IPR2017-02022
`U.S. Patent 7,917,285
`
`
`Filed on behalf of Unified Patents Inc.
`By:
`Jason R. Mudd, Reg. No. 57,700
`Eric A. Buresh, Reg. No. 50,394
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`Tel: (913) 777-5600
`Email: jason.mudd@eriseip.com
`
`Jonathan Stroud, Reg. No. 72,518
`Ashraf A. Fawzy, Reg. No. 67,914
`Unified Patents Inc.
`1875 Connecticut Ave. NW, Floor 10
`Washington, D.C., 20009
`Tel: (202) 805-8931
`Email: jonathan@unifiedpatents.com
`Email: afawzy@unifiedpatents.com
`
`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
` ____________
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`GEOGRAPHIC LOCATION INNOVATIONS, LLC
`Patent Owner
`
`____________
`
`IPR2017-02022
`Patent 7,917,285
` ____________
`
` PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT 7,917,285
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`IPR2017-02022
`U.S. Patent No. 7,917,285
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`TABLE OF CONTENTS
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`I. INTRODUCTION ............................................................................................. 1
`II. SUMMARY OF THE ’285 PATENT ............................................................. 1
`A. DESCRIPTION OF THE ALLEGED INVENTION OF THE ’285 PATENT ...................... 1
`B. SUMMARY OF THE PROSECUTION HISTORY OF THE ’285 PATENT ....................... 4
`III. REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37 C.F.R.
`§ 42.104 .................................................................................................................... 5
`A. GROUNDS FOR STANDING UNDER 37 C.F.R. § 42.104(A) .................................. 5
`B. IDENTIFICATION OF CHALLENGE UNDER 37 C.F.R. § 42.104(B) AND RELIEF
`REQUESTED ............................................................................................................. 5
`C. LEVEL OF SKILL OF A PERSON HAVING ORDINARY SKILL IN THE ART ................. 7
`D. CLAIM CONSTRUCTION UNDER 37 C.F.R. § 42.104(B)(3) ................................. 7
`IV. THERE IS A REASONABLE LIKELIHOOD THAT THE
`CHALLENGED CLAIMS OF THE ’285 PATENT ARE UNPATENTABLE 7
`A. GROUND 1: OSHIZAWA IN VIEW OF IKEDA RENDERS CLAIMS 1-2, 5-7, AND 9
`OBVIOUS ................................................................................................................. 7
`B. GROUND 2: VAN BOSCH IN VIEW OF CHOWANIC RENDERS CLAIMS 13-14 AND 16
`OBVIOUS ............................................................................................................... 43
`C. GROUND 3: VAN BOSCH IN VIEW OF CHOWANIC IN FURTHER VIEW OF OSHIZAWA
`RENDERS CLAIM 15 OBVIOUS ................................................................................ 69
`D. GROUND 4: VAN BOSCH IN VIEW OF CHOWANIC IN FURTHER VIEW OF COOPER
`RENDERS CLAIMS 17 AND 18 OBVIOUS .................................................................. 71
`V. CONCLUSION ............................................................................................... 75
`VI. MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(A)(1) ..................... 76
`A. REAL PARTY-IN-INTEREST ............................................................................. 76
`B. RELATED MATTERS ........................................................................................ 76
`C. LEAD AND BACK-UP COUNSEL ....................................................................... 79
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`
`I.
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`INTRODUCTION
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`Petitioner Unified Patents Inc. (“Petitioner”) respectfully requests an inter
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`partes review (“IPR”) of claims 1, 2, 5-7, 9, and 13-18 (collectively, the
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`“Challenged Claims”) of U.S. Patent 7,917,285 (“the ’285 Patent”).
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`II.
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`SUMMARY OF THE ’285 PATENT
`A. Description of the alleged invention of the ’285 Patent
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`The ’285 Patent purports to address problems associated with requiring users
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`to manually program locations into conventional GPS devices. ’285 Patent
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`(EX1001), at 1:15-2:13. To do so, the ’285 Patent proposes devices, systems, and
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`methods for remotely entering location addresses into a user’s GPS device to
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`automatically program it with destinations for route guidance. Id. at Abstract, 2:25-
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`30, 3:53-67.
