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`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
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`
`Slepian et al.
`In re Patent of:
`5,954,781 Attorney Docket No.: 43930-0004IP1
`U.S. Patent No.:
`Sep. 21, 1999
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`Issue Date:
`Appl. Serial No.: 08/813,270
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`Filing Date:
`March 10’ 1997
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`Title:
`METHOD AND APPARATUS FOR OPTIMIZING VEHI-
`CLE OPERATION
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`DECLARATION OF MR. SCOTT ANDREWS
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`UNIFIED 1008
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`1
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`I. 
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`II. 
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`Table of Contents
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`Introduction ...................................................................................................... 3 
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`Qualifications ................................................................................................... 3 
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`III.  Materials Considered ....................................................................................... 6 
`
`IV.  Applicable Legal Standards ............................................................................. 7 
`
`A.  My Understanding of Claim Construction ............................................ 7 
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`B.  My Understanding of Anticipation ....................................................... 8 
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`C.  My Understanding of Obviousness ....................................................... 9 
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`V. 
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`Level of Ordinary Skill in the Art ................................................................. 13 
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`VI.  Brief Overview of the ’781 Patent ................................................................. 14 
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`VII.  Combinations based on Westbrook ............................................................... 16 
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`A.  M. H. Westbrook & J. D. Turner, AUTOMOTIVE SENSORS (1994)
`(“Westbrook”) ..................................................................................... 16 
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`B. 
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`C. 
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`D. 
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`E. 
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`F. 
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`U.S. Patent 4,559,599 to Habu et al. (“Habu”) ................................... 25 
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`U.S. Patent 5,693,876 to Ghitea, Jr. et al. (“Ghitea”) ......................... 26 
`
`Combination of Westbrook, Habu, and Ghitea ................................... 30 
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`U.S. Patent 5,905,457 to Rashid (“Rashid”) ....................................... 36 
`
`Combination of Westbrook, Habu, Ghitea, and Rashid ...................... 38 
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`VIII.  Combinations based on Jurgen ...................................................................... 41 
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`A. 
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`R. Jurgen (Ed.), AUTOMOTIVE ELECTRONICS HANDBOOK (1995)
`(“Jurgen”) ............................................................................................ 41 
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`B. 
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`U.S. Patent 5,017,916 (“Londt”) ......................................................... 46 
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`2
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`C. 
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`The Combination of Jurgen and Londt ............................................... 49 
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`IX.  Conclusions .................................................................................................... 51 
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`I.
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`Introduction
`I, Scott Andrews, declare as follows:
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`1.
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`I have been retained on behalf of Unified Patents, Inc. to offer technical
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`opinions relating to U.S. Patent No. 5,954,781 (the ’781 Patent), and prior art refer-
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`ences relating to its subject matter.
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`II. Qualifications
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`2. My name is Scott Andrews. I am currently a consultant for Cogenia
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`Partners, LLC, focusing on systems engineering, business development and tech-
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`nical strategy supporting automotive and information technology. I have been in
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`this position since 2001. My consulting engineering engagements generally relate
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`to advanced vehicle technologies and systems. For example, I recently served as the
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`technical lead on a project funded by the National Highway Traffic Safety Admin-
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`istration (NHTSA) to develop requirements for connected vehicle safety systems in
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`preparation for NHTSA regulations governing such systems. I have also served as
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`a technical consultant on multiple projects sponsored by the Federal Highway Ad-
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`ministration (FHWA) related to connected vehicle technology research. Several of
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`these projects included extensive work with vehicle interfaces and vehicle systems,
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`including the collection and use of safety information, engine operational infor-
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`mation and other vehicle information.
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`4
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`3.
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`I have over 30 years of professional experience in the field of automo-
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`tive technologies and systems, including vehicle information systems and vehicle
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`safety and control systems. Further, I have authored numerous published technical
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`papers and am a named inventor on 13 U.S. and foreign patents.
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`4.
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`I received a Bachelor of Science degree in Electrical Engineering from
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`University of California, Irvine in 1977 and a Master of Science degree in Electronic
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`Engineering from Stanford University in 1982. From 1977 to 1979, I worked at Ford
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`Aerospace where I designed, tested and delivered microwave radar receiver systems.
