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. 8,296,146 (the “’146 patent”). I
`
`have over 35 years of experience in fields relevant to the ’146 patent, including
`
`telecommunications systems and navigation systems.
`
`2.
`
`I have reviewed the ’146 patent, as well as its prosecution history and the
`
`prior art cited during its prosecution. I have also reviewed U.S. Patent No.
`
`6,707,421 (“Drury”), the Richard Lind et al. publication, The Network Vehicle – A
`
`Glimpse
`
`into
`
`the Future of Mobile Multi-Media, 17th DASC, The
`
`AIAA/IEEE/SAE Digital Avionics Systems Conference – Bellevue, WA – Oct.
`
`31-Nov. 7, 1998 – Proceedings (“Lind”), U.S. Patent No. 6,230,123 (“Class”), U.S.
`
`Patent No. 6,249,740 (“Ito”), Chapter 11 of the Automotive Electronics Handbook
`
`(“Jurgen”), and “Plaintiff and Counter-Defendant West View Research, LLC’s
`
`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. 8,296,146 (the “’146 patent”). I
`
`have over 35 years of experience in fields relevant to the ’146 patent, including
`
`telecommunications systems and navigation systems.
`
`2.
`
`I have reviewed the ’146 patent, as well as its prosecution history and the
`
`prior art cited during its prosecution. I have also reviewed U.S. Patent No.
`
`6,707,421 (“Drury”), the Richard Lind et al. publication, The Network Vehicle – A
`
`Glimpse
`
`into
`
`the Future of Mobile Multi-Media, 17th DASC, The
`
`AIAA/IEEE/SAE Digital Avionics Systems Conference – Bellevue, WA – Oct.
`
`31-Nov. 7, 1998 – Proceedings (“Lind”), U.S. Patent No. 6,230,123 (“Class”), U.S.
`
`Patent No. 6,249,740 (“Ito”), Chapter 11 of the Automotive Electronics Handbook
`
`(“Jurgen”), and “Plaintiff and Counter-Defendant West View Research, LLC’s
`
`1
`
`VWGoA - Ex. 1002
`Volkswagen Group of America, Inc., Petitioner
`
`1
`
`
`
`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 ’146 Patent
`
`3.
`
`The ’146 patent describes an information system for use in an elevator,
`
`although it states that the disclosed systems and methods may also be used 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. ’146 patent, col. 2, lines 1 to 3, col. 6,
`
`lines 38 to 41 and lines 49 to 50, Figs. 1 and 2. The system responds to verbal
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`commands. Id., col. 7, lines 35 to 39. Signals captured by a microphone 118 as
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`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
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`digital representations of the user’s speech. Id. The digital representations are
`
`compared to a speech library to identify matching known words and the desired
`
`functionality is implemented. Id., col. 7, lines 39 to 45. Input to and output from
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`the system may be by a display device 113. Id., col. 6, line 65 to col. 7, line 3, col.
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`8, lines 21 to 23.
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`4.
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`One function of the display device includes accessing a network via a
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`network interface 300 which permits the user to rapidly access updated information
`
`2
`
`2
`
`
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`on a variety of predetermined topics of interest. Id., col. 11, lines 13 to 19.
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`Examples of such information include URLs for news headlines, weather, sports
`
`scores, financial data, directions to local airports or public transportation, etc. Id.,
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`col. 11, lines 19 to 26.
`
`5.
`
`According to the ’146 patent, the system 100 can include one or more data
`
`terminals 702 which allow the user to plug in a personal electronic device (PED)
`
`704 having a standardized interface into the system to obtain a download of
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`information. ’146 patent, col. 12, lines 19 to 46. A representation of this
`
`embodiment is shown in Fig. 7:
`
`6.
`
`According to the ’146 patent, “the term ‘PED’ includes, but is not limited to,
`
`personal digital assistants
`
`(PDAs) such as
`
`the Apple Newton®, US
`
`Robotics/3COM PalmPilot®, or Palm III®, laptop computer, notebook computer,
`
`or the like.” ’146 patent, col. 12, lines 25 to 28. Furthermore, the data terminal, via
`3
`
`3
`
`
`
`which the PED 704 may be plugged into to the system 100, “includes a connector
`
`712 which is a 9-pin RS-232 serial connection of the type well known in the
`
`electronic arts, although other types of connectors and protocols may be used.”
