UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`VOLKSWAGEN GROUP OF AMERICA, INC.
`
`Petitioner
`
`
`Patent No. 8,290,778
`Issue Date: October 16, 2012
`Title: COMPUTERIZED INFORMATION PRESENTATION APPARATUS
`__________________________________________________________________
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 8,290,778
`PURSUANT TO 35 U.S.C. § 312 and 37 C.F.R. § 42.104
`
`Case No. IPR2016-00125
`__________________________________________________________________
`
`
`
`
`
`
`
`

`
`I. 
`II. 
`III. 
`
`TABLE OF CONTENTS
`Mandatory Notices (37 C.F.R. § 42.8) ........................................................... 1 
`Grounds for Standing (37 C.F.R. § 42.104(a)) ............................................... 2 
`Identification of Challenge (37 C.F.R. § 42.104(b)(1)-(3)) and Relief
`Requested (37 C.F.R. § 42.22(a)(1)) .............................................................. 2 
`A. 
`Background of the ’778 Patent ............................................................. 2 
`B. 
`Patents and Printed Publications Relied On ......................................... 4 
`C. 
`Statutory Grounds for Challenge (37 C.F.R. § 42.104(b)(1)-(2)) ........ 6 
`D. 
`Claim Construction (37 C.F.R. § 42.104(b)(3)) ................................... 6 
`E. 
`Explanation of Differences Between Challenged Independent
`Claims ................................................................................................... 7 
`IV.  How Challenged Claims Are Unpatentable (37 C.F.R. § 42.104(b)(4)-
`(5)) .................................................................................................................. 9 
`A. 
`Claims 1, 22, 28, and 30 are Obvious in View of the
`Disclosures of Ito and Lind .................................................................. 9 
`1. 
`Claims 1, 28, and 30 ................................................................ 11 
`2. 
`Claim 22 ................................................................................... 20 
`3. 
`Obviousness in View of Ito and Lind ...................................... 23 
`4. 
`The Level of Skill in the Industry ............................................ 25 
`5. 
`Claim Charts ............................................................................ 25 
`Claims 3, 5, and 27 are Obvious in View of the Disclosures of
`Ito, Lind, and Fujiwara ....................................................................... 37 
`1. 
`Claims 3 and 5 .......................................................................... 38 
`2. 
`Claim 27 ................................................................................... 39 
`3. 
`Obviousness in View of Ito, Lind, and Fujiwara ..................... 47 
`4. 
`Claim Charts ............................................................................ 49 
`Claims 8 and 9 are Obvious in View of the Disclosures of Ito,
`Lind, and Walters ............................................................................... 55 
`1. 
`Claims 8 and 9 .......................................................................... 56 
`-i-
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`B. 
`
`C. 
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`

`
`2. 
`Obviousness in View of Ito, Lind, and Walters ....................... 57 
`Obviousness in View of Ito, Lind, and Walters ..................... ..57
`2.
`Claim Charts ............................................................................ 58 
`3. 
`Conclusion .................................................................................................... 60 
`
`3.
`
`Claim Charts .......................................................................... ..58
`
`Conclusion .................................................................................................. ..6O
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`
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`-ii-
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`V. 
`
`V.
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`

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`
`
`Exhibit 1001
`
`Exhibit 1002
`
`Exhibit 1003
`
`Exhibit 1004
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`
`Exhibit 1005
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`
`Exhibit 1006
`
`Exhibit 1007
`
`Exhibit 1008
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`Exhibit 1009
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`Exhibit 1010
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`
`Exhibit 1011
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`Exhibit 1012
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`
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`
`
`
`
`LISTING OF EXHIBITS
`
`U.S. Patent No. 8,290,778 to Gazdzinski
`
`Declaration of Scott Andrews
`
`U.S. Patent No. 6,249,740 to Ito et al.
`
`The Network Vehicle - A Glimpse into the Future of
`Mobile Multi-Media, by R. Lind et al.
`
`European Patent Application Publication No. 0 829 704
`to Fujiwara et al.
`
`U.S. Patent No. 6,188,956 to Walters
`
`Redline Comparison of Challenged Independent Claims
`
`U.S. Patent No. 5,274,560 to LaRue
`
`U.S. Patent No. 6,211,777 to Greenwood et al.
`
`“Plaintiff and Counter-Defendant West View Research,
`LLC Revised Disclosure of Asserted Claims and
`Infringement Contentions, Pursuant to Patent L.R. 3.1
`and the June 10, 2015 Court Order,” dated June 26, 2015
`
`U.S. Copyright Registration No. TX 4-900-822, “1998
`IEEE/AIAA 17th Digital Avionics Systems Conference -
`Oct 31, 1998 - Bellevue, WA - (98CH36267), dated
`December 8, 1998
`
`Library of Congress Public Catalog Information, 17th
`DASC: The AIAA/IEEE/SAE Digital Avionics Systems
`Conference: Proceedings:
`[Electronics
`in motion]:
`Bellevue, WA, Oct. 31-Nov. 7, 1998
`
`-iii-
`
`
`
`