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`From 1979 to 1983, I worked at Teledyne Microwave, where I developed high reli-
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`ability microwave components and developed CAD tools. From 1983 to 1996, I
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`worked at TRW, Inc., where I held various positions. From 1983 to 1985, I was a
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`Member of the technical staff and a Department Manager in the Space Electronics
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`sector. Between 1985 and 1990 I was a project manager working on various com-
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`munications systems projects including the U.S. Department of Defense Advanced
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`Research Projects Administration (ARPA) MIMIC Program. Between 1990 and
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`1993 I was the Manager of MMIC (monolithic-microwave-integrated-circuit) Prod-
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`ucts Organization. In this role, I developed business strategy and managed customer
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`and R&D programs. During this time, I also developed the first single chip 94 GHz
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`Radar, used for automotive cruise control and anti-collision systems. In 1993 I trans-
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`ferred to the TRW Automotive Electronics Group, and managed about 30 engineers
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`5
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`in the Systems Engineering and Advanced Product Development organization. In
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`this role, I managed advanced development programs such as automotive radar,
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`adaptive cruise control, occupant sensing, automatic crash notification systems, in-
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`vehicle information systems, and other emerging transportation products.
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`5.
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`I previously was employed as a Project General Manager in the Elec-
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`tronics Division of Toyota Motor Corporation. I worked at Toyota headquarters in
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`Toyota City, Japan from April 1996 to around April 2000. Between July 1999 and
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`April 2000, I transitioned from working in Japan to working in a Toyota office in
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`San Jose, California. In this position, I was responsible for leading the development
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`of vehicle telematics systems, infotainment systems, including on-board and off-
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`board navigation systems, traffic information systems, vehicle communications sys-
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`tems, safety applications, and automated vehicle control systems.
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`6.
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`In 1998, I founded the Automotive Multimedia Interface Collaboration,
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`a consortium of car makers developing standards for in-vehicle computing and in-
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`terfaces between consumer multimedia systems and consumer electronics devices.
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`This work resulted in a variety of standards for vehicle interfaces, user interfaces
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`and vehicle software management that were eventually transferred to other standards
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`organizations such as ISO and the OSGi Alliance.
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`7.
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`In the various positions mentioned above, I was responsible for research
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`and development projects relating to numerous vehicle information systems, user
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`interface systems, sensory systems, control systems and safety systems, and also had
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`the opportunity to collaborate with numerous researchers and suppliers to the auto
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`industry. I therefore believe that I have a detailed understanding of the state of the
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`art during the relevant period, as well as a sound basis for opining how persons of
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`ordinary skill in the art at that time would understand the technical issues in this
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`case. In 2000, I founded Cogenia, Inc. to develop enterprise class data management
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`software systems. I served as the company’s Chief Executive Officer until 2001,
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`when I created Cogenia Partners, my current consulting firm.
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`8.
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`A copy of my curriculum vitae is attached hereto, and it includes a list-
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`ing of my prior experience in litigation matters as an expert. My work on this case
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`is being billed at an hourly rate, with reimbursement for actual expenses. My com-
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`pensation is not contingent upon the outcome of these proceedings or on the content
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`of my opinions.
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`III. Materials Considered
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`9.
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`In forming my opinions expressed in this declaration, I have considered
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`and relied upon my education, background, and experience. I reviewed U.S. Patent
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`No. 5,954,781 (“the ’781 patent”) and its patent file history.
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`10. Additionally, I have reviewed and relied upon the following list of ma-
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`terials in preparation of this declaration:
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`
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`U.S. Patent 5,954,781 (EX1001)
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`7
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`
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`M. H. Westbrook & J. D. Turner, AUTOMOTIVE SENSORS (1994) (“West-
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`brook”) (EX1002_
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`
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`
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`
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`U.S. Patent 4,559,599 (“Habu”) (EX1003)
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`U.S. Patent 5,693,876 (“Ghitea”) (EX1004)
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`R. Jurgen (Ed.), AUTOMOTIVE ELECTRONICS HANDBOOK (1995) (“Jurgen”)
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`(EX1005)
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`
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`
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`
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`
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`
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`U.S. Patent 5,017,916 (“Londt”) (EX1006)
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`U.S. Patent 5,905,457 (“Rashid”) (EX1007)
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`EP Publication No. 0 392 953 (“Tresse”) (EX1012)
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`PCT Publication No. 91/07672 (“Montague”) (EX1013)
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`U.S. Patent 5,357,438 (“Davidian”) (EX1014)
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`11.