`
`’146 patent, col. 12, lines 28 to 32.
`
`The Disclosures of Drury and Lind - Claims 1, 10, 11, 18, 27, and 30
`
`7.
`
`Drury and Lind disclose a “[c]omputer readable apparatus” as claimed in
`
`claim 1 of the ’146 patent. For example, Drury discloses that the system may be a
`
`“computer that is coupled to the handset module and to the communication module
`
`is programmed to perform … functions,” and that a “processor 212 is also coupled
`
`to a static storage 222 which is a non-volatile storage used to store code and data
`
`for operation of the system.” Drury, col. 2, lines 10 to 13 and col. 10, lines 23 to
`
`25. Lind describes that “[t]he Network Vehicle is created by integrating existing
`
`hardware and software
`
`technologies
`
`including voice recognition, wireless
`
`communication, global positioning via satellite, head-up displays, JavaTM
`
`technology, microprocessors, Web access, and other Internet/intranet features.”
`
`Lind, pages I21-1 to I21-2.
`
`8.
`
`Drury and Lind disclose a “storage medium comprising at least one
`
`computer program with a plurality of instructions” as claimed in claim 1 of the
`
`’146 patent. For example, Drury discloses that “processor 212 is … coupled to a
`
`static storage 222 which is a non-volatile storage used to store code and data for
`
`4
`
`4
`
`
`
`operation of the system.” Drury, col. 10, lines 23 to 25. Lind describes that “[t]he
`
`Network Vehicle is created by integrating existing hardware and software
`
`technologies
`
`including voice recognition, wireless communication, global
`
`positioning via satellite, head-up displays, JavaTM technology, microprocessors,
`
`Web access, and other Internet/intranet features.” Lind, pages I21-1 to I21-2. It
`
`was obvious, at the time the ’146 patent was filed, that the code described by Drury
`
`and the computer programs disclosed by Lind include “a plurality of instructions,”
`
`as claimed in claim 1 of the ’146 patent. Chapter 11 of Jurgen, for example,
`
`describes automotive computers and microcontrollers, as they existed in the mid-
`
`1990s. It was known, for example, in the mid-1990s that microcontrollers include
`
`an “instruction set,” which “consists of a set of unique commands which the
`
`programmer uses to instruct the microcontroller on what operation to perform.”
`
`Jurgen, pages 11.12 to 11.13. Additionally, Jurgen includes a discussion of the
`
`common types of programming languages used in the automotive field, including
`
`high level languages, such as C, and low level languages, such as assembly
`
`language, each of which permit a microcontroller or CPU to execute machine
`
`instructions. Jurgen, pages 11.15 to 11.17.
`
`9.
`
`Drury and Lind disclose “the computer readable apparatus being part of a
`
`computerized information system disposed on or within a transport apparatus
`
`configured to transport at least one person from one location to another” as claimed
`
`5
`
`5
`
`
`
`in claim 1 of the ’146 patent. For example, Drury discloses that it “relates to an
`
`information system for motor vehicles,” and “each in-vehicle system 105 includes
`
`an onboard computer 210.” Drury, col. 1, lines 13 to 14, col. 9, lines 65 to 66, and
`
`Figs. 1 and 2. Lind describes that “[t]he Network Vehicle is created by integrating
`
`existing hardware and software technologies including voice recognition, wireless
`
`communication, global positioning via satellite, head-up displays, JavaTM
`
`technology, microprocessors, Web access, and other Internet/intranet features.”
`
`Lind, pages I21-1 to I21-2.
`
`10. Drury and Lind disclose “the computerized information system being
`
`configured to adaptively provide a user with desired information relating to a
`
`plurality of topical areas” as claimed in claim 1 of the ’146 patent. For example,
`
`Drury discloses that “the navigation service of the vehicle information system as a
`
`whole … [is] provided through a combination of functions that are performed by
`
`server system 125 and by an in-vehicle system 105.” Drury, col. 5, lines 1 to 7 and
`
`Figs. 1 and 2. Also, Drury discloses that a user is provided with, for example,
`
`traffic-related information and communication services. Drury, col. 6, lines 1 to 7.
