Petitioner Volkswagen Group of America, Inc.
`
`Oral Hearing
`Inter Partes Review of
`U.S. Patent No. 8,781,839
`IPR2016-00177
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`
`February 7, 2017
`
`VWGoA ‐ Ex. 1017
`Volkswagen Group of America, Inc., Petitioner
`West View Research, LLC. ‐ Patent Owner
`IPR2016‐00177
`1
`
`

`

`U.S. Patent No. 8,781,839
`
`Title: Computerized Information
`and Display Apparatus
`
`Filed: January 21, 2013
`
`Issued: July 15, 2014
`
`Named Inventor:
`Robert Gazdzinski
`
`2
`
`

`

`U.S. Patent No. 8,781,839
`The ’839 patent describes an interactive
`display in an elevator that is responsive to
`verbal commands. Ex. 1001, 7:5-27.
`
`Signals captured by microphone 118 as
`part of speech recognition module 104 are
`digitized by analog to digital converter
`141 and processed using a speech
`recognition algorithm to produce digital
`representations of the user’s speech. Ex.
`1001 at 7:59-63.
`
`The digital representations are compared
`to a speech library to identify known
`words and the desired functionality is
`implemented. Id. at 7:63-8:2; Ex. 1002 at
`¶ 3.
`
`3
`
`

`

`U.S. Patent No. 8,781,839
`
`A touch screen display 113, as shown
`in Fig. 2, generates messages or
`display formats based on the user’s
`input and query. See Ex. 1001 at
`8:45-47.
`
`The user can speak the specific name
`of the party they wish to find, the
`speech recognition module 104
`converts the detected speech to a
`digital format, and the digitized
`speech is compared to the contents of
`a directory file to find any matches.
`Ex. 1001 at 10:9-19.
`
`4
`
`

`

`Claim 1
`
`1. Computerized apparatus useful for locating an organi-
`zation or entity, the organizration or entity being disposed
`within a building or structure. the apparatus comprising:
`a wireless interface;
`
`data processing apparatus;
`a touch-screen input and display device:
`a speech digitization apparatus in data coruniunication
`with the data processing apparatus; and
`a storage apparatus in data conuuunication with the data
`processing apparatus. said storage apparatus cornpri sing
`at least one computer program, said at least one program
`being configured to:
`receive a digitired speech input via the speech digitiza-
`tion apparatus. the input relating to an organization or
`entity which a user wishes to locate;
`based at least in part on the input, causing recognition of
`at least one word therein relating to the organization
`or entity, and identification ofa location associated
`with the organization or entity based at least in part on
`the at least one recognized word. the location being
`inside ofthe building or stmcture; and
`provide a graphical or visual representation of the loca-
`tion on the touch screen input and display device in
`’839 Patent (Ex. 1001)
`order to aid a user in finding the organi zatien or entity,
`the graphical or visual representation ol‘ the location
`also comprising a graphical or visual representation
`ofat least the immediate surroundings of the organi-
`zation or entity,
`the immediate surroundings being
`inside the huildin or stn1cture_
`
`5
`
`

`

`Claims 10, 11, and 16
`
`Claims 10, 11, and 16
`
`ll]. The apparatus cfclaiin 1, wherein the ccniputerized
`apparatus is nicinited cn cr prcidinate tc a surface cf a land-
`inchile tralisprrrt apparatus such that an uperatcr cf the ti'aI1s-
`pert apparatus can view and access a tcuch screen ofthe much
`screen input and display device, and make input tn the speech
`digitization apparatus, while cperating the transpcrt appara-
`tus_
`
`nu ieauuu e
`eapparatus u c ann ,w erenit
`.
`the leeaticn eaniprises accessing a rernete server via a net-
`werk in data ccinrnuuieatien with the ecnipnterized appara-
`tus via the wireless interface.
`
`16. The apparatus cf claim 1, wherein the computerized
`apparatus is further cenfigured te display advertising centent
`’839 Patent (Ex. 1001)
`selected by ene er inure reniete servers accessed via a net-
`wcrk in data ccnununicaticn with the ccnipntcrizcd appara-
`lus via the wireless interlace.
`
`6
`
`

