UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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` ____________
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`UNIFIED PATENTS INC.
`Petitioner
`
`v.
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`GEOGRAPHIC LOCATION INNOVATIONS, LLC
`Patent Owner
`
`____________
`
`Case No. IPR2017-02022
`Patent No. 7,917,285
` ____________
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`
`
`DECLARATION OF SCOTT ANDREWS
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`IPR2017-02022
`Unified EX1003 Page 1
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
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`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`GEOGRAPHIC LOCATION INNOVATIONS, LLC
`Patent Owner
`
`____________
`
`Case No. IPR2017-02022
`Patent No. 7,917,285
` ____________
`
`
`
`DECLARATION OF SCOTT ANDREWS
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`IPR2017-02022
`Unified EX1003 Page 1
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`I, Scott Andrews, hereby declare the following:
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`I.
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`INTRODUCTION
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`1.
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`I, Scott Andrews, have been retained by counsel for Petitioner Unified
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`Patents, Inc. (“Petitioner”) as a technical expert in the above-captioned case.
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`Specifically, I have been asked by counsel for Petitioner to render certain opinions
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`in regards to the accompanying IPR petition with respect to U.S. Patent No.
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`7,917,285 (“the ’285 Patent”). I understand that the Challenged Claims are claims
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`1, 2, 5-7, 9, and 13-18. My opinions are limited to those Challenged Claims.
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`2. My compensation in this matter is not based on the substance of my
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`opinions or the outcome of this matter. I have no financial interest in Petitioner. I
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`have been informed that Geographic Location Innovations, LLC (“Geographic”) is
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`the current assignee of the ’285 Patent. I have no financial interest in Petitioner or
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`Geographic, and I have no other interest in the outcome of this matter.
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`3.
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`In reaching my opinions in this matter, I have reviewed the following
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`materials:
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`• U.S. Patent No. 7,917,285 to Rothschild (Ex. 1001);
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`• U.S. Patent No. 5,987,381 to Oshizawa (Ex. 1004, Oshizawa);
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`• U.S. Patent Application Publication No. 2002/0174360 to Ikeda (Ex.
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`1005, Ikeda);
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`• U.S. Patent Application Publication No. 2005/0221876 to Van Bosch et
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`al. (Ex. 1006, Van Bosch);
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`• U.S. Patent No. 6,175,803 to Chowanic et al. (Ex. 1007, Chowanic);
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`• U.S. Patent Application Publication No. US 2006/0058953 to Cooper et
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`al. (Ex. 1008, Cooper);
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`• U.S. Patent No. 4,502,123 to Minami et.al. (Ex. 1011, Minami);
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`• Robert L. French, Automobile Navigation: Where is it Going?, IEEE
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`Aerospace and Electronic Systems Magazine (Volume: 2, Issue: 5, May
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`1987) (Ex. 1012, French 1987);
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`• Robert L. French, Historical overview of automobile navigation
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`technology, 36th IEEE Vehicular Technology Conference (1986) (Ex.
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`1013, French 1986);
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`• V.W. Imnan and J.I. Peters, TravTek Global Evaluation and Executive
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`Summary, U.S. Department of Transportation Federal Highway
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`Administration, Pub. No. FHWA-RD-96-031 (March 1996) (Ex. 1014,
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`Imnan);
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`• C. Blumentritt, K. Balke, E. Symour, R. Sanchez, TravTek System
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`Architecture Evaluation, U.S. Department of Transportation Federal
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`Highway Administration, Pub. No. FHWA-RD-94-141 (July 1995) (Ex.