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`The system includes a GPS device 100, which may be “any type of
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`navigation or positional information device including but not limited to a vehicle-
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`mounted device, a GPS receiver coupled to a desktop computer or laptop, etc.” Id.
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`at 4:1-8. The GPS device determines its location using a location information
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`module, “employing conventional location information processing technology,”
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`such as “GPS,” “Loran,” or “any other available locational technology.” Id. at 5:5-
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`11. The GPS device also includes “a communication module 112 for transmitting
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`stored data to another device, e.g., a personal computer, a personal digital assistant
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`(PDA), a server residing on the Internet, etc.”
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` 1
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`As shown in the figure below, the GPS device 100 communicates via a
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`communications network 302 with a remote customer service center (CSC) having
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`a live operator 303 that has access to a server 304 for looking up address
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`information and for transmitting information to the GPS device:
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`Id. at Fig. 3, 9:13-20; see also id. at 8:13-16. The communications network may
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`be a telematics network that, for example, enables data and voice communications
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`using “any known communication means,” such as RF, satellite, CDMA, 3G, and
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`more. Id. at 8:13-16. The system can also include a local computer 310 coupled to
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`the communications network 302. Id. at 9:64-10:33. The user may remotely
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`request entry of an address into the GPS device 100 for purposes of the GPS device
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`providing route guidance to the address.
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`When the user requests remote entry of an address into GPS device 100, the
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`user is connected to the customer service center (CSC) via analog or digital
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`communications or any other type of communication link. Id. at 8:62-9:3. The
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`vehicle or device is identified using an identifier, such as a cellular phone number
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`or IP address, which can be transmitted to the CSC or detected using conventional
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`techniques, such as using caller ID and a database lookup. Id. at 9:3-12. The
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`request for the address may be received by voice communications as the user
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`communicates with a live operator 303 who inputs the request into the server 304
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`or the request may be directly received electronically by the server. Id. at 9:17-39.
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`The live operator accesses the server 304 to look-up the requested location
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`information. Id. For example, the user may provide the name and city of a desired
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`location, which the operator uses to look-up the address and/or latitude/longitude
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`coordinates of the location. Id. at 12:12-52. The determined address or coordinate
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`information is then transmitted to the device 100, which uses it to generate route
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`guidance to the location. Id.
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`In certain embodiments, the user can also request location information using
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` 3
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`a local computer. Id. at 9:64-10:5. Specifically, the user connects th e local
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`computer 310 to the server, which uses an identifier associated with the local
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`computer to identify the user. Id. at 10:21-27. “The remote server then utilizes a
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`standard database lookup program, based on the received identifier, to find out
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`information on the user’s device including the transmission information for the
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`device which may be the cellular telephone number of the device or a vehicle or
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`the Internet address (e.g., the IP address) of the device or vehicle.” Id. at 10:27-33.
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`The server then looks up the requested location information and transmits it to the
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`GPS device, which can then provide route guidance to the user. Id. at 10:34-49.
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`In other embodiments, the user can use the device interface or their voice to
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`tell the customer service center they need address information stored on another
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`registered device or vehicle, and that information can be remotely accessed and
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`entered into the user’s current device for obtaining route guidance. Id. at 10:62-
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`11:48.
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`B.
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`Summary of the prosecution history of the ’285 Patent
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`The application that resulted in the ’285 Patent was filed on April 28, 2006.
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`’285 Patent File History (EX1002), at 2. For purposes of this proceeding,
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`Petitioner assumes the priority date for the Challenged Claims is April 28, 2006.
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`During prosecution, the Examiner twice rejected as anticipated pending
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`claim 25, which subsequently issued as claim 1. Id. at 66, 97. To overcome these
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`rejections, Applicant amended pending claim 25 to include the limitation “wherein
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`the request is received from a remote computer with a first identifier and the server
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`being configured to determine a second identifier for identifying the positional
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`information device based on the received first identifier.” Id. at 107. In this same
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`amendment, Applicant also added independent claim 45, which subsequently
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`issued as Claim 13 and included a limitation relating to the server receiving and
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`transmitting to the positional information device a “time and date associated with
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`the requested at least one location.” Id. at 109-110. The Examiner subsequently
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`issued a Notice of Allowance allowing independent claims 25 and 45 and their
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`dependent claims. Id. at 122. No reasons for allowance were given. Id. Claims 25
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`and 45 subsequently issued as claims 1 and 13, respectively. Id. at 128.