`

`Claims 22, 23, and 29
`
`Claims 22, 23, and 29
`
`21. The apparatus et' elairn 1, wherein the at least ene
`euntputer prugratn is Further eunflgured tn generate en the
`teueh-screen input and display deviee a pl tu'ality ef seft flute-
`tiun keys er ieens, at least ene ef the sell Funetien keys er
`ieens has-'i11g a funetien asse-eiated tltere-with relating te
`ehtaining direetiens. and at least ene efthe sell futtetien keys
`er ieens ha 'ing a funetien asseeiated therewith relating te
`peints at" interest.
`
`23. The apparatus ef elaint 21. wherein the at least ene ef
`the seft funetien keys er ieens having a funetien asseeiated
`therewith relating te direetiens eentprises a funetien fer
`nhtaining dire-etinns frern a eurrent Ineatinn nf the user.
`
`29. The apparatus ef elaint 1. further eentprising videe data
`’839 Patent (Ex. 1001)
`apparatus in data eenuntutieatien with the preeessing appa-
`ratus and eenligured In enable videe data le he generalecl and
`dis la ed en the dis la deyiee.
`
`7
`
`

`

`Claim 35
`
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`
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`
`Claim 35
`
`35. Computerized apparatus comprising:
`a wireless interface;
`data processing apparatus;
`a touch-screen input and display device;
`a speech recognition apparatus in data communication
`with the data processing apparatus; and
`a storage apparatus in data communication with the data
`processing apparatus, said storage apparatus comprising
`at least one computerprogram, said at least one program
`being configured to:
`receive a digitized speech input via the speech recogni-
`tion apparatus, the input relating to an organization or
`entity disposed withinabuilding or stzructurewhicha
`user wishes to locate;
`based at least in part on the input, cause identification of
`a location inside of the building or structure associ-
`ated with the organization or entity; and
`provide a graphical or visual representation of the loca-
`tion on the touch screen input and display device in
`orderto aid auserinfindingtheorganization ore-ntity,
`the graphical or visual representation of the location
`comprising amap graphic showing the location of the
`organization or entity relative to other organizations
`or entities proximate thereto inside ofthe building or
`structure;
`
`wherein the digitized speech is generated based at least in
`part on user speech received via a microphone in com-
`munimtion with the speech recognition apparatus, the
`microphone being mounted within the computerized
`apparatus proximate the touch-screen input and display
`device so that the user can speak into the microphone
`while viewing the touch—screen input and display
`device; and
`wherein the computerized apparatus:
`is iurther configured to provide a user a graphical rep-
`resentalion ofdirections from their current location to
`
`the organization or entity, the graphical representation
`of directions comprising the map graphic displayed
`on the touch-screen input and display device havi rig at
`
`’839 Patent (Ex. 1001)
`
`8
`
`

`

`Claims at Issue
`
`Grounds of Unpatentability:
`• Claims 1, 10, 11, 16, 22, 23, and 35 are obvious in view of
`Ito, Ezaki, and Hollenberg.
`• Claim 29 is obvious in view of Ito, Ezaki, Hollenberg, and
`Hsieh.
`
`9
`
`

`

`The Challenged Claims are Unpatentable
`
`The claims describe apparatuses for:
`• Recognizing a user’s speech input relating to an
`organization or entity that a users wishes to locate,
`• Identifying a location of the organization or entity,
`• Display the location
`
`These claimed devices were well known in the prior art,
`including the systems described by Ito, Ezaki, and
`Hollenberg.
`
`10
`
`

`

`The Prior Art
`
`• U.S. Patent No. 6,249,740 to Ito – Ex. 1003
`
`• U.S. Patent No. 6,201,544 to Ezaki – Ex. 1004
`
`• U.S. Patent No. 6,091,956 to Hollenberg – Ex. 1005
`
`• U.S. Patent No. 5,574,443 to Hsieh – Ex. 1006
`
`11
`
`

`

`Ito Describes a Voice-Controlled Navigation System
`
`Ito discloses a navigation system that includes a
`vehicle navigation apparatus 100 that is mounted in a
`vehicle as a movable body. Ex. 1003, 8:11-16. Ito
`also discloses a “base apparatus” 150 that wirelessly
`connects to the navigation apparatus, as shown in
`Fig. 1. See id. at 10:51-57.
`
`The system further includes a data input device to
`“[use] voice recognition” to allow the user to “use
`his/her voice to input corresponding data and
`commands” to control the navigation system. Id. at
`10:39-47.
`
`The display device is also equipped with a touch
`panel. Id. at 10:48-50. Using the display device, Ito
`displays detailed maps of the departure point, course
`change points along a recommended route, and the
`destination, including information such as the
`presence or absence of parking and other facilities in
`the area around the destination. See id. at 14:33-36,
`18:62-67.
`
`12
`
`