`
`
`
`Exhibit 1013
`
`
`Exhibit 1014
`
`
`Exhibit 1015
`
`
`Exhibit 1016
`
`
`Exhibit 1017
`
`
`
`
`
`
`
`MARC Tags corresponding to Library of Congress
`Public Catalog
`Information, 17th DASC: The
`AIAA/IEEE/SAE Digital Avionics Systems Conference:
`Proceedings: [Electronics in motion]: Bellevue, WA, Oct.
`31-Nov. 7, 1998
`
`The Network Vehicle - A Glimpse into the Future of
`Mobile Multi-Media, by R. Lind et al., SAE Technical
`Paper Series 982901
`
`U.S. Copyright Registration No. TX 5-149-812,
`“November 1998 Quarterly Technical Papers on
`Microfiche (MICQ-N98),” dated June 2, 2000
`
`U.S. Copyright Office Public Catalog Information,
`“Quarterly technical papers on microfiche,” ISSN 0148-
`7191
`
`Society of Automotive Engineers (SAE), Abstract, “The
`Network Vehicle - A Glimpse into the Future of Mobile
`Multimedia,” Paper No. 982901, http://papers.sae.org/
`982901/
`
`-iv-
`
`
`
`

`
`
`
`I. Mandatory Notices (37 C.F.R. § 42.8)
`Real Party-in-Interest: Volkswagen Group of America, Inc. (“VWGoA”), which is
`
`a subsidiary of Volkswagen AG.
`
`Related Matters: The following judicial matter may affect, or may be affected by, a
`
`decision in this inter partes review: West View Research, LLC v. Audi AG, et al.,
`
`No. 3:14-cv-02668-BAS-JLB (S.D. Cal.), naming as defendants: VWGoA d/b/a
`
`Audi of America, Inc.; Volkswagen AG (which, as indicated as above, is the parent
`
`of VWGoA); and Audi AG (which is a subsidiary of Volkswagen AG). In this
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`litigation, West View has accused, for example, an “Audi ‘Smart Display’
`
`Android-Based Tablet” as infringing the claims of U.S. Patent No. 8,290,778 (“the
`
`’778 patent”), which is being challenged by this petition. See, Ex. 1010.
`
` The following judicial matters in the Southern District of California may affect,
`
`or may be affected by, a decision in this inter partes review: West View Research,
`
`LLC v. Bayerische Motoren Werke AG, et al. (3:14-cv-02670); West View
`
`Research, LLC v. Hyundai Motor Company, Ltd., et al. (3:14-cv-02675); West
`
`View Research, LLC v. Nissan Motor Company, Ltd., et al. (3:14-cv-02677); and
`
`West View Research, LLC v. Tesla Motors, Inc. (3:14-cv-02679).
`
` The following administrative matters may affect, or may be affected by, a
`
`decision in this inter partes review: IPR2015-01941; IPR2016-00123; IPR2016-
`
`00124; IPR2016-00137; IPR2016-00146; IPR2016-00156; IPR2016-001177; U.S.
`
`1
`
`

