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DECLARATION OF SCOTT ANDREWS
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`I, Scott Andrews, declare as follows:
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`I hold a B.Sc. degree in Electrical Engineering from University of
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`1.
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`California–Irvine and a M.Sc. degree in Electronic Engineering from Stanford
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`University. In various positions at, among others, TRW and Toyota, I have been
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`responsible for research and development projects relating to, among others,
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`numerous vehicle navigation systems, information systems, and user interface
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`systems. My qualifications are further set forth in my curriculum vitae (Exhibit A).
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`I have been retained by Volkswagen Group of America, Inc. in connection with its
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`petition for inter partes review of U.S. Patent No. 8,781,839 (the “’839 patent”). I
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`have over 35 years of experience in fields relevant to the ’839 patent, including
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`telecommunications systems and navigation systems.
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`2.
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`I have reviewed the ’839 patent, as well as its prosecution history and the
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`prior art cited during its prosecution. I have also reviewed U.S. Patent No.
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`6,249,740 (“Ito”), U.S. Patent No. 6,201,544 (“Ezaki”), U.S. Patent No. 6,091,956
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`(“Hollenberg”), U.S. Patent No. 5,574,443 (“Hsieh”), U.S. Patent No. 6,064,323
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`(“Ishii”), U.S. Patent No. 4,558,300 (“Goldman”), U.S. Patent No. 6,211,777
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`(“Greenwood”), and “Plaintiff and Counter-Defendant West View Research,
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`LLC’s Revised Disclosure of Asserted Claims and Infringement Contentions,
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`1
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`1
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`VWGoA - Ex. 1002
`Volkswagen Group of America, Inc., Petitioner
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`Pursuant to Patent L.R. 3.1 and the June 10, 2015 Court Order” (“Infringement
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`Contentions”), dated June 26, 2015.
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`The ’839 Patent
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`3.
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`The ’839 patent describes an interactive display in an elevator that is
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`responsive to verbal commands. ’839 patent, col. 7, lines 5 to 27. Signals captured
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`by a microphone 118 as part of a speech recognition module 104 are digitized by
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`an analog to digital converter 141 and processed using a speech recognition
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`algorithm to produce digital representations of the user’s speech. ’839 patent, col.
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`7, lines 59 to 63. The digital representations are compared to a speech library to
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`identify known words and the desired functionality is implemented. ’839 patent,
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`col. 7, line 63 to col. 8, line 2. The display device includes a touch screen display
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`113 that “generates a variety of different messages or display formats” based on
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`the user’s input and query. ’839 patent, col. 8, lines 45 to 47. For example, one
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`such message or display format includes a building directory. ’839 patent, col. 9,
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`line 37 to col. 11, line 37. The user can speak the specific name of the party the
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`user wishes to find, the speech recognition module 104 converts the detected
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`speech to a digital format, and the digitized speech is compared to the contents of a
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`directory file to find any matches. ’839 patent, col. 10, lines 9 to 19.
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`The Disclosures of Ito, Ezaki, and
`Hollenberg – Claims 1, 10, 11, 16, 22, 23, and 35
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`4.
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`Ito, Ezaki, and Hollenberg disclose a “[c]omputerized apparatus useful for
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`locating an organization or entity, the organization or entity being disposed within
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`a building or structure” as claimed in claim 1 and a “[c]omputerized apparatus” as
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`claimed in claim 35. For example, Ito discloses an apparatus that includes both a
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`processing section and a display. Ito, col. 9, lines 51 to 67. The display in Ito is a
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`touch panel display, which is located in the vehicle. Id. at col. 10, lines 39 to 45.