`
`Lind describes that “[t]he Network Vehicle is created by integrating existing
`
`hardware and software technologies including … Web access, and other
`
`Internet/intranet features.” Lind, pages I21-1 to I21-2. According to Lind, the
`
`Network Vehicle’s “voice recognition technology allows drivers and passengers to
`
`6
`
`6
`
`
`
`verbally request and listen to e-mail messages, locate a restaurant or hotel, ask for
`
`navigation help or for specific music or sports scores, and use voice-activated
`
`telephone services.” Lind, page I21-2.
`
`11. Drury and Lind disclose at least one computer program configured to
`
`“receive a digitized representation of a speech input of the user of the transport
`
`apparatus via a speech recognition apparatus in communication with the
`
`computerized information system, the speech input relating to a desired function to
`
`be performed by the computerized information system, the desired function
`
`relating to at least one of the topical areas” as claimed in claim 1 of the ’146
`
`patent. For example, Drury discloses that “the computer that is coupled to the
`
`handset module and to the communication module is programmed to perform the
`
`functions of … accepting driver information command … for example … speaking
`
`a command that is interpreted by a speech recognition system,” and that the
`
`“onboard computer 2310 processes the spoken commands, or alternatively, passes
`
`the speech signal to a remote server that performs all or some of the speech
`
`recognition function.” Drury, col. 2, lines 10 to 13 and lines 19 to 22, col. 43, lines
`
`28 to 34. Lind describes that “[t]he Network Vehicle is created by integrating
`
`existing hardware and software technologies including voice recognition, … Web
`
`access, and other Internet/intranet features.” Lind, pages I21-1 to I21-2. According
`
`to Lind, the Network Vehicle’s “voice recognition technology allows drivers and
`
`7
`
`7
`
`
`
`passengers to verbally request and listen to e-mail messages, locate a restaurant or
`
`hotel, ask for navigation help or for specific music or sports scores, and use voice-
`
`activated telephone services.” Lind, page I21-2. Lind discloses that 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, check
`
`e-mail and voicemail, request news, sports, and stock information.” Lind, page
`
`I21-3. As West View has acknowledged (and I agree) “all speech recognition
`
`systems inherently digitize the speaker’s analog voice.” Infringement Contentions,
`
`page 729.
`
`12. Drury and Lind disclose at least one computer program configured to “cause
`
`wireless access of a remote server to access information necessary to perform the
`
`desired function” as claimed in claim 1 of the ’146 patent. For example, Drury
`
`discloses that its computer is programmed to perform the function of, e.g.,
`
`“retrieving information through the wireless communication interface from the
`
`server in response to the driver information commands.” Drury, col. 2, lines 10 to
`
`13 and lines 22 to 24. Drury also discloses that “in-vehicle systems 105 are
`
`coupled to server system 125 by wireless communication links” and that the in-
`
`vehicle system establishes the communication session by making a cellular
`
`telephone call to the server system and then establishing a data communication
`
`session with the server system using its modem. Drury, col. 5, lines 25 to 26 and
`
`8
`
`8
`
`
`
`col. 18, lines 52 to 57. Lind discloses that “[t]he Network Vehicle is created by
`
`integrating existing hardware and software
`
`technologies
`
`including voice
`
`recognition, wireless communications …, Web access, and other Internet/intranet
`
`features.” Lind, pages I21-1 to I21-2. According to Lind, “[t]he Network Vehicle
`
`also has … Netscape Communicator software for Web browsing and e-mail,” Lind,
`
`page I21-3, and that 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, check e-mail and voicemail, request news, sports, and stock
`
`information,” Lind, page I21-3.
`
`13. Drury and Lind disclose that at least one computer program is configured to
`
`“receive accessed information obtained from the remote server via the wireless
`
`interface” as claimed in claim 1 of the ’146 patent. For example, Drury discloses
`
`that its computer is programmed to perform the function of, e.g., “retrieving
`
`information through the wireless communication interface from the server in
`
`response to the driver information commands” Drury, col. 2, lines 10 to 13 and
`
`lines 22 to 24. For example, “the in-vehicle system receives the planned route, spot
`
`map, and GPS correction data from the server system.” Drury, col. 19, lines 55 to
`
`58. Lind discloses that “[t]he Network Vehicle is created by integrating existing
`
`hardware and software
`
`technologies
`
`including voice recognition, wireless
`
`communications …, Web access, and other Internet/intranet features.” Lind, pages
`
`9
`
`9
`
`
`
`I21-1 to I21-2. The Network Vehicle includes a wireless modem that “provides the
`
`uplink out of the vehicle directly to Internet service providers,” and “[t]he
`
`downlink return path from the Internet to the Network Vehicle can come through
`
`either the satellite …, or through the wireless modem.” Lind, page I21-2.
