UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`VOLKSWAGEN GROUP OF AMERICA, INC.
`
`Petitioner
`
`
`Patent No. 8,781,839
`Issue Date: July 15, 2014
`Title: COMPUTERIZED INFORMATION AND
`DISPLAY APPARATUS
`__________________________________________________________________
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 8,781,839
`PURSUANT TO 35 U.S.C. § 312 and 37 C.F.R. § 42.104
`
`Case No. IPR2016-00177
`__________________________________________________________________
`
`
`
`
`
`
`
`

`
`
`
`I. 
`II. 
`III. 
`
`TABLE OF CONTENTS
`Mandatory Notices (37 C.F.R. § 42.8) ........................................................... 1 
`Grounds for Standing (37 C.F.R. § 42.104(a)) ............................................... 2 
`Identification of Challenge (37 C.F.R. § 42.104(b)(1)-(3) and Relief
`Requested (37 C.F.R. § 42.22(a)(1)) .............................................................. 2 
`A.  Background of the ’839 Patent .................................................................. 2 
`1. 
`The ’839 Patent .......................................................................... 2 
`2. 
`Prosecution History of the ’839 Patent ...................................... 4 
`B.  Patents and Printed Publications Relied On .............................................. 4 
`C.  Statutory Grounds for Challenge (37 C.F.R. § 42.104(b)(1)–(2)) ............ 5 
`D.  Claim Construction (37 C.F.R. § 42.104(b)(3)) ....................................... 5 
`IV.  How
`the Challenged Claims are Unpatentable (37 C.F.R. §
`42.104(b)(4)-(5)) ............................................................................................. 5 
`A.  Claims 1, 10, 11, 16, 22, 23, and 35 are Obvious in View of the
`Disclosures of Ito, Ezaki, and Hollenberg ........................................... 5 
`1. 
`Claim 1 ....................................................................................... 8 
`2. 
`Claim 10 ................................................................................... 19 
`3. 
`Claim 11 ................................................................................... 21 
`4. 
`Claim 16 ................................................................................... 22 
`5. 
`Claim 22 ................................................................................... 23 
`6. 
`Claim 23 ................................................................................... 26 
`7. 
`Claim 35 ................................................................................... 28 
`8. 
`Obviousness in View of Ito, Ezaki, and Hollenberg ............... 36 
`9. 
`The Level of Skill in the Industry ............................................ 38 
`10.  Claim Charts ............................................................................ 39 
`B.  Claim 29 is Obvious in View of the Disclosures of Ito, Ezaki,
`Hollenberg, and Hsieh ........................................................................ 57 
`1. 
`Claim 29 ................................................................................... 58 
`-i-
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`

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`2. 
`
`Obviousness in View of Ito, Ezaki, Hollenberg, and
`Hsieh ........................................................................................ 58 
`Claim Chart .............................................................................. 59 
`3. 
`Conclusion .................................................................................................... 60 
`
`
`
`-ii-
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`
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`V. 
`
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`

`
`LISTING OF EXHIBITS
`
`U.S. Patent No. 8,781,839 to Gazdzinski
`
`Declaration of Scott Andrews
`
`U.S. Patent No. 6,249,740 to Ito et al.
`
`U.S. Patent No. 6,201,544 to Ezaki
`
`U.S. Patent No. 6,091,956 to Hollenberg
`
`U.S. Patent No. 5,574,443 to Hsieh
`
`U.S. Patent No. 6,064,323 to Ishii et al.
`
`U.S. Patent No. 4,558,300 to Goldman
`
`U.S. Patent No. 6,211,777 to Greenwood et al.
`
`“Plaintiff and Counter-Defendant West View Research,
`LLC’s Revised Disclosure of Asserted Claims and
`Infringement Contentions, Pursuant to Patent L.R. 3.1
`and the June 10, 2015 Court Order,” dated June 26, 2015.
`
`-iii-
`
`
`
`
`
`Exhibit 1001
`
`Exhibit 1002
`
`Exhibit 1003
`
`Exhibit 1004
`
`Exhibit 1005
`
`Exhibit 1006
`
`Exhibit 1007
`
`Exhibit 1008
`
`Exhibit 1009
`
`Exhibit 1010
`
`
`
`
`
`
`
`

