ito and Lind disclose computerized information and display systems used in
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`“a land-mobile transport apparatus” as claimed in claims 43, 44, 45, 46, and 48 of
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`the ’504 patent. Ito discloses an apparatus that includes both a processing section
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`and a display. Ito, col. 9, lines 51 to 67. The display in Ito is a touch panel display,
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`which is located in the vehicle. Id. at col. 10, lines 39 to 45. Lind also discloses a
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`vehicle system that includes a “network computer” that is part of the “on board
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`system.” Lind, page I21-2. Additionally, Lind discloses “three displays for the
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`driver,” one of which is a “touch-screen LCD” located on the vehicle’s center
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`console that “serves as a user interface.” Id. at page I21-3.
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`6.
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`Ito and Lind disclose “a wireless network interface” as claimed in claim 43
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`of the ’504 patent. For example, Ito discloses a vehicle apparatus 100 that
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`wirelessly communicates with a base station using a “transmitting and receiving
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`section 108” that “includes devices such as a modem and the like.” Ito, col. 10,
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`lines 51 to 57. Ito discloses that this wireless connection may “utilize systems such
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`as car phones, portable phones PHS or the like.” Id. These systems are wireless.
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`Lind discloses a vehicle that includes “‘smart’ features” that “are enabled mainly
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`because of the real-time data-streaming capabilities over a wireless network.”
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`Lind, page I21-2. Lind discloses that a “wireless modem” is used as part of the
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`system that connects to this wireless network, as well as a “roof-mounted antenna.”
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`Id.
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`7.
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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 claim 43 of the ’504 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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`8.
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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 at least the
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`DirecTV and DirecPC antennas:
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`9.
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`Ito and Lind disclose “a display device configured to be viewable by an
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`occupant of the land-mobile apparatus during use” as claimed in claim 43 of the
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`’504 patent. For example, Ito discloses a “display 106,” that includes a liquid
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`crystal display or cathode ray tube (“CRT”) that is equipped with a touch panel and
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`is mounted in the vehicle. Ito, col. 10, lines 48 to 50 and col. 8, lines 11 to 16. The
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`display 106 is used to display information, such as a travel route and/or travel
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`directions. Ito, col. 15, lines 22 to 26. The display 106 is also viewable by an
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`occupant, e.g., the driver. Lind discloses display devices for use by the driver and
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`additional displays for use by the vehicle passengers. According to Lind, the center
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`console includes a touch-screen LCD in the center console. Lind, pages I21-3, I21-
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`4.
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`10.
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`Ito and Lind disclose “a storage apparatus comprising at least one computer
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`program” as claimed in claim 43 of the ’504 patent. For example, Ito discloses a
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`“program storage section 102” that “serves as a memory for storing programs
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`which will be executing [sic] by the processing section 101, such as a program for
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`displaying routes on the display 106.” Ito, col. 9, lines 51 to 67. Lind discloses a
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`“main processor” that executes a command and control application for managing
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`various functions. Lind, page I21-6.
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`11.
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`Ito and Lind disclose at least one program configured to “obtain digitized
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`speech generated based on speech received from the occupant, the digitized speech
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`relating to a desired information which the occupant wishes to obtain” as claimed
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`in claim 43 of the ’504 patent. For example, Ito discloses that, among the inputs
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`the user may enter into the system, are “information about the destination, such as
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`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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`relates to “desired information which the occupant wishes to obtain,” the desired
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`information being, e.g., navigation data. Lind also discloses that the user may use
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`voice commands to, e.g., “locate a restaurant or hotel” and “ask for navigation
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`help,” Lind, page I21-2, and to “request travel directions and traffic updates from
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`the Web or other sources,” Lind, page I21-3. As discussed above, West View has
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`also acknowledged (and I agree), “all speech recognition systems inherently
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`digitize
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`the speaker’s analog voice.” Infringement Contentions, at 729.
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`Additionally, when using software to process speech, speech is digitized in order to
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`be processed. See, LaRue, col. 5, lines 17 to 30, (which receives an analog voice
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`input through a microphone, amplifies it, digitizes it, and then analyzes it using a
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`digital signal processor).
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`12.
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`Ito and Lind disclose at least one program configured to “cause, based at
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`least in part on the digitized speech, access of a remote network entity to cause
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`retrieval of the desired information” as claimed in claim 43 of the ’504 patent. For
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`example, Ito discloses that a “remote network entity,” which is the database of
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`navigation data located at the base station, is searched based upon the user inputs.
