DECLARATION OF SCOTT ANDREWS
`
`I, Scott Andrews, declare as follows:
`
`I hold a B.Sc. degree in Electrical Engineering from University of
`
`
`
`1.
`
`California–Irvine and a M.Sc. degree in Electronic Engineering from Stanford
`
`University. In various positions at, among others, TRW and Toyota, I have been
`
`responsible for research and development projects relating to, among others,
`
`numerous vehicle navigation systems, information systems, and user interface
`
`systems. My qualifications are further set forth in my curriculum vitae (Exhibit
`
`A). I have been retained by Volkswagen Group of America, Inc. in connection
`
`with its petition for inter partes review of U.S. Patent No. 8,290,778 (the “’778
`
`patent”). I have over 35 years of experience in fields relevant to the ’778 patent,
`
`including telecommunications systems and navigation systems.
`
`2.
`
`I have reviewed the ’778 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 Proceedings (“Lind”),
`
`European Patent Application Publication No. 0 829 704 (“Fujiwara”), U.S. Patent
`
`No. 5,274,560 (“LaRue”), U.S. Patent No. 6,188,956 (“Walters”), U.S. Patent No.
`
`6,211,777 (“Greenwood”), and “Plaintiff and Counter-Defendant West View
`
`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. 8,290,778 (the “’778
`
`patent”). I have over 35 years of experience in fields relevant to the ’778 patent,
`
`including telecommunications systems and navigation systems.
`
`2.
`
`I have reviewed the ’778 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 Proceedings (“Lind”),
`
`European Patent Application Publication No. 0 829 704 (“Fujiwara”), U.S. Patent
`
`No. 5,274,560 (“LaRue”), U.S. Patent No. 6,188,956 (“Walters”), U.S. Patent No.
`
`6,211,777 (“Greenwood”), and “Plaintiff and Counter-Defendant West View
`
`1
`
`VWGoA - Ex. 1002
`Volkswagen Group of America, Inc., Petitioner
`1
`
`
`
`Research, 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.
`
`The ’778 Patent
`
`3.
`
`The ’778 patent describes an information system for use in an elevator,
`
`although the ’778 patent states that the disclosed systems and methods may also be
`
`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
`
`routine basis) such as trams, shuttles, and moving walkways. ’778 patent, col. 6,
`
`lines 23 to 24; col. 2, lines 2 to 8; col. 6, lines 11 to 18. The elevator information
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`system is responsive to verbal commands. Id. at col. 6, lines 23 to 44. 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
`
`recognition algorithm to produce digital representations of the user’s speech. Id. at
`
`col. 7, lines 9 to 13. The digital representations are compared to a speech library to
`
`identify matching known words and the desired functionality is implemented. Id. at
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`col. 7, lines 13 to 16.
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`4.
`
`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
`
`user to rapidly access updated information on a variety of predetermined topics of
`
`2
`
`2
`
`
`
`interest. For example, URLs for news headlines, weather, sports scores, financial
`
`data, directions to local airports or public transportation, etc., may be provided. Id.
`
`at col. 10, lines 55 to 67.
`
`The Disclosures of Ito and Lind – Claims 1, 22, 28, and 30
`
`5.
`
`Ito and Lind disclose a “computerized apparatus’ as claimed in claims 1, 22,
`
`28, and 30 of the ’778 patent. For example, Ito discloses an apparatus that includes
`
`a CPU as the “main component” of the processing section 101. Ito, col. 9, lines 51
`
`to 67. Lind discloses a “network computer” that is part of the “on-board network.”
`
`Lind, page I21-2.
`
`6.
`
`Ito and Lind disclose “a wireless interface” as claimed in claims 1, 28, and
`
`30 of the ’778 patent. For example, Ito discloses a navigation apparatus 100 that
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`wirelessly communicates with a base station using a “transmitting and receiving
`
`section 108” that “includes devices such as a modem and the like.” Ito, col. 8, lines
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`51 to 57. Ito discloses that this wireless connection may “utilize systems such as
`
`car phones, portable phones PHS or the like.” Id. These systems are wireless. Lind
`
`discloses a vehicle, referred to as the Network 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.