`

`Ezaki Describes a Detailed Navigation System
`Displaying Floors of Buildings
`
`Ezaki describes a navigation apparatus
`that includes a processor 18 “for
`controlling the navigation apparatus as
`a whole,” a display controller 21 “for
`generating a map image,” and a
`display device 27 “for displaying an
`image output.” Ex. 1004, 5:10-25,
`Fig. 2.
`
`Using detailed map information,
`Ezaki describes displaying the shapes
`of buildings and roads and, in
`particular, “visually displaying the
`floor number of the floor on which a
`building user serving as the target
`[destination] is located.” Id. at 3:39-
`40, 4:36-45.
`
`13
`
`

`

`Hollenberg Describes a Mobile Computer System for
`Direction Within a Building
`
`Hollenberg describes a system for communication of
`information consisting of at least one mobile computer
`18, and at least one service provider (including
`computer network 30a, transceivers 32, GPS receiver
`34a, control system 36a, data 38a, and memory 39a).
`Ex. 1005, 5:13-14, 11:43-12:12.
`
`The system has two modes of operation: location
`finding, and a mode in which “situation information
`services” are provided. Ex. 1005, 12:43-13:7, 13:8-17.
`
`The mobile computer can be mounted in a vehicle, for
`example, for use by visitors to a city to view traffic
`information and area attractions near their hotel. Id. at
`6:31-54. Then, removing the mobile computer from
`the vehicle, “the visitors could carry their situation
`information device with them as they explore the city
`on foot and use it to learn about the city as they
`approach historical sites and attractions.” Ex. 1005,
`6:50-54.
`
`14
`
`

`

`Hollenberg Describes a Mobile Computer System for
`Direction Within a Building
`
`The mobile computer can be used “for
`location finding in topographically
`complex areas … surrounded by
`buildings, e.g., in urban ‘canyons’ and
`those enclosed within a buildings, such as
`shopping malls” or department stores. Ex.
`1005, 5:13-28, 7:36-40.
`
`As shown in Figs. 2 and 4, the display of
`the mobile computer can show the current
`location of the mobile computer and
`direction of travel (6a, 6f), a floor plan or
`map of the area surrounding the current
`location, and items of interest proximate to
`the mobile computer (6d, 3e, 3f). See Ex.
`1005, 13:22-46, 14:58-15:25.
`
`15
`
`

`

`Hsieh Describes Monitoring Vehicle with Cameras
`
`Hsieh describes a “vehicle
`monitoring apparatus [that]
`includes a rear video camera” as
`well as “a television placed in the
`vehicle.” Ex. 1006, Abstract.
`
`In reference to Fig. 2, the
`apparatus further includes a
`“system control circuit” which
`actuates a “rear video camera
`CCD1,” which is “mounted on a
`wind deflector 12 on a rear portion
`of the car.” See id. at 2:18-20;
`2:60-62.
`
`16
`
`

`

`The Petition Properly and Sufficiently
`Construed the Challenged Claims
`
`The specification of the ’839 patent does not present
`any special definition for any claim term, and the
`prosecution history of the ’839 patent does not include
`any claim construction arguments.
`
`All of the terms of the challenged claims should
`therefore be given their broadest reasonable
`construction in view of the specification. See 37 C.F.R.
`§ 42.100(b).
`
`17
`
`

`

`The Petition was Not Required to Analyze Claims 1
`and 35 Under 35 U.S.C. § 112, ¶ 6
`
`West View argues that claims 1 and 35 have “textbook recitations of purely
`functional language with no recited structure,” and that the Petition cannot make out
`a prima facie showing of obviousness without performing § 112, ¶ 6 analysis.
`Response, at 32-38.
`
`VWGoA is not required to perform this § 112, ¶ 6 analysis of claims 1 and 35:
`– The Petition provided a claim construction analysis, stating that claims 1 and 35
`should be given their broadest reasonable construction in view of the specification.
`Petition, at 5.
`– Claims 1 and 35 include a storage apparatus and at least one computer program. The
`Federal Circuit has noted that “structure” in the context of computer software claims
`does not have to be physical structure. Apple Inc. v. Motorola, Inc., 757 F.3d 1286,
`1298-99 (Fed. Cir. 2014).
`– Claims 1 and 35 do not include the term “means.” See, e.g., Williamson v. Citrix
`Online, LLC, 792 F.3d 1339, 1348–49 (Fed. Cir. 2015) (maintaining the presumption
`that a limitation lacking the word “means” is not subject to § 112, ¶ 6).
`
`18
`
`