`
`
`
`Patent Nos. 8,301,456; 8,117,037; 7,711,565; 7,093,693; 6,988,071; 6,615,175.
`
`Lead Counsel: Michael J. Lennon (Reg. No. 26,562).
`
`Backup Counsel: Clifford A. Ulrich (Reg. No. 42,194) and Michelle Carniaux
`
`(Reg. No. 36,098).
`
`Service: VWGoA agrees to electronic service at the following e-mail addresses:
`
`mlennon@kenyon.com, culrich@kenyon.com, and mcarniaux@kenyon.com.
`
`Service may be made at the following address: Kenyon & Kenyon LLP, One
`
`Broadway, New York, NY 10004 (Tel.: 212-425-7200; Fax: 212-425-5288).
`
`II. Grounds for Standing (37 C.F.R. § 42.104(a))
` VWGoA certifies that the ’778 patent is available for inter partes review and
`
`that it is not barred or estopped from requesting an inter partes review challenging
`
`the patent claims on the grounds identified in this petition.
`
`III. Identification of Challenge (37 C.F.R. § 42.104(b)(1)-(3)) and Relief
`Requested (37 C.F.R. § 42.22(a)(1))
` VWGoA challenges claims 1, 3, 5, 8, 9, 22, 27, 28, and 30 of the ’778 patent
`
`under 35 U.S.C. § 103, and cancelation of these claims is requested.
`
`A. Background of the ’778 Patent
` The ’778 patent issued on October 16, 2012, from U.S. Patent Application
`
`Serial No. 13/404,853 (“the ’853 application”), filed February 24, 2012. The ’778
`
`patent claims to be a continuation or division of a number of prior applications, the
`
`2
`
`

`
`
`
`earliest of which was filed on June 10, 1999.1 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 transport large numbers of people
`
`and equipment between two locations on a routine basis) such as trams, shuttles,
`
`and moving walkways. Ex. 1001, 6:23-24; 2:2-8; 6:11-18. The elevator
`
`information system is responsive to verbal commands. Ex. 1001, 6:23-44. Signals
`
`captured by a microphone 118 as part of a speech recognition module 104 are
`
`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.,
`
`7:9-13. The digital representations are compared to a speech library to identify
`
`matching known words and the desired functionality is implemented. Id., 7:13-16.
`
` One function of the display device includes accessing a network via a 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 interest.
`
`For example, URLs for news headlines, weather, sports scores, financial data,
`
`directions to local airports or public transportation, etc., may be provided. Id.,
`
`
`1 VWGoA does not concede that any claim of the ’778 patent is entitled to a filing
`
`date earlier than the February 24, 2012 filing date of the ’853 application.
`
`3
`
`

`
`
`
`10:55-67.
`
` Of the challenged claims, claims 1, 27, 28, and 30 are independent; challenged
`
`claims 3, 5, 8, 9, and 22 ultimately depend from claim 1.
`
`B. Patents and Printed Publications Relied On
`1. U.S. Patent No. 6,249,740 (“Ito,” Ex. 1003), filed January 21, 1999 and issued
`
`June 19, 2001, constitutes prior art against the ’778 patent under at least 35 U.S.C.
`
`§ 102(e).
`
`2. The Network Vehicle - A Glimpse into the Future of Mobile Multi-Media, by R.
`
`Lind, et al. (“Lind,” Ex. 1004), published by the Institute of Electrical and
`
`Electronics Engineers (IEEE) and presented at the 1998 IEEE/AIAA 17th Digital
`
`Avionics Systems Conference on October 31, 1998, bearing a copyright notice
`
`dated 1998 (see Ex. 1004, p. ii, “Copyright © 1998 by the Institute of Electrical
`
`and Electronics Engineers, Inc.”), bearing a Library of Congress and Copyright
`
`Office date stamp of December 8, 1998 (see Ex. 1004, page after p. xv), registered
`
`with and deposited in the U.S. Copyright Office on December 8, 1998 (see Ex.
`
`1011, also stating October 31, 1998 as the date of first publication in the U.S.),
`
`constitutes prior art against the ’778 patent under at least 35 U.S.C. § 102(a).2
`
`
`2 Page ii of Ex. 1004 states a Library of Congress Control Number (LCCN) of 98-
`
`86916. The U.S. Library of Congress’s online catalog record, Ex. 1012, for this
`
`
`
`4
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`