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`Ito also discloses a “processing section 101” with “a CPU as its main component”
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`and a “program storage section 102” that “serves as a memory for storing programs
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`which will be executed by a processing section.” Ito, col. 9, lines 51 to 67. Ito
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`discloses that the user operates an input section 105 to “input information about the
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`destination, such as the facility name.” Id. at col. 15, lines 50 to 54. And Ito
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`describes, for example, displaying maps on a display device, including a
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`recommended route to the selected destination on an output display. Ito, col. 10,
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`lines 39 to 50, col. 16, lines 24 to 27. Ezaki discloses a navigation apparatus which
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`displays a detailed map, including the visual display of “the floor number of a
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`floor, in a building, on which a target institution is located.” Ezaki, col. 2, lines 62
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`to 65. The “target institution” Ezaki’s navigation apparatus is an “organization or
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`entity.” Additionally, Ezaki’s navigation apparatus is computerized, as element 18
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`in Figure 2 is a CPU. Hollenberg also discloses a navigation system that includes
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`“at least one mobile computer” that can be used for location finding in areas
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`“enclosed within buildings, such as shopping malls.” Hollenberg, col. 5, lines 13 to
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`28.
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`5.
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`Ito and Hollenberg disclose “a wireless interface” as claimed in claims 1 and
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`35. For example, Ito discloses that the transmitting and receiving section “includes
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`devices such as a modem and the like” for communicating wirelessly with the base
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`station. Ito, col. 10, lines 51 to 57. Ito also discloses that car phones, portable
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`phones, PHS, and the like may be used to connect the navigation apparatus and the
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`base station. Ito, col. 10, lines 51 to 57. The transmitting and receiving section 108
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`interfaces with these wireless systems. Additionally, Hollenberg discloses a
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`wireless system for providing information to “mobile computers” and that these
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`mobile computers have “multiple transmitters and receivers,” including “a
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`transceiver for wireless voice and data telecommunications.” Hollenberg, Abstract,
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`col. 5, lines 13 to 28.
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`6.
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`Ito, Ezaki, and Hollenberg disclose a “data processing apparatus” as claimed
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`in claims 1 and 35. For example, Ito discloses a CPU as the main component of the
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`processing section 101. Ito, col. 9, lines 51 to 67; Fig. 1. Additionally, Ezaki
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`discloses a processor (CPU) for controlling the navigation apparatus. Ezaki, col. 5,
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`lines 10 to 11. Hollenberg discloses a computer including a “computer central
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`processing unit” and a “DSP unit.” Hollenberg, col. 6, lines 22 to 26.
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`7.
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`Ito and Hollenberg disclose “a touch-screen input and display device” as
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`claimed in claims 1 and 35. Ito discloses a display 106 that includes a liquid crystal
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`display or CRT that is equipped with a touch panel as a data input device. Ito, col.
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`10, lines 39 to 50. A user “can use a finger or the like to touch an icon or the like
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`displayed on the screen of the display 106.” Ito, col. 10, lines 39 to 50. Hollenberg
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`discloses “a touch-screen graphical display unit 4a” that displays menus or icons.
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`Hollenberg, col. 12, lines 13 to 40.
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`8.
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`Ito discloses “a speech digitization apparatus in data communication with
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`the data processing apparatus” as claimed in claims 1 and “a speech recognition
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`apparatus in data communication with the data processing apparatus” as claimed in
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`claim 35. Ito discloses that the input section 105 may be “a data input device using
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`voice recognition,” in which the user uses his or her voice to input data and
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`commands. Ito, col. 10, lines 39 to 47. The input 105, as shown in Figure 1, is
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`connected to, and therefore in data communication with, the processing section 101
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`(i.e., the data processing apparatus). West view has acknowledged (and I agree)
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`that “all speech recognition systems inherently digitize the speaker’s analog
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`voice.” Infringement Contentions, p. 729.
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`9.
