UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`VOLKSWAGEN GROUP OF AMERICA, INC.
`
`Petitioner
`
`
`Patent No. 8,719,038
`Issue Date: May 6, 2014
`Title: COMPUTERIZED INFORMATION AND
`DISPLAY APPARATUS
`__________________________________________________________________
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 8,719,038
`PURSUANT TO 35 U.S.C. § 312 and 37 C.F.R. § 42.104
`
`Case No. IPR2016-00146
`__________________________________________________________________
`
`
`
`
`
`
`
`

`
`
`
`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 ’038 Patent .................................................................. 2 
`1. 
`The ’038 Patent .......................................................................... 2 
`2. 
`Prosecution History of the ’038 Patent ...................................... 4 
`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 
`IV.  How Challenged Claims Are Unpatentable (37 C.F.R. § 42.104(b)(4)–
`(5)) .................................................................................................................. 7 
`A.  Claims 1, 4, 16, 22, 54, and 66 are Obvious in View of the
`Disclosures of Lind, Ito, and Class ...................................................... 7 
`1. 
`Claim 1 ....................................................................................... 9 
`2. 
`Claim 4 ..................................................................................... 15 
`3. 
`Claim 16 ................................................................................... 16 
`4. 
`Claim 22 ................................................................................... 18 
`5. 
`Claim 54 ................................................................................... 24 
`6. 
`Claim 66 ................................................................................... 30 
`7. 
`Obviousness in View of Lind, Ito, and Class .......................... 32 
`8. 
`The Level of Skill in the Industry ............................................ 35 
`9. 
`Claim Charts ............................................................................ 36 
`B.  Claim 5 is Obvious in View of the Disclosures of Lind, Ito, Class,
`and Ezaki ............................................................................................ 51 
`1. 
`Claim 5 ..................................................................................... 52 
`2. 
`Obviousness in View of Lind, Ito, Class, and Ezaki ............... 53 
`-i-
`
`
`
`
`
`
`

`
`3. 
`Claim Chart .............................................................................. 53 
`C.  Claim 12 is Obvious in View of the Disclosures of Lind, Ito,
`Class, and Fujiwara ............................................................................ 54 
`1. 
`Claim 12 ................................................................................... 55 
`2. 
`Obviousness in View of Lind, Ito, Class, and Fujiwara .......... 58 
`3. 
`Claim Chart .............................................................................. 59 
`Conclusion .................................................................................................... 60 
`
`
`
`-ii-
`
`
`
`
`
`V. 
`
`
`
`
`
`
`
`

`
`
`
`Exhibit 1001
`
`Exhibit 1002
`
`Exhibit 1003
`
`
`Exhibit 1004
`
`
`Exhibit 1005
`
`Exhibit 1006
`
`Exhibit 1007
`
`
`Exhibit 1008
`
`Exhibit 1009
`
`Exhibit 1010
`
`Exhibit 1011
`
`Exhibit 1012
`
`
`Exhibit 1013
`
`
`
`
`
`LISTING OF EXHIBITS
`
`U.S. Patent No. 8,719,038 to Gazdzinski
`
`Declaration of Scott Andrews
`
`Notice of Allowance, dated November 25, 2013 in U.S.
`Patent Application Serial No. 13/752,222
`
`The Network Vehicle – A Glimpse into the Future of
`Mobile Multi-Media, by R. Lind et al., The 17th DASC –
`The AIAA/IEEE/SAE Digital Avionics Systems
`Conference – Bellevue, WA – Oct. 31-Nov. 7, 1998 –
`Proceedings
`
`U.S. Patent No. 6,249,740 to Ito et al.
`
`U.S. Patent No. 6,230,132 to Class et al.
`
`European Patent Application Publication No. 0 829 704
`to Fujiwara et al.
`
`U.S. Patent No. 6,064,323 to Ishii et al.
`
`U.S. Patent No. 6,157,705 to Perrone
`
`U.S. Patent No. 6,201,544 to Ezaki
`
`U.S. Patent No. 5,283,559 to Kalendra et al.
`
`“Plaintiff and Counter-Defendant West View 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,” dated June 26, 2015
`
`U.S. Copyright Registration No. TX 4-900-822, “1998
`IEEE/AIAA 17th Digital Avionics Systems Conference -
`-iii-
`
`
`