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`I have also considered all other materials cited herein.
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`IV. Applicable Legal Standards
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`A. My Understanding of Claim Construction
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`12.
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`I have been informed that claim terms of an expired patent in IPR are
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`construed in accordance with the standard set forth in Phillips. See Facebook Inc.
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`v. Pragmatus AV LLC, 582 Fed.Appx 864, 866 (Fed. Cir. 2014). I have been in-
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`formed that this means that the words of a claim “are generally given their ordinary
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`and customary meaning” as understood by a person of ordinary skill in the art in
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`question at the time of the invention. Phillips v. AWH Corp., 415 F.3d 1303, 1316,
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`75 USPQ2d 1321, 1329 (Fed. Cir. 2005). I have also been informed that the claim
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`terms must be construed in light of the specification and the prosecution history, and
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`not in isolation. Id. at 1313..
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`13. For the purpose of this proceeding, I have used March 10, 1997, which
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`is the filing date of the ’781 patent, as the approximate time of the invention.
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`B. My Understanding of Anticipation
`14.
`I understand that documents and materials that qualify as prior art can
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`be used to invalidate a patent claim as anticipated or as obvious.
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`15.
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`I understand that, once the claims of a patent have been properly con-
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`strued, the second step in determining anticipation of a patent claim requires a com-
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`parison of the properly construed claim language to the prior art on a limitation-by-
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`limitation basis.
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`16.
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`I understand that a prior art reference “anticipates” an asserted claim,
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`and thus renders the claim invalid, if all elements of the claim are disclosed in that
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`prior art reference, either explicitly or inherently (i.e., necessarily present).
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`17.
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`I understand that anticipation in an inter partes review must be shown
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`by a preponderance of the evidence.
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`9
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`C. My Understanding of Obviousness
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`18.
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`I understand that a patent claim is invalid if the claimed invention
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`would have been obvious to a person of ordinary skill in the field at the time of the
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`claimed invention. This means that even if all of the requirements of the claim cannot
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`be found in a single prior art reference that would anticipate the claim, the claim can
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`still be invalid.
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`19. As part of this inquiry, I have been asked to consider the level of ordi-
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`nary skill in the field that someone would have had at the time the claimed invention
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`was made. In deciding the level of ordinary skill, I considered the following:
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`
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`
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`
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`the levels of education and experience of persons working in the field;
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`the types of problems encountered in the field; and
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`the sophistication of the technology.
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`20. To obtain a patent, a claimed invention must have, as of the priority
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`date, been nonobvious in view of the prior art in the field. I understand that an in-
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`vention is obvious when the differences between the subject matter sought to be
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`patented and the prior art are such that the subject matter as a whole would have
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`been obvious at the time of the invention to a person having ordinary skill in the art.
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`21.
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`I understand that a person of ordinary skill in the art provides a refer-
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`ence point from which the prior art and claimed invention should be viewed. This
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`reference point prevents one from using his or her own insight or hindsight in decid-
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`ing whether a claim is obvious.
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`22.
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`I also understand that an obviousness determination includes the con-
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`sideration of various factors such as (1) the scope and content of the prior art, (2) the
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`differences between the prior art and the asserted claims, (3) the level of ordinary
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`skill in the pertinent art, and (4) the existence of secondary considerations such as
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`commercial success, long-felt but unresolved needs, failure of others, etc.
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`23.
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`I understand that an obviousness evaluation can be based on a combi-
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`nation of multiple prior art references. I understand that the prior art references them-
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`selves may provide a suggestion, motivation, or reason to combine, but other times
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`the nexus linking two or more prior art references is simple common sense. I further
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`understand that obviousness analysis recognizes that market demand, rather than
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`scientific literature, often drives innovation, and that a motivation to combine refer-
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`ences may be supplied by the direction of the marketplace.