`
`3
`
`3
`
`
`
`7.
`
`Ito and Lind disclose a “data processing apparatus” as claimed in claims 1
`
`and 28 of the ’778 patent and a “means for data processing” as claimed in claim 30
`
`of the ’778 patent. For example, Ito discloses, in Figure 1, a “processing section
`
`101,” which includes a CPU. Ito, col. 9, lines 51 to 67, Figure 1:
`
`8.
`
`Lind discloses
`
`that
`
`the Network Vehicle
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`includes,
`
`for example,
`
`“microprocessors.” Lind, page I21-1. Lind also discloses, in Figure 2, a “network
`
`computer”:
`
`9.
`
`Ito and Lind disclose “a touch-screen input and display device” as claimed
`
`in claims 1 and 28 of the ’778 patent and “a touch-screen input and display means”
`
`4
`
`4
`
`
`
`as claimed in claim 30 of the ’778 patent. Ito discloses a display 106, equipped
`
`with a touch panel, that is used to display information such as travel route and/or
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`travel directions. Ito, col. 10, lines 48 to 50 and col. 15, lines 22 to 26. Lind
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`discloses three display devices for the driver, one of which is a display device on
`
`the center console that includes a touch-screen LCD. Lind, page I21-3.
`
`10.
`
`Ito and Lind disclose “a speech recognition apparatus in data communication
`
`with the data processing apparatus” as claimed in claims 1 and 28 of the ’778 and
`
`“a speech recognition apparatus in data communication with the means for data
`
`processing” as claimed in claim 30 of the ’778 patent. Ito discloses an “input
`
`section 105” that uses voice recognition. Ito, col. 10, lines 39 to 47. The input
`
`section 105 is shown connected to and in data communication with the processing
`
`section 101 in Figure 1 of Ito:
`
`11.
`
`Lind discloses that “[t]he Network Vehicle is created by integrating existing
`
`hardware
`
`and
`
`software
`
`technologies
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`including voice
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`recognition, …
`
`microprocessors, … and other Internet/intranet features.” Lind, page I21-1 to I21-
`
`5
`
`5
`
`
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`2. Lind also discloses that voice commands may be used to control the vehicle’s
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`functions, including navigation, to “locate a restaurant or hotel,” Lind, page I21-2,
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`and that, by using the advanced speech recognition system of the Network Vehicle,
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`“the driver can: … request travel directions and traffic updates from the Web or
`
`other sources,” Lind, page I21-3.
`
`12.
`
`Ito and Lind disclose “a storage apparatus in data communication with the
`
`data processing apparatus, said storage apparatus comprising at least one computer
`
`program” as claimed in claims 1 and 28 of the ’778 patent and “a storage apparatus
`
`in data communication with the means for data processing, said storage apparatus
`
`comprising at least one computer program” as claimed in claim 30 of the ’778
`
`patent. Ito discloses a “program storage section 102,” which serves as a memory
`
`for storing the programs that are executed by the processing section 101. Ito, col. 9,
`
`lines 51 to 67. The program storage section is connected to and is in data
`
`communication with the processing section 101. Lind discloses that “[t]he Network
`
`Vehicle is created by integrating existing hardware and software technologies
`
`including voice recognition, … microprocessors, … and other Internet/intranet
`
`features.” Lind, pages I21-1 to I21-2. Such integration implicitly entails data
`
`communication between the storage and data processing components of the
`
`Network Vehicle’s system.
`
`6
`
`6
`
`
`
`13.