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`1015, Blumentritt);
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`• R. Lind, R. Schumacher, R. Reger, R. Olney, H. Yen, and R. Freeman,
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`The network vehicle-a glimpse into the future of mobile multi-media, The
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`AIAA/IEEE/SAE Digital Avionics Systems Conference Proceedings,
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`17th DASC. (1998) (Ex. 1016, Lind);
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`• Network Vehicle Screenshots (Ex. 1017, Network Vehicle Screenshots);
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`• Yilin Zhao, Telematics: Safe and Fun Driving, IEEE Intelligent Systems,
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`10-14 (2002) (Ex. 1009, Zhao);
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`• K.Y. Cho, C.H. Bae, Y. Chu, and M. W. Suh, Overview of Telematics: A
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`System Architecture Approach, International Journal of Automotive
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`Technology, Vol. 7, No. 4, 509-517 (2006) (Ex. 1010, Cho); and
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`• Takao Kamai, Hayami Encho, Ichiro Kugo, Katsuharu Yokoyama, and
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`Masato Maruoka, MONET – Compatible Car-mounted Information
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`Terminal, Fujitsu Ten Tech. J., No. 11 (1998) (Ex. 1019, Kamai).
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`A. Qualifications
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`4.
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`I have over 25 years of experience in fields relevant to the ’285 Patent,
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`including vehicle navigation systems and telematics-aided vehicle navigation
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`systems. In various positions at, among others, TRW and Toyota, I have been
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`responsible for research and development projects relating to, among others,
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`numerous vehicle navigation systems, information systems, and user interface
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`systems.
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`5.
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`I received an undergraduate Bachelor of Science degree in Electrical
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`Engineering from the University of California, Irvine in 1977. I received a
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`Master’s of Science degree in Electronic Engineering from Stanford University in
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`1982.
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`6.
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`From 1977 to 1983, I held engineering positions at Ford Aerospace and
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`Teledyne Microwave where I worked on, among other things, transmitter-receiver
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`systems for guided missiles and other related military electronics.
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`7.
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`From 1983 to 1993, I worked at TRW, Inc. (“TRW”) in the Space &
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`Electronics Group, where I served as a project manager, a department manager,
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`and an assistant program manager on a variety of spacecraft communications
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`systems projects. My last position at TRW in the Space & Electronics Group was
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`as the manager of the Monolithic Microwave Integrated Circuits (“MMIC”)
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`Products Organization. In that role, I developed TRW’s commercial gallium
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`arsenide (GaAs) MMIC business. During my time in the MMIC Products
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`Organization, I helped produce one of the first cellular phone related RF integrated
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`circuits. I also developed the first single chip 94 GHz radar, intended for use in
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`automotive adaptive cruise control systems. While I was at TRW in the Space &
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`Electronics Group, I received several awards for outstanding performance on
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`independent research and development projects.
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`8.
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`In 1993, while still at TRW, I moved to the Automotive Electronics
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`Group and became the Director of Systems Engineering and Advanced Products.
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`In this role, I was responsible for the overall management of TRW’s advanced
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`development programs in the automotive electronics space. These programs
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`included, among other things, wireless remote keyless entry systems, vehicle
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`tracking and location systems (e.g., roadside assistance and emergency response
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`systems, including those using global positioning system (“GPS”) technology),
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`emergency vehicle warning systems (e.g., transmitter-receiver systems that would
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`provide a warning inside the user’s vehicle when an active emergency vehicle was
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`in the vicinity), automotive collision avoidance radar, and other types of vehicle
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`information systems. I served in this role until 1996.
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`9. While at TRW, I also led the development of an in-vehicle information
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`system based on off-board map databases, wireless data communications, and
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`radio based location technologies, and developed business and product strategies
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`related to various off-board information services.
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`10. From 1996 to 2000, I worked at Toyota Motor Corporation (“Toyota”)
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`at the Toyota Headquarters in Toyota City, Japan, as a Project General Manager in
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`the R&D Management Division. My
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`responsibilities
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`included
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`the
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`conceptualization and development of multimedia systems and new technology
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`products and services for Toyota’s future generations of passenger vehicles. My
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`work at Toyota included, among other things, the development of system concepts
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`for RFID tag based tolling and secure vehicle identification systems. These
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`concepts included the ability to securely query the identity of a passing automobile
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`using a short range radio communications system, and to receive an encrypted
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`response containing, among other things the vehicle license and VIN number.
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`Several navigation related systems and services, including systems for supporting
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`various ways of inputting destination information in vehicle navigation systems.