`
`
`
`I. Mandatory Notices (37 C.F.R. § 42.8)
`Real Party-in-Interest: Volkswagen Group of America, Inc. (“VWGoA”), which is
`
`a subsidiary of Volkswagen AG.
`
`Related Matters: The following judicial matter may affect, or may be affected by, a
`
`decision in this inter partes review: West View Research, LLC v. Audi AG, et al.,
`
`No. 3:14-cv-02668-BAS-JLB (S.D. Cal.), naming as defendants: VWGoA d/b/a
`
`Audi of America, Inc.; Volkswagen AG (which, as indicated as above, is the parent
`
`of VWGoA); and Audi AG (which is a subsidiary of Volkswagen AG). In this
`
`litigation, West View has accused, for example, “Audi Smart Display” products as
`
`infringing the claims of U.S. Patent No. 8,781,839 (“the ’839 patent”), which is
`
`being challenged by this petition. See, Ex. 1010.
`
` The following judicial matters in the Southern District of California may affect,
`
`or may be affected by, a decision in this inter partes review: West View Research,
`
`LLC v. Bayerische Motoren Werke AG, et al. (3:14-cv-02670); West View
`
`Research, LLC v. Hyundai Motor Company, Ltd., et al. (3:14-cv-02675); West
`
`View Research, LLC v. Nissan Motor Company, Ltd., et al. (3:14-cv-02677); and
`
`West View Research, LLC v. Tesla Motors, Inc. (3:14-cv-02679).
`
` The following administrative matters may affect, or may be affected by, a
`
`decision in this inter partes review: IPR2015-01941; IPR2016-00123; IPR2016-
`
`00124; IPR2016-00125; IPR2016-00137; IPR2016-00146; IPR2016-00156; U.S.
`
`1
`
`

`
`
`
`Patent Nos.: 8,447,612; 8,117,037; 7,711,565; 7,093,693; 6,988,071; 6,615,175,
`
`and 8,290,778.
`
`Lead Counsel: Michael J. Lennon (Reg. No. 26,562).
`
`Backup Counsel: Clifford A. Ulrich (Reg. No. 42,194) and Michelle Carniaux
`
`(Reg. No. 36,098).
`
`Service: VWGoA agrees to electronic service at the following e-mail addresses:
`
`mlennon@kenyon.com, culrich@kenyon.com, and mcarniaux@kenyon.com.
`
`Service may be made at the following address: Kenyon & Kenyon LLP, One
`
`Broadway, New York NY 10004 (Tel.: 212-425-7200; Fax: 212-425-5288).
`
`II. Grounds for Standing (37 C.F.R. § 42.104(a))
` VWGoA certifies that the ’839 patent is available for inter partes review and
`
`that VWGoA is not barred or estopped from requesting an inter partes review
`
`challenging the patent claims on the grounds identified in this petition.
`
`III. Identification of Challenge (37 C.F.R. § 42.104(b)(1)-(3) and Relief
`Requested (37 C.F.R. § 42.22(a)(1))
` VWGoA challenges claims 1, 10, 11, 16, 22, 23, 29, and 35 of the ’839 patent
`
`under 35 U.S.C. § 103(a), and cancelation of these claims is requested.
`
`A. Background of the ’839 Patent
`1. The ’839 Patent
` The ’839 patent issued on July 15, 2014, from U.S. Patent Application Serial
`
`No. 13/746,266 (“the ’266 application”), filed Jan. 21, 2013. The ’839 patent
`
`claims to be a continuation or division of a number of prior applications, the
`
`2
`
`