`
`Ito and Lind disclose at least one computer program that is configured to
`
`“receive a digitized speech input via the speech recognition apparatus, the input
`
`relating to an organization or entity which a user wishes to locate” as claimed in
`
`claim 1 of the ’778 patent and “receive a digitized speech input via the speech
`
`recognition apparatus, the input relating to an organization or entity to which a user
`
`wishes to obtain directions” as claimed in claims 28 and 30 of the ’778 patent. Ito
`
`discloses that, among the inputs the user may enter into the system, are
`
`“information about the destination, such as the facility name, telephone number
`
`and address thereof, and a route search request.” Ito, col. 15, lines 47 to 58. This
`
`input of information about the destination is related to both “an organization or
`
`entity which a user wishes to locate” (as claimed in claims 1 and 28 of the ’778
`
`patent) and “an organization or entity to which a user wishes to obtain directions”
`
`(as claimed in claim 30 of the ’778 patent). Lind discloses that “[t]he key
`
`technologies and system components behind the Network Vehicle are advanced
`
`speech recognition software.” Lind, page I21-3. According to Lind, by using the
`
`Network Vehicle’s advanced speech recognition system, “the driver can: …
`
`request travel directions and traffic updates from the Web or other sources.” Id.
`
`Additionally, West View has also acknowledged (and I agree), “all speech
`
`recognition systems inherently digitize the speaker’s analog voice.” Infringement
`
`Contentions, at 729. Moreover, it is obvious in vehicular speech recognition
`
`7
`
`7
`
`
`
`systems that a driver’s analog voice is input through a microphone, amplified,
`
`digitized, and analyzed using a digital signal processor. LaRue, col. 5, lines 17 to
`
`30.
`
`14.
`
`Ito and Lind disclose at least one computer program configured to “based at
`
`least in part on the input, cause identification of a location associated with the
`
`organization or entity” as claimed in claim 1 of the ’778 patent, “receive from a
`
`remote network entity a location associated with the organization or entity, the
`
`location having been determined based at least in part on the input” as claimed in
`
`claim 28 of the ’778 patent, and “receive from a remote network entity a location
`
`associated with the organization or entity, the location having been determined
`
`based at least in part on the input” as claimed in claim 30 of the ’778 patent. For
`
`example, Ito discloses that the user inputs are used to search a remote network
`
`entity, which is a database of navigation data that is not located in the vehicle, and
`
`that the vehicle receives position information related to the destination, or an
`
`intersection close to the position of the destination. Ito, Fig. 1, col. 8, lines 28 to
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`40. This information is received by the navigation apparatus 100 via the wireless
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`interface. Ito, col. 1, line 64 to col. 11, line 30 and col. 15, lines 30 to 37. Lind
`
`discloses that “[t]he key technologies and system components behind the Network
`
`Vehicle are advanced speech recognition software.” Lind, page I21-3. According
`
`to Lind, by using the Network Vehicle’s advanced speech recognition system, “the
`
`8
`
`8
`
`
`
`driver can: … request travel directions and traffic updates from the Web or other
`
`sources.” Id. Lind also discloses that the Network Vehicle’s “voice recognition
`
`technology allows drivers and passengers to verbally … locate a restaurant or hotel
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`[and] ask for navigation help.” Id. at page I21-2.
`
`15.
`
`Ito and Lind disclose at least one computer program configured to “display
`
`said directions from the user’s current location to the organization or entity on the
`
`touch screen input and display means” as claimed in claim 30 of the ’778 patent.
`
`For example, Ito discloses that guidance data received from the wireless interface,
`
`including a “recommended route” is displayed on the display 106 in the form of a
`
`map. Ito, col. 16, lines 21 to 27, col. 17, lines 10 to 19, Figures 9(A) and 9(B).
`
`Figure 9(A) of Ito discloses the display of directions from a departure point to a
`
`destination being displayed on the display device:
`
`9
`
`9
`
`
`
`16.
`
`Lind discloses that “[d]rivers can use a head-up display projected through
`
`the windshield to navigate to their destination.” Lind, page. I21-2. Lind also
`
`discloses that the “center console’s touch-screen LCD serves as a user interface for
`
`controlling nearly all of the Network Vehicle’s multimedia functions,” including
`
`navigation functions. Id. According to Lind, the Network Vehicle “can display …
`
`appropriate maps or simply provide route directions on the … command console,”
`
`and Figure 9, reproduced below, is an example of a navigation function display,
`
`which is shown to be a touch-screen display. Lind, page I21-7.
`
`17.