`
`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
`
`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/
`
`U.S. Patent No. 5,274,560 to LaRue
`
`-iv-
`
`
`
`
`
`
`Exhibit 1014
`
`
`Exhibit 1015
`
`
`Exhibit 1016
`
`
`Exhibit 1017
`
`
`Exhibit 1018
`
`
`Exhibit 1019
`
`
`Exhibit 1020
`
`
`
`
`
`
`
`

`
`
`
`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
`
`litigation, West View has accused, for example, an Audi A3 with “MMI/Connect,”
`
`an Audi Q7 with “Smart Display,” and a Volkswagen Golf GTI with “MIB”
`
`system as infringing the claims of U.S. Patent No. 8,719,038 (“the ’038 patent,”
`
`Ex. 1001), which is being challenged by this petition. See, Ex. 1012.
`
` 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-
`
`1
`
`

`
`
`
`00124; IPR2016-00125; IPR2016-00137; IPR2016-00156; IPR2016-00177; U.S.
`
`Patent Nos. 8,447,612; 8,117,037; 7,711,565; 7,093,693; 6,988,071; and
`
`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 ’038 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, 4, 5, 12, 16, 22, 54, and 66 of the ’038 patent
`
`under 35 U.S.C. § 103(a), and cancelation of these claims is requested.
`
`A. Background of the ’038 Patent
`1. The ’038 Patent
` The ’038 patent issued on May 6, 2014, from U.S. Patent Application Serial No.
`
`13/752,222 (“the ’222 application”), filed on January 28, 2013. The ’038 patent
`
`2
`
`

`
`
`
`claims to be a continuation or division of a number of prior applications, the
`
`earliest of which was filed on June 10, 1999.1
`
` The ’038 patent describes an elevator information system that allows a user to
`
`verbally initiate a query of a database. Ex. 1001, 7:4-25; Ex. 1002, ¶ 3. 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. Ex. 1001, 7:26-27, 7:57-60; Ex. 1002, ¶ 3. A touch screen
`
`display 113 generates a variety of different messages or display formats based on
`
`the user’s input and query (e.g., a building directory). Ex. 1001, 8:43-45, 9:35-
`
`11:34; Ex. 1002, ¶ 3. The user can speak the specific name of the party they wish
`
`to find, and the digitized speech is compared to the contents of a directory file to
`
`find any matches. Ex. 1001, 10:7-16; Ex. 1002, ¶ 3. Any matching fields within the
`
`entries of the directory file are provided to the user, either audibly via a speech
`
`synthesis module 112 and speaker 111, or visually via the display 113. Ex. 1001,
`
`10:17-19; Ex. 1002, ¶ 3. The user can also add defining information to the initial
`
`query statement to form a Boolean search statement. Ex. 1001, 10:47-50; Ex. 1002,
`
`¶ 3. A location graphic file is displayed on the display device 113 as a floor map
`
`
`1 VWGoA does not concede that any claim of the ’038 patent is entitled to a filing
`
`date earlier than the January 28, 2013 filing date of the ’222 application.
`
`3
`
`

`
`
`
`graphic 502 illustrating the location of the selected person or firm. Ex. 1001,
`
`11:15-17; Ex. 1002, ¶ 3.
`
` Of the challenged claims, claims 1, 22, 54, and 66 are independent.
`
`2. Prosecution History of the ’038 Patent
` Without any prior claim rejections, the USPTO issued a Notice of Allowance on
`
`November 25, 2013. According to the Examiner (see Ex. 1003, p. 2), the claims of
`
`the ’222 application were found allowable for the following reasons:
`
`The claims are allowed, because, the prior arts of record do not teach
`the steps performed for determining a location associated with the one
`of the possible matches that best correlates and presenting the location
`and associated surroundings as recited in the claims.
`B. Patents and Printed Publications Relied On
` 1. 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.
`
`1013, also stating October 31, 1998 as the date of first publication in the U.S.),
`
`4
`
`