`
`
`
`earliest of which was filed on June 10, 1999.1
`
` The ’839 patent describes an interactive display in an elevator that is responsive
`
`to verbal commands. Ex. 1001, 7:5-27; Ex. 1002, ¶ 3. Signals captured by a
`
`microphone 118 as part of a speech recognition module 104 are digitized by an
`
`analog to digital converter 141 and processed using a speech recognition algorithm
`
`to produce digital representations of the user’s speech. Id., 7:59-63. The digital
`
`representations are compared to a speech library to identify known words and the
`
`desired functionality is implemented. Id., 7:63-8:2; Ex. 1002, ¶ 3.
`
` The display device includes a touch screen display 113 that “generates a variety
`
`of different messages or display formats” based on the user’s input and query. Id.,
`
`8:45-47. For example, one such message or display format includes a building
`
`directory. Id., 9:37-11:37; Ex. 1002, ¶ 3. The user can speak the specific name of
`
`the party the user wishes 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, 10:9-19; Ex. 1002, ¶ 3.
`
` Of the challenged claims, claims 1 and 35 are independent. Challenged claims
`
`10, 11, 16, 22, 23, and 29 each ultimately depend from claim 1.
`
`
`1 VWGoA does not concede that any claim of the ’839 patent is entitled to a
`
`priority date earlier than the January 21, 2013, filing date of the ’266 application.
`
`3
`
`

`
`
`
`2. Prosecution History of the ’839 Patent
` The ’266 application was filed with a preliminary amendment, which canceled
`
`claims 1 to 40 and added claims 41 to 87. In an Office Action dated December 31,
`
`2013, all of the claims were rejected on the ground of non-statutory double
`
`patenting over claims 1 to 30 of U.S. Patent No. 8,290,778. In response, Mr.
`
`Gazdzinski filed a terminal disclaimer on March 31, 2014. The USPTO
`
`subsequently issued a Notice of Allowance on May 8, 2014, allowing application
`
`claims 41 to 87, without any stated reasons for allowance.
`
`B. Patents and Printed Publications Relied On
`1. U.S. Patent No. 6,249,740 (“Ito,” Ex. 1003), filed January 21, 1999 and
`
`
`
`issued on June 19, 2001, constitutes prior art to the ’839 patent under at least 35
`
`U.S.C. § 102(e).
`
`
`
`2. U.S. Patent No. 6,201,544 (“Ezaki”, Ex. 1004), filed August 10, 1998 and
`
`issued on March 13, 2001, constitutes prior art to the ’839 patent under at least 35
`
`U.S.C. § 102(e).
`
`
`
`3. U.S. Patent No. 6,091,956 (“Hollenberg,” Ex. 1005), filed on June 12, 1997
`
`and issued on July 18, 2000, constitutes prior art to the ’839 patent under at least
`
`35 U.S.C. § 102(b).
`
`
`
`4. U.S. Patent No. 5,574,443 (“Hsieh,” Ex. 1006), issued November 12, 1996,
`
`constitutes prior art against the ’839 patent under 35 U.S.C. § 102(b).
`
`
`
`Ito, Ezaki, Hollenberg, and Hsieh were not cited by Mr. Gazdzinski or the
`
`4
`
`

`
`
`
`Examiner during prosecution of the ’839 patent.
`
`C. Statutory Grounds for Challenge (37 C.F.R. § 42.104(b)(1)–(2))
`1. Claims 1, 10, 11, 16, 22, 23, and 35 are obvious under 35 U.S.C. § 103(a) in
`
`
`
`view of the disclosures of Ito, Ezaki, and Hollenberg.
`
`
`
`2. Claim 29 is obvious under 35 U.S.C. § 103(a) in view of the disclosures of
`
`Ito, Ezaki, Hollenberg, and Hsieh.
`
`D. Claim Construction (37 C.F.R. § 42.104(b)(3))
` Generally, the claim terms in an unexpired patent should be given their broadest
`
`reasonable construction in view of the specification. 37 C.F.R. § 42.100(b). Claim
`
`terms are generally presumed to take on their ordinary and customary meaning.
`
`The specification of the ’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. Therefore, all claim terms should be given their
`
`broadest reasonable construction.
`
`IV. How the Challenged Claims are Unpatentable (37 C.F.R. § 42.104(b)(4)-
`(5))
`A. Claims 1, 10, 11, 16, 22, 23, and 35 are Obvious in View of the
`Disclosures of Ito, Ezaki, and Hollenberg
` As described in detail below, claims 1, 10, 11, 16, 22, 23, and 35 are invalid
`
`under 35 U.S.C. § 103(a) as obvious in view of the disclosures of Ito, Ezaki, and
`
`Hollenberg.
`
`
`
`Ito describes an automobile navigation system that includes a vehicle
`
`5
`
`