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`Ito, Ezaki, and Hollenberg also disclose “a storage apparatus in data
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`communication with the data processing apparatus, said storage apparatus
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`comprising at least one computer program” as claimed in claims 1 and 35. Ito
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`discloses a “program storage section 102” which serves as a memory for storing
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`programs executed by the processing section. Ito, col. 9, lines 51 to 67. As shown
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`in Figure 1, the program storage section is connected to in data communication
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`with the processing section. Ezaki discloses a navigation apparatus which includes
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`“a ROM for storing various types of programs” such as for “guide route
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`searching.” Ezaki, col. 5, lines 10 to 22. The ROM 19 is connected to the CPU 18
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`via a bus 28. Ezaki, Fig. 2. Hollenberg discloses the necessary memory (“storage,
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`drives, and RAM units”) and computer programs to “provide for efficient situation
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`information exchange.” Hollenberg, col. 5, lines 13 to 28. These computer
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`programs include a “user’s computer control program” by which the mobile
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`computer “requests information and services and subsequently processes the
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`information communicated from the service provider.” Hollenberg, col. 23, line 64
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`to col. 24, line 3.
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`10.
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`Ito discloses “at least one program being configured to … receive a digitized
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`speech input via the speech digitization apparatus, the input relating to an
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`organization or entity which a user wishes to locate” as claimed in claim 1; Ito
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`discloses “at least one program being configured to … receive a digitized speech
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`input via the speech recognition apparatus,” and Ezaki and Hollenberg disclose
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`“the input relating to an organization or entity disposed within a building or
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`structure which a user wishes to locate,” as claimed in claim 35. Ito discloses that,
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`among the inputs that the user may make to the input 105 (which uses voice
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`recognition), are “information about the destination, such as the facility name,
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`telephone number and address thereof, and a route search request.” Ito, col. 15,
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`lines 47 to 58. This input is related to an organization or entity that a user wishes to
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`locate. Ezaki discloses a system that allows the user to cause a search of a yellow
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`pages directory or institution database and, in response, the apparatus “calculates a
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`user name list (object list) of a building … from the building database stored in the
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`Yellow Page data memory.” Ezaki, col. 6, lines 49 to 58. Therefore, Ezaki
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`discloses that an organization or entity the user wishes to locate can be disposed
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`within a building. Hollenberg discloses a system that includes capabilities for
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`location finding in areas such as “those enclosed within buildings, such as
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`shopping malls.” Hollenberg, col. 5, lines 13 to 28.
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`11.
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`Ito discloses “based at least in part on the input, causing recognition of at
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`least one word therein relating to the organization or entity” as claimed in claim 1.
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`The programs in Ito can receive input of data and commands from “a data input
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`device using voice recognition.” Ito, col. 10, lines 39 to 47. Information about the
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`destination, e.g., a facility name, can be input. The information includes a least one
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`word relating to a facility. Additionally, as described, for example, in Ishii, col. 3,
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`lines 11 to 18, it is obvious that in voice recognition systems, software programs
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`process a representation of speech in order to identify a spoken word or phrase.
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`12.
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`Ito, Ezaki, and Hollenberg disclose “identification of a location associated
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`with the organization or entity based at least in part on the at least one recognized
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`word, the location being inside of the building or structure” as claimed in claim 1.
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`Ito discloses that the user inputs are used to search a database of navigation data,
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`which uses the inputs to extract a position of the destination, or “facility position.”
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`Ito, col. 11, lines 1 to 30, col. 15, lines 50 to 67. Ezaki discloses a navigation
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`apparatus for a vehicle that displays a detailed map that provides directions to a
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`target destination. Ezaki, col. 1, line 58 to col. 2, line 19. The displayed map
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`includes the shapes of buildings and roads, and visually displays “the floor number
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`of a floor, in a building, on which a target institution is located to reliably guide a
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`user to the target institution.” Ezaki, col. 2, lines 62 to 65. Hollenberg also
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`discloses a system that identifies a location inside a building or structure, such as a
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`shopping mall. Hollenberg, col. 5, lines 13 to 28.
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`13.