`
`
`
`constitutes prior art against the ’038 patent under at least 35 U.S.C. § 102(a).2
`
` 2. U.S. Patent No. 6,249,740 (“Ito,” Ex. 1005), filed January 21, 1999,
`
`constitutes prior art against the ’038 patent under at least 35 U.S.C. § 102(e).
`
` 3. U.S. Patent No. 6,230,132 (“Class,” Ex. 1006), filed on March 10, 1998,
`
`
`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. 1014, for this
`
`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. 1015,
`
`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. 1016. Ex. 1017 is the U.S. Copyright
`
`Registration for Ex. 1016, stating a November 1998 date of first publication in the
`
`U.S., Ex. 1018 is the U.S. Copyright Office’s public catalog record for Ex. 1016,
`
`stating November 1998 date of publication of Ex. 1016, and Ex. 1019 is the SAE’s
`
`abstract for Ex. 1016, stating a November 1998 date of publication of Ex. 1016.
`
`5
`
`

`
`
`
`constitutes prior art against the ’038 patent under at least 35 U.S.C. § 102(e).
`
` 4. U.S. Patent No. 6,201,544 (“Ezaki”, Ex. 1010), filed on August 10, 1998,
`
`constitutes prior art against the ’038 patent under at least 35 U.S.C. § 102(e).
`
` 5. European Patent Application Publication No. 0 829 704 (“Fujiwara,” Ex.
`
`1007), published March 18, 1998, constitutes prior art against the ’038 patent
`
`under 35 U.S.C. § 102(b).
`
` Lind, Ito, Ezaki, and Fujiwara were not cited by Mr. Gazdzinski or the Examiner
`
`during prosecution of the ’038 patent. Class was cited in an IDS filed on November
`
`14, 2013, but was not discussed during prosecution.
`
`C. Statutory Grounds for Challenge (37 C.F.R. § 42.104(b)(1)–(2))
` 1. Claims 1, 4, 16, 22, 54 and 66 are obvious under 35 U.S.C. § 103(a) in view
`
`of Lind, Ito, and Class.
`
` 2. Claim 5 is obvious under 35 U.S.C. § 103(a) in view of Lind, Ito, Class, and
`
`Ezaki.
`
` 3. Claim 12 is obvious under 35 U.S.C. § 103(a) in view of Lind, Ito, Class, and
`
`Fujiwara.
`
`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.
`
`The specification of the ’038 patent does not present any special definition for any
`
`6
`
`

`
`
`
`claim term, and the prosecution history of the ’038 patent does not include any
`
`claim construction arguments. Therefore, all claim terms should be given their
`
`broadest reasonable construction.
`
`IV. How Challenged Claims Are Unpatentable (37 C.F.R. § 42.104(b)(4)–(5))
`A. Claims 1, 4, 16, 22, 54, and 66 are Obvious in View of the Disclosures of
`Lind, Ito, and Class
` As described in detail below, claims 1, 4, 16, 22, 54, and 66 are invalid under 35
`
`U.S.C. § 103(a) as obvious in view of the disclosures of Lind, Ito, and Class.
`
` Lind discloses a “Network Vehicle” that includes hardware and software that
`
`allows wireless connection to, and information retrieval from, the Internet. Ex.
`
`1004, I21-1-I21-2. The system includes a speech recognition and text-to-speech
`
`system that “allows the driver to access virtually all the vehicle’s features through
`
`voice commands and enables the vehicle to talk back using synthesized speech;”
`
`for example, the user can request “travel directions.” Ex. 1004, I21-3. Navigation
`
`maps are displayed on a center console’s touch-screen LCD (Ex. 1004, I21-3, I21-
`
`7), as shown in Fig. 9:
`
`
`
`
`
`
`
`Ito discloses a vehicle computer and display system that includes a vehicle
`
`navigation apparatus 100, mounted in a vehicle as a movable body, and a “base
`
`7
`
`