`
`
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`navigation apparatus 100 that is mounted in a vehicle as a movable body. Ex. 1003,
`
`8:11-16. In addition, Ito discloses a “base apparatus” 150, that wirelessly connects
`
`to the navigation apparatus, as shown in Fig. 1. Id., 10:51-57.
`
`
`
` The system contains 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., 10:39-47. The display device is also equipped with a
`
`touch panel. Id., 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. Id., 18:62-67.
`
` Ezaki describes a navigation apparatus for a vehicle 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 particularly “visually displaying
`
`the floor number of the floor on which a building user serving as the target
`
`6
`
`

`
`
`
`[destination] is located.” Id., 4:36-59.
`
` 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, 11:43-12:12, Fig. 1.
`
`
`
` 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; 13:8-16.
`
` The mobile computer of Hollenberg 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., 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.” Id., 6:50-54. Additionally, the mobile computer can be used
`
`“for location finding in topologically complex areas … surrounded by buildings,
`
`7
`
`

`
`
`
`e.g., in urban ‘canyons’ and those enclosed within buildings, such as shopping
`
`malls” or department stores. Ex. 1005, 5:13-28, 7:36-40. As shown in Figs. 2 and
`
`4, reproduced below, 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 also Figs. 6 and 11.
`
`
`
` As described below, Ito, Ezaki, and Hollenberg disclose all of the limitations of
`
`claims 1, 10, 11, 16, 22, 23, and 35.
`
`1. Claim 1
`i.
`“[c]omputerized apparatus useful for locating an organization or
`entity, the organization or entity being disposed within a building
`or structure, the apparatus comprising:”
`Ito describes a “vehicle navigation apparatus” which includes a “processing
`
`
`
`section 101” with “a CPU as its main component” and a “program storage section
`
`102” that “serves as a memory for storing programs which will be executing by the
`
`processing section.” Ex 1003, 9:52-67, Fig. 1, Ex. 1002, ¶ 4. Ito describes that the
`
`8
`
`

`
`
`
`user operates an input section 105 to “input information about the destination, such
`
`as the facility name.” Ex. 1003, 15:50-54; Ex. 1002, ¶ 4. A “facility” may be
`
`“disposed within a building or structure.” Ex. 1002, ¶ 4.
`
` Ezaki discloses a navigation apparatus for a vehicle which displays a detailed
`
`map including the shapes of buildings and roads and visually displays “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.” Ex. 1004, 2:62-65; Ex. 1002, ¶ 4. The “target
`
`institution” disclosed in Ezaki is an “organization or entity.” Ex. 1002, ¶ 4. As
`
`shown in Fig. 2, Ezaki’s navigation apparatus is computerized (element 18 is a
`
`CPU). Ex. 1004, Fig. 2; Ex. 1002, ¶ 4.
`
` Hollenberg discloses a system that include “at least one mobile computer”
`
`which is capable “for location finding in topographically complex, that is,
`
`mountainous areas or areas surrounded by buildings, e.g., in urban ‘canyons’ and
`
`those enclosed within buildings, such as shopping malls.” Ex. 1005, 5:13-28; Ex.
`
`1002, ¶ 4. An example of the claimed “structure” in the specification of the ’839
`
`patent is a “shopping mall.” Ex. 1001, 2:39-40.
`
`ii. “a wireless interface”
`Ito discloses that the “transmitting and receiving section 108” in the vehicle
`
`
`
`navigation apparatus 100 communicates with the base station and “includes
`
`devices such as a modem and the like.” Ex. 1003, 10:51-57; Ex. 1002, ¶ 5.
`
`9
`
`