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`Ito, Ezaki, and Hollenberg disclose at least one computer program
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`configured to “provide a graphical or visual representation of the location on the
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`touch screen input and display device in order to aid a user in finding the
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`organization or entity” as claimed in claims 1 and 35. Ito discloses a display device
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`that displays detailed maps, including a recommended route to the selected
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`destination. Ito, col. 16, lines 24 to 27. An exemplary map showing destination PA
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`is shown in Figure 9(A). Ezaki discloses a display device for displaying a map
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`and/or menu image. Ezaki, col. 5, lines 10 to 23. The displayed map displays the
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`shapes of buildings and roads, and visually displays “the floor number of a floor, in
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`a building, on which a target institution is located to reliably guide a user to the
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`target institution.” Ezaki, col. 2, lines 62 to 65. This map, shown in Figure 1,
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`“displays the floor by an L-shaped mark FL.” Hollenberg discloses a graphical
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`display, on which maps can be displayed. Hollenberg, col. 7, lines 31 to 40. Figure
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`2 of Hollenberg depicts an “exemplary retail store floor plan,” that displays items
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`of interest near the user’s current location. Hollenberg, col. 10, lines 52 to 55; Fig.
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`2.
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`14.
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`Ito, Ezaki, and Hollenberg disclose “the graphical or visual representation of
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`the location also comprising a graphical or visual representation of at least the
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`immediate surroundings of the organization or entity” as claimed in claim 1, and
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`“the graphical or visual representation of the location comprising a map graphic
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`showing the location of the organization or entity relative to other organizations or
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`entities proximate thereto inside of the building or structure” as claimed in claim
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`35. Ito discloses displaying area guidance for the area surrounding the destination
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`point. As shown in Figure 9(A) of Ito, a graphical representation of the immediate
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`surroundings of the destination is displayed. Ito, Fig. 9(A). An exemplary map of
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`the area surrounding the departure point (“PD”) is shown in Figure 9(B). See Ito,
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`col. 17, lines 4 to 19. Although Figure 9(B) illustrates a departure point, Ito
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`discloses that destination points are treated in generally the same manner (id.,
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`14:19-38), describing that when “the vehicle has entered the surrounding area A3
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`of the destination PA … a map thereof is displayed on the display 106” and “an
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`enlarged view of the destination PA may be displayed when the vehicle comes
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`within a prescribed distance to the destination PA.” Ito, col. 18, lines 36 to 52. The
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`maps shown in Figures 40(C) and 44, for example, of Ito include a department
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`store, a fire station, and a bank shown relative to each other. The maps disclosed
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`by Ito include graphical representation of immediate surroundings, and also a
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`graphical representation of a map graphic in which the immediate surroundings of
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`an entity or organization are displayed. Ezaki discloses a display device 27 in a
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`navigation apparatus for displaying a map and/or menu image. Ezaki, col. 5, lines
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`10 to 23. The detailed map information in Ezaki includes neighboring buildings of
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`a “target location” displayed by an indicator shown in Figure 5. Ezaki, col. 5, line
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`66 to col. 6, line 3. Ezaki also displays a “user name list of the building,” or tenant
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`list, which is “a visual representation of the immediate surroundings within the
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`building of the entity” and also a graphical representation of a “map graphic” on
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`which the “immediate surroundings” or an entity or organization are displayed.
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`Hollenberg also discloses, in Figure 2, a graphical display showing “an exemplary
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`retail-store floor plan” and “floor plan details” such as the locations of nearby exit
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`doors or an escalator, both of which are around the user’s location. Hollenberg,
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`Fig. 2, col. 10, lines 52 to 55, col. 13, lines 22 to 46. Figure 4 also discloses an
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`“urban plan” with organizations (3e, 3f) near the user’s current location.
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`Hollenberg, col. 10, lines 60 to 64, col. 14, line 65 to col. 15, line 8.