`
`
`
`apparatus” 150 that wirelessly connects to the navigation apparatus, as shown in
`
`Fig. 1. Ex. 1005, 8:11-16, 10:51-57.
`
`
`
` The system includes a “data input device using voice recognition” that allows
`
`the user to “use his/her voice to input corresponding data and commands” to
`
`control the navigation system. Ex. 1005, 10:39-47. Also disclosed is a display
`
`device, which may be an LCD or a CRT display unit, equipped with a touch panel.
`
`Ex. 1005, 10:48-50. The user can input information about a destination, such as a
`
`facility name. Ex. 1005, 15:52-53. If a user inputs partial information (such as
`
`several digits of a telephone number), the potential matches are displayed for the
`
`user’s selection of the appropriate destination. Ex. 1005, 16:5-16. An “outline
`
`map” showing the recommended route to the destination and a map of the area
`
`around the departure point can be displayed. Ex. 1005, 16:24-27, 17:4-19, Figs.
`
`9(A), 9(B), 40(C), and 44.
`
` Class describes a navigation system using speech input of a destination location.
`
`Ex. 1006, Abstract, 8:7-8. Class discloses a device having a speech dialogue
`
`system 1, a navigation system 2, and an external database 4. Id., Fig. 10:
`
`8
`
`

`
`
`
`
`
` Class describes a process of determining a list of potential matches in response
`
`to the user’s initial input (Ex. 1006, 8:7-8 and 8:16-18), and narrowing the
`
`potential matches in response to additional user input to identify the desired
`
`location; the system creates an “ambiguity list” of potential matches to the speech
`
`input, and uses “input dialogues” for additional user input to resolve the ambiguity
`
`and identify the desired location. Ex. 1006, 9:6-8, 9:18-31, 10:43-11:60.
`
` As described below, Lind, Ito, and Class disclose all of the limitations of claims
`
`1, 4, 16, 22, 54, and 66.
`
`1. Claim 1
`i.
`“[c]omputer readable apparatus configured to aid a user in
`locating an organization or entity, the apparatus comprising a
`storage medium having a computer program configured to run on
`a processor, the program configured to, when executed on the
`processor:”
` Lind describes that the “Network Vehicle is created by integrating existing
`
`hardware and software
`
`technologies
`
`including voice recognition, wireless
`
`communications, global positioning via satellite, head-up displays, JavaTM
`
`technology, microprocessors, Web access, and other Internet/intranet features,”
`
`that one of its features is “virtual navigation,” that “[a]t the heart of the onboard
`
`9
`
`

`
`
`
`system is a network computer,” and that a user can “locate a restaurant or hotel.”
`
`Ex. 1004, I21-1-I21-2; Ex. 1002, ¶ 4. Ito describes a “vehicle navigation
`
`apparatus” which includes a “processing section 101” with “a CPU as its main
`
`component” and a “program storage section 102” that “serves as a memory for
`
`storing programs which will be executing by the processing section.” Ex 1005,
`
`9:52-67 and Fig. 1, Ex. 1002, ¶ 4. Ito describes that the user operates an input
`
`section 105 to “input information about the destination, such as the facility name.”
`
`Ex. 1005, 15:50-54; Ex. 1002, ¶ 4. Class discloses “a method and apparatus for
`
`real-time speech input of a destination address into a navigation system.” Ex, 1006,
`
`1:11-13; Ex. 1002, ¶ 4.
`
`ii. “obtain a representation of a first speech input from the user, the
`first speech input relating to a name of a desired organization or
`entity”
` Lind describes “advanced speech recognition software,” which allows the user
`
`to “locate a restaurant or hotel.” Ex. 1004, I21-2 and I21-3; Ex. 1002, ¶ 5. The
`
`speech recognition system is adapted to receive “voice commands” and to
`
`“understand most drivers instantly.” Ex. 1004, I21-3; Ex. 1002, ¶ 5. Ito describes
`
`“a data input device using voice recognition” for the user to “use his/her voice to
`
`input corresponding data and commands.” Ex. 1005, 10:39-47, Ex. 1002, ¶ 5. The
`
`user of the vehicle navigation apparatus uses the input device “to input information
`
`about the destination, such as the facility name, telephone number and address.”
`
`10
`
`