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`24.
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`I understand that if a technique has been used to improve one device,
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`and a person of ordinary skill in the art would recognize that it would improve sim-
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`ilar devices in the same way, using the technique is obvious unless its actual appli-
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`cation is beyond his or her skill.
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`25.
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`I also understand that practical and common sense considerations
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`should guide a proper obviousness analysis, because familiar items may have obvi-
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`ous uses beyond their primary purposes. I further understand that a person of ordi-
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`nary skill in the art looking to overcome a problem will often be able to fit together
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`the teachings of multiple publications. I understand that obviousness analysis there-
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`fore takes into account the inferences and creative steps that a person of ordinary
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`skill in the art would employ under the circumstances.
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`26.
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`I understand that a particular combination may be proven obvious by
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`showing, among other things, that it was obvious to try the combination. For exam-
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`ple, when there is a design need or market pressure to solve a problem and there are
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`a finite number of identified, predictable solutions, a person of ordinary skill has
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`good reason to pursue the known options within his or her technical grasp because
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`the result is likely the product not of innovation but of ordinary skill and common
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`sense.
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`27. The combination of familiar elements according to known methods is
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`likely to be obvious when it does no more than yield predictable results. When a
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`work is available in one field of endeavor, design incentives and other market forces
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`can prompt variations of it, either in the same field or a different one. If a person of
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`ordinary skill can implement a predictable variation, the patent claim is likely obvi-
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`ous.
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`28.
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`I understand that a proper obviousness analysis focuses on what was
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`known or obvious to a person of ordinary skill in the art, not just the patentee. Ac-
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`cordingly, I understand that any need or problem known in the field of endeavor at
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`the time of invention and addressed by the patent can provide a reason for combining
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`the elements in the manner claimed.
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`29.
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`I understand that a claim can be obvious in light of a single reference,
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`without the need to combine references, if the elements of the claim that are not
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`found explicitly or inherently in the reference can be supplied by the common sense
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`of one of skill in the art.
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`30.
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`I understand that secondary indicia of non-obviousness may include (1)
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`a long felt but unmet need in the prior art that was satisfied by the invention of the
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`patent; (2) commercial success of processes covered by the patent; (3) unexpected
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`results achieved by the invention; (4) praise of the invention by others skilled in the
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`art; (5) taking of licenses under the patent by others; (6) deliberate copying of the
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`invention; (7) failure of others to find a solution to the long felt need; and (8) skep-
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`ticism by experts. I understand that evidence of secondary indicia of non-obvious-
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`ness, if available, should be considered as part of the obviousness analysis.
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`31.
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`I also understand that there must be a relationship between any such
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`secondary considerations and the invention. I further understand that contemporane-
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`ous and independent invention by others is a secondary consideration supporting an
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`obviousness determination.
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`32.
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`In sum, my understanding is that prior art teachings are properly com-
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`bined where a person of ordinary skill in the art having the understanding and
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`knowledge reflected in the prior art and motivated by the general problem facing the
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`inventor, would have been led to make the combination of elements recited in the
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`claims. Under this analysis, the prior art references themselves, or any need or prob-
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`lem known in the field of endeavor at the time of the invention, can provide a reason
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`for combining the elements of multiple prior art references in the claimed manner.
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`33.
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`I understand that obviousness in an inter partes review must be shown
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`by a preponderance of the evidence.
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`V. Level of Ordinary Skill in the Art
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`34. A person of ordinary skill in the art related to, and at the time of the
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`invention of, the ’781 Patent (“POSITA”) would have been someone with a working
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`knowledge of electrical engineering, including sensors, processing systems, and no-
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`tification circuitry. The person would have a Bachelor of Science degree in electrical
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`engineering or a comparable field, in combination with training or at least two years
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`of related work experience with vehicular systems such as automotive electronics. I
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`am familiar with the knowledge and capabilities of one of ordinary skill in these
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`areas based on my experience working with colleagues from academia, with under-
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`graduate and graduate students, and with engineers practicing in industry.