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`For example, one system I worked with, the Toyota Monet (MObile NETwork)
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`system included a feature wherein a user could identify a location on a map
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`displayed on a web page, and then send that location over the internet to a user’s
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`Monet device in their car as an email attachment. The user could then select the
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`location to automatically set it as the navigation destination. I also developed
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`various other navigation related systems, such as traffic information delivery and
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`display systems, and systems for delivering internet audio from a remote server to
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`the car.
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`11. While at Toyota, I also established the Automotive Multimedia
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`Interface Collaboration (“AMI-C”), a partnership of carmakers to develop a
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`uniform computing architecture for vehicle multimedia systems. AMI-C was
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`primarily aimed at developing standards for the integration and use of consumer
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`devices in vehicles, and for a common computing platform to facilitate the rapid
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`introduction of new systems and software in the vehicle. For example, a typical
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`AMI-C system might support the aftermarket integration of a cellular telephone
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`subsystem and supporting software applications to provide location-based services
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`such as off-board navigation and traffic information to support an in-vehicle
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`navigation display system.
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`12.
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`In 2000, I founded Cogenia, Inc. to develop an enterprise-class mobile
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`data management software system. While at Cogenia, Inc., I developed and
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`oversaw the company’s business concept and strategic plan, which led to the
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`successful raising of over $2.2M in capital in less than ten months. I also led the
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`executive team in the development of an enterprise data system for managing data
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`between multiple user endpoints or devices. This included home and work
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`computing environments, as well as multiple mobile devices. In each case, key
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`data useful to the user was pre-positioned so that it could be easily accessed when
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`and where the user needed it the most. Cogenia, Inc. ceased operations in
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`December 2000.
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`13.
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`I founded Cogenia Partners, LLC as an independent consultant in the
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`intelligent vehicles and mobile systems industry in January 2001. My primary
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`clients have been various navigation and mobile device makers, automotive
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`manufacturers, and the U.S. Department of Transportation. Since 2001 my work
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`has focused on systems for delivery of services to vehicle occupants, either through
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`personal devices, or through equipment embedded in the vehicle. These systems
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`have included applications for vehicle and roadway safety, information and
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`entertainment, and operational concepts and system designs for HOT lane
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`management using dedicated short range and wide area cellular communications.
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`Between 2006 and 2011, I served as the Chief System Architect for a large
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`Connected Vehicle test bed in the greater Detroit area. This project included
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`extensive systems engineering work, and real world test and evaluation of short-
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`range vehicle to roadside and vehicle to vehicle communications systems and
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`applications, including various tolling applications. This work also included active
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`involvement with various vehicle communications standards, including SAE
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`J2735, SAE J2945, and a variety of standards associated with Dedicated Short
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`Range Communications
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`(DSRC) systems used,
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`for example
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`in vehicle
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`management, traffic data collection and distribution, safety, tolling and other
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`applications. More recently I have served as a technical lead on a project to support
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`the National Highway Traffic Safety Administration (NHTSA) with
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`the
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`development of performance standards in anticipation of an upcoming rule to
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`mandate the inclusion of connected vehicle equipment in vehicles. I have also
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`developed a variety of test and evaluation systems for the Federal Highway
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`Administration to support the assessment of connected vehicle systems in the
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`roadway environment.
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`14.
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`I am a member of the Institute of Electrical and Electronics Engineers
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`(“IEEE”), the IEEE Standards Association, the Institute of Navigation (“ION”),
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`and the International Council on Systems Engineering (“INCOSE”), and the
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`Society of Automotive Engineers (“SAE”).
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`15.
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`I am a named inventor on nine U.S. patents, three Japanese patents,
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`and one European patent, including U.S. Patent Nos. 7,802,263; 8,209,705; and
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`8,566,843, all three entitled “System, Method and Computer Program Product for
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`Sharing Information in a Distributed Framework” (filed December 15, 2003, July
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`30, 2008, and June 22, 2012, respectively; issued September 21, 2010, June 26,
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`2012, and October 22, 2013, respectively); U.S. Patent No. 7,742,603, entitled
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`“Security for Anonymous Vehicular Broadcast Messages” (filed March 27, 2006,
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`issued June 22, 2010); and U.S. Patent No. 6,122,682, entitled “Communication
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`System for Controlling Data Processing According to a State of a Communication
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`Terminal Device” (filed March 23, 1998, issued September 19, 2000).