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`Ito, Figure 1 and col. 8, lines 28 to 40. Ito discloses that, upon the user inputting a
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`route search request, the vehicle transmits that search as well as data related to its
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`location to the base apparatus and, after a route search takes place at the base
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`apparatus, a map and guidance data (the desired information) are transmitted, via
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`the network interface, back to the navigation apparatus 100. Id. at col. 10, line 64
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`to col. 11, line 30 and col. 15, lines 30 to 37. Lind discloses that the driver can use
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`the 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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`13.
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`Ito and Lind disclose at least one computer program configured to “receive
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`the desired information via the network interface” as claimed in claim 43 of the
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`’504 patent. For example, Ito discloses that the user inputs, including one or more
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`terms, are used to search the database of navigation data which is located remotely
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`from the vehicle. Ito, col. 8, lines 28 to 50. The vehicle transmits location data as
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`well as the request for a route search to the base apparatus, which includes the
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`database. Id. at col. 10, line 64 to col. 11, line 30 and col. 15, lines 30 to 37. The
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`map and guidance data are transmitted via the network interface back to the
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`navigation apparatus. Id. Lind discloses that the driver can use the advanced
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`speech recognition system of the Network Vehicle to “request travel directions and
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`traffic updates from the Web or other sources.” Lind, page I21-3.
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`14.
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`Ito and Lind disclose that “the computerized information and display
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`apparatus is further configured to display at least a portion of the desired
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`information on the display device, the at least portion 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 43 of the ’504 patent. For example, Ito discloses that the desired information
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`(the navigation information) is received via the network interface and displayed on
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`the display 106 as a recommended route in the form of an outline map. Ito, col. 16,
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`lines 21 to 27. The recommended route, displayed in the form of an outline map,
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`may include facilities that are searched using voice inputs (Id. at col. 16, lines 5 to
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`19), and the displayed map includes a “destination established as described above”
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`(e.g., established based upon user input) (Id. at col. 16, lines 21 to 27). According
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`to Lind, by using the Network Vehicle’s advanced speech recognition system, “the
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`driver can: … request travel directions and traffic updates from the Web or other
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`sources.” Lind, page I21-3. Lind also discloses that navigation information can be
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`displayed on the display. Id. at pages I21-2 (“Drivers can use a head-up display
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`projected through the windshield to navigate to their destination”), I21-3 (the head-
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`up display (HUD) “displays … navigation information”) and Figure 9.
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`15.
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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 land-
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`mobile apparatus” as claimed in claim 44. For example, Ito discloses that the
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`displayed information includes a map and directions to a desired entity, which is
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`accessible by a vehicle, as shown in Figure 9(A), below:
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`16.
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`Ito discloses that the destination may be “one’s own house.” Ito, col. 27,
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`lines 6 to 9. One’s own house is accessible by the “land-mobile apparatus,” or
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`automobile, by parking it in the garage. Lind discloses that “the driver can: …
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`request travel directions and traffic updates from the Web or other sources.” Lind,
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`page I21-3.
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`17.
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`Ito and Lind disclose that “the desired information comprises at least both
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`the map and the directions to the particular organization or entity accessible by the
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`land-mobile apparatus, and the directions include at least one arrow showing a path
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`for the land-mobile apparatus to follow to get to the organization or entity” as
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`claimed in claim 45 of the ’504 patent. Ito discloses in Figure 9(A), above, that the
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`displayed desired information can be both a map and directions to a destination
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`accessible by the land-mobile apparatus. Additionally, Ito discloses that the
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`displayed directions include at least one arrow showing a path for the land-mobile
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`apparatus to follow to get to the destination, shown in Figures 9(A), above, and
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`9(B), below:
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`18.
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`Lind discloses that “the driver can: … request travel directions and traffic
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`updates from the Web or other sources.” Lind, page I21-3. Lind also discloses that
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`navigation information can be displayed on the display. Id. at pages I21-2
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`(“Drivers can use a head-up display projected through the windshield to navigate
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`to their destination”), I21-3 (the head-up display (HUD) “displays … navigation
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`information”) and Figure 9. It is obvious to use arrows in the navigation display of
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`Lind to conveniently provide turn-by turn instructions to the driver.
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`19.