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`III. REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37 C.F.R.
`§ 42.104
`A. Grounds for standing under 37 C.F.R. § 42.104(a)
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`Petitioner certifies that the ’285 Patent is available for IPR and that the
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`Petitioner is not barred or estopped from requesting IPR challenging the claims of
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`the ’285 Patent.
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`B.
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`Identification of challenge under 37 C.F.R. § 42.104(b) and relief
`requested
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`In view of the prior art and evidence presented, claims 1, 2, 5-7, 9, and 13-
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`18 of the ’285 Patent are unpatentable and should be cancelled. 37 C.F.R.
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`IPR2017-02022
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`US. Patent No. 7,917,285
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`§ 42.104(b)( 1). Further, based on the prior art references identified below, IPR of
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`the Challenged Claims should be granted. 37 C.F.R. § 42.104(b)(2).
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`Pro . osed Grounds of Un . atentabili
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`Exhibits
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`Ground 1: Claims 1-2 and 5-7, and 9 are obvious under § 103(a)
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`over US. Patent No. 5,987,381 to Oshizawa (“Oshizawa”) in View
`of US. Patent Application Publication No. 2002/0174360A1 to
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`EX1004,
`EX1005
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`Ikeda (“Ikeda”)
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`Ground 2: Claims 13-14 and 16 are obvious under § 103(a) over
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`US. Patent Application Publication No. 2005/0221876A1 to Van
`Bosch et al. (“Van Bosch”) in View of US. Patent No. 6,175,803 to
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`EX1006,
`EX1007
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`Chowanic et al. (“Chowanic”)
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`Ground 3: Claim 15 is obvious under § 103(a) over Van Bosch in
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`EX1006
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`EX1007,
`View of Chowanic in further View of Oshizawa
`EX] 004
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`Ground 4: Claims 17 and 18 are obvious under § 103(a) over Van
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`Bosch in View of Chowanic in further View of US. Patent
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`EX1006,
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`Application Publication No. 2006/0058953A1 to Cooper et al.
`(“Cooper”)
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`EE§11%%78-
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`Section IV identifies where each element of the Challenged Claims is found
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`in the prior art. 37 C.F.R. §42.104(b)(4). The exhibit numbers of the supporting
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`evidence relied upon to support
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`the challenges are provided above and the
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`relevance of the evidence to the challenges raised are provided in Section IV. 37
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`C .F.R. § 42.104(b)(5). Exhibits EX1001—EX1019 are also attached.
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`Level of skill of a person having ordinary skill in the art
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`C.
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`A person having ordinary skill in the art at the time of the ’285 Patent would
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`have been a person having the equivalent of a bachelor’s degree in electrical
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`engineering, computer engineering, computer science, or a similar discipline, and
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`at least one to two years of experience working with vehicle navigation systems or
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`vehicle telematics technologies, or an equivalent amount of similar work
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`experience or education, with additional education substituting for experience and
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`additional experience substituting for education. Decl. (EX1003) at ¶53.
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`D. Claim construction under 37 C.F.R. § 42.104(b)(3)
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`In this proceeding, claim terms of an unexpired patent should be given their
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`“broadest reasonable construction in light of the specification.” 37 C.F.R.
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`§ 42.100(b); Cuozzo Speed Techs., LLC v. Lee, 136 S. Ct. 2131, 2144-46 (2016).
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`Petitioner proposes that for purposes of this IPR, the claim terms of the ’285 Patent
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`be given their ordinary and customary meaning that the term would have to one of
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`ordinary skill in the art in light of the specification.
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`IV. THERE IS A REASONABLE LIKELIHOOD THAT THE
`CHALLENGED CLAIMS OF THE ’285 PATENT ARE
`UNPATENTABLE
`A. Ground 1: Oshizawa in view of Ikeda renders claims 1-2, 5-7, and 9
`obvious
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`Oshizawa issued on November 16, 1999 and thus qualifies as prior art with
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`regard to the ’285 Patent under 35 U.S.C. § 102(b) (pre-AIA). Oshizawa
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`(EX1004). Oshizawa was not cited or substantively discussed during prosecution
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`of the ’285 Patent. Oshizawa describes “[a]n on-board automobile navigation
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`system . . . us[ing] destination data downloaded from a remote transmission
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`source.” Id. at 2:53-55; see also id. at 4:49-50 (“The present invention simplifies
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`the process of entering a desired destination for the user.”).