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`16.
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`I have authored numerous technical papers, and have been invited to
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`give professional talks at various conferences, including Mobility 21, the 4G
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`Summit,
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`the World Congress on Intelligent Transportation Systems,
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`the
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`International Task Force on Vehicle Automation, the International Congress on
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`Transportation Electronics (Convergence), and others.. My curriculum vitae (Ex.
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`1018 of accompanying Petition) includes a list of all publications I have authored
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`in the last 10 years and provides further detail regarding my background and
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`qualifications.
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`17.
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`In summary, I have extensive familiarity with systems, networks,
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`architectures, and methods related to vehicle communications and navigation
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`systems, and I am familiar with what the states of these technologies were at the
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`relevant April 2006 timeframe of the ’285 Patent and before.
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`II. LEGAL FRAMEWORK
`18.
`I am a technical expert and do not offer any legal opinions. However,
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`counsel has informed me that in proceedings before the USPTO the claims of an
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`unexpired patent are to be given their broadest reasonable interpretation in view of
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`the specification from the perspective of one skilled in the art. The broadest
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`reasonable interpretation does not mean the broadest possible interpretation.
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`Rather, the meaning given to a claim term must be consistent with the ordinary and
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`customary meaning of the term (unless the term has been given a special definition
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`in the specification), and must be consistent with the use of the claim term in the
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`specification and drawings. Further, the broadest reasonable interpretation of the
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`claims must be consistent with the interpretation that those skilled in the art would
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`reach. I have been informed that the ’285 Patent has not expired.
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`19.
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`I have also been informed that the implicit or inherent disclosures of a
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`prior art reference may anticipate the claimed invention. Specifically, if a person
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`having ordinary skill in the art at the time of the invention would have known that
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`the claimed subject matter is necessarily present in a prior art reference, then the
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`prior art reference may “anticipate” the claim. Therefore, a claim is “anticipated”
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`by the prior art if each and every limitation of the claim is found, either expressly
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`or inherently, in a single item of prior art.
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`20. Counsel has also informed me that a person cannot obtain a patent on
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`an invention if his or her invention would have been obvious to a person of
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`ordinary skill in the art at the time the invention was made. A conclusion of
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`obviousness may be founded upon more than a single item of prior art. In
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`determining whether prior art references render a claim obvious, counsel has
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`informed me that courts consider the following factors: (1) the scope and content
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`of the prior art, (2) the differences between the prior art and the claims at issue, (3)
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`the level of skill in the pertinent art, and (4) secondary considerations of non-
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`obviousness. In addition, the obviousness inquiry should not be done in hindsight.
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`Instead, the obviousness inquiry should be done through the eyes of one of skill in
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`the relevant art at the time the patent was filed.
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`21.
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`In considering whether certain prior art renders a particular patent
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`claim obvious, counsel has informed me that courts allow a technical expert to
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`consider the scope and content of the prior art, including the fact that one of skill in
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`the art would regularly look to the disclosures in patents, trade publications,
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`journal articles, industry standards, product literature and documentation, texts
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`describing competitive technologies, requests for comment published by standard
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`setting organizations, and materials from industry conferences. I believe that all of
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`the references that my opinions in this IPR are based upon are well within the
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`range of references a person of ordinary skill in the art would consult to address the
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`type of problems described in the Challenged Claims.
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`22.
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`I understand that the United States Supreme Court’s most recent
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`statement on the standard for determining whether a patent is obvious was stated in
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`2007 in the KSR decision. Specifically, I understand that the existence of an
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`explicit teaching, suggestion, or motivation to combine known elements of the
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`prior art is a sufficient, but not a necessary, condition to a finding of obviousness.
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`Thus, the teaching suggestion-motivation test is not to be applied rigidly in an
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`obviousness analysis. In determining whether the subject matter of a patent claim
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`is obvious, neither the particular motivation nor the avowed purpose of the
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`patentee controls. Instead, the important consideration is the objective reach of the
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`claim. In other words, if the claim extends to what is obvious, then the claim is
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`invalid.