`
`According to Lind, “[t]he Network Vehicle also has … Netscape Communicator
`
`software for Web browsing and e-mail,” Lind, page I21-3, and that 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, check
`
`e-mail and voicemail, request news, sports, and stock information,” Lind, page
`
`I21-3.
`
`14. Drury and Lind disclose at least one computer program configured to
`
`“implement the desired function of the computerized information system using at
`
`least a portion of the received information and at least one of: (i) a touch-screen
`
`display and input device of the computerized information system; and/or (ii) a
`
`speech synthesis apparatus of the computerized information system” as claimed in
`
`claim 1 of the ’146 patent. For example, Drury discloses that its computer is
`
`programmed to perform the function of, e.g., “presenting the retrieved information
`
`on the handset module.” Drury, col. 2, lines 24 to 25. The information may be
`
`presented “on the display of the handset” or “by playing the information on the
`
`audio device of the handset.” Drury, col. 2, lines 27 to 28. For example, “voice
`
`10
`
`10
`
`
`
`output device 246 provides audio output of speech commands that are stored or
`
`formed on onboard computer, for example, using compressed or concatenated
`
`waveforms or a speech synthesizer.” Drury, col. 11, lines 18 to 21. Lind discloses
`
`that the “[t]he center console’s touch-screen LCD serves as a user interface for
`
`controlling nearly all of the Network Vehicle’s multimedia functions,” (Lind, page
`
`I21-3) and that maps can be displayed on the command console (Lind, page I21-7
`
`and Fig. 9). Lind also discloses that the vehicle can “talk back using synthesized
`
`speech” (Lind, page I21-3) and that route directions can be provided “on the head-
`
`up display … or as spoken instructions” (Lind, page I21-7).
`
`15. Drury and Lind disclose a “[c]omputer readable apparatus of a computerized
`
`information system” as claimed in claim 18 of the ’146 patent. For example, as
`
`described above in paragraph 7, Drury discloses that the system may be a
`
`“computer that is coupled to the handset module and to the communication module
`
`is programmed to perform … functions,” and that a “processor 212 is also coupled
`
`to a static storage 222 which is a non-volatile storage used to store code and data
`
`for operation of the system.” Drury, col. 2, lines 10 to 13 and col. 10, lines 23 to
`
`25. Lind describes that “[t]he Network Vehicle is created by integrating existing
`
`hardware and software
`
`technologies
`
`including voice recognition, wireless
`
`communication, global positioning via satellite, head-up displays, JavaTM
`
`11
`
`11
`
`
`
`technology, microprocessors, Web access, and other Internet/intranet features.”
`
`Lind, pages I21-1 to I21-2.
`
`16. Drury and Lind disclose “the apparatus comprising a storage apparatus, the
`
`storage apparatus having computerized means” as claimed in claim 18 of the ’146
`
`patent. For example, as described above in paragraph 8, Drury discloses that
`
`“processor 212 is … coupled to a static storage 222 which is a non-volatile storage
`
`used to store code and data for operation of the system.” Drury, col. 10, lines 23 to
`
`25. Lind describes that “[t]he Network Vehicle is created by integrating existing
`
`hardware and software
`
`technologies
`
`including voice recognition, wireless
`
`communication, global positioning via satellite, head-up displays, JavaTM
`
`technology, microprocessors, Web access, and other Internet/intranet features.”
`
`Lind, pages I21-1 to I21-2. Since the Network Vehicle integrates hardware and
`
`software, it is implicit that a storage apparatus is included in the Network Vehicle
`
`to, for example, store software for execution by the microprocessor.