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`15. Hollenberg and Ezaki disclose “the immediate surroundings being inside the
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`building or structure” as claimed in claim 1. Hollenberg describes a mobile
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`computer for location finding within buildings including by providing users with
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`maps and floor plan details to “help find their way around the store or shopping
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`mall.” Hollenberg, col. 5, lines 13 to 28; col. 7, lines 31 to 40; col. 13, lines 22 to
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`45. Figure 2 depicts a “graphical display showing an exemplary retail-store floor
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`plan” showing “floor plan details” such as the locations of a near exit (3b) or an
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`escalator (3d) around a user’s location (6a). Hollenberg, Fig. 2 and col. 10, lines 52
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`to 55, col. 13, lines 22 to 46. As described above, Ezaki displays “a user name list
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`of the building” on a part of the display screen with the map information; the user
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`name list of the tenants in the building is a visual representation of the immediate
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`surroundings within the building of the entity. Ezaki, col. 2, lines 62 to 65, col. 3,
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`lines 21 to 24.
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`16.
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`Ito and Hollenberg disclose “the computerized apparatus is mounted on or
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`proximate to a surface of a land-mobile transport apparatus such that an operator of
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`the transport apparatus can view and access a touch screen of the touch screen
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`input and display device, and make input to the speech digitization apparatus,
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`11
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`while operating the transport apparatus” as claimed in claim 10. Ito discloses that
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`the vehicle navigation apparatus 100 may be “mounted in a vehicle as a movable
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`body.” Ito, col. 8, lines 11 to 16. Ito describes an input 105 of the navigation
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`apparatus includes a touch panel display 106 such that the user (e.g., the driver of
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`the vehicle) “can use a finger or the like to touch an icon or the like displayed on
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`the screen of the display 106” and a data input device using voice recognition so
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`that the user (e.g., the driver) can use his/her voice to input corresponding data and
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`commands.” Ito, col. 10, lines 39 to 47; col. 14, lines 19 to 38. In order for a driver
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`to be able to view the detailed guidance provided on the display and to input
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`commands via the touch screen or voice recognition, both the voice input device
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`(e.g., a microphone) and touch screen display are accessible to the driver and the
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`navigation apparatus is mounted on or proximate to some surface of the vehicle (“a
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`land-mobile transport apparatus”) accessible to the driver. Hollenberg describes a
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`mobile computer having a graphical display unit for location finding that can be
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`mounted in an automobile. Hollenberg, col. 6, lines 31 to 54. Figs. 7 and 8 of
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`Hollenberg illustrate a bracket that can be used for installing and mounting the
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`mobile computer in a vehicle, “for example, device 2d may be inserted into bracket
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`40 mounted in a vehicle for greater operative mobility and used for networking
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`with vehicular systems.” Hollenberg, col. 19, line 61 to col. 20, line 51. When used
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`in a vehicle, the display can provide local information, for example traffic
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`congestion information. Hollenberg, col. 6, lines 31 to 54. In order for a driver of a
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`vehicle to be able to view the information provided on the graphical display, the
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`mobile computer is mounted on or proximate to some surface of the automobile (“a
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`land-mobile transport apparatus”) accessible to the driver.
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`17.
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`Ito and Hollenberg disclose that “the identification of the location comprises
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`accessing a remote server via a network in data communication with the
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`computerized apparatus via the wireless interface” as claimed in claim 11. Ito
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`discloses that the user inputs are used to search a remote network entity, which is a
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`database of navigation data that is not located in the vehicle, and that the vehicle
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`receives position information related to the destination, or an intersection close to
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`the position of the destination. Ito, Fig. 1, col. 8, lines 28 to 40, col. 8, line 52 to
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`col. 9, line 8. This information is received by the navigation apparatus 100 via the
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`wireless interface. Ito, col. 10, line 64 to col. 11, line 30, col. 15, lines 30 to 37.