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` I further understand the obviousness analysis often necessitates
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`consideration of the interrelated teachings of multiple patents, the effects of
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`demands known to the technological community or present in the marketplace, and
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`the background knowledge possessed by a person having ordinary skill in the art.
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`All of these issues may be considered to determine whether there was an apparent
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`reason to combine the known elements in the fashion claimed by the patent.
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`23.
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`I also understand that in conducting an obviousness analysis, a precise
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`teaching directed to the specific subject matter of the challenged claim need not be
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`sought out because it is appropriate to take account of the inferences and creative
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`steps that a person of ordinary skill in the art would employ. I understand that the
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`prior art considered can be directed to any need or problem known in the field of
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`endeavor at the time of invention and can provide a reason for combining the
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`elements of the prior art in the manner claimed. In other words, the prior art need
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`not be directed towards solving the same specific problem as the problem
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`addressed by the patent. Further, the individual prior art references themselves
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`need not all be directed towards solving the same problem. Under the KSR
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`obviousness standard, common sense is important and should be considered.
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`Common sense teaches that familiar items may have obvious uses beyond their
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`primary purposes.
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`24.
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`I also understand that the fact that a particular combination of prior art
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`elements was “obvious to try” may indicate that the combination was obvious even
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`if no one attempted the combination. If the combination was obvious to try
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`(regardless of whether it was actually tried) or leads to anticipated success, then it
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`is likely the result of ordinary skill and common sense rather than innovation. I
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`further understand that in many fields it may be that there is little discussion of
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`obvious techniques or combinations, and it often may be the case that market
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`demand, rather than scientific literature or knowledge, will drive the design of an
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`invention. I understand that an invention that is a combination of prior art must do
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`more than yield predictable results to be non-obvious.
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`25.
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`I understand that for a patent claim to be obvious, the claim must be
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`obvious to a person of ordinary skill in the art at the time of the invention. I
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`understand that the factors to consider in determining the level of ordinary skill in
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`the art include (1) the educational level and experience of people working in the
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`field at the time the invention was made, (2) the types of problems faced in the art
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`and the solutions found to those problems, and (3) the sophistication of the
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`technology in the field.
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`26.
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`I understand that at least the following rationales may support a finding
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`of obviousness:
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`•
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`•
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`•
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`•
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`•
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`Combining prior art elements according to known methods to yield
`predictable results;
`Simple substitution of one known element for another to obtain
`predictable results;
`Use of a known technique to improve similar devices (methods, or
`products) in the same way;
`Applying a known technique to a known device (method, or product)
`ready for improvement to yield predictable results;
`“Obvious to try”—choosing from a finite number of identified,
`predictable solutions, with a reasonable expectation of success;
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`•
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`•
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`•
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`•
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`27.
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`A predictable variation of work in the same or a different field of
`endeavor, which a person of ordinary skill would be able to
`implement;
`If, at the time of the alleged invention, there existed a known problem
`for which there was an obvious solution encompassed by the patent’s
`claim;
`Known work in one field of endeavor may prompt variations of it for
`use in either the same field or a different one based on technological
`incentives or other market forces if the variations would have been
`predictable to one of ordinary skill in the art; and/or
`Some teaching, suggestion, or motivation in the prior art that would
`have led one of ordinary skill to modify the prior-art reference or to
`combine prior-art reference teachings to arrive at the claimed
`invention.
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`I understand that even if a prima facie case of obviousness is
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`established, the final determination of obviousness must also consider “secondary
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`considerations” if presented. In most instances, the patentee raises these secondary
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`considerations of non-obviousness. In that context, the patentee argues an
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`invention would not have been obvious in view of these considerations, which
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`include: (a) commercial success of a product due to the merits of the claimed
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`invention; (b) a long-felt, but unsatisfied need for the invention; (c) failure of
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`others to find the solution provided by the claimed invention; (d) deliberate
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`copying of the invention by others; (e) unexpected results achieved by the
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`invention; (f) praise of the invention by others skilled in the art; (g) lack of
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`independent simultaneous invention within a comparatively short space of time;
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`(h) teaching away from the invention in the prior art.