`
`Ito and Lind disclose at least one computer program configured to “provide
`
`a graphical or visual representation of the location on the touch screen input and
`
`display device in order to aid a user in finding the organization or entity, the
`
`graphical or visual representation of the location also comprising a graphical or
`
`visual representation of the surroundings of the organization or entity” as claimed
`
`in claim 1 of the ’778 patent, “provide a graphical or visual representation of the
`
`location of the organization or entity on the touch screen input and display device
`
`10
`
`10
`
`
`
`in order to aid a user in finding the organization or entity, the graphical or visual
`
`representation of the location also comprising a graphical or visual representation
`
`of the surroundings of the organization or entity” as claimed in claim 28 of the
`
`’778 patent, and “provide a graphical or visual representation of the location on the
`
`touch screen input and display means in order to aid a user in finding the
`
`organization or entity, the graphical or visual representation of the location also
`
`comprising a graphical or visual representation of the surroundings of the
`
`organization or entity” as claimed in claim 30 of the ’778 patent. Ito discloses that
`
`the map to an organization or entity (the destination) includes a graphical
`
`representation of the entity and its surroundings. The above map shown in Figure
`
`9(A) of Ito includes a graphical representation of the entity (the destination) as well
`
`as a graphical representation of the roads and intersections that surround it. These
`
`maps are part of the navigation data that is transmitted from the base apparatus to
`
`the vehicle navigation apparatus. Ito, col. 8, lines 41 to 50. Ito discloses that “area
`
`guidance data is … extracted for … the surrounding area A3 around the destination
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`PA,” Ito, col. 14, lines 19 to 23, and that “map data of the surrounding area A3 is
`
`read out of the data storage 103 and a map thereof is displayed on the display 106,”
`
`Ito, col. 18, lines 37 to 43. In Figures 40(C) and 44, reproduced below, Ito shows
`
`the displayed images in the vehicle navigation apparatus as including landmarks,
`
`such as a bank, fire station, and department store among the surroundings:
`
`11
`
`11
`
`
`
`18.
`
`Lind discloses that “[d]rivers can use a head-up display projected through
`
`the windshield to navigate to their destination.” Lind, page I21-2. Lind also
`
`discloses that the “center console’s touch-screen LCD serves as a user interface for
`
`controlling nearly all of the Network Vehicle’s multimedia functions,” including
`
`navigation functions. Id. According to Lind, the Network Vehicle “can display …
`
`appropriate maps or simply provide route directions on the … command console,”
`
`and Figure 9, reproduced above, is an example of a navigation function display,
`
`which is shown to be a touch-screen display. Lind, page I21-7.
`
`19.
`
`Ito and Lind disclose at least one computer program that is “configured to
`
`generate on the touch-screen input and display device a plurality of soft function
`
`keys or icons, at least one of the soft function keys or icons having a function
`
`associated therewith relating to obtaining directions, and at least one of the soft
`
`function keys or icons having a function associated therewith relating to points of
`
`interest” as claimed in claim 22 of the ’778 patent. For example, Ito discloses that
`
`the user can “touch an icon of a desired guidance area on the display 106 to select
`12
`
`12
`
`
`
`the guidance area.” Ito, col. 30, lines 61 to 63. Additionally, Ito discloses various
`
`icons labeled with the prefix K that assist the user with selecting various guidance
`
`options. Ito, col. 30, line 63 to col. 32, line 60, Figures 23 to 25. Lind describes that
`
`the Network Vehicle’s center console touch-screen LCD display can be
`
`“reconfigured to display e-mail, navigation maps, Web browser, cellular phone
`
`faceplate …, and more” and that it can display buttons and controls (i.e., soft
`
`function keys or icons) that are activated by touch. Lind, page I21-3. In Figure 9,
`
`reproduced below, which is an example of a navigation function display, Lind
`
`shows soft function keys or icons relating to “Entertainment,” “Navigation,”
`
`“Office,” “AutoWeb,” and “Information,” at the top of the display:
`
`20.