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`Hollenberg discloses a mobile computer in communication with an “information
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`service provider,” which responds to user requests, for example, for “proximate
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`situation information.” Hollenberg, col. 5, lines 13 to 28; col. 11, lines 42 to 67;
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`col. 18, line 57 to col. 19, line 14. Figure 1 shows a service provider, which
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`includes network 30a and data 38a, is connected to a communications network 31a,
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`and is also in communication with mobile computers 18a, 18b, and 18c via
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`transceivers 14a, 14b, and 14c; the service provider transmits “proximate
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`information” and “requested information” from data 38, network 30a and
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`communications network 31a to the mobile computers. Hollenberg, col. 13, lines 9
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`to 21. A remote server is accessed in order to receive information at the mobile
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`computer.
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`18. Hollenberg discloses that “the computerized apparatus is further configured
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`to display advertising content selected by one or more remote servers accessed via
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`a network in data communication with the computerized apparatus via the wireless
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`interface” as claimed in claim 16. Hollenberg discloses the display of advertising
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`content, in that its mobile computer can display “merchant’s advertising messages”
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`or “special offers to customers.” Hollenberg, col. 9, lines 11 to 14; col. 9, lines 23
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`to 25. For example, referring to Figure 2, Hollenberg describes that “[a]s the user’s
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`location … approaches within a selectable distance of proximate information
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`station 3a, proximate station banner 6d [‘Fragrances 1 hr. Special’] appears on
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`display 4a, followed by proximate merchandise banner 6e [‘Petite armure on sale
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`33.00’] to call user’s attention to, for example, a short-term offer of merchandise.”
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`Hollenberg, col. 13, lines 22 to 45. Referring to Figure 4, Hollenberg further
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`describes that as the user “approaches within a selectable distance of … retail store
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`site 3e … an advertising message … would appear on the display.” Hollenberg,
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`col. 16, lines 11 to 49. That information is retrieved by the above-discussed
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`“service provider” from its network 30a and data 38a, or through communications
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`network 31a, and transmitted to the user’s mobile computer; in discussing the
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`“service provider computer control program,” Hollenberg describes that “the
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`service provider selects appropriate information from the system database (DB)
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`specific to user information … and this information is transmitted to the user.”
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`Hollenberg, col. 13, lines 9 to 21, col. 23, lines 9 to 18 and 48 to 54.
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`19.
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`Ito discloses that “at least one computer program is further configured to
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`generate on the touch-screen input and display device a plurality of soft function
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`keys or icons” as claimed in claim 22. Ito discloses that the user can “touch an icon
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`of a desired guidance area on the display 106 to select the guidance area” as shown
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`in Figure 22. Ito, col. 30, lines 61 to 63. These buttons in Ito are soft function keys
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`or icons. Additionally, Figures 23 to 25 of Ito describe various icons that assist the
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`user with selecting various guidance options. Ito, col. 30, line 63 to col. 32, line 60.
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`Hollenberg describes a mobile computer with a graphical display unit which
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`displays various menus and icons that can be selected by a user; for example, the
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`display can provide a service provider menu 6c, a device control icon 8a, a visit list
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`control icon 5a, a look-ahead icon 8f, or a proximate information menu 6p.
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`Hollenberg, col. 12, lines 13 to 40, col. 13, lines 46 to 63, col. 18, lines 1 to 18.
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`Selecting a provided menu or icon will “caus[e] the computer to proceed in
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`processing or executing the pertinent information or code.” Hollenberg, col. 13,
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`lines 60 to 63.
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`20.