`
`
`
`Ex. 1005, 15:50-54 (emphasis added); Ex. 1002, ¶ 5. Class discloses “input
`
`dialogues for speech input of a destination address for a navigation system.” Ex.
`
`1006, 6:30-32; Ex. 1002, ¶ 5. Class discloses that its system facilitates “more rapid
`
`speech entry of a desired destination address,” Ex. 1006, 4:9-10, and that the
`
`speech input of the destination location may be made by street name, place name,
`
`etc. Ex. 1002, ¶ 5. As admitted by West View, “all speech recognition systems
`
`inherently digitize the speaker’s analog voice.” Ex. 1012, at 729.
`
`iii. “cause use of at least a speech recognition algorithm to process
`the representation to identify at least one word or phrase therein”
` As previously noted, Lind describes “advanced speech recognition software” to
`
`receive “voice commands” and will “understand most drivers instantly.” Ex. 1004,
`
`p. I21-3, Ex. 1002, ¶¶ 4, 6. Additionally, Ito describes “a data input device using
`
`voice recognition” for the user to “use his/her voice to input corresponding data
`
`and commands,” including “information about the destination, such as facility
`
`name, telephone number and address thereof.” Ex. 1005, 10:39-47, 15:50-54; Ex.
`
`1002, ¶ 6. Class discloses “input dialogues for speech input of a destination address
`
`for a navigation system.” Ex. 1006, 6:30-32; Ex. 1002, ¶ 6. At the time the alleged
`
`invention of claim 1 was made, it was obvious to use voice-recognition software
`
`using predetermined voice recognition algorithms, such as the Hidden Markov
`
`Model, to process a representation of speech in order to identify a spoken word or
`
`phrase. See, Ex. 1008, 3:11-18 (which describes a voice recognition circuit 14 that
`
`11
`
`

`
`
`
`performs the recognition operation in accordance with a predetermined voice
`
`recognition algorithm such as HMM or Hidden Markov Model); Ex. 1002, ¶ 6.
`
`iv. “use at least the identified at least one word or phrase to identify a
`plurality of possible matches for the name”
` Class describes a method and apparatus for input of destination locations in a
`
`navigation system and, in particular, describes a disambiguation method in which
`
`the speech recognition engine identifies an ambiguity list that contains entries of
`
`place names that could match the input speech, sorted by probability. Ex. 1006,
`
`8:16-18, 9:6-11; Ex. 1002, ¶ 7. This ambiguity list is used to “identify a plurality of
`
`possible matches for the name.” Ex. 1002, ¶ 7.
`
`v.
`
`“cause the user to be prompted to enter a subsequent input in
`order to aid in identification of one of the plurality of possible
`matches which best correlates to the desired organization or
`entity”
` Class describes methods for reducing the number of potential matches by
`
`requesting additional user input, such as by asking the user to confirm that a
`
`particular location is the desired destination (Ex. 1006, 8:23-32, 9:21-31), by a
`
`series of “interrogation dialogs” asking the user to input additional information,
`
`such as, e.g., postal code) (id., 10:43-11:60), or, if no more than a certain number
`
`of potential matches are left, by way of a list that is either read out or displayed for
`
`the user’s selection (id., 10:57-59, 9:50-10:11); Ex. 1002, ¶ 8. Ito also discloses a
`
`method for resolving ambiguities. If a user enters only the first several digits of a
`
`telephone area code as the information for the navigation destination, several
`
`12
`
`