`
`
`
`3. European Patent Application No. 0 829 704 (“Fujiwara,” Ex. 1005), published
`
`March 18, 1998, constitutes prior art to the ’778 patent under 35 U.S.C. § 102(b).
`
`4. U.S. Patent No. 6,188,956 (“Walters,” Ex. 1006), filed December 30, 1998 and
`
`issued February 13, 2001, constitutes prior art against the ’778 patent under at least
`
`35 U.S.C. § 102(e).
`
`
`
`Ito, Lind, Fujiwara, and Walters were not cited by Mr. Gazdzinski or the
`
`
`LCCN demonstrates that Lind was indexed under LC Classification and Call No.
`
`“TL693 .D55 1998” and under Dewey Class No. 629.135. According to Ex. 1013,
`
`the Library of Congress record for Lind was last updated on April 16, 1999 at
`
`3:16:32.8 p.m. (MARC Tag 005 specifies the date and time of the latest record
`
`transaction in the format yyyymmddhhmmss.f (see http://www.loc.gov/marc/
`
`authority/ad005.html); the MARC Tag 005 field for Lind is 19990416151632.8,
`
`which translates to April 16, 1999 at 3:16:32.8 p.m.). Lind was also published
`
`(with minor differences) in 1998 by the Society of Automotive Engineers as SAE
`
`Technical Paper Series 982901, Ex. 1014. Ex. 1015 is the U.S. Copyright
`
`Registration for Ex. 1014, stating a November 1998 date of first publication in the
`
`U.S., Ex. 1016 is the U.S. Copyright Office’s public catalog record for Ex. 1014,
`
`stating November 1998 date of publication of Ex. 1015, and Ex. 1017 is the SAE’s
`
`abstract for Ex. 1014, stating a November 1998 date of publication of Ex. 1014.
`
`5
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`

`
`
`
`Examiner during prosecution of the ’778 patent.
`
`C. Statutory Grounds for Challenge (37 C.F.R. § 42.104(b)(1)-(2))
`1. Claims 1, 22, 28, and 30 are obvious under 35 U.S.C. § 103(a) in view of Ito
`
`and Lind.
`
`2. Claims 3, 5, and 27 are obvious under 35 U.S.C. § 103(a) in view of Ito, Lind,
`
`and Fujiwara.
`
`3. Claims 8 and 9 are obvious under 35 U.S.C. § 103(a) in view of Ito, Lind, and
`
`Walters.
`
`D. Claim Construction (37 C.F.R. § 42.104(b)(3))
` Generally, the claim terms in an unexpired patent should be given their broadest
`
`reasonable construction in view of the specification. 37 C.F.R. § 42.100(b). Claim
`
`terms are generally presumed to take on their ordinary and customary meaning.
`
` Claim 30 recites two elements that include the word “means”: (1) “means for
`
`data processing,” and (2) “touch screen input and display means.” When a claim
`
`term uses the word “means,” a rebuttable presumption that § 112(6) applies is
`
`created. Personalized Media Communications, LLC v. Int’l Trade Commission,
`
`161 F.3d 696, 703-04 (Fed. Cir. 1998).
`
` The term “means for data processing” is subject to 35 U.S.C. § 112(6) since it is
`
`expressed as a “means” for performing a function—“data processing” —without
`
`reciting structure in support thereof. The ’778 patent describes that “the processor
`
`106, video RAM 107, storage device 108, 110, and other components (including
`
`6
`
`

`
`
`
`necessary power supplies, not shown) are disposed within equipment storage
`
`housings (not shown)” as an “arrangement … used primarily to allow rapid access
`
`to and processing of data by the system 100.” Ex. 1001, 8:11-18. Therefore, the
`
`“means for data processing” recited in claim 30 should be construed to mean “a
`
`processor” and equivalents thereof. 3
`
` The term “touch screen input and display means” is not subject to 35 U.S.C. §
`
`112(6), as claim 30 does not recite a function corresponding to the “means.” Cole
`
`v. Kimberly-Clark Corp., 102 F.3d 524, 531 (Fed. Cir. 1996) (holding that the
`
`perfunctory addition of the word “means” did not render a claim subject to 35
`
`U.S.C. § 112(6), as the claim recited the necessary structure.).
`
` All other claim terms should be given their broadest reasonable construction in
`
`light of the specification.
`
`E. Explanation of Differences Between Challenged Independent Claims
` Three of the four challenged independent claims of the ’778 patent (claims 1,
`
`28, and 30) are similar to one another, and can be analyzed together. Each claims
`
`
`3 The video RAM 107, storage devices 108, 110, power supplies, and equipment
`
`housings, which are not necessary for performing the claimed function of “data
`
`processing,” do not constitute “corresponding structure.” Northrop Grumman
`
`Corp. v. Intel Corp., 325 F.3d 1346 (Fed. Cir. 2003).
`
`7
`
`