`

`The Petition was Not Required to Analyze Claims 1
`and 35 Under 35 U.S.C. § 112, ¶ 6
`
`West View does not argue that this analysis would have any bearing
`on the obviousness of any challenged claim:
`– West View does not argue that the prior art fails to describe
`any of claim limitations in question.
`– West View does not perform a § 112, ¶ 6 analysis of the
`claims to show that the prior art does not describe any of the
`claim limitations.
`
`19
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe a
`Computerized Location Apparatus
`
`Ezaki (Ex. 1004), 2:62-65
`
`Hollenberg (Ex. 1005), 5:13-28
`
`20
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe a
`Wireless Interface
`
`Ito (Ex. 1003), 10:51-57
`
`Hollenberg (Ex. 1005), 5:14-25
`
`21
`
`

`

`The Networked Systems of the Prior Art Describe
`the Claimed “Wireless Interface”
`
`West view does not dispute that “wireless interface” should be given its
`broadest reasonable construction, in view of the specification; and West View
`does not propose any construction.
`
`West View only argues that the claimed “wireless interface” includes
`“terrestrial high-data bandwidth interface specifically chosen to support, inter
`alia, the explicit temporal requirements of the information system of the
`invention (i.e., having to converge on an entity location or other desired
`information within ‘only seconds’).” Response, at 40-44.
`
`But the claims to not describe a terrestrial high-data bandwidth interface
`specifically chosen to support temporal requirements. And West View does not
`argue (and does not attempt to show) that the specification includes any special
`definition or disclaimer to narrow the term’s construction.
`
`22
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe a Data
`Processing Apparatus
`
`Ito (Ex. 1003), 9:53-60
`
`Ezaki (Ex. 1004), 5:10-11
`
`Hollenberg (Ex. 1005), 6:23-24
`
`23
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe a
`Touch Screen Input and Display
`
`Ito (Ex. 1003), 10:39-50
`
`Hollenberg (Ex. 1005), 12:17-28
`
`24
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe Speech
`Digitization
`
`Ito (Ex. 1003), 10:39-47
`
`Ito (Ex. 1003), Fig. 1
`
`25
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe
`Computer Programming
`
`Ito (Ex. 1003), 9:54-64
`
`Ezaki (Ex. 1004), 5:11-14
`
`Hollenberg (Ex. 1005), 5:17-20
`
`26
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe
`Receiving Digitized Speech
`
`Ito (Ex. 1003), 9:34-37
`
`Ito (Ex. 1003), 10:39-47
`
`Ito (Ex. 1003), 15:51-54
`
`27
`
`

`

`The Voice Recognition System of Ito Describes the
`Claimed “Digitized Speech Input”
`
`West View admits that, for speech to be recognized, it must be
`digitized:
`“All speech recognition systems inherently digitize the speaker’s
`analog voice.”
`
`Ex. 1010, p. 729
`
`West View only argues that the prior art does not specify where, or
`by what components, the speech is digitized. Response, at 23–27. No
`such limitations are claimed.
`
`28
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe
`Recognizing Speech
`
`Ito (Ex. 1003), 10:45-47
`
`Ito (Ex. 1003), 15:51-53
`
`29
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe
`Identifying Location of an Entity in a Building
`
`Ito (Ex. 1003), 11:13-27
`
`Hollenberg (Ex. 1005), 5:13-28
`
`30
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe
`Identifying Location of an Entity in a Building
`
`Ezaki (Ex. 1004), 1:59-61
`
`Ezaki (Ex. 1004), 2:5-9
`
`Ezaki (Ex. 1004), 2:62-65
`
`31
`
`