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`Ito and Lind disclose that “the desired information comprises at least both
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`the map and directions to the particular organization or entity accessible by the
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`land-mobile apparatus” as claimed in claim 46 of the ’504 patent. Ito discloses in
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`Figures 9(A) and 9(B), above, that the displayed desired information can be both a
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`map and directions to a destination accessible by the land-mobile apparatus. Lind
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`discloses that “the driver can: … request travel directions and traffic updates from
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`the Web or other sources.” Lind, page I21-3. Lind also discloses that navigation
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`information can be displayed on the display. Id. at pages I21-2 (“Drivers can use a
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`head-up display projected through the windshield to navigate to their destination”),
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`I21-3 (the head-up display (HUD) “displays … navigation information”) and
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`Figure 9.
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`20.
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`Ito and Lind disclose that “the computerized information and display
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`apparatus further comprises a speech synthesis apparatus which is configured to
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`generate audible sounds for the occupant, the sounds comprising human-
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`intelligible words relating to the occupant’s digitized speech” as claimed in claim
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`46 of the ’504 patent. For example, Ito discloses that the apparatus includes a
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`“voice output section” 107, and that the program storage section 102 includes “a
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`program for outputting a route guidance voice via the voice output section 107.”
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`Ito, col. 9, lines 61 to 67. Lind discloses that the vehicle has a “text-to-speech”
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`system that can “talk back using synthesized speech.” Lind, page I21-3. The
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`system in Lind can provide route directions “as spoken instructions” (which
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`include “human-intelligible words”). Id. at page I21-7. The outputs of Ito’s
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`“speech synthesis apparatus” and Lind’s “text-to-speech” apparatus include
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`“human-intelligible words” to provide the route directions disclosed in Ito and
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`Lind as spoken instructions.
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`21.
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`Ito and Lind disclose that “the computerized information and display
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`apparatus further comprises a speech synthesis apparatus which is configured to
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`generate audible sounds for the occupant, the sounds comprising one or more
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`human-intelligible words which direct the occupant to take one or more actions so
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`as to enable the occupant to locate an organization or entity of interest” as claimed
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`in claim 48 of the ’504 patent. For example, Ito discloses that the route guidance
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`voice output through the voice output section enables the occupant to “locate an
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`organization or entity of interest,” namely, a destination. Ito, col. 9, lines 61 to 67.
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`Ito discloses that the apparatus includes a “voice output section” 107, and that the
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`program storage section 102 includes “a program for outputting a route guidance
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`voice via the voice output section 107.” Ito, col. 9, lines 61 to 67. Lind discloses
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`that the vehicle has a “text-to-speech” system that can “talk back using synthesized
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`speech.” Lind, page I21-3. The system in Lind can provide route directions “as
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`spoken instructions.” Id. at page I21-7. The outputs of Ito’s “speech synthesis
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`apparatus” and Lind’s “text-to-speech” apparatus include “human-intelligible
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`words” to provide the route directions disclosed in Ito and Lind as spoken
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`instructions. Spoken instructions regarding route guidance include “human-
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`intelligible words.”
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`The Level of Skill in the Art
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`22.
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`Several years before the earliest filing date claimed as priority by the ’504
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`patent, as well as contemporaneously with filing of the application for the ’504
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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
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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.
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`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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`27. 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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`28.
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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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`29.
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`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
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`Multimedia on Wheels: Connecting Cars to Cyberspace (IEEE 1998)) and Exhibit
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`F (Jameel et al., Web on Wheels: Toward Internet-Enabled Cars (IEEE January
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`1998)), included “an on-board, integrated wireless communication system and the
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`computing infrastructure to provide Internet connectivity from the car to any
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`specific server on the Internet while stationary or in motion.” The Internet Car
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`included “Personal device (smart cards, HPCs) [to] be used to personalize car
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`seats, climate, phone numbers, Internet services bookmarks, and computing man
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`machine interface.” The Internet Car also permitted drivers to “access … voice-
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`mail, e-mail, and travel-related information such as restaurant guides and movie
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`theater locations” “in a hands-free, eyes-free manner through voice commands and
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`speech technology.”
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`30. Microsoft’s Auto PC, described in Exhibit G (Jost, The car as a mobile-
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`media platform, Automotive Engineering International, pp. 49-53 (May 1998)),
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`included “the benefits of interactive speech technology, connectivity, information
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`on demand, and enhanced entertainment to the automobile.”