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`The ’285 Patent is broadly directed to the field of “navigational or positional
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`information systems.” ’285 Patent (EX1001), at 1:9-13. Oshizawa similarly
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`relates to “the field of on-board navigation systems for street vehicles.” Oshizawa
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`(EX1004), at 1:5-6. As such, Oshizawa is in the same field of endeavor and is
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`analogous to the claimed invention of the ’285 Patent. Oshizawa’s general system,
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`including a communications center housing a human operator and computer
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`system, a communication device (such as a mobile telephone), and an on-board
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`vehicle navigation system is depicted below:
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`lCOMAUNICATlONSCENTER 159
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`IPR2017-02022
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`US. Patent No. 7,917,285
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`Id. at Fig. 2B. Oshizawa describes this embodiment as using two independent
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`communications links 162 and 163. Id. at 6:10-30.
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`Ikeda was published on November 21, 2002 and therefore qualifies as prior
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`art with regard to the ’285 Patent under 35 U.S-C- § 102(b) (pre-AIA)-
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`Ikeda
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`(EX1005).
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`Ikeda was not cited or substantively discussed during prosecution of
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`the ’285 Patent. Ikeda generally describes a system where a user uses a mobile
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`phone to remotely request services for an associated vehicle navigation system-
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`See, e.g., Id. at Abstract, [0166], [0208], Fig. 8. Ikeda’s vehicle navigation system
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`provides positional
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`information in that it displays the present position of the
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`vehicle on a map and “[n]avigation information, such as information on routes and
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`regional guides.” Id. at [0071]. Thus, like the ’285 Patent, Ikeda is also directed to
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`a “navigational or positional information system.” Ikeda is therefore in the same
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`IPR2017-02022
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`U.S. Patent No. 7,917,285
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`field of endeavor and is analogous to the claimed invention of the ’285 Patent.
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`Ikeda’s general system, including a navigation system having a “navigation ID,” a
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`depicted below:
`n. 2
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`Id. at Fig. 1. Like the embodiment described above in Oshizawa, Ikeda’s general
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`system includes separate communications links for the navigation system and the
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`mobile phone. Id.
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`i. Claim 1
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`1. A system for remotely entering location information into a positional
`information device, the system comprising:
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`To the extent it is deemed limiting, Oshizawa discloses the preamble.
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`Oshizawa teaches a system for remotely entering a desired destination (i.e.,
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`“location
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`information”)
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`into an on-board vehicle navigation device (i.e.,
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`“positional information device”) by a user using a mobile telephone (i.e., “remote
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`computer”) to contact an operator in a remote communications center so as to
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`“simplif[y] the process of entering a desired destination for the user”:
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`A user of the navigation system in a vehicle utilizes a cellular
`telephone or any other wireless, two-way audio communications link
`to contact an operator in a remote communications center. The user
`informs the operator of his desired destination. The operator in the
`communications center accesses a computer database to determine the
`exact location of the desired destination in terms of latitude/longitude,
`street address, or other similar information. The operator then
`causes the information specifying the exact location to be
`transmitted from the communications center to the on-board
`vehicle navigation system over a data link. The on-board vehicle
`navigation system receives the location information and uses it to
`compute a route from the vehicle's current position to the desired
`destination.
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`Oshizawa (EX1004), at Abstract (emphases added), 4:49-50.
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`[1(a)(i)] a server configured to receive a request for an address of at least one
`location not already stored in the positional information device,
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`The ’285 Patent discloses an embodiment where a server being operated by
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`a live operator in a customer service center receives the user’s location request via
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`voice communications from the user—the operator inputs the request into the
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`server to lookup the address of the requested location and then causes the address
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`to be wirelessly transmitted from the server to the device:
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`Once connected to the customer service center, the user can
`communicate with
`the customer service center with voice
`communications or with a vehicle user interface (VUI) including but
`not limited to keyboard, voice recognition, or mouse or pointer. In one
`embodiment, the customer service center includes a live operator 303
`that has access to server 304 for looking up address information and
`transmitting the information to the device. In this embodiment, the
`user will interact with the live operator via voice communications.