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`VI. Brief Overview of the ’781 Patent
`35. The ’781 patent is generally related to an “[a]pparatus for optimizing
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`operation of an engine-driven vehicle.” EX1001, Abstract. “It has long been rec-
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`ognized that the improper operation of a vehicle may have many adverse effects.
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`For example, the fuel efficiency of a vehicle may vary dramatically based upon how
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`the vehicle is operated.” EX1001, 1:12-15. The ’781 patent refers to operating a
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`vehicle at excessive speeds, excessive RPMs, and excessive manifold pressures as
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`leading to reduced fuel economy and increased operating costs. EX1001, 1:15-18.
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`These increased operating costs can be considerable, particularly for an owner or
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`operator of a fleet of vehicles. EX1001, 1:17-20. Accordingly, the ’781 patent de-
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`scribes a processor subsystem for determining when to issue notifications as to rec-
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`ommended changes in vehicle operation that, when executed by the driver, may in-
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`crease efficient vehicle operation. Notably, the recited “processor subsystem” is not
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`limited to any specific physical implementation. For example, the ‘781 patent only
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`describes the processor subsystem in terms of functionality without restricting the
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`physical components or hardware. See EX1001 at 5:54-59, 13:46-52.
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`36. The ’781 patent describes three types of circuits for issuing notifica-
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`tions that indicate operating inefficiencies: a shift notification circuit (upshift and
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`downshift), a fuel overinjection notification circuit, and a vehicle proximity alarm
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`circuit. The upshift notification circuit issues a notification that the engine of the
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`vehicle is being operated at an excessive engine speed. EX1001, 5:3-8. The down-
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`shift notification circuit issues a notification that the engine of the vehicle is being
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`operated at an insufficient engine speed. EX1001, 5:20-23. The fuel overinjection
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`notification circuit issues a notification that excessive fuel is being supplied to the
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`engine of the vehicle, and the vehicle proximity alarm circuit issues an alarm when
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`the vehicle is too close to an object. EX1001, 7:18-22. In the context of the ’781
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`Patent, the plain and ordinary meaning of “excessive fuel is being supplied” is that
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`more fuel is being supplied than is desired according to some threshold metric such
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`as a target fuel efficiency.
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`37. According to the ’781 patent, a series of sensors, including road speed
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`sensor 18, RPM sensor 20, manifold pressure sensor 22, throttle sensor 24, wind-
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`shield wiper sensor 30, and brake sensor 32, are coupled to processor subsystem 12,
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`and are periodically polled by the processor subsystem to determine their states or
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`levels. EX1001, 5:65-6:4. The system 10 includes a memory subsystem 14, which
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`stores information used by the processor subsystem 12 to determine whether to take
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`corrective actions and/or issue notifications via activation of the notification circuits.
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`EX1001, 6:43-46. In the context of ’781 Patent, the plain and ordinary meaning of
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`the processor subsystem “activat[ing]” a notification circuit is where the processor
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`subsystem determines when to provide a notification using the specified circuit. See
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`e.g., EX1001 at 13:2-17.
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`38. Notably, beyond the broad goal of “optimizing vehicle operation,” the
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`’781 Patent does not set forth any specific advantages of the combination of notifi-
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`cation circuits it integrates into a vehicle. In other words, there is no teaching in the
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`’781 Patent that any particular set of driver notification circuits result in an unex-
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`pected increase in efficient vehicle operation. Rather, a POSITA reading the ’781
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`Patent would have understood that the driver notification circuits independently con-
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`tribute to potential increases in efficient and/or safe vehicle operation, the selection
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`of which would have simply been a design choice.