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`Ito and Hollenberg disclose “at least one of the soft function keys or icons
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`having a function associated therewith relating to obtaining directions” as claimed
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`in claim 22. Ito discloses that icons K1 to K5 have functions relating to obtaining
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`directions; specifically, they are used to select the “desired guidance areas.” Ito,
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`col. 30, line 66 to col. 31, line 14, Fig. 22. Figures 23 and 24 of Ito shows further
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`display screens with selectable icons (“Please touch desired item”) providing
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`options for obtaining directions. Ito, Figs. 23 and 24, col. 31, line 39 to col. 32, line
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`6. Hollenberg describes displaying various menus and icons that can be executably
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`selected by a user. Hollenberg, col. 12, lines 13 to 40; col. 13, lines 46 to 63. As
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`shown in Figure 2, the display in Hollenberg includes a menu option for displaying
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`a floor map that can be used to orient oneself within the building or otherwise find
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`proximate items of interest, such as exit doors or escalators. Hollenberg, Fig. 2,
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`col. 13, lines 38 to 45. The floor map menu option is a soft function key which
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`relates to obtaining directions.
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`21.
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`Ito and Hollenberg disclose “at least one of the soft function keys having a
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`function associated therewith relating to points of interest” as claimed in claim 22.
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`Of the soft function keys described in relation to Figure 22 of Ito, one of the
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`options the user can select includes “the icon K2 for ‘surrounding area of
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`destination.’” Ito, Fig. 22, col. 30, line 63 to col. 31, line 14. The “surrounding area
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`of destination” soft key provides information on points of interest in the vicinity of
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`the destination, for example, “further in the case where the driver need to have
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`information on the presence or absence of parking and various facilities in the area
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`around the destination, it is convenient for the drive [sic] to have area guidance
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`data around the destination.” Ito, col. 31, lines 22 to 26. “Parking and various
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`facilities” are points of interest. Hollenberg describes displaying various menus
`
`and icons that can be executably selected by a user; certain menus and icons relate
`
`to points of interest, such as, with reference to Figure 2, the “proximate station
`
`banner 6d” and “proximate merchandise banner 6e,” both of which may be
`
`“mappable hypertext items that the user may executably select in order to receive
`
`additional information” (Hollenberg, col. 12, lines 13 to 40; col. 13, lines 46 to 63),
`
`or, with reference to Figure 6, “proximate information menu 6p,” “proximate
`
`submenu 6q to provide user with information pertinent to the attractions located
`
`near the relatively approaching highway interchange,” (Hollenberg, col. 19, lines
`
`24 to 33). Additionally, Figure 6 shows the soft key “Visitor Sights,” element 6p,
`
`and sub-menus soft keys 6q (“AguaVerde,” “OldeManor,” “Ville Dalfijn,” “Yacht
`
`Basin”) as points of interest. Hollenberg further describes a “look ahead icon 8f,”
`
`which “selectably provides information for areas beyond user’s current area;” upon
`
`selection, the display shows “map data of locations in advance of the mobile user’s
`
`current location,” including an airport, which is a point of interest. Hollenberg, Fig.
`
`11, col. 19, lines 58 to 60, col. 21, lines 32 to 54.
`
`17
`
`17
`
`

`
`22.
`
`Ito and Hollenberg disclose that “the at least one of the soft function keys or
`
`icons having a function associated therewith relating to directions comprises a
`
`function for obtaining directions from a current location of the user” as claimed in
`
`claim 23. Ito discloses that icons K1 to K5 have functions relating to obtaining
`
`directions; they are used to select the “desired guidance areas.” Ito, col. 30, line 66
`
`to col. 31, line 3. Figure 24 also shows options for selecting a recommended route
`
`from the departure point to the destination indicated by lines only or with detailed
`
`information. Ito, Fig. 24. The departure point is calculated from using GPS data
`
`obtained at the position measuring section 104 of the navigation apparatus to
`
`measure the current position of the vehicle so that the current position of the
`
`vehicle is the departure point. Ito, 15:47-58. Therefore, when the user requests
`
`guidance and directions from a departure point, including by displaying either an
`
`outline map or a detailed map for the recommended route, the request relates to
`
`directions from the current location of the vehicle and user. Hollenberg also
`
`discloses, in Figure 2, a display that includes a “device location and direction
`
`symbol 6a” that displays the current location of the user on a map. Hollenberg, col.