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`’285 Patent (EX1001), at 9:13-21; see also id. at 3:27-29 (“In a further aspect, the
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`server is operated by a live operator and the request for the at least one
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`location is received by voice communications.”), 2:48-49, 3:6-8 (emphases
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`added).
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`Furthermore, Claim 9, which depends from Claim 1, recites “wherein the
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`server is operated by a live operator and the request for the at least one location is
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`received by voice communications.” Therefore, the BRI of this limitation in Claim
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`1 must at least include the embodiment of Claim 9.
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`Oshizawa discloses this exact embodiment. Specifically, Oshizawa teaches
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`that a server (i.e., computer system 165) operated by a human operator in a
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`communication center 150 receives the user’s location request (i.e., a request for a
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`desired destination address) via voice communications from the user’s “cellular
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`telephone” (i.e., “communication device 172”). Oshizawa (EX1004) at Abstract;
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`see also, id. at 5:1-19, 6:31-44, Figs. 2A-B, 3 (steps 301-302). “[T]he user states
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`U.S. Patent No. 7,917,285
`the desired destination to the operator. For example, the user may provide the name
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`of a business as the desired destination.” Id. at 6:41-44. The operator then enters
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`the desired destination information into the computer system 165 (i.e., server) to
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`look up the “coordinates” of the desired destination, such as by accessing a
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`database 174. Id. at 6:44-54 (“In step 303, the operator uses the computer system
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`165 to access the database 174 to determine the exact coordinates of the desired
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`destination in terms that are usable by the navigation system 100”), Fig. 3 (step
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`303). Oshizawa teaches that the “coordinates” can be a “street address.” Id . at
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`6:44-54, Abstract. Therefore, Oshizawa teaches that a server (computer system
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`165) receives a request for an address of a desired destination via voice
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`communications transmitted by a remote computer (the user’s cellular telephone
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`172).1
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`1 Petitioner notes, as discussed immediately above, that claim 1 does not require
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`the server to “directly” receive the request from the remote computer, and instead,
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`encompasses embodiments, such as recited in claim 9, where the request is
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`received via voice communications to a live operator who then enters the request
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`into the server.
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`U.S. Patent No. 7,917,285
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`Id. at Fig. 2B.
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`Hence, in step 301 he first uses communication device 172 (which
`may be a cellular
`telephone)
`to establish
`two-way audio
`communication with the operator in the communication center 150,
`who is using communication device 171; the user of navigation
`system 100 thereby initiates the communication link 161. In step 302,
`the user states the desired destination to the operator. For
`example, the user may provide the name of a business as the desired
`destination. In step 303, the operator uses the computer system 165
`to access the database 174 to determine the exact coordinates of the
`desired destination in terms that are usable by the navigation system
`100; for example, the navigation system may require that
`coordinates be provided in terms of latitude/longitude, street
`address, link (street segment) identifier, node (intersection) identifier,
`or other type of location information.
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`Id. at 6:36-51 (emphases added).
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`U.S. Patent No. 7,917,285
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`
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`Id. at Fig. 3 (excerpt); see also id. at 5:1-8, Fig. 2A.
`
`The claimed “an address of at least one location not already stored in the
`
`positional information device” is met by Oshizawa, at least because Oshizawa does
`
`not require the recited negative limitation (i.e., does not require the address to
`
`already be stored in the positional information device). A negative limitation may
`
`be satisfied by silence in the prior art where the prior art does not require the
`
`presence of the element recited in the negative limitation. See Süd-Chemie, Inc. v.
`
`Multisorb Technologies, Inc., 554 F.3d 1001, 1004-05 (Fed. Cir. 2009) (affirming
`
`determination that claim limitation of “uncoated” film was met by prior art that
`
`disclosed film without mention of any coating and without description of any
`
`requirement of a coating); Palo Alto Networks, Inc. v. Juniper Networks, Inc.,
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`IPR2013-00466, Paper 17, at 18 (January 28, 2014) (“[A] negative limitation
`
`
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`requiring the absence of an element may be adequately described by a cited prior
`
`art reference if that reference does not otherwise require the presence of the
`
`element recited in the negative limitation.”) (emphasis in original); see also Google
`
`Inc. et al. v. Core Wireless Licensing S.A.R.L., IPR2015-01715, Paper 8, at 14
`
`(February 18, 2016) (same).