`

`The Navigation Systems of the Prior Art Describe
`“Identification of a Location”
`
`West View does not dispute that “identification of a location” should be
`given its broadest reasonable construction in view of the specification.
`
`West View argues that the term “identification of a location” must be
`narrowed to include determining whether the “location” is an (i) address,
`(ii) geographic or other coordinate, or (iii) otherwise, must be determined to
`understand, e.g., “how/what apparatus in the patent fulfills the
`‘identification of a location’” to compare the prior art and the ’839 patent.
`Patent Owner Response at 29 (emphasis in original).
`
`West View’s argument relate to unclaimed subject matter. Claims 1, 11, and
`35 do not recite exactly how, or by what component, identification of a
`location is performed.
`
`32
`
`

`

`The Navigation Systems of the Prior Art Describe
`“Identification of a Location … Inside of the
`Building or Structure”
`West View does not dispute that “identification of a location associated with
`the organization or entity … the location being inside of the building or
`structure” should be given its broadest reasonable construction, in view of
`the specification; and West View does not propose any construction.
`
`West View only argues that the ’839 patent distinguished a building’s floor.
`Patent Owner Response, 40 (citing Ex. 1001, 2:66-3:5). But the ’839 patent
`describes floor numbers as “location information,” and only contrasts floor
`numbers with “precise location information”:
`
`33
`
`

`

`The Navigation Systems of the Prior Art Describe
`“Identification of a Location … Inside of the
`Building or Structure”
`
`Claims 1 and 35, however, do not describe “precise location
`information,” and neither the specification nor the prosecution
`history of the ’839 patent presents any special definition of this term.
`
`Ezaki describes a detailed map including a visual display of “the
`floor number of a floor, in a building, on which a target institution is
`located, to reliably guide a user to the target institution.” Ezaki (Ex.
`1004), 2:62-65. Ezaki’s description of a floor number of a floor in a
`building describes “identification of a location associated with the
`organization or entity … the location being inside of the building or
`structure,” under its broadest reasonable interpretation.
`
`34
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe
`Navigational Display of Location
`
`Ito (Ex. 1003), 18:62-67
`
`Ezaki (Ex. 1004), 2:63-64
`
`Ezaki (Ex. 1004), 5:15-22
`
`Hollenberg (Ex. 1005), 8:36-43
`
`35
`
`

`

`The Navigation and Display Systems of the Prior Art
`Describe “Graphical or Visual Representation”
`
`West View does not dispute that “graphical or visual representation”
`should be given its broadest reasonable construction, in view of the
`specification; and West View does not propose any construction.
`
`The map, L-shaped mark, floor number, floor plan, floor plan details,
`guidance information, user name list of tenants, and urban plan
`described by Ito, Ezaki, and Hollenberg constitute disclosure of a
`“graphical or visual representation” under its broadest reasonable
`interpretation.
`
`36
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe
`Representation of Surroundings
`
`Ito (Ex. 1003), Fig. 9(B)
`
`Ezaki (Ex. 1004), Fig. 5
`
`37
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe
`Representation of Surroundings
`
`Hollenberg (Ex. 1005), 5:14-28
`
`Hollenberg (Ex. 1005), 7:37-39
`
`38
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe
`Surroundings within the Building or Structure
`
`Ezaki (Ex. 1004), 2:37-38
`
`Ezaki (Ex. 1004), 3:21-24
`
`39
`
`

`

`Claim 1: Ito, Ezaki, and Hollenberg Describe
`Surroundings within the Building or Structure
`
`Hollenberg (Ex. 1005), 10:53-55
`
`Hollenberg (Ex. 1005), Fig. 2
`
`40
`
`

`

`Claim 10: Ito, Ezaki, and Hollenberg Describe a
`Mounted Apparatus
`
`Ito (Ex. 1003), 8:15-16
`
`Ito (Ex. 1003), 10:39-47
`
`41
`
`

`

`Claim 11: Ito, Ezaki, and Hollenberg Describe
`Wirelessly Accessing a Remote Server
`
`Ito (Ex. 1003), 8:53-62
`
`Hollenberg (Ex. 1005), 5:13-20
`
`42
`
`

`

`Claim 16: Ito, Ezaki, and Hollenberg Describes
`Displaying Selected Advertising
`
`Hollenberg (Ex. 1005), 9:11-14
`
`Hollenberg (Ex. 1005), 16:17-23
`
`Hollenberg (Ex. 1005), 23:49-53
`
`43
`
`

`

`Claim 22: Ito, Ezaki, and Hollenberg Describes
`Generating Soft Function Keys or Icons
`
`Hollenberg (Ex. 1005), 13:47-63
`
`44
`
`