`
`
`
`Additionally, Ito discloses that the connection may “utilize systems such as car
`
`phones, portable phones PHS or the like.” Ex. 1003, 10:51-57; Ex. 1002, ¶ 5.
`
`These systems are wireless, and the transmitting and receiving section 108
`
`interfaces with the wireless network, and is a “wireless interface.” Ex. 1002, ¶ 5.
`
` Hollenberg describes a “wireless system for providing services and time-critical
`
`information about places and events to mobile computers” (Ex. 1005, Abstract)
`
`and discloses a “mobile computer with multiple transmitters and receivers” that
`
`includes “a transceiver for wireless voice and data telecommunications” (i.e., a
`
`wireless interface) and exchanges information with a computerized “known-
`
`location information service provider” (Ex. 1005, 5:13-28). See also id., 12:13-15
`
`(“handheld computing and wireless communications device”); Ex. 1002, ¶ 5.
`
`iii. “data processing apparatus”
`Ito discloses that a CPU (i.e., a data processing apparatus) is the “main
`
`
`
`component” of the processing section 101. Ex. 1003, 9:51-67, Fig. 1; Ex. 1002, ¶
`
`6. Ezaki discloses “a processor (CPU) for controlling the navigation apparatus.”
`
`Ex. 1004, 5:10-11; Ex. 1002, ¶ 6. Hollenberg discloses a computer having
`
`computer equipment including a “computer central processing unit” and a “DSP
`
`unit.” Ex. 1005, 5:13-28; 6:15-30; Ex. 1002, ¶ 6. These are data processing
`
`apparatuses.
`
`iv. “a touch-screen input and display device”
`Ito discloses a display 106 that includes a liquid crystal display or CRT that is
`
`
`
`10
`
`

`
`
`
`equipped with a touch panel as a data input device. Ex. 1003, 10:39-50; Ex. 1002,
`
`¶ 7. The display is used to display information such as travel route and/or travel
`
`directions. Ex. 1003, 15:22-26; Ex. 1002, ¶ 7. A user “can use a finger or the like
`
`to touch an icon or the like displayed on the screen of the display 106.” Ex. 1003,
`
`10:39-50; Ex. 1002, ¶ 7.
`
` Hollenberg describes “a touch-screen graphical display unit” on which one or
`
`more menus or icons can be displayed. For example, the display unit shows
`
`“device location and direction symbol 6a which symbol can be a mappable
`
`hypertext item that the user may executably select in order to receive additional
`
`information or execute computer code associated with it.” Ex. 1005, 12:13-40; Ex.
`
`1002, 7.
`
`v.
`
`“a speech digitization apparatus in data communication with the
`data processing apparatus ”
`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.” Ex. 1003, 10:39-47; Ex. 1002, ¶ 8. This input 105, as shown
`
`in Fig. 1, is connected to and in data communication with the processing section
`
`101 (i.e., the data processing apparatus). Ex. 1002, ¶ 8.
`
` Additionally, West View has admitted that “all speech recognition systems
`
`inherently digitize the speaker’s analog voice.” Ex. 1010, p. 729.
`
`11
`
`