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`28.
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` I further understand that secondary considerations evidence is only
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`relevant if the offering party establishes a connection, or nexus, between the
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`evidence and the claimed invention. The nexus cannot be based on prior art
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`features. The establishment of a nexus is a question of fact. While I understand
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`that Patent Owner has not offered any secondary considerations at this time, I will
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`supplement my opinions in the event that Patent Owner raises secondary
`
`considerations during the course of this proceeding.
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`III. OPINION
`A. Background of the Technology
`
`29.
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`I was asked to briefly summarize the background of the prior art from
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`the standpoint of a person having ordinary skill in the art (a “PHOSITA”), which
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`person I have defined below, prior to the April 28, 2006 priority date of the ’285
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`Patent. The navigation/positional information systems described in the ’285 Patent
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`were well known for many years prior to 2006. Development in the field of
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`vehicle navigation systems began in earnest in the 1980s. Even early navigation
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`systems were able to provide positional and navigational information to the user.
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`The first introduction of an in-vehicle electronic navigation system was the Honda
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`Electro Gyrocator. This map based navigation system was introduced in August
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`1981, as a dealer option for the second-generation Honda Accord. This system
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`was based on a dead reckoning system that used a gyro and wheel sensors to
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`measure the motion of the vehicle from a known point. As the vehicle was driven,
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`a small dot would move on the screen mimicking the motions of the vehicle.
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`Transparent maps were then placed over the screen so that the user could relate the
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`position of the dot to the road network. When the dot reached the edge of the
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`screen the user would select the next map overlay and reset the dot to the
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`appropriate point on the new map. A photograph of this system is shown below.
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`(http://world.honda.com/history/challenge/1981navigationsystem/index .html):
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`
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`In 1991 Toyota introduced the first fully integrated touch screen
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`30.
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`system that was able to control the entire audio system, the climate control system,
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`trip computer functions, navigation, and television. The EMV system was initially
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`IPR2017-02022
`Unified EX1003 Page 18
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`put into production in 1991 on the Toyota Soarer (known in the U.S. as the Lexus
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`SC300 sports coupe). The figure below shows the basic EMV unit. This system
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`differed from the Honda Electro Gyrocator because it contained a digital map
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`database that allowed the map to scroll across the screen as the vehicle moved.
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`Toyota Soarer Electro MultiVision System (Circa 1993)
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`31. Vehicle navigation systems proved to be very popular in Japan. In
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`addition to integrated, factory-installed systems, numerous aftermarket navigation
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`systems became available in the consumer market in the 1995 time frame. I
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`attended the Second International World Congress on Intelligent Transportation
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`Unified EX1003 Page 19
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`Systems, in Yokohama Japan in the fall of 1995. At that conference no fewer than
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`twenty different systems were demonstrated in a fleet of demonstration vehicles.
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`This massive demonstration was primarily intended to launch the Japanese Vehicle
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`Information Communications System, known generally as VICS. Each of the
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`demonstrated navigation systems included wireless communications capability to
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`allow the system to receive traffic information that was then displayed on the
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`navigation screen. This system was launched in the fall of 1995 (at the conference)
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`and became operational in most major Japanese metro regions in late 1996.
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`32. VICS was the result of a public-private partnership between the
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`Japanese government, the Japanese auto makers, and the Japanese electronic
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`equipment manufacturers. The Japanese government established the VIC center,
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`which was a central facility in Tokyo that collected traffic information from a
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`variety of sources and distributed it through three different mechanisms: infrared
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`beacons mounted on city infrastructure, such as traffic signals for detailed city
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`center information; an FM sub-carrier for wide area traffic congestion; and a
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`microwave beacon system for expressway information. The cost of operating the
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`VICS infrastructure was partially offset by a fee assessed on the sale of every
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`VICS-equipped navigation unit.
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`33.