`

`Claim 22: Ito, Ezaki, and Hollenberg Describes
`Generating Soft Function Keys or Icons
`
`Ito (Ex. 1003), Fig. 22
`
`45
`
`

`

`Claim 22: Ito, Ezaki, and Hollenberg Describes
`Generating Soft Function Keys or Icons
`
`Hollenberg (Ex. 1005), Fig. 2
`
`46
`
`

`

`Claim 22: Ito, Ezaki, and Hollenberg Describes
`Generating Soft Function Keys or Icons
`
`Ito (Ex. 1003), 30:66-31:3
`
`Hollenberg (Ex. 1005), 21:55-61
`
`47
`
`

`

`Claim 23: Ito, Ezaki, and Hollenberg Describe Soft
`Function Keys or Icons for Obtaining Directions
`
`Ito (Ex. 1003), Fig. 24
`
`48
`
`

`

`Claim 23: Ito, Ezaki, and Hollenberg Describe Soft
`Function Keys or Icons for Obtaining Directions
`
`Hollenberg (Ex. 1005), Fig. 2
`
`Hollenberg (Ex. 1005), 12:22-30
`
`49
`
`

`

`Claim 35: Ito, Ezaki, and Hollenberg Describe a
`Map Showing Proximate Locations in a Building
`
`Ito (Ex. 1003), Fig. 9(B)
`
`Ezaki (Ex. 1004), 2:37-38
`
`50
`
`

`

`Claim 35: Ito, Ezaki, and Hollenberg Describe a
`Map Showing Proximate Locations in a Building
`
`Hollenberg (Ex. 1005), Fig. 2
`
`Hollenberg (Ex. 1005), 12:22-24
`
`51
`
`

`

`Claim 35: Ito, Ezaki, and Hollenberg Describe Voice
`Recognition and Microphones
`
`Ito (Ex. 1003), 10:39-47
`
`52
`
`

`

`Claim 35: Ito, Ezaki, and Hollenberg Describe a
`Mounted Microphone Near a Touch Screen
`
`Ito (Ex. 1003), 8:13-16
`
`Ito (Ex. 1003), 10:39-47
`
`53
`
`

`

`Claim 35: Ito, Ezaki, and Hollenberg Describe
`Displaying Directions
`
`Ito (Ex. 1003), Fig. 9
`
`54
`
`

`

`Claim 35: Ito, Ezaki, and Hollenberg Describe
`Displaying Directions
`
`Hollenberg (Ex. 1005), Fig. 2
`
`Hollenberg (Ex. 1005), Fig. 11
`
`55
`
`

`

`Claim 35: Ito, Ezaki, and Hollenberg Describe Map
`Graphics Including an Arrow
`
`Ito (Ex. 1003), Fig. 10(A)
`
`Ito (Ex. 1003), Fig. 9
`
`56
`
`

`

`Claim 35: Ito, Ezaki, and Hollenberg Describe Map
`Graphics Including an Arrow
`
`Hollenberg (Ex. 1005), Fig. 2
`
`57
`
`

`

`Claim 35: Ito, Ezaki, and Hollenberg Describe
`Wireless Interfaces, and an IEEE 802.11 Compliant
`Interface Would have been Obvious
`
`Ito (Ex. 1003), 10:51-57
`
`Hollenberg (Ex. 1005), 5:14-25
`
`58
`
`

`

`Claim 35: Ito, Ezaki, and Hollenberg Describe Wireless
`Interfaces, and an IEEE 802.11 Compliant Interface Would
`have been Obvious
`
`Greenwood (Ex. 1009), 3:11-17
`
`59
`
`

`

`Claim 35: Hollenberg Describes “Identification of a
`Location Inside of the Building or Structure Associated
`with the Organization or Entity”
`
`West View asserts that the “identification of a location inside
`of the building or structure associated with the organization or
`entity” is not disclosed by Hollenberg’s transponding
`transceiver for location finding within a shopping mall. See
`Patent Owner Response at 45-46.
`
`West View mischaracterizes the Petition’s argument. As
`described in the Petition (at 7-9), Hollenberg describes a
`transceiver for location finding in a building such as a
`shopping mall (Ex. 1005 at 5:13-28). In other words, the
`system described by Hollenberg assists customers with finding
`their way around the inside of a building or structure such as a
`shopping mall. See Petition at 38 (citing Ex. 1005).
`
`60
`
`