`
`
`
`vi. “and a storage apparatus in data communication with the data
`processing apparatus, said storage apparatus comprising at least
`one computer program, said at least one program being
`configured to:”
` As shown in Fig. 1, Ito discloses that the “program storage section 102,” which
`
`serves as a memory for storing the programs that are executed by the processing
`
`section 101, is connected to and in data communication with the processing
`
`section. Ex. 1003, 9:51-67; Fig.1; Ex. 1002, ¶ 9.
`
` Ezaki describes a navigation apparatus which includes “a ROM for storing
`
`various types of programs” such as for “guide route searching;” As shown in Fig.
`
`2, the ROM 19 is connected to the CPU 18 via a bus 28 and is in data
`
`communication with the processor. Ex. 1004, 5:10-22, Fig. 2; Ex. 1002, ¶ 9.
`
` Hollenberg describes “computer equipment with memory, which term includes
`
`storage, drives, and RAM units, and computer programs to provide for efficient
`
`situation information exchange.” Ex. 1005, 5:13-28; Ex. 1002, 9. Computer
`
`programs executed on the mobile computer include a “user’s computer control
`
`program” by which the mobile computer “requests information and services and
`
`subsequently processes the information communicated from the service provider.”
`
`Ex. 1005, 23:64-24:3, see also id., 12:12-16; Ex. 1002, ¶ 9. To execute a program
`
`on a computer, the program is stored in a storage apparatus, which is in data
`
`communication with a data processing apparatus, such as the described central
`
`processing unit or DSP, to execute the stored program. Ex. 1002, ¶ 9.
`
`12
`
`

`
`
`
`
`
`vii. “receive a digitized speech input via the speech digitization
`apparatus, the input relating to an organization or entity which a
`user wishes to locate”
`Ito discloses that the input 105 may be a data input device that uses voice
`
`recognition. Ex. 1003, 10:39-47. Among the inputs that the user may enter into the
`
`system are “information about the destination, such as the facility name, telephone
`
`number and address thereof, and a route search request.” Id., 15:47-58 (emphasis
`
`added); Ex. 1002, ¶ 10; see also Ex. 1003, 9:33-37; 14:33-38. This input is related
`
`to “an organization or entity which a user wishes to locate.” Ex. 1002, ¶ 10.
`
`viii. “based at least in part on the input, causing recognition of at least
`one word therein relating to the organization or entity”
` The programs in Ito can receive input from “a data input device using voice
`
`recognition…. With the data input device which uses voice recognition, the user
`
`can use his/her voice to input corresponding data and commands.” Ex. 1003,
`
`10:39-47; Ex. 1002, ¶ 11. The user can input, for example, “information about the
`
`destination, such as facility name, telephone number and address thereof.” Ex.
`
`1003, 15:50-54. Such information, e.g., the facility name, includes at least one
`
`word relating to a facility, which as discussed above, includes an organization or
`
`entity. Ex. 1002, ¶ 11.
`
`
`
`It is obvious that in voice recognition systems, software programs process a
`
`representation of speech in order to identify a spoken word or phrase. See, Ex.
`
`1007, 3:11-18, (which describes a voice recognition circuit 14 that performs a
`
`13
`
`