`
`Ito discloses that the icons K1 to K5 have functions related to obtaining
`
`directions, specifically to select the “desired guidance areas.” Ito, col. 29, line 66 to
`
`col. 30, line 3. Lind discloses that the one of the functions of one of the soft
`
`function keys or icons is “Navigation,” which has a function related to “navigation
`
`maps.” Lind, pages I21-3, I21-7. Additionally, Lind discloses a soft function key or
`
`13
`
`13
`
`
`
`icon to “start” route guidance in Figure 9. Beginning guidance to a point of interest
`
`is a function relating to points of interest. Therefore, Lind discloses “a least one of
`
`the soft function keys or icons having a function associated therewith relating to
`
`points of interest” as claimed in claim 22 of the ’778 patent.
`
`The Level of Skill in the Art
`
`21.
`
`Several years before the earliest filing date claimed as priority by the ’778
`
`patent, as well as contemporaneously with filing of the application for the ’778
`
`patent, other automotive industry companies had already developed, and were
`
`developing, vehicles with Internet connectivity (allowing users to, for example,
`
`retrieve information wirelessly from remote databases while inside their vehicles),
`
`speech-recognition functionality, and navigation functionality.
`
`22. As described by Lind, the Network Vehicle was designed and developed by
`
`Delphi Delco Electronics Systems, IBM, Netscape Communication, and Sun
`
`Microsystems. The Network Vehicle developers loaded several computing and
`
`communications devices into a vehicle, to demonstrate that the technology could
`
`successfully be used in a variety of ways. The Network Vehicle included a roof-
`
`mounted antenna to provide a satellite connection to the Internet. Lind, page I21-2.
`
`The system associated with the Network Vehicle included an off-board network
`
`architecture, including, for example, a home/office computer and an IBM web
`
`server. Lind, page I21-2. As described by Lind, the Network Vehicle developers
`
`14
`
`14
`
`
`
`provided a Website for users of the Network Vehicle to remotely access the
`
`computing systems located in the vehicle. The vehicle Website allowed users to
`
`“plan trips on the vehicle web site, then download them to your vehicle.” Lind,
`
`page I21-7.
`
`23.
`
`Lind also describes systems in which a user can receive various types of
`
`information inside the vehicle, including e-mail. The Network Vehicle was
`
`demonstrated at the Computer Dealer’s Exhibits (COMDEX ’97) conference in
`
`Las Vegas, Nevada on November 17-19, 1997. At this demonstration, the use of
`
`the Network Vehicle Website described by Lind, as noted above, was
`
`demonstrated to attendees of the conference.
`
`24.
`
`I have reviewed screenshots of the Network Vehicle Website; those
`
`screenshots are attached as Exhibit B. I acquired these screenshots pursuant to my
`
`work as an expert witness engaged by Volkswagen Group of America, Inc. in
`
`connection with the litigation Affinity Labs of Texas, LLC v. BMW North America,
`
`LLC, et al., Case No. 9:08-cv-00164 (E.D. Tex.).
`
`25.
`
`In 1997, I personally attended a demonstration of the Network Vehicle,
`
`conducted by Delphi and a Delphi supplier, at Toyota’s headquarters in Toyota
`
`City, Japan. At that event, the features of the Network Vehicle were demonstrated
`
`and the system operation was explained.
`
`15
`
`15
`
`
`
`26. Referring to Exhibit B, as illustrated on, e.g., the “Driver profile” page, the
`
`Network Vehicle maintained a set of profiles for each driver, including personal
`
`data, entertainment preferences, information preferences, vehicle preferences, and
`
`a personal address book.
`
`27. Referring to Exhibit C (VW is working on a multimedia car, Reuters AG,
`
`April 22, 1996), Volkswagen had also designed a “multimedia car” and presented
`
`an “Infotainment Car” at a conference in Hannover, Germany in 1996; the
`
`Infotainment Car included, for example, a PC with Internet connectivity.
`
`28.