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`VII. Combinations based on Westbrook
`A. M. H. Westbrook & J. D. Turner, AUTOMOTIVE SENSORS (1994)
`(“Westbrook”)
`39. Westbrook is a textbook that provides a detailed description of many of
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`the sensors in use in motor vehicles at the time of its publishing, as well as examples
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`of the control systems in which those sensors were used. See Westbrook (EX1002)
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`at x. The objective of these vehicle control systems and the sensors upon which they
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`rely is to realize “an integrated total vehicle system which can be looked upon as a
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`complete vehicle control system, with all systems being fully interactive.” Id. at
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`239. Such an integrated vehicle simplifies the task of a driver navigating the vehicle
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`in a complex and ever-changing environment. Id. at xv. Thus, one goal is to use
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`these control systems to automate “as many as possible of the mechanical functions
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`of the vehicle.” Id. Another goal of these control systems—and a recurring theme
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`throughout Westbrook—is “to make the vehicle operate more efficiently and effec-
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`tively within its total environment”. Id. at 29.
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`40. Each of the automated control systems in a vehicle relies upon data col-
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`lected by sensors. Id. at xiii. At the time of Westbrook, a car “contain[ed] on average
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`about 30 sensors,” which “include, for example, the transducers necessary to ensure
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`efficient and clean operation of the engine.” Id. at 207. Westbrook includes a sam-
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`pling of these sensors in a page-and-a-half long table starting on page 9. The partic-
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`ular sensors listed in this table are “typical” for “engine and transmission (‘power-
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`train’) control.” Id. at 9. By their very nature, these sensors collectively monitor
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`operation of the vehicle in which they are installed and gather data. Among West-
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`brook’s list of sensors are an inlet manifold absolute or differential pressure sensor,
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`a crankshaft mounted timing/trigger/speed sensor (i.e., a sensor that measures engine
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`speed in RPM), a road speed sensor, and a throttle position sensor. Id.
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`41. Each of these sensors is connected to one or more microprocessors,
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`which “decide what action should be taken” based on the data collected by the sen-
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`sor. Id. at at xiii. In FIG. 12.2 (reproduced below), Westbrook illustrates numerous
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`sensors connected to a “central microprocessor” via “in-vehicle data links or multi-
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`plex systems.” Id. at 4, 207-08.
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`42. This “central microprocessor” would in turn be connected to the various
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`control systems throughout the vehicle, such as those shown in FIG. 2.1 (reproduced
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`below). See id. Each of these control systems may themselves include one or more
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`microprocessors for taking actions specific to that control system based on the data
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`provided by the sensors. Indeed, at the time of Westbrook, it was common for vehi-
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`cles include a number of microprocessors for accomplishing the various automated
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`tasks needed to control the vehicle1. These microprocessors serve as a processing
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`subsystem for the entire vehicle, connected either directly or indirectly via another
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`processor to the various sensors positioned throughout the vehicle.
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`1 See, e.g., Trevor Mellard, AUTOMOTIVE ELECTRONIC SYSTEMS (1991); AU-
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`TOMOTIVE HANDBOOK (3d ed. 1993); Ronald Jurgen, AUTOMOTIVE ELECTRONICS
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`HANDBOOK (1994).
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`43. These microprocessors are often coupled to semiconductor memory
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`that stores information (e.g., look-up tables) that the processor relies upon to execute
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`its routines. See Westbrook (EX1002) at xiii, xvi, 10. For example, Westbrook de-
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`scribes that “pressure and speed signals [] provide the input to a microprocessor
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`which is programmed to look up the optimum advance angle from a three-dimen-
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`sional table relating speed, load, and advance angle and stored in memory (see
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`figure 2.2).” Id. at 10 (emphasis added).
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`44. A look-up table is effectively just a large set of data points that are cor-
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`related with one another in the table according to a predefined relationship. See id.
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`at 10-11. A microprocessor uses a look-up table by taking one or more dimensions
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`of measured sensor data to “look-up” a correlated output value stored in the table.
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`Thus, instead of utilizing complex and processor intensive calculations, a micropro-
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`cessor is simply searching a large table of stored values or “set points.” In West-
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`brook’s example of controlling ignition advance, a microprocessor would collect a
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`manifold pressure and engine speed reading from the appropriate sensors and search
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`its memory to find the manifold pressure and engine speed set points corresponding
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`to the measured data in the look-up table. See id. Correlated with those manifold
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`pressure and engine speed set points is an ignition advance angle output value that
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`the microprocessor reads from memory and uses to control the ignition system. See
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`id.