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`31. Visteon’s ICES system, described in Exhibit H, included a voice-activated
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`control system that permitted “drivers to control vehicle functions that are usually
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`operated manually,” and “[t]hrough speech recognition, the driver can send e-mail,
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`obtain turn-by-turn Global Positioning Satellite (GPS)-based navigation to a
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`specific destination, ask for traffic and weather conditions, locate a restaurant or
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`hotel, or change the musical selection on the stereo.” Wireless Internet connectivity
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`was included in Visteon’s ICES system and “used for vehicle-to-roadside
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`assistance or to receive e-mail and Internet information.”
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`Obviousness in View of Ito and Lind
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`32.
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`The systems described in claims 43, 44, 45, 46, and 48 of the ’504 patent
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`were obvious from the disclosures of Ito and Lind.
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`33. Both Ito and Lind describe systems that provide information to the driver of
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`an automobile. Lind, page I21-1; Ito, col. 2, lines 65 to 67 and col. 3, lines 2 to 3.
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`Both of these systems also address problems related to providing a user of an
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`automobile with navigation information, and displaying that information in a
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`useful manner. Id. The ’504 patent purports to address problems related to
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`“obtaining and displaying information” (’504 patent, Abstract) and to “allow the
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`occupants of the elevator … to use their time more efficiently and obtain needed
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`information” (Id. at col. 4, lines 1 to 6). Ito and Lind disclose the necessary
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`hardware to receive voice inputs, wirelessly connect to a remote database, and
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`retrieve navigation information including maps. Ito, col. 9, lines 51 to 67, col. 10,
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`lines 51 to 57; Lind, pages I21-1 to I21-3, I21-7. Maps, such as those shown in
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`Figures 9(A) and 9(b) of Ito, can be displayed in the Network Vehicle disclosed by
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`Lind in order to address problems related to “obtaining and displaying
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`information” as stated in the ’504 patent. And selecting maps and/or directions to a
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`particular destination, organization, or entity that is accessible by the transport
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`apparatus or accessible by the occupant, and providing speech output for the
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`vehicle occupant, are no more than particular implementations of the geographic
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`database disclosed in Ito, as well as the databases used in the automotive industry
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`vehicles and systems that preceded the application for the ’504 patent.
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`The Disclosures of Ito, Lind, and Fujiwara – Claims 1 and 37
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`34.
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`Fujiwara discloses that “the computerized information and display apparatus
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`is further configured to display advertising content on the display device, the
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`content received via the network interface and selected based at least in part on the
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`digitized speech” as claimed in claim 1 of the ’504 patent and that “the
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`computerized information and display apparatus is further configured to display
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`advertising content and at least a portion of the desired information on the display
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`device, the content received via the network interface and selected based at least in
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`part on the digitized speech” as claimed in claim 37 of the ’504 patent. For
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`example, Ito discloses that the desired information (the navigation information) 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. The
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`recommended route, displayed in the form of an outline map, may include facilities
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`that are searched using voice inputs (Id. at col. 16, lines 5 to 19), and the displayed
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`map includes a “destination established as described above” (e.g., established
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`based upon user input) (Id. at col. 16, lines 21 to 27). According to Lind, by using
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`the Network Vehicle’s advanced speech recognition system, “the driver can: …
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`request travel directions and traffic updates from the Web or other sources.” Lind,
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`page I21-3. Lind also discloses that navigation information can be displayed on the
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`display. Id. at pages I21-2 (“Drivers can use a head-up display projected through
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`the windshield to navigate to their destination”), I21-3 (the head-up display (HUD)
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`“displays … navigation information”) and Figure 9. According to Fujiwara,
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`information obtained from an “information offering server 3 connected through a
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`network 4 such as the internet … according to the request of the user” is provided
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`to the user, and is received by the system via the network interface. Fujiwara, col.
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`4, lines 14 to 22. Fujiwara discloses the display of advertising content, such as
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`information relating to the hotel “H&H Tokyo” such as room rates, vacancy
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`information, and a free sauna, in Figure 22 and at 5:53-6:2.
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`35.
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`In addition to advertising content, Fujiwara also displays icons showing
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`multiple hotels. Id. at Figure 22. Also, Lind discloses that voice recognition
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`technology could be used to “locate a restaurant or hotel.” Lind, page I21-2.
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`36.
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`The system claimed in claim 1 of the ’504 patent is obvious from the
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`disclosures of Ito, Lind, and Fujiwara. It is obvious that advertising information, as
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`disclosed by Fujiwara, can be used in the systems of Ito and Lind, to “provide a
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`navigation system, by which much information is capable to be accessed so as to
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`suitably control the amount of information to be communicated and the received
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`information is capable to be displayed intelligibly.” Fujiwara, col. 1, line 55 to col.