`
`
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`slightly different apparatuses that require the delivery of information from a remote
`
`database to a transport apparatus (such as an automobile), which contains a display
`
`for displaying that information. For ease of reference, a table showing the
`
`differences between the four challenged independent claims is attached hereto as
`
`Exhibit 1007.
`
` As an example of the minor differences, claim 1 requires that the system “cause
`
`identification of a location” based upon a voice input, while claims 28 and 30
`
`require the receipt of a location from a remote network entity, based on the voice
`
`input. Claims 28 and 30 also add the requirement to claim 1 that directions from
`
`the current location to the identified location are displayed on a display device.
`
`Claim 30 replaces occurrences of the term “apparatus” or “device” in claim 28
`
`with the term “means.”
`
` The remaining challenged independent claim, claim 27, contains similar
`
`features to the other independent claims (see Ex. 1007), but adds additional claim
`
`elements. Briefly, the additional requirements include: (1) a microphone that
`
`receives speech input; (2) the at least one program is configured to cause display of
`
`advertising content; (3) the identification of a location taking place via a remote
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`server via the wireless interface; (4) the use of an iterative or hierarchical input
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`system; (5) the display of an arrow on a map graphic to show the path for the user
`
`to follow; and (6) an interface compliant with an IEEE 802.11 standard.
`
`8
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`

`
`
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`IV. How Challenged Claims Are Unpatentable (37 C.F.R. § 42.104(b)(4)-(5))
`A. Claims 1, 22, 28, and 30 are Obvious in View of the Disclosures of Ito
`and Lind
` As described in detail below, claims 1, 22, 28, and 30 are obvious in view of the
`
`disclosures of Ito and Lind, and are thus invalid under 35 U.S.C. § 103(a).
`
`
`
`Ito discloses an automobile navigation system that includes a vehicle navigation
`
`apparatus, 100, that is mounted in a vehicle as a movable body. Ex. 1003, 8:11-16.
`
`In addition, Ito discloses a “base apparatus” 150, that wirelessly connects to the
`
`navigation apparatus, as shown in Figure 1. Id., 10:51-57.
`
`
`
` The system contains a data input device that “us[es] voice recognition” and
`
`allows the user to “use his/her voice to input corresponding data and commands.”
`
`Ex. 1003, 10:39-47. Speech commands are used for control of the navigation
`
`system. Id., 10:39-47. Also disclosed is a display device, which may be an LCD or
`
`a CRT display unit, equipped with a touch panel. Id., 10:48-50.
`
` Lind discloses an automobile that contains hardware and software that allows
`
`connections via an “off-board network” that wirelessly connects to the Internet, as
`
`well as allows wireless information retrieval from other sources like DirecTV. Ex.
`
`9
`
`

`
`
`
`1004, p. I21-2. This off-board network is shown in Figure 3:
`
`
`
`
`
` Lind states that the system includes a speech recognition system that “allows
`
`the driver to access virtually all the vehicle’s features through voice commands.”
`
`Id., I21-3. The voice commands may be used for a request for travel directions and
`
`traffic updates from the web, and requests for news, sports, and stock information.
`
`Id. This information from the web, as shown in Figure 3, is received wirelessly.
`
`Id., I21-2.
`
` Lind also discloses three display devices, including a heads-up display
`
`projected on the windshield in front of the driver, as well as two other displays
`
`inside the vehicle. Ex. 1004, p. I21-3. On the heads-up display, the Network
`
`Vehicle can display, e.g., navigation information. Id. The command console may
`
`also display navigation information, as shown in Figure 9 (see also Ex. 1004, p.
`
`I21-3 and I21-7):
`
`10
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`