`
`17. Drury and Lind disclose a storage apparatus having computerized means
`
`configured to “receive, via a speech recognition means of the computerized
`
`information system, an input from the user, the input relating to a user’s request to
`
`obtain directions to a business or entity from the computerized information
`
`system” as claimed in claim 18 of the ’146 patent. For example, as described in
`
`paragraph 11, Drury discloses that “the computer that is coupled to the handset
`
`12
`
`12
`
`
`
`module and to the communication module is programmed to perform the functions
`
`of … accepting driver information command … for example … speaking a
`
`command that is interpreted by a speech recognition system,” and that the
`
`“onboard computer 2310 processes the spoken commands, or alternatively, passes
`
`the speech signal to a remote server that performs all or some of the speech
`
`recognition function.” Drury, col. 2, lines 10 to 13 and lines 19 to 22, col. 43, lines
`
`28 to 34. Drury describes that the vehicle information system includes a navigation
`
`service “provided through a combination of functions that are performed by server
`
`system 125 and by an in-vehicle system 105” and that the navigation service
`
`“enable[s] an operator of a vehicle to specify a desired destination, and then to be
`
`guided by the system to that destination while driving the vehicle.” Drury, col. 5,
`
`lines 1 to 6. Lind describes that “[t]he Network Vehicle is created by integrating
`
`existing hardware and software technologies including voice recognition, … Web
`
`access, and other Internet/intranet features.” Lind, pages I21-1 to I21-2. According
`
`to Lind, the Network Vehicle’s “voice recognition technology allows drivers and
`
`passengers to verbally request and listen to e-mail messages, locate a restaurant or
`
`hotel, ask for navigation help or for specific music or sports scores, and use voice-
`
`activated telephone services.” Lind, page I21-2. Lind discloses that 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, check
`
`13
`
`13
`
`
`
`e-mail and voicemail, request news, sports, and stock information.” Lind, page
`
`I21-3.
`
`18. Drury and Lind disclose a storage apparatus having computerized means
`
`configured to “cause utilization of a wireless interface and a means for networking
`
`in order to access information disposed on a remote server or database, the
`
`information relating to the directions to the business or entity, the business or
`
`entity disposed at least partly within a building” as claimed in claim 18 of the ’146
`
`patent. For example, as described in paragraph 12, Drury discloses that its
`
`computer is programmed to perform the function of, e.g., “retrieving information
`
`through the wireless communication interface from the server in response to the
`
`driver information commands.” Drury, col. 2, lines 10 to 13 and lines 22 to 24.
`
`Drury also discloses that “in-vehicle systems 105 are coupled to server system 125
`
`by wireless communication links” and that the in-vehicle system establishes the
`
`communication session by making a cellular telephone call to the server system
`
`and then establishing a data communication session with the server system using
`
`its modem.” Drury, col. 5, lines 25 to 26 and col. 18, lines 52 to 57. Drury
`
`describes that the vehicle information system includes a navigation service
`
`“provided through a combination of functions that are performed by server system
`
`125 and by an in-vehicle system 105” and that the navigation service “enable[s] an
`
`operator of a vehicle to specify a desired destination, and then to be guided by the
`
`14
`
`14
`
`
`
`system to that destination while driving the vehicle.” Drury, col. 5, lines 1 to 6.
`
`According to Drury, the “[s]erver system 125 provides various services to in-
`
`vehicle system 105, in a ‘client-server’ arrangement in which in-vehicle systems
`
`105 request services from server system 125” and that “a route planning function is
`
`performed by server system 125 at the request of in-vehicle system 105 while route
`
`guidance functions are performed by in-vehicle system 105.” Drury, col. 5, lines
`
`18 to 24. Drury discloses that the “[i]n-vehicle systems 105 are coupled to server
`
`system 125 by wireless communication links.” Drury, col. 5, lines 25 to 26. And,
`
`Drury discloses that the “[s]erver computer is coupled to external information
`
`systems 130,” which can be “coupled to server system 125 over a data network
`
`330, such as the Internet.” Drury, col. 12, lines 39 to 42. The remote server system
`
`125 includes a yellow pages database 522 that can be “use[d] to convert the
`
`telephone number of a desired destination to a street address in a ‘reverse’
`
`telephone number lookup.” Drury, col. 18, lines 4 to 7. The remote server system
`
`125 “also provides other map-related information such as the locations of typical
`
`points of interest such as city centers, restaurants, and gas stations.” Drury, col. 5,
`
`lines 59 to 63. City centers, restaurants, and gas stations, for example, are
`
`businesses and entities disposed at least partly within a building. Lind discloses
`
`that “[t]he Network Vehicle is created by integrating existing hardware and
`
`software technologies including voice recognition, wireless communications …,
`
`15
`
`15
`
`
`
`Web access, and other Internet/intranet features.” Lind, pages I21-1 to I21-2.