`
`Here, Oshizawa does not require
`
`the user’s requested destination
`
`“coordinates”/“address” to be already stored on the on-board vehicle navigation
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`device prior to the user’s request for remote input of the destination. Instead,
`
`Oshizawa teaches a navigation system “which uses destination data downloaded
`
`from a remote transmission source.” Oshizawa (EX1004) at 7:25-27 (emphasis
`
`added); see also id. at 1:8-9, 4:19-22 (describing “inputting a desired destination”
`
`in the remote manner described), 4:49-50 (process of “entering a desired
`
`destination”).
`
` Indeed, Oshizawa’s purpose in requesting remote input of
`
`destination data (e.g., address/coordinates) is to download and use a destination
`
`address that the user has not already entered in their device so as to simplify
`
`destination entry, just like the ’285 Patent. Id. Therefore, a PHOSITA would have
`
`understood Oshizawa does not require its disclosed on-board navigation system to
`
`already store the user’s desired destination address locally—and that doing so
`
`would render moot the primary objective of Oshizawa. Decl. (EX1003) at ¶60.
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`
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`Further, to the extent Oshizawa’s silence is not found to teach this element,
`
`it would have nonetheless been obvious to a PHOSITA from Oshizawa that the
`
`user’s desired destination address would not be already stored on the user’s on-
`
`board vehicle navigation device, as Oshizawa teaches using a remotely
`
`downloaded destination address, as discussed above, and there would be no reason
`
`to download the address to the device if it had already been previously stored.
`
`Decl. (EX1003) at ¶61. A PHOSITA would have appreciated from Oshizawa that
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`it would be beneficial to remotely download the user’s desired destination address
`
`rather than having it already be stored locally because Oshizawa teaches that this
`
`simplifies destination entry for the user. Id. at ¶62; see also Oshizawa (EX1004) at
`
`1:38-53, 2:10-23, 2:53-55, 4:49-5:15. A PHOSITA also would have appreciated
`
`that not already storing the address locally would have furthered Oshizawa’s stated
`
`desire to reduce system cost, such as by eliminating the need for additional
`
`memory to locally store locations and their respective addresses. Decl. (EX1003) at
`
`¶62; see also Oshizawa (EX1004) at 1:57-59.
`
` [1(a)(ii)] to determine the address of the least one location
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`Oshizawa’s server is configured to determine the address of the requested
`
`destination/location—specifically, the operator causes the server (computer system
`
`165) to access a database 174 to determine the address of the requested
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`destination/location:
`
`
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`A user of the navigation system in a vehicle utilizes a cellular
`telephone or any other wireless, two-way audio communications link
`to contact an operator in a remote communications center. The user
`informs the operator of his desired destination. The operator in the
`communications center accesses a computer database to determine the
`exact
`location of
`the desired destination
`in
`terms of
`latitude/longitude, street address, or other similar information.
`
`Id. at Abstract (emphasis added).
`
`In step 303, the operator uses the computer system 165 to access the
`database 174 to determine the exact coordinates of the desired
`destination in terms that are usable by the navigation system 100; for
`example, the navigation system may require that coordinates be
`provided in terms of latitude/longitude, street address, link (street
`segment) identifier, node (intersection) identifier, or other type of
`location information.
`
`Id. at 6:44-51 (emphasis added).
`
`
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`U.S. Patent No. 7,917,285
`
`Id. at Fig. 3 (excerpt); see also, id. at 5:58-6:9.
`
`[1(a)(iii)] and to transmit the determined address to the positional information
`device,
`
`The operator then causes the server (computer system 165) to transmit the
`
`determined coordinates, which may be an address, to the on-board navigation
`
`system:
`
`A user of the navigation system in a vehicle utilizes a cellular
`telephone or any other wireless, two-way audio communications link
`to contact an operator in a remote communications center. The user
`informs the operator of his desired destination. The operator in the
`communications center accesses a computer database to determine the
`exact location of the desired destination in terms of latitude/longitude,
`street address, or other similar information. The operator then
`causes the information specifying the exact location to be
`transmitted from the communications center to the on-board
`vehicle navigation system over a data link.