`
`12, lines 22 to 40. This device location and direction symbol is a soft function key
`
`that relates to the current location of the user. The display in Hollenberg also
`
`includes a menu option for displaying a floor map that can be used to orient oneself
`
`and find proximate items of interest in relation to the user’s current location.
`
`18
`
`18
`
`

`
`Hollenberg, Fig. 2, col. 13, lines 38 to 45. Additionally, Hollenberg further
`
`describes a “look ahead icon 8f,” which “selectably provides information for areas
`
`beyond user’s current area;” upon selection, the display shows “map data of
`
`locations in advance of the mobile user’s current location,” including roads,
`
`airports, or towns, along with estimated travel times and mileages to them, and
`
`thereby provides directions from a current location of the user. Hollenberg, Fig. 11,
`
`col. 19, lines 58 to 60, col. 21, lines 32 to 54.
`
`23.
`
`Ito discloses that “the digitized speech is generated based at least in part on
`
`user speech received via a microphone in communication with the speech
`
`recognition apparatus” as claimed in claim 35. Ito discloses that the input section
`
`105 may be “a data input device using voice recognition,” with which “the user can
`
`use his/her voice to input corresponding data and commands.” Ito, col. 10, lines 39
`
`to 47. Voice recognition systems rely on microphones for obtaining a user’s voice
`
`input. Additionally, West View has acknowledged (and I agree) that “all speech
`
`recognition systems inherently digitize the speaker’s analog voice.” Infringement
`
`Contentions, at p. 729.
`
`24.
`
`Ito discloses “the microphone being mounted within the computerized
`
`apparatus proximate the touch-screen input and display device so that the user can
`
`speak into the microphone while viewing the touch-screen input and display
`
`device” as claimed in claim 35. As discussed above, Ito discloses a vehicle
`
`19
`
`19
`
`

`
`navigation apparatus that accepts voice commands; this apparatus is described as
`
`being mounted in a vehicle. In order for a driver of a vehicle to be able to view the
`
`detailed guidance provided on the display and to input commands via the touch
`
`screen or voice recognition, both the voice input device (e.g., a microphone) and
`
`touch screen display are accessible to the driver. Neither claim 35 nor the
`
`specification defines “proximate” in terms of how close the microphone and the
`
`touch-screen input and display device must be; since the microphone and touch-
`
`screen input and display device described, for example, by Ito are accessible to the
`
`driver of a vehicle, the microphone is located “proximate” the touch-screen input
`
`and display device.
`
`25.
`
`Ito and Hollenberg disclose “the graphical representation of directions
`
`comprising the map graphic displayed on the touch-screen input and display device
`
`having at least one arrow showing the path for the user to follow inside of the
`
`building or structure” as claimed in claim 35. Figure 9(B) of Ito shows an example
`
`of a displayed map; as shown in Figure 9(B) (reproduced below), “a map for the
`
`area around the departure point PD is displayed on the display[]. In this displayed
`
`map, the road R1 is highlighted by markings MA, and in this way the searched
`
`route is indicated. Further, an arrow MB showing the direction of travel and a mark
`
`MC showing the vehicle position by map matching are also indicated.” Ito, col. 17,
`
`lines 10 to 14, Fig. 9(B).
`
`20
`
`20
`
`

`
`Arrows are also disclosed in Figs. 10(A), 10(B), 29(B), 30(B), 31(B), 32(B), and
`
`40(A) to (C) of Ito, each illustrating a displayed map image having an arrow
`
`showing a path for the recommended route. The map displayed in Hollenberg
`
`includes a “device location and direction symbol 6a” that represents the current
`
`location of the user on the map. Hollenberg, col. 12, lines 22 to 40. As shown in
`
`Figure 2, the direction symbol includes an arrow.
`
`26.
`
`Ito and Hollenberg disclose “an interface compliant wi

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