`
`
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`
`
`
`
` As described below, Ito and Lind disclose all of the limitations of claims 1, 22,
`
`28, and 30 of the ’778 patent.
`
`1. Claims 1, 28, and 30
`i. Claims 1, 28, and 30: “Computerized apparatus comprising:”
`Ito discloses a “computerized apparatus.” Ito discloses that a CPU is the “main
`
`
`
`component” of the processing section 101. Ex. 1003, 9:51-67; Ex. 1002, ¶ 5.
`
` As shown in Figure 2, Lind discloses that a “network computer” as part of the
`
`on-board network. Ex. 1004, p. I21-2; Ex. 1002, ¶ 5.
`
`
`
`ii. Claims 1, 28, and 30: “a wireless interface,”
`Ito discloses that the “transmitting and receiving section 108” in the vehicle
`
`
`
`navigation apparatus 100 communicates with the base station and “includes
`
`11
`
`

`
`
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`devices such as a modem and the like.” Ex. 1003, 8:51-57; Ex. 1002, ¶ 6.
`
`Additionally, Ito discloses that the connection may “utilize systems such as car
`
`phones, portable phones PHS or the like.” Ex. 1003, 8:51-57; Ex. 1002, ¶ 6. These
`
`systems are wireless, and the transmitting and receiving section 108 interfaces with
`
`the wireless network, and is thus a “wireless interface.” Ex. 1002, ¶ 6.
`
` Lind discloses that “smart features” of the Network Vehicle “are enabled
`
`mainly because of the real-time data-streaming capabilities over a wireless
`
`network.” Ex. 1004, p. I21-2; Ex. 1002, ¶ 6. The links to the wireless network
`
`include satellite links as well as a “wireless modem.” Ex. 1004, p I21-2; Ex. 1002,
`
`¶ 6. The system disclosed in Lind details a “roof-mounted antenna” that picks up
`
`video and data signals. Ex. 1004, p. I21-2; Ex. 1002, ¶ 6.
`
`iii. Claims 1, 28, and 30: “[means for] data processing [apparatus],”
`Ito discloses that a CPU (i.e., a data processing apparatus) is the “main
`
`
`
`component” of the processing section 101. Ex. 1003, 9:51-67, Fig. 1; Ex. 1002, ¶
`
`7.
`
` As shown in Figure 2, Lind discloses that a “network computer” (i.e., a data
`
`processing apparatus) as part of the on-board network. Ex. 1004, p. I21-2; Ex.
`
`1002,¶ 7.
`
` As discussed in Section (III)(D), above, at page 6, the “means for data
`
`processing” should be construed under 35 U.S.C. §112(6) to mean “a processor”
`
`12
`
`