`
`Id. at Abstract (emphasis added).
`
`In step 304, the operator enters a command into the computer system
`165 to cause the coordinates to be encoded and transmitted on from
`the communications center 150 to the on-board navigation system
`100 via the non-audio data channel of link 161.
`
`Id. at 6:54-58 (emphasis added).
`
`
`
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`IPR2017-02022
`
`US. Patent No. 7.917.285
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`
`
`USER INITIATES 2-WAY AUDIO
`COMMUNICATION WITH OPERATOR
`
`
`IN COMMUNICATIONS CENTER
`
`301
`
`
`
`
`
`OPERATOR ACCESSES DATABASE WITH
`DESIRED DESTINATION TO DETERMINE
`
`
`COORDINATES OF DESIRED DESTINATION
`
` _____ .
`
`
`. ““W
`_
`.
`OPERATOR CAUSES COORDINATES AND ANY
`I
`SECONDARY INFORMATION TO BE TRANSMI'ITED
`TO ON-BOARD NAVIGATION SYSTEM
`
`Id. at Fig. 3 (excerpt) (annotated): see also, id. at 6:20-28. 6:44-51. Fig. 2B.
`
`[1 (b)] wherein the request is received from a remote computer with a first
`identifier and the server being configured to determine a second identifier for
`identijjiing the positional
`information device based on the received first
`identifier;
`
`Oshizawa teaches that
`
`the user’s destination request
`
`is sent by voice
`
`communications (consistent with claim 9 and embodiments of the ’285 Patent. as
`
`discussed above)) from the user’s communication device 172 such as a cellular
`
`telephone (i. 2.. “remote computer”) that is remote from the operator and computer
`
`system 165. Id. at Abstract. 6:36—58. Fig. 2B. As discussed. the request is received
`
`into the computer system 165 (server) by the operator entering the desired
`
`destination into the computer system 165 (i. e.. server) to look up the exact
`
`coordinates. such as the “street address" of the desired destination. Id. at 6:44-58.
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`20
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`IPR2017-02022
`
`US. Patent No. 7,917,285
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`As also discussed, Oshizawa teaches that after the request has been received into
`
`the computer system 165 and the coordinates/address for the desired destination
`
`has been determined.
`
`the computer system 165 then transmits the determined
`
`coordinates/address to the appropriate on-board navigation system 100 for the user.
`
`Foow’Jucfifius‘cant—5153 ————— '
`
`
`
`I | II I I II lI I l I I
`
`Id. at Fig. 2B (annotated): see also id. at 6:20—30. 6:54-72.
`
`Oshizawa does not expressly describe how the server computer system 165
`
`associates the user’s communication device 172 (remote computer) with the
`
`correct on-board navigation system 100 (positional information device) for the user
`
`(such as by using a first identifier for the user’s communication device to look up a
`
`corresponding second identifier for the correct navigation system).
`
`Ikeda. however. expressly teaches a server that uses a database table. which
`
`associates a first identifier for the user’s mobile phone with a second identifier for
`
`21
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`IPR2017-02022
`U.S. Patent No. 7,917,285
`the user’s vehicle navigation system to determine the correct navigation system for
`
`the user. Ikeda (EX1005) at Abstract (“[A] service server that provides services
`
`accesses a specified navigation system, which is the product purchased by the user,
`
`using a device ID that is uniquely assigned to the navigation system . . . .”), [0012],
`
`[0166], [0208], [210], Figs. 1, 5. Ikeda’s server provides support services to an in-
`
`vehicle navigation system 100 based on a request received from a mobile phone
`
`200. Id. at Abstract, [0166], [0208], Fig. 8 (step S401 – “Security request sent to
`
`application server together with terminal ID and password”). For the first
`
`identifier, the mobile device has a “unique terminal ID,” which is also referred to
`
`as “a mobile ID” and may be, e.g., a “telephone number” for the mobile phone. Id.
`
`at [0012], [0133], Fig. 5. For the second identifier, the navigation system 100 has a
`
`navigation ID that uniquely identifies the navigation system 100 and that may also
`
`be a telephone number, e.g., a telephone number for the navigation system’s
`
`c