`
`In 1997, for example, in the Connected CarPC described in Exhibit D (In-
`
`Car Computing and Communication Enables Entertainment, Productivity and
`
`Information, Dedicated Conference on ATT/ITS Advances for Enhancing
`
`Passenger, Freight & Intermodal Transportation Systems, p. 411-417 (1997)),
`
`communication links were already available for use in automobiles to provide
`
`traffic information, Internet access to find hotels, restaurants, and travel guides,
`
`and to schedule maintenance, perform remote diagnostics and receive software
`
`updates. The “Connected CarPC environment” at that time included both speech
`
`recognition functionality and Internet access.
`
`29.
`
`The Daimler-Benz Internet Multimedia on Wheels Concept Car, also
`
`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
`
`16
`
`16
`
`
`
`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
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`speech technology.”
`
`30. 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.”
`
`31. Visteon’s ICES system, described in Exhibit H, 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
`
`17
`
`17
`
`
`
`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
`
`32.
`
`The systems described in claims 1, 22, 28, and 30 of the ’778 patent were
`
`obvious from the disclosures of Ito and Lind.
`
`33. 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 ’778 patent purports to address problems related to
`
`“providing directions and other information to a user” (’778 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 42). 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 ’778 patent. And providing graphical or visual
`
`representations on a touch screen of a location and surroundings thereof is no more
`
`18
`
`18
`
`
`
`than 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 ’778 patent.
`
`The Disclosures of Ito, Lind, and Fujiwara – Claims 3, 5, and 27
`
`34.
`
`Fujiwara discloses that at least one computer program is “configured to
`
`cause display of advertising that is contextually related to the organization or
`
`entity” as claimed in claim 3 of the ’778 patent. For example, Fujiwara discloses
`
`the display of advertising content, such as information about the hotel “H&H
`
`Tokyo” such as room rates, vacancy information, and a free sauna, in Figure 22
`
`and at 5:53-6:2.
`
`35.
`
`This advertising information is contextually related to the hotels that are
`
`displayed on the map.
`
`36.
`
`Fujiwara discloses
`
`that “the advertising
`
`is displayed substantially
`
`contemporaneous with a display of the graphical or visual representation of that
`
`19
`
`19
`
`
`
`location” as claimed in claim 5 of the ’778 patent. As illustrated in Figure 22,
`
`advertising, navigation, and destination information is displayed at the same time
`
`on the same display.
`
`37.
`
`Ito and Fujiwara “the graphical or visual representation of the location
`
`comprising a map graphic showing the location of the organization or entity
`
`relative to other organizations or entities proximate thereto” as claimed in claim 27
`
`of the ’778 patent. For example, Ito discloses in Figures 40(C) and 44 that the
`
`image displayed in the vehicle navigation apparatus includes a bank, a fire station,
`
`and a department store displayed relative to each other. Fujiwara discloses in
`
`Figure 22 that the display of a map graphic includes the location of a hotel relative
`
`to other hotels in the area.
`
`38.
`
`Ito and Lind disclose that “the digitized speech is received via a microphone
`
`associated with the speech recognition apparatus, the microphone being mounted
`
`within the computerized apparatus proximate the touch-screen input and display
`
`device so that the user can speak into the microphone while viewing the touch-
`
`screen input and display device” as claimed in claim 27 of the ’778 patent. Ito and
`
`Lind disclose “a microphone” as claimed in claim 22 of the ’037 patent. Ito and
`
`Lind disclose voice recognition systems, and Lind discloses a “microphone” as
`
`claimed in claim 22 of the ’037 patent. For example, Ito describes an input device
`
`that “us[es] voice recognition,” Ito, col. 10, lines 39 to 47, and Lind discloses a
`
`20
`
`20
`
`
`
`speech recognition system that “allows the driver to access virtually all the
`
`vehicle’s features through voice commands,” Lind, page I21-3. Lind discloses that
`
`a “command and control application, … running on the vehicle’s main processor,
`
`… controls devices such as … microphone, … and controls vehicle software, such
`
`as the voice recognition … applications.” Lind, page I21-6. As demonstrated, for
`
`example, by LaRue, at col. 5, line 17, voice recognition systems rely on
`
`microphones for obtaining voice or speech input. It is obvious from these
`
`disclosures that a microphone can be used to input a user’s voice into an
`
`automotive voice recognition system, such as the navigation system disclosed in
`
`Ito and the ViaVoice speech recognition system disclosed in Lind. LaRue, col. 5,
`
`line 17. Neither claim 27 nor the specification of the ’778 patent describes
`
`“proximate” in terms of how close the microphone and the touch-screen input and
`
`display device are to each other. Since the microphone and touch-screen input and
`
`display device described, for example, by Lind are provided within the Network
`
`Vehicle, the microphone is located “proximate” the touch-screen input and display
`
`device.