`
`
`
`and equivalents thereof. Both Ito and Lind disclose the use of a “CPU” and
`
`“microprocessors” (Ito, Ex. 1003, 9:51-67; Lind, Ex. 1004, p. I21-1).
`
`iv. Claims 1, 28, and 30: “a touch-screen input and display [device] /
`[means],”
`Ito discloses a display 106 that includes a liquid crystal display or CRT that is
`
`
`
`equipped with a touch panel. Ex. 1003, 10:48-50; Ex. 1002, ¶ 9. The display is
`
`used to display information such as travel route and/or travel directions. Ex. 1003,
`
`15:22-26; Ex. 1002, ¶ 9. Since the device has a touch-screen, it also is an input
`
`device.
`
` Lind discloses three display devices for the driver (and additional display
`
`devices for the passengers). One display device for the driver is a heads-up display,
`
`and the center console additionally contains a touch-screen LCD (touch-screen
`
`input and display device). Ex. 1004, p I21-3, I21-4; Ex. 1002, ¶ 9.
`
` As discussed in Section (III)(D), above, at page 6, the “touch-screen input and
`
`display means” does not invoke 35 U.S.C. § 112(6) because no function is recited.
`
`Ito’s display 106 and Lind’s touch-screen LCD disclose the “touch-screen input
`
`and display means” of claim 30.
`
`v. Claims 1, 28, and 30: “a speech recognition apparatus in data
`communication with the [means for] data processing [apparatus],
`and”
`Ito discloses that the input section 105 may be an input device that uses voice
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`
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`recognition, and is therefore a speech recognition apparatus. Ex. 1003, 10:39-47;
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`Ex. 1002, ¶ 10. The input 105, as shown in Figure 1, is connected to and in data
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`communication with the processing section 101 (i.e., the data processing
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`apparatus/means for data processing). Ex. 1002, ¶ 10.
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`
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` Lind also discloses that “[t]he Network Vehicle is created by integrating
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`existing hardware and software technologies including voice recognition, …
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`microprocessors, … and other Internet/intranet features.” Ex. 1004, p. I21-1-I21-2;
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`Ex. 1002, ¶ 11. Lind also discloses that the user may use voice commands to, e.g.,
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`“locate a restaurant or hotel” and “ask for navigation help,” Ex. 1004, p. I21-2; Ex.
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`1002, ¶ 11, and that, by using the advanced speech recognition system of the
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`Network Vehicle, “the driver can: … request travel directions and traffic updates
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`from the Web or other sources,” Ex. 1004, p. I21-3; Ex. 1002, ¶ 11.
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`vi. Claims 1, 28, and 30: “a storage apparatus in data
`communication with the [means for] data processing [apparatus],
`said storage apparatus comprising at least one computer program,
`said at least one program being configured to:”
`Ito discloses that the “program storage section 102,” which serves as a memory
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`
`
`for storing the programs that are executed by the processing section 101, is
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`connected to, and therefore “in data communication with,” the processing section.
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`Ex. 1003, 9:51-67; Ex. 1002, ¶ 12.
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` Lind discloses that “[t]he Network Vehicle is created by integrating existing
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`hardware
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`and
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`software
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`technologies
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`including voice
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`recognition, …
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`microprocessors, … and other Internet/intranet features.” Ex. 1004, p. I21-1-I21-2;
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`Ex. 1002, ¶ 12. Such integration implicitly entails data communication between the
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`storage and data processing components of the Network Vehicle’s system. Ex.
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`1002, ¶ 12.
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`vii. Claims 1, 28, and 30: “receive a digitized speech input via the
`speech recognition apparatus, the input relating to an
`organization or entity [which a user wishes to locate] / [to which a
`user wishes to obtain directions]”
`Ito discloses that the input 105 may be a data input device that uses voice
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`
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`recognition. Ex. 1003, 10:39-47. Among the inputs that the user may enter into the
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`system are “information about the destination, such as the facility name, telephone
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`number and address thereof, and a route search request.” Id., 15:47-58 (emphasis
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`added); Ex. 1002, ¶ 13; see also Ex. 1003, 9:33-37; 14:33-38. This input is related
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`to both “an organization or entity which a user wishes to locate” (as claimed in
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`claims 1 and 28) and “an organization or entity to which a user wishes to obtain
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`directions” (as claimed in claim 30). Ex. 1002, ¶ 13.
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` Lind also discloses that the user may use voice commands to, e.g., “the driver
`
`can: … request travel directions and traffic updates from the Web or other sources”
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`15
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`using the Network Vehicle’s advanced speech recognition system. Ex. 1004, p.
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`I21-3; Ex. 1002, ¶ 13.
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`
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`It is obvious in vehicular speech recognition systems that a driver’s analog
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`voice is input through a microphone, amplified, digitized, and analyzed using a
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`digital signal processor. Ex. 1008, 5:17-30; Ex. 1002, ¶ 13.
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` Additionally, West View has admitted that “all speech recognition systems
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`inherently digitize the speaker’s analog voice.” Ex. 1010, at 729. Thus, by West