`
`
`
`speech recognition operation in accordance with a voice recognition algorithm);
`
`Ex. 1002, ¶ 11.
`
`ix. “and identification of a location associated with the organization
`or entity based at least in part on the at least one recognized word,
`the location being inside of the building or structure”
`Ito discloses that the user inputs are used to search a database of navigation
`
`
`
`data, which uses the inputs to extract a position of the destination, or “facility
`
`position.” Ex. 1003, 11:1-30; 15:50-67; Ex. 1002, ¶ 12.
`
` Ezaki discloses a navigation apparatus for a vehicle that displays a detailed map
`
`that provides directions to a target destination. Ex. 1004, 1:58-2:19; Ex. 1002, ¶ 12.
`
`The displayed map includes the shapes of buildings and roads, and visually
`
`displays “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.” Ex. 1004, 2:62-65; Ex.
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`1002, ¶ 12; see also Ex. 1004, 7:14-20.
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` Hollenberg discloses a system that includes “at least one mobile computer”
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`having capabilities “for location finding in topographically complex, that is,
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`mountainous areas or areas surrounded by buildings, e.g., in urban ‘canyons’ and
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`those enclosed within buildings, such as shopping malls.” Ex. 1005, 5:13-28; Ex.
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`1002, ¶ 12.
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`x.
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`“and provide a graphical or visual representation of the location
`on the touch screen input and display device in order to aid a user
`in finding the organization or entity”
`Ito discloses displaying detailed maps on a display device, including a
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`14
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`recommended route to the selected destination on an output display. Ex. 1003,
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`16:24-27. An exemplary map showing destination PA is provided in Fig. 9(A):
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` Ezaki discloses a display device 27 in a navigation apparatus for displaying a
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`map and/or menu image. Ex. 1004, 5:10-23. The displayed map includes 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.” Ex. 1004, 2:62-65; Ex. 1002, ¶ 13. Additionally, the map
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`“displays the floor by an L-shaped mark FL in the three-dimensional building BL
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`such that the number of floors can be identified; and, at the same time, the floor
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`number (6F) is displayed.” Ex. 1004, 7:14-20; Fig. 1:
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` The L-shaped mark denoting the floor of the target entity is a graphical
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`representation of the location of the entity. Ex. 1002, ¶ 13. The floor number is a
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`visual representation of the location of the entity. Ex. 1002, ¶ 13.
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` Hollenberg discloses a mobile computer with a graphical display on which
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`users “can receive services like maps and other aids to help them find their way
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`around the store or shopping mall to the desired merchandise or store.” Ex. 1005,
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`7:31-40; Ex. ¶ 13. Fig. 2 depicts a “graphical display showing an exemplary retail-
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`store floor plan” (i.e., a “graphical representation”), displaying items of interest
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`near the user’s current location. Ex 1005, Fig. 2, 10:52-55, see also 13:22-45; Ex.
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`1002, ¶ 13.
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`xi. “the graphical or visual representation of the location also
`comprising a graphical or visual representation of at least the
`immediate surroundings of the organization or entity”
`Ito discloses displaying area guidance for the area surrounding the destination
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`point, including “guidance information on the presence or absence of parking and
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`various facilities in the area around the destination.” Ex. 1003, 14:19-38. An
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`exemplary map shown in Fig. 9(A), below, discloses the display of a graphical
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`representation of the immediate surroundings of the destination, which may be an
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`organization or entity. Ex. 1003, Fig. 9(A); Ex. 1002, ¶ 14. And an exemplary map
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`of the area surrounding the departure point (“PD”) is shown in Fig. 9(B); see Ex.
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`16
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`1003, 17:4-19. Although Fig. 9(B), below, 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.” Id., 18:36-52; Ex. 1002, ¶ 14.
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`The 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.
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` Ezaki discloses a display device 27 in a navigation apparatus for displaying a
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`map and/or menu image. Ex. 1004, 5:10-23; Ex. 1002, ¶ 14. The displayed map
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`includes the shapes of buildings and roads, and displays “detailed map
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`information” which includes neighboring buildings of a “target location” displayed
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`by an indicator as shown in Fig. 5, below. Ex. 1004, 5:66-6:3. The detailed map
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`information is a graphical representation of the immediate surroundings of the
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`entity. Ex. 1002, ¶ 14.
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`17
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` Ezaki further displays “a user name list of the building” on a part of the display
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`screen with the map information; the user name list of the tenants in the building is
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`a visual representation of the immediate surroundings within the building of the