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`2, line 2. Modifying the systems of Ito and Lind, which already transmit map and
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`navigation information to the vehicle, and display map and navigation information
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`in the vehicle, to also transmit the advertising information disclosed in Fujiwara,
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`would require no structural modifications of the system and would not provide
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`unexpected results. Providing advertising information, as disclosed by Fujiwara, in
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`the systems of Ito and Lind benefits the user by providing useful information, such
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`as room rates, vacancy information, etc., such that users can be alerted of services
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`of which they might not otherwise be aware.
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`I declare that all statements made herein of my own knowledge are true and
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`that all statements made on information and belief are believed to be true, and
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`further that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under §1001 of Title 18 of the United States Code.
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`10/30/15
`Dated: _______
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`____________________________
`___________________________________________________________________________________________________________________________________________________________________________________________________
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`Scott Andrews
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`2222
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`EXHIBIT A
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`EXHIBIT AEXHIBIT A
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`(650) 279-0242
`
`
`Scott Andrews
`
`915 Western Ave.
`Petaluma, CA 94952
`
`Summary
`Creative, energetic, and innovative internationally recognized executive experienced in
`general management, systems engineering, advanced product development, advanced
`technology, business development, strategic planning, and program management
`
` •
`
` Vehicle Electrical/Electronics Systems
`• Vehicle Information Systems
`• Communications Systems
`• ITS and Related Industries
`• Program and Project Management
`
`
`• Enterprise Software
`• Multimedia/Internet Computing
`• Vehicle Safety and Control Systems
`• Spacecraft Electronics
`• Mobile Information Technology
`
`Experience
`
`Consultant
`12/2001-Present
`Systems engineering, business development and technical strategy consulting supporting
`automotive and information technology.
`Current Engagements:
`• Technical consultant to ARINC for connected vehicle application systems
`engineering and development of high precision connected vehicle test bed for
`FHWA (Federal High Way Admin.)
`• Technical consultant to Booz Allen for connected vehicle performance measures
`development project for NHTSA (National Highway Traffic Safety Admin.)
`• Technical consultant to Booz Allen for connected vehicle standards for FHWA
`• Technical consultant to American Association of State Highway Transportation
`Officials (AASHTO) for connected vehicle deployment analysis and strategy
`• Technical consultant to Michigan State DOT (Enterprise Pooled Fund) to develop
`a system architecture and deployment strategy for Rural ITS
`• Expert witness for Toyota in a case brought by American Vehicular Sciences
`(AVS)
`• Expert witness for Toyota in a patent case brought by Affinity Labs
`• Expert Witness for TomTom in a patent case brought by AVS
`• Expert witness for Liberty Mutual, Geico and Hartford in a patent case brought by
`Progressive Insurance
`• Expert witness for Ford in a patent case brought by Medius.
`• Expert witness for Ford in a patent inventorship case brought by Berry.
`• Expert witness for Ford and GM in a patent case brought by Affinity Labs
`• Expert witness for M/A Com in a patent case against Laird
`• Expert witness for VW/Audi in a patent case brought by Velocity
`• Expert witness for VW/Audi in a case brought by Beacon, GmbH.
`• Expert witness for Wasica in a patent case against Shrader and Continental
`
`Recent Engagements:
`• Expert Witness for Samsung, Nokia, ZTE and Sony in an ITC patent case brought
`by Pragmatus
`• Expert Witness for TomTom in a case brought by AOT/Adolph
`• Expert Witness for TomTom in a case brought by Cuozzo
`• Expert Witness for Navico in a case brought by Honeywell
`Scott Andrews
`
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`Page 1
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`• Expert witness for Bentley in a case brought by Cruise Control Technologies.
`• Expert witness for Google in a case brought by Walker Digital
`• Expert witness for Emtrac in a case brought by GTT (3M)
`• Expert witness for Motorola in a case brought against Microsoft
`• Co-Principal investigator for Integrated Advanced Transportation System;
`research program funded by FHWA
`• Expert Witness for Volkswagen/Sirius-XM in patent infringement case relating to
`traffic information systems
`• Expert Witness for Pioneer in patent infringement related International Trade
`Commission matter
`• Expert Witness for Volkswagen in patent infringement case relating to the iPod
`interface
`• Chief System Architect for the Vehicle Infrastructure Inte