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`View’s own admissions, Ito and Lind inherently disclose receiving a digitized
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`speech input via a speech recognition apparatus, i.e., the voice recognition system
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`described by Ito and the ViaVoice speech recognition system described by Lind.
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`viii. Claims 1, 28, and 30: “[based at least in part on the input, cause
`identification of a location associated with the organization or
`entity] / [receive form [sic] 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]; [and]”
`Ito discloses that the user inputs are used to search a remote network entity, the
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`
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`database of navigation data, which is located remotely from the vehicle. Ex. 1003,
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`Fig. 1; 8:28-40; Ex. 1002, ¶ 14. The remote database uses the inputs to extract a
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`position of the destination, or “facility position or an intersection close to such
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`facility position.” Ex. 1003, Fig. 1, 8:28-40; Ex. 1002, ¶ 14. This information, as
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`well as the map and guidance data to the location, are received via the network
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`interface by navigation apparatus 100. Ex. 1003, 10:64-11:30, 15:30-37; Ex. 1002,
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`¶ 14.
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` Lind discloses that “[t]he key technologies and system components behind the
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`Network Vehicle are advanced speech recognition software.” Ex. 1004, p. I21-3;
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`Ex. 1002, ¶ 14. 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.” Ex. 1004, p. I21-3; Ex. 1002, ¶ 14. 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
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`navigation help.” Ex. 1004, I21-2; Ex. 1002, ¶ 14.
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`ix. Claims 28 and 30: “display said directions from the user’s current
`location to the organization or entity on the touch screen input
`and display [device] / [means]; and”
`Ito discloses that the guidance data, which is received via the wireless interface,
`
`
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`is displayed on the display device. Ex. 1002, ¶ 15. For example, a “recommended
`
`route is displayed on the display 106 in the form of an outline map.” Ex. 1003,
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`16:21-27; Fig. 9(A); 17:10-19; Fig. 9(B); Ex. 1002, ¶ 15. As shown in Figs. 9(A)
`
`and 9(B), the system displays directions from the user’s current location (Fig.
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`9(A): DEPARTURE POINT PD; Fig. 9(B): current position MC) to the
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`organization or entity (Fig. 9(A): DESTINATION PA). Ex. 1002, ¶ 15.
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` Lind also discloses that navigation information can be displayed on the heads-
`
`up display. Ex. 1004, p. I21-3 and Fig. 9; Ex. 1002, ¶ 16. Lind discloses that
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`17
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`“[d]rivers can use a head-up display projected through the windshield to navigate
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`to their destination.” Ex. 1004, p. I21-2; Ex. 1002, ¶ 16. Lind also discloses that the
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`“center console’s touch-screen LCD serves as a user interface for controlling
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`nearly all of the Network Vehicle’s multimedia functions,” including navigation
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`functions. Ex. 1004, p. I21-2; Ex. 1002, ¶ 16. According to Lind, the Network
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`Vehicle “can display … appropriate maps or simply provide route directions on the
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`… command console,” and Fig. 9 is an example of a navigation function display,
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`which is shown to be a touch-screen display. Ex. 1004, p. I21-7; Ex. 1002, ¶ 16.
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`x. Claims 1, 28, and 30: “provide a graphical or visual
`representation of the location [of the organization or entity] on the
`touch screen input and display [device] / [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.”
`Ito discloses that the map to an organization or entity (the destination) includes
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`
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`a graphical representation of the entity and its surroundings. Ex. 1002, ¶ 17. The
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`above map shown in Fig. 9(A) of Ito includes a graphical representation of the
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`entity (the destination) as well as a graphical representation of the roads and
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`intersections that surround it.
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` These maps are part of the navigation data that is transmitted from the base
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`apparatus to the vehicle navigation apparatus. Ex. 1003, 8:41-50; Ex. 1002, ¶ 17.
`
`Ito discloses that “area guidance data is … extracted for … the surrounding area
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`A3 around the destination PA,” Ex. 1003, 14:19-23, and that “map data of the
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`surrounding area A3 is read out of the data storage 103 and a map thereof is
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`displayed on the display 106,” Ex. 1003, 18:37-43. Ex. 1002, ¶ 17. In Figures
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`40(C) and 44, reproduced below, Ito shows the displayed images in the vehicle
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`navigation apparatus as including landmarks, such as a bank, fire station, and
`
`department store among the surroundings:
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`
`
` Lind discloses that “[d]rivers can use a head-up display projected through the
`
`windshield to navigate to their destination.” Ex. 1004, p. I21-2; Ex. 1002, ¶ 18.
`
`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. Ex. 1004, p. I21-2; Ex. 1002, ¶ 18. According to
`
`Lind, the Network Vehicle “can display … appropriate maps or simply provide
`
`route directions on the … command console,” and Fig. 9 is an example of a
`
`navigation function display, which is shown to be a touch-screen display. Ex.
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`1004, p. I21-7; Ex. 1002, ¶ 18.
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