`
`
`
`facilities may match those digits. Ex. 1005, 16:5-19. A list of matching facilities is
`
`“displayed at the vehicle” such that “the user views such facilities to decide
`
`whether or not the destination is included in the searched facilities, and then selects
`
`the appropriate destination from the plurality of searched facilities;” the display of
`
`multiple facilities prompts the user to respond by selecting one. Ex. 1005, 16:5-19;
`
`see also 11:27-30; Ex. 1002, ¶ 8.
`
`vi. “receive data relating to the subsequent user input”
` Class discloses that after requesting subsequent input to resolve the ambiguity of
`
`the multiple potential matches, the system receives the requested input. Ex. 1006,
`
`8:31-32, 9:26-31, 10:7-10, 10:26-29, 10:34-38, 10:50-55, 11:34-43; Ex. 1002, ¶ 9.
`
`Ito describes a method where the user selects a desired destination from the list of
`
`multiple matching facilities; the selection is a “subsequent user input.” Ex. 1005,
`
`16:5-19. Ex. 1002, ¶ 9.
`
`vii. “based at least in part on the data, determine which of the
`plurality of possible matches is the one that best correlates”
` Class describes that based on the subsequent user input (see, e.g., the example in
`
`Ex. 1006, 17:27-18:55, describing additional details the user provides), the system
`
`determines which of a plurality of possible matches (see id., 17:27-29, describing
`
`18 potential matches) is the one that best correlates (see 18:57-62, describing final
`
`search result based on user’s additional details). Ex. 1002, ¶ 10; Ex. 1006, 9:29-31,
`
`10:34-37, 11:17-21, and the examples at 16:57-18:65, 21:20-23:37. Ex. 1002, ¶ 10.
`
`13
`
`

`
`
`
`viii. “determine a location associated with the one of the possible
`matches that best correlates”
` As described above, Class describes a disambiguation method to determine a
`
`destination location, such as a city. Ex. 1006, 9:29-31, 10:34-37, 11:17-21, 18:23-
`
`64; Ex. 1002, ¶ 11. In addition, after arriving at the destination (such as a city) that
`
`best correlates through its disambiguation method, the system in Class determines
`
`(either through user interrogation or by default in case no street list is available for
`
`the destination) “a street or a special destination, for example the railroad station,
`
`airport, downtown, etc.,” “since only a complete destination address can be
`
`transferred to the navigation system.” Ex. 1006, 7:11-34; Ex. 1002, ¶ 11.
`
`ix. “and select and cause presentation of a visual representation of
`the location, as well as at least an immediate surroundings
`thereof, on a display viewable by the user”
` Lind describes several display screens, including a center console that can
`
`display navigation maps viewable by a user (e.g., a driver); an exemplary display is
`
`shown in Fig. 9. Ex. 1004, I21-3, I21-7; Ex. 1002, ¶ 12. Ito discloses displaying
`
`detailed maps, including a recommended route to the selected destination on an
`
`output display. Ex. 1005, 16:24-27, Figs. 9(A), 9(B), 40(C), 44; Ex. 1002, ¶ 12. An
`
`exemplary map of the area surrounding the departure point (“PD”) is shown in Fig.
`
`9(B); see Ex. 1005, 17:4-19. Although Fig. 9(B) illustrates a departure point, Ito
`
`discloses that destination points are treated in generally the same manner. Id.,
`
`14:19-38. See Ex. 1002, ¶ 12.
`
`14
`
`

`
`
`
`
`
`x.
`
`“the visual representation further comprising visual
`representations of one or more other organizations or entities
`proximate to the location.”
`Ito further describes displaying area guidance for the area surrounding the
`
`destination point, including “guidance information on the presence or absence of
`
`parking and various facilities in the area around the destination.” Ex. 1005, 14:33-
`
`38. Parking, various facilities around the destination, a department store, a fire
`
`station, and a bank are “organizations or entities proximate” to the destination
`
`location. Ex. 1002, ¶ 13. An exemplary map with a visual representation of other
`
`entities around a point of interest is shown in Fig. 9(B), and the maps shown in
`
`Figs. 40(C) and 44 include a department store, a fire station, and a bank displayed
`
`relative to each other. Although Fig. 9(B) illustrates a departure point (PD);
`
`departure points and destination points are treated in generally the same manner.
`
`Ex. 1005, 14:19-38; Ex. 1002, ¶ 12.
`
`2. Claim 4: “The apparatus of claim 1, wherein the prompt for the
`subsequent user input comprises a display of a listing of the
`plurality of possible matches on a touch-screen input and display
`device, such that the user can select one of the plurality of possible
`matches via a touch of the appropriate region of the touch-screen
`device.”
`If no more than a certain number of potential matches are left, Class describes
`
`
`
`reducing the number of potential matches by requesting additional user input by
`
`way of a list of the remaining matches that is either read out or displayed for the
`
`user’s selection (Ex. 1006, 10:57-59, 9:50-10:11, 17:62-18:21); Ex. 1002, ¶ 14.
`
`15
`
`