`
`According to Lind, “[t]he Network Vehicle also has … Netscape Communicator
`
`software for Web browsing and e-mail,” Lind, page I21-3, and that 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, check
`
`e-mail and voicemail, request news, sports, and stock information,” Lind, page
`
`I21-3.
`
`19. Drury and Lind disclose a storage apparatus having computerized means
`
`configured to “receive the accessed information received via the wireless interface”
`
`as claimed in claim 18 of the ’146 patent. As described, for example, in paragraph
`
`13, Drury discloses that its computer is programmed to perform the function of,
`
`e.g., “retrieving information through the wireless communication interface from
`
`the server in response to the driver information commands” Drury, col. 2, lines 10
`
`to 13 and lines 22 to 24. For example, “the in-vehicle system receives the planned
`
`route, spot map, and GPS correction data from the server system.” Drury, col. 19,
`
`lines 55 to 58. Lind discloses that “[t]he Network Vehicle is created by integrating
`
`existing hardware and software technologies including voice recognition, wireless
`
`communications …, Web access, and other Internet/intranet features.” Lind, pages
`
`I21-1 to I21-2. The Network Vehicle includes a wireless modem that “provides the
`
`uplink out of the vehicle directly to Internet service providers,” and “[t]he
`
`16
`
`16
`
`
`
`downlink return path from the Internet to the Network Vehicle can come through
`
`either the satellite …, or through the wireless modem.” Lind, page I21-2.
`
`According to Lind, “[t]he Network Vehicle also has … Netscape Communicator
`
`software for Web browsing and e-mail,” Lind, page I21-3, and that 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, check
`
`e-mail and voicemail, request news, sports, and stock information,” Lind, page
`
`I21-3.
`
`20. Drury and Lind disclose a storage apparatus having computerized means
`
`configured to “provide the user with at least a portion of the accessed information
`
`relating to the directions to the business or entity via at least one of: (i) a touch
`
`screen input and display device of the computerized information system; and/or (ii)
`
`a means for speech synthesis” as claimed in claim 18 of the ’146 patent. For
`
`example, Drury discloses that route guidance information is provided on “a
`
`displayed map on which the planned route and vehicle’s location are dynamically
`
`displayed.” Drury, col. 1, lines 47 to 49. According to Drury, a navigation system
`
`includes “an output device, such as the display on a telephone handset, for
`
`presenting the planned route information.” Drury, col. 3, lines 25 to 32. Drury
`
`further discloses that a planned route and a spot map are downloaded to the vehicle
`
`and that “[t]he in-vehicle system begins providing initial guidance commands and
`
`17
`
`17
`
`
`
`displaying the spot map around the starting location to the operator as soon as it is
`
`downloaded without necessarily waiting for the complete route to be downloaded.”
`
`Drury, col. 8, lines 42 to 52. Additionally, according to Drury, “a voice output
`
`device 246 provides audio output of speech commands that are stored or formed on
`
`onboard computer, for example, using compressed or concatenated waveforms or a
`
`speech synthesizer.” Drury, col. 11, lines 18 to 21. Lind discloses that the “[t]he
`
`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
`
`(Lind, page I21-3) and that maps can be displayed on the command console (Lind,
`
`page I21-7 and Fig. 9). Lind also discloses that the vehicle can “talk back using
`
`synthesized speech” (Lind, page I21-3) and that route directions can be provided
`
`“on the head-up display … or as spoken instructions” (Lind, page I21-7).
`
`21. Drury and Lind disclose that the computerized information system is
`
`“fixedly mounted within a transport apparatus, the transport apparatus capable of
`
`transport multiple persons including the user from one location to another, the
`
`fixed mounting such that the user can interface with each of the touch screen input
`
`and display device, the speech synthesis means, and the speech recognition means,
`
`while operating the transport apparatus” as claimed in claim 18 of the ’146 patent.