`
`39.
`
`Fujiwara discloses at least one computer program is “configured to cause
`
`display of advertising content selected by one or more remote servers accessed via
`
`a network in data communication with the computerized apparatus via the wireless
`
`interface, the advertising being selected based at least in part on an attribute or
`
`21
`
`21
`
`
`
`aspect of the organization or entity” as claimed in claim 27 of the ’778 patent.
`
`Fujiwara discloses that an information offering equipment 2 obtains “various
`
`information from an information offering server 3 connected through a network 4
`
`such as the internet, and to provide it to a user.” Fujiwara, col. 4, lines 14 to 22.
`
`Fujiwara discloses that hotels are displayed in Figure 22, and that the displayed
`
`advertising information includes room rates and vacancy information. Both of
`
`these types of information relate to the “attribute” that the destinations are hotels.
`
`40.
`
`Ito and Lind disclose that “the identification of the location comprises
`
`accessing a remote server via a network in data communication with the
`
`computerized apparatus via the wireless interface” as claimed in claim 27 of the
`
`’778 patent. Ito discloses that the user inputs are used to search a remote network
`
`entity, which is a database of navigation data that is not located in the vehicle, and
`
`that the vehicle receives position information related to the destination, or an
`
`intersection close to the position of the destination. Ito, Fig. 1, col. 8, lines 28 to
`
`40. This information is received by the navigation apparatus 100 via the wireless
`
`interface. Ito, col. 1, line 64 to col. 11, line 30 and col. 15, lines 30 to 37. Lind
`
`discloses that “[t]he key technologies and system components behind the Network
`
`Vehicle are advanced speech recognition software.” Lind, page I21-3. According
`
`to Lind, by using the Network Vehicle’s advanced speech recognition system, “the
`
`driver can: … request travel directions and traffic updates from the Web or other
`
`22
`
`22
`
`
`
`sources.” Id. Lind also discloses that the Network Vehicle’s “voice recognition
`
`technology allows drivers and passengers to verbally … locate a restaurant or hotel
`
`[and] ask for navigation help.” Id. at page I21-2.
`
`41.
`
`Ito discloses that at least one computer program is “configured to receive
`
`and utilize inputs in an iterative or hierarchical fashion to progress through a menu
`
`structure comprising multiple possible matching organizations or entities” as
`
`claimed in claim 27 of the ’778 patent. For example, Ito discloses that the user can
`
`input only the first several digits of a telephone area code as the information about
`
`a destination, and that the system transmits the searched facilities data to the
`
`vehicle. Ito, col. 15, line 59 to col. 16, line 19. After receiving multiple potential
`
`search hits, “[t]he searched facilities are displayed at the vehicle, and the user
`
`views such facilities to decide whether or not the destination is included in the
`
`searched facilities.” Id. The user then makes a second input in order to select the
`
`appropriate desired destination from the list of searched facilities. Id. This is an
`
`iterative process that progresses through a menu structure.
`
`42.
`
`Ito and Lind disclose that the computerized apparatus is “configured to
`
`provide a user a graphical representation of directions from their current location to
`
`a business or organization, the graphical representation of directions comprising
`
`the map graphic displayed on the touch-screen input and display device having at
`
`least one arrow showing the path for the user to follow” as claimed in claim 27 of
`
`23
`
`23
`
`
`
`the ’778 patent. For example, Ito discloses that guidance data received from the
`
`wireless interface, including a “recommended route” is displayed on the display
`
`106
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