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`45. Westbrook also describes the use of memory for individual sensor di-
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`agnostics and calibration, including storing prior levels of sensed pressure and RPM
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`values. For example, Westbrook describes that systems can use low-cost sensors
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`“with relatively poor linearity but high repeatability” by initially cycling each of the
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`sensors “under carefully controlled condition through their full operating cycle, ide-
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`ally in situ in the vehicle.” Westbrook (EX1002) at 5, 239-40. The incremental
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`change of the sensor output “then represents the calibration of the sensor.” Id. The
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`vehicle stores this data in “memory where it can be used as the calibration curve
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`against which future operational measurements are made.” Id. In other words, pre-
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`viously measured values are stored and can be compared and calibrated with cur-
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`rently measured values. This means the vehicle stores, at least temporarily, present
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`and prior values for each of the sensors to facilitate diagnostics and calibration. Id.
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`46. Each of these building blocks represents the constituent parts of each
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`of the various vehicle control systems described by Westbrook. The control systems
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`described by Westbrook include systems that determine “optimum operation [of the
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`transmission] for economy and performance” (id. at 20), systems that determine fuel
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`flow in order to meet the steadily increasing “demand for the measurement of ‘in-
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`stantaneous’ and trip fuel economy” (id. at 25), and systems for collision avoidance
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`that “perceiv[e] the environment and traffic situation using multiple sensors [e.g.,
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`radar], predict[] possible collisions with objects and other vehicles and provid[e]
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`appropriate driver information and possible intervention where appropriate” (id. at
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`214, 230).
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`47. One of the control systems for which Westbrook devotes specific atten-
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`tion is the “collision avoidance and autonomous driver warning system.” Id. at 229-
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`234. Westbrook describes the use of vehicle radar to detect “objects in front of the
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`vehicle and in the same road lane which are either stopped or travelling at signifi-
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`cantly lower speed.” Id. at 229-30 (emphasis added). Radar is a device that relies
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`upon the emission (via a transmitter) and reception (via a receiver) of electromag-
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`netic waves to detect information about objects relative to the radar’s antenna. In
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`this regard, the radar system is a “detector” in that it detects information about phys-
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`ical objects. A POSITA would have understood that such detection relies upon the
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`radar system’s ability to measure the distance to and relative speed of these detected
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`objects.
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`48. Like the other sensors described by Westbrook, the radar detector de-
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`scribed as part of the collision avoidance system senses information about the envi-
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`ronment of the vehicle and returns it to the relevant control systems within the vehi-
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`cle. Thus, like the other sensors pictured in FIG. 12.2, a POSITA would have un-
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`derstood that the radar detector would be connected to the “central processor” and
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`could be connected to one or more other processors specific to the collision avoid-
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`ance system—altogether part of the vehicle’s processor subsystem. In fact, a
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`POSITA would have understood that the “collision avoidance and autonomous
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`driver warning system” is a type of “traffic and road information system” shown in
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`FIG. 2.1. The processor subsystem processes the input from the vehicle radar “to
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`give a driver warning at a high level of reliability.” Id. at 230. The “driver warning”
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`output and display of the collision avoidance and autonomous driver warning sys-
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`tems described by Westbrook are forms of a vehicle proximity alarm circuit that
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`issues an alarm that the vehicle is too close to another object.
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`49. One well-known method of processing the speed and distance data de-
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`tected by Westbrook’s radar in order to generate the desribed driver warning was
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`through a look-up routine based on a vehicle speed/stopping distance table. West-
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`brook describes optimization of engine operation through the use of data “stored in
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`a microprocessor memory in the form of a look-up table.” See Westbrook (EX1002)
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`at xvi, 7, 10, 13. Though Westbrook does not explicitly describe a “first vehicle
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`speed/stopping distance table,” a POSITA would have found it obvious to store such
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`a table for use by the exemplary vehicle’s central processor in implementing the
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`functionality of the collision avoidance and autonomous driver warning systems de-
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`scribed by Westbrook2. Such tables reduce required processing power and increase
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`the speed of performing complex cal