`
`For example, Drury describes “an information system for motor vehicles” that
`
`includes an “[o]nboard computer” that “provides the navigation and control of user
`
`18
`
`18
`
`
`
`interface functionality.” Drury, col. 42, lines 2 to 4. According to Drury, the
`
`onboard computer “is used to coordinate the operation of other components,
`
`including … input/output (I/O) devices 240, which provide an interface between
`
`the operator of the vehicle and the navigation system, and communication system
`
`250, which provides communication links from GPS satellites 140 and to and from
`
`server system 125.” Col. 9, line 65 to col. 10, line 6. Input/output (I/O) devices 240
`
`include, for example, a display 242, which “is used at times to provide visual
`
`feedback to the operator when inputting information,” Drury, col. 10, line 51 and
`
`col. 11, lines 12 to 13, and a voice output device 246, which “provides audio
`
`output of speech commands,” Drury, col. 11, lines 17 to 21. Lind describes that
`
`“[t]he Network Vehicle is created by integrating hardware and software
`
`technologies including voice recognition, … head-up displays, Web access, and
`
`other Internet/intranet features.” Lind, pages I21-1 to I21-2. According to Lind, the
`
`Network Vehicle’s “voice recognition technology allows drivers and passengers to
`
`verbally request and listen to e-mail messages, locate a restaurant or hotel, ask for
`
`navigation help or for specific music, and use voice-activated telephone services,
`
`all done safely without interfering with driving.” Lind, page I21-2. The Network
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`Vehicle’s “advanced speech recognition and text-to-speech system, ViaVoiceTM,
`
`… allows the driver to access virtually all the vehicle’s features through voice
`
`commands and enables the vehicle to talk back using synthesized speech.” Lind,
`
`19
`
`19
`
`
`
`page I21-3. According to Lind, “[t]he Network Vehicle is equipped with three
`
`displays for the driver: the head-down display (HDD), the head-up display (HUD),
`
`and the center console display,” the “center console’s touch-screen LCD serv[ing]
`
`as a user interface for controlling nearly all of the Network Vehicle’s multimedia
`
`functions,” including navigation functions. Lind, page I21-3. Lind describes that
`
`“[v]oice-activated commands can be used with all of the center console functions
`
`and, in some cases, is combined with text-to-speech input to minimize driver
`
`distractions.” Lind, page I21-3.
`
`22. Drury and Lind disclose that the computerized information system is
`
`“configured to support an ad hoc communication link with a portable electronic
`
`device of the user, the ad hoc link being used to transfer data between the
`
`computerized information system and the portable electronic device, the data
`
`relating at least in part to the user's request to obtain directions” as claimed in
`
`claim 18 of the ’146 patent. As discussed above, the ’146 patent describes that a
`
`user can plug a personal electronic device (PED) into the system to obtain a
`
`download of information. ’146 patent, col. 12, lines 19 to 46. Examples of these
`
`personal electronic devices (PEDs), according to the ’146 patent, include various
`
`PDAs and laptops, ’146 patent, col. 12, lines 25 to 28 (“As used herein, the term
`
`‘PED’ [personal electronic device] includes, but is not limited to, personal digital
`
`assistants (PDAs) such as the Apple Newton®, US Robotics/3COM PalmPilot®,
`
`20
`
`20
`
`
`
`or Palm III®, laptop computer, notebook computer, or the like.”), and the PED can
`
`be connected to the system using, e.g., an RS-232 serial connection. ’146 patent,
`
`col. 12, lines 28 to 32. Drury describes that “an onboard computer 2310” that
`
`“couples cellular phone module 2320 and handset module 2360,” Drury, col. 41,
`
`lines 56 to 58, and that the onboard computer 2310 and handset module 2360 can
`
`be connected “through in-vehicle radio frequency communication,” Drury, col. 43,
`
`lines 44 to 46. The handset module includes a display 2362, and the “[o]nboard
`
`computer 2310 provides navigation instructions to the driver on” display 2362
`
`“using an extended set of displayable symbols (i.e., glyphs, pictograms) that
`
`include arrows indicating different degrees of turns, such as 45, 90, and 135 turns
`
`in each direction, and 0 degree and 180 degree (U-turn) turn.” Drury, col. 42, lines
`
`53 to 61. According to Lind, a portable computerized device or “removable
`
`personal digital assistant (PDA),” (Lind, page I21-2), such as an IBM WorkPad
`
`(which is a Palm device, like the PalmPilot and Palm III devices described in the
`
`’146 patent as examples of a PED), can be placed in a slot built into the center
`
`console. Lind, page I21-5. Additionally, the diagram of the on-board network in
`
`Lind shows the “PDA Dock” for the WorkPad PDA being connected to the
`
`network computer via an RS-232 connection (which is identical to the type of
`
`connection described in the ’146 patent between the personal electronic device
`
`(PED) 704 and the system 100). Lind, page I21-2, Figure 2. Lind discloses that
`
`21
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