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`In 1996, when I was working in Japan for Toyota, navigation systems
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`were standard in many cars. In any auto parts store, one could select from dozens
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`Unified EX1003 Page 20
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`of aftermarket navigation systems. Almost all of these were either equipped with
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`the VICS system or were VICS- capable, which meant that they could accept data
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`from a separately purchased VICS receiver. During my four years in Japan, 1996-
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`2000, the availability of VICS data grew from a few intersections in the city
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`centers to being available for almost every arterial road and effectively all city
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`streets in any reasonably sized town.
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`34. Toyota also launched an online information service known as Monet.
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`Monet provided a universal connector to which the user could attach their cellular
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`phone. The system would use the cellular phone to interact with a back-end server
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`that provides an array of services. For example a user could view real time video
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`from traffic cameras at selected intersections, obtain restaurant information,
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`including menus, and receive email in the car. The email function also included a
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`feature whereby other users could identify a location on a map displayed on a web
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`page, for example on a desktop computer, and send that location to a specified
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`Monet unit. Upon receiving the location information, the Monet user could then,
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`with the press of a button, cause that location to be set as the navigation
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`destination. The Monet System is partially described in a publication form Fujitsu
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`Ten, one of the hardware manufacturers for the system (see Ex. 1019, Kamai).
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`35. U.S. Patent No. 4,502,123 to Minami et.al. (Ex. 1011), which was filed
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`in 1982 and issued in 1985, describes another early navigation system “arranged to
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`IPR2017-02022
`Unified EX1003 Page 21
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`display a road map in accordance with road map information from a cassette tape,
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`and the present location of a motor vehicle equipped with the navigation system.”
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`Ex. 1011, Minami at Abstract. Using Minami’s system “the user who may be the
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`motor vehicle driver or an occupant, will be informed with the present location and
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`the travelling locus both shown on the map displayed on the CRT screen.” Id.
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`11:10-12. Minami accomplishes this using distance and direction sensors to
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`determine the present location of the vehicle via dead reckoning and map matching
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`techniques. Id. at 2:61-3:5, 6:52-7:47. Minami’s system also includes a
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`microcomputer that “generates a display output signal with which a map of a
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`specific region and information of trvelling [sic] route are displayed, by processing
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`various data from the direction detector 1, the distance sensor 2 and the reading
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`unit 3.” Id. at 2:61-3:27.
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`36. By the late 1980s, skilled artisans were already designing systems
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`combining vehicle navigation systems with mobile data communications. In a
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`paper from 1987, R.L. French suggests, “Digital maps and mobile data
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`communications combine synergistically with vehicular navigation to multiply its
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`usefulness and effectiveness, and to enhance the potential market for both
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`consumer and commercial applications.” Ex. 1012, French 1987 at 6. In this 1987
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`paper, Mr. French proposes an architecture for such a combined system including a
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`IPR2017-02022
`Unified EX1003 Page 22
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`location sensor, such as Navstar GPS, and a data transceiver used to provide
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`“vehicle-to-infrastructure data communications”:
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`Id. at Fig. 2; see also, id. at p. 8.
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`37. Mr. French also proposes several enhancements to vehicle navigation
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`systems provided by mobile data communications and suggests using mobile
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`cellular radio for two-way voice and data communications:
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`Major potential roles for data communications in future automobile
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`navigation systems will be to provide current updates (road additions,
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`closures, detours, etc.) for on-board map data bases, and to provide
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`real-time information on traffic conditions for systems that include on-
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`board route generation. Mobile data communications offer additional
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`advantages for commercial vehicles using navigation systems,
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`including centralized vehicle location monitoring and dispatch control.
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`IPR2017-02022
`Unified EX1003 Page 23
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`Mobile cellular radio offers great potential for
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`two-way data
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`communications with vehicles equipped with navigation systems. As
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`the public adopts the idea of the ‘mobile office’, there will be
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`considerable demand for cellular radio for the transmission of data as
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`well as voice. The necessary modems are already beginning to appear
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`on the market.
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`Id. at p. 10 (emphasis added).
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`38. One such navigation system combining vehicle navigation and cellular
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`communications was the TravTek system developed in the early 1990s
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