`
`
`
`Further, Lind describes a “center console’s touch-screen LCD” which “serves as a
`
`user interface for controlling nearly all of the Network Vehicle’s multimedia
`
`functions” including “navigation.” Ex. 1004, I21-3; Ex. 1002, ¶ 14. Ito similarly
`
`describes that input is received via “a touch panel provided on the display 106”
`
`with which a “user can use a finger or the like to touch an icon or the like
`
`displayed on the screen of the display 106.” Ex. 1005, 10:39-50; Ex. 1002, ¶ 14. Ito
`
`further describes that if there is a plurality of potentially matching facilities, a list
`
`of matching facilities is “displayed at the vehicle” such that “the user views such
`
`facilities to decide whether or not the destination is included in the searched
`
`facilities, and then selects the appropriate destination from the plurality of searched
`
`facilities.” Ex. 1005, 16:5-19; Ex. 1002, ¶ 14.
`
`3. Claim 16
`i.
`“The apparatus of claim 1, wherein the causation of use of at least
`a speech recognition algorithm, the use of at least the identified at
`least one word or phrase, the causation of the user to be prompted
`to enter a subsequent input, the receipt of the data relating to the
`subsequent user input, the determination of which of the plurality
`of possible matches is the one that best correlates, the
`determination of the location, and the selection of the visual
`representation, are each performed by at least one networked
`server in wireless communication with client device, the client
`device and the at least one server forming a client-server
`relationship”
` Lind describes that advanced features of the network vehicle, including the
`
`navigation functionality, are enabled by “a client-server network architecture.” Ex.
`
`1004, Abstract; Ex. 1002, ¶ 15. Lind also describes wireless connection between
`
`16
`
`

`
`
`
`the Network Vehicle and the Internet. Ex. 1004, I21-2 (“A wireless modem
`
`provides the uplink out of the vehicle directly to Internet service providers. The
`
`downlink return path from the Internet to the Network Vehicle can come through
`
`either the satellite … or through the wireless modem.”); Ex. 1002, ¶ 15. Ito
`
`describes a navigation system having “a navigation base apparatus 150 arranged at
`
`a base and a vehicle navigation apparatus 100 mounted in a vehicle as a movable
`
`body.” Ex. 1005, 8:13-16. As shown in Fig. 1, the base apparatus 150
`
`communicates wirelessly with the vehicle navigation apparatus. Ex. 1005, 8:58-62.
`
`These two devices form a client-server relationship. Ex. 1002, ¶ 15. The base
`
`apparatus 150 performs various operations that are central to the system’s
`
`navigation function, as shown in Fig. 3; see Ex. 1005, 10:58-15:38 (section titled
`
`“Operations of the Navigation Base Apparatus”); Ex. 1002, ¶ 15. For example, the
`
`base apparatus “carries out a route search using data stored in a data base;” in this
`
`way, Ito explains, “there is no need for the vehicle navigation apparatus 100 to
`
`store map data or other data,” which “makes it possible to simplify the structure of
`
`the vehicle navigation apparatus 100.” Ex. 1005, 8:18-20, 8:36-41, 11:31-36. The
`
`base apparatus further determines “the departure point and destination required for
`
`a route search” (Ex. 1005, 10:65-67). Ito describes that “in establishing the
`
`destination, the position data of the facility corresponding to the telephone number
`
`or the address transmitted from the vehicle navigation apparatus 10