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`entity. Ex. 1004, 2:62-65, 3:21-24; Ex. 1002, ¶ 14.
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` Hollenberg describes a mobile computer with a graphical display on which
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`users “can receive services like maps and other aids to help them find their way
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`around the store or shopping mall.” Ex. 1005, 7:31-40. Fig. 2 depicts a “graphical
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`display showing an exemplary retail-store floor plan” showing “floor plan details”
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`such as the locations of nearby exit doors (3b) or an escalator (3d) around a user’s
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`location (6a). Ex. 1005, Fig. 2 and 10:52-55, 13:22-46; Ex. 1002, ¶ 14. And Fig. 4
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`illustrates an exemplary “urban plan” with organizations (3e, 3f) near the user’s
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`current location (6f). Ex. 1005, Fig. 4 and 10:60-64, 14:65-15:8; Ex. 1002, ¶ 14.
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`Both maps are graphical representations of immediate surroundings. Ex. 1002, ¶
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`14.
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`xii. “the immediate surroundings being inside the building or
`structure”
` Hollenberg describes a mobile computer for location finding within buildings
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`18
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`including by providing users with maps and floor plan details to “help find their
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`way around the store or shopping mall.” Ex. 1005, 5:13-28; 7:31-40; 13:22-45; Ex.
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`1002, ¶ 15. Fig. 2 depicts a “graphical display showing an exemplary retail-store
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`floor plan” showing “floor plan details” such as the locations of a near exit (3b) or
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`an escalator (3d) around a user’s location (6a). Ex. 1005, Fig. 2 and 10:52-55,
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`13:22-46; Ex. 1002, ¶ 15.
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` As described above, Ezaki displays “a user name list of the building” on a part
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`of the display screen with the map information; the user name list of the tenants in
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`the building is a visual representation of the immediate surroundings within the
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`building of the entity. Ex. 1004, 2:62-65, 3:21-24; Ex. 1002, ¶ 15.
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`2. Claim 10: “The apparatus of claim 1, wherein the computerized
`apparatus is mounted on or proximate to a surface of a land-mobile
`transport apparatus such that an operator of the transport
`apparatus can view and access a touch screen of the touch screen
`input and display device, and make input to the speech digitization
`apparatus, while operating the transport apparatus.”
`Ito discloses that the vehicle navigation apparatus 100 may be “mounted in a
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`
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`vehicle as a movable body.” Ex. 1003, 8:11-16; Ex. 1002, ¶ 16. Ito describes an
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`input 105 of the navigation apparatus includes a touch panel display 106 such that
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`19
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`the “user can use a finger or the like to touch an icon or the like displayed on the
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`screen of the display 106” and a data input device using voice recognition so that
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`“the user can use his/her voice to input corresponding data and commands” where
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`the user is a driver of the vehicle. Ex. 1003, 10:39-47; 14:19-38; Ex. 1002, ¶ 16. In
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`order for a driver to be able to view the detailed guidance provided on the display
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`and to input commands via the touch screen or voice recognition, both the voice
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`input device (e.g., a microphone) and touch screen display are accessible to the
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`driver, and the navigation apparatus is mounted on or proximate to some surface of
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`the vehicle (“a land-mobile transport apparatus”) accessible to the driver. Ex. 1002,
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`¶ 16.
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` Hollenberg describes a mobile computer having a graphical display unit for
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`location finding that can be “mounted” in an automobile. Ex. 1005, 6:31-54; Ex.
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`1002, ¶ 16. Figs. 7 and 8 of Hollenberg illustrate a bracket that can be used for
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`installing and mounting the mobile computer in a vehicle, “for example, device 2d
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`may be inserted into bracket 40 mounted in a vehicle for greater operative mobility
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`and used for networking with vehicular systems.” Ex. 1005, 19:61-20:51; Ex.
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`1002, ¶ 16. When used in a vehicle, the display can provide local information, for
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`example traffic congestion information. Ex. 1005, 6:31-54; Ex. 1002, ¶ 16. In order
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`for a driver of a vehicle to be able to view the information provided on the
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`graphical display, the mobile computer is mounted on or proximate to some
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`20
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`surface of the automobile (“a land-mobile transport apparatus”) accessible to the
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`driver. Ex. 1002, ¶ 16.
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`3. Claim 11: “The apparatus of claim 1, wherein the identification of
`the location comprises accessing a remote server via a network in
`data communication with the computerized apparatus via the
`wireless interface.”
`Ito discloses that the user inputs are used to search