`

`Claims 35: The Prior Art Describes an “Arrow
`Showing the Path for the User to Follow Inside of the
`Building or Structure”
`West View asserts that “[n]one of the references
`relied upon by Petitioner in its obviousness
`analysis teaches a map graphic having an arrow
`showing the path for the user to follow inside of the
`building or structure.” Patent Owner Response at
`51-52 (emphasis in original).
`
`However, as described in the Petition (e.g., at 34-
`35), Ito describes the displayed map of Fig. 9(B),
`which depicts “the area around the departure point
`PD,” and road R1, which is “highlighted by
`markings MA, and in this way the searched route is
`indicated.” Ex. 1003 at 17:10-14.
`
`Further, Hollenberg describes a map which
`includes a “device location and direction symbol
`6a” that represents the current location of the user
`on the map. Ex. 1005 at 12:22-40. As shown in
`Fig. 2, the direction symbol includes an arrow. Ex.
`1002 at ¶ 25.
`
`Ito (Ex. 1003), Fig. 9(B)
`
`Hollenberg (Ex. 1005), Fig. 2
`
`61
`
`

`

`Claims 1, 10, 11, 16, 22, 23, and 35 are Obvious in
`View of Ito, Ezaki, and Hollenberg
`It would have been obvious to use the guidance functions described by
`Ezaki and Hollenberg in the vehicle computer and display system
`described by Ito.
`
`Just as the ’839 patent purports to solve problems related to
`“determining the location of a ... store within a building when
`unfamiliar” (Ex. 1001, 2:59-60), the cited prior art addresses problems
`related to providing route guidance, even inside buildings.
`
`Like the ’839 patent, Ito addresses problems associated with providing
`“satisfactory route guidance” (Ex. 1003, 2:64-66), and Ezaki
`endeavors to “reliably guide a user to the target institution” (Ex. 1004,
`2:64-65).
`
`62
`
`

`

`Other Prior Industry Development Shows the
`Obviousness of the ’839 Patent
`Several years before the earliest filing date referred to on the face of
`the ’839 patent, June 10, 1999, as well as contemporaneously to the
`filing of the ’839 patent, other companies developed, and were
`developing, vehicles with Internet connectivity, speech-recognition
`functionality, and navigation functionality:
`• Volkswagen Infotainment Car
`• Connected CarPC
`• Daimler-Benz Internet Multimedia on Wheels Concept Car
`• Microsoft’s Auto PC
`• Visteon’s ICES system
`
`See Andrews Decl. (Ex. 1002), ¶¶ 27-37.
`
`63
`
`

`

`Claim 29: Ito, Ezaki, Hollenberg, and Hsieh
`Describe Generating and Displaying Video
`
`Hollenberg (Ex. 1005), 29:16
`
`Hsieh (Ex. 1006), Abstract
`
`64
`
`

`

`Claim 29 is Obvious in View of Ito, Ezaki,
`Hollenberg, and Hsieh
`
`It would have been obvious to use the rear-facing video camera described by Hsieh in
`the navigation systems disclosed in Ito, Ezaki, and Hollenberg to, for example,
`“provide a vehicle monitoring apparatus including a rear video camera mounted on a
`rear portion of a vehicle … to transmit a ‘picture’ of the subject positioned at the rear
`side of the vehicle to display a picture on a television placed in the vehicle.” Hsieh
`(Ex. 1006), 1:39-53.
`
`A rear-facing camera would provide the systems of Ito, Ezaki, and Hollenberg a back-
`up camera, and would utilize existing computing technology and display already
`available in the systems of Ito, Ezaki, and Hollenberg, such as video displays.
`
`See Andrews Decl. (Ex. 1002), ¶ 42.
`
`65
`
`

`

`Claim 29 is Obvious in View of Ito, Ezaki,
`Hollenberg, and Hsieh
`
`Indeed, it would have been obvious that the rear-facing video camera in Hsieh could be
`incorporated into the systems in Ito in order to provide, e.g., a backup camera, which
`would utilize the existing computing technology and display already available in those
`systems. Ex. 1002 at ¶ 42.
`
`Providing a known backup camera as disclosed in Hsieh in the computerized
`information and display systems disclosed in Ito, Ezaki, and Hollenberg would have
`required no major modifications to those systems, because they already included
`displays capable of displaying video images generated by CCD cameras, and would
`have provided only expected results. Id.
`
`66
`
`