Case 5:16-cv-00178-RWS Document 100-6 Filed 10/23/17 Page 1 of 29 PageID #: 2267
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
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`Case No. 5:16-cv-00178-RWS
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`LEAD CASE
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`JURY TRIAL DEMANDED
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`
`
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`Case No. 5:16-cv-00179-RWS
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`JURY TRIAL DEMANDED
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` Plaintiff,
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`Defendants.
`
`Plaintiff,
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`Defendants.
`
`v.
`
`v.
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`
`
`
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`HITACHI MAXELL, LTD.,
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`
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`
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`HUAWEI DEVICE USA INC. and HUAWEI
`DEVICE CO., LTD.,
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`
`
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`HITACHI MAXELL, LTD.,
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`
`
`
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`ZTE CORPORATION and ZTE USA INC.,
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`
`
`
`
`
`DECLARATION OF SCOTT ANDREWS IN SUPPORT OF DEFENDANTS’
`RESPONSIVE CLAIM CONSTRUCTION BRIEF
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`
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`1.
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`2.
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`I, Scott Andrew, do declare as follows:
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`I have been retained by counsel for ZTE (USA) to provide this declaration in
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`support of the Defendants’ Responsive Claim Construction relating to certain claim terms in U.S.
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`Patent No. 6,748,317 titled “PORTABLE TERMINAL WITH THE FUNCTION OF WALKING
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`NAVIGATION” (the “‘317 Patent”). If called as a witness, I could and would testify
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`competently to the matters set forth herein.
`
`4837-9087-4439.v3
`
`ZTE v. Maxell
`IPR2018-00235
`Maxell Ex. No. 2003
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`3.
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`My opinions are based on my years of education, research and experience, as well
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`as my investigation and study of relevant materials. The materials that I studied for this
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`declaration include all exhibits of the petition.
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`I.
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`BACKGROUND AND QUALIFICATIONS
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`4.
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`Attached hereto as Appendix A is a true and correct copy of my curriculum vitae.
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`I have summarized by educational background, work experience, and relevant qualifications in
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`this section.
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`5.
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`I am currently the Technical Partner of Cogenia Partners, LLC. For the last 20
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`years, I have focused exclusively on the development and management of technologies in
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`support of Intelligent Transportation Systems.
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`6.
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`I received my Master of Science degree in Electrical Engineering from Stanford
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`University in 1982 and a Bachelor of Science degree in Electrical Engineering from University
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`of California, Irvine in 1977.
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`7.
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`From 1983 to 1996, I worked at TRW, Inc. as Director of System Engineering &
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`Advanced Product Development. My responsibilities included leadership and overall
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`management of advanced development programs, development of business strategy and business
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`plan, and overall management of customer and R&D programs.
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`8.
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`From 1996 to April 2000, I worked at Toyota Motor Corporation, Japan as Project
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`General Manager in the R&D Management Division. My responsibilities included the
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`conceptualization and development of multimedia and new technology products and services for
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`Toyota's future generations of passenger vehicles in the United States and Europe. Heavy
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`emphasis was placed on strategy for information systems, and on development of technical
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`concepts for computing and Internet oriented systems.
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`9.
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`While at Toyota Motor Corporation, I was also responsible for leading Toyota's
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`US Automated Highway Systems program, management of technical contracts with Carnegie
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`Mellon University Robotics Lab (Image based collision warning systems), and the development
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`of Toyota's position on the US Intelligent Vehicle Initiative.
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`10.
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`In April 2000, I founded Cogenia, Inc. My responsibilities as the President and
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`CEO of the company included development of business concepts and plans, corporate
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`administration including financial and legal management, leadership of the executive team in
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`product development, fundraising, business development, organizational development, and
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`investor relations.
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`11.
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`From December 2001 to present, I have been the Technical Partner at Cogenia
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`Partners, LLC. In this role, I have consulted with all of the major carmakers, and many leading
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`consumer products and services companies in support of the creation and delivery of intelligent
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`transportation systems (ITS), safety applications, and mobile devices.
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`12.
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`At Cogenia Partners, LLC., my responsibilities include: Systems engineering,
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`business development and technical strategy consulting supporting automotive and information
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`technology.
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`13. My current engagements at Cogenia Partners, LLC. include:
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`• Subject matter expert of the development of security systems management
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`operations for connected vehicle on behalf of the U.S. DOT National
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`Highway Traffic Safety Admin. (NHTSA).
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`• Technical lead for connected vehicle performance measures development
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`project for the U.S. DOT National Highway Traffic Safety Admin.
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`(NHTSA)
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`
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`14.
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`A complete list of current and past engagements at Cogenia Partners, LLC. is
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`provided in my curriculum vitae, which is attached as Appendix A.
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`15.
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`I have published more than 20 articles, and am an inventor or co-inventor of 13
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`issued patents.
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`16. My professional affiliations include:
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`• Society of Automotive Engineers (SAE)
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`•
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`•
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`•
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`•
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`International Institute of Electrical and Electronic Engineers (IEEE)
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`Institute of Navigation (ION)
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`International Council on Systems Engineering (INCOSE)
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`IEEE Standards Association
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`17.
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`In addition, I have 12 years of experience severing as a technical expert witness
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`for patent litigation. I have been involved in district court patent cases, ITC cases, IPRs and Re-
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`examinations. My practice areas include: Navigation and positioning systems, automotive
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`control systems and user interface technologies, location based services and systems, digital
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`maps, GPS technology, traffic information systems, Intelligent Transportation Systems (ITS),
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`etc. A detailed summary of litigation experience and key practice areas is provided as Appendix
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`B.
`
`II.
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`LEVEL OF ORDINARY SKILL IN THE ART
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`18.
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`In rendering the opinions set forth in this declaration, I was asked to consider the
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`patent claims and the prior art through the eyes of a person of ordinary skill in the art. I
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`considered factors such as the educational level and years of experience of those working in the
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`pertinent art; the types of problems encountered in the art; the teachings of the prior art; patents
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`and publications of other persons or companies; and the sophistication of the technology. I
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`understand that a person ordinary skill in the art is not a specific real individual, but rather a
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`hypothetical individual having the qualities reflected by the factors discussed above.
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`19.
`
`In my opinion, a person ordinary skill in the art, at the time of the ‘317 Patent,
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`would have a bachelor’s degree in computer science, computer engineering, electrical
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`engineering, or a related field, with two years of experience in navigation, GPS technology and
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`computer programming. Extensive experience and technical training may substitute for
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`educational requirements, while advanced education such as a relevant MS or PhD might
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`substitute for experience.
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`III. MATERIAL CONSIDERED
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`20.
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`I have considered the following information in forming my opinions:
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`a. The ‘317 Patent;
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`b. The Prosecution History of the ’317 Patent;
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`c. P.R. 4-3 Joint Claim Construction and Prehearing Statement (dated Aug.
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`31, 2017); and
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`d. Plaintiff’s Opening Claim Construction Brief (dated Oct. 2, 2017)
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`IV. UNDERSTANDING OF THE LAW
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`21.
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`I understand that the claims of a patent are presumed to be valid, and that
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`invalidity of a claim must be proven by clear and convincing evidence.
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`A.
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`22.
`
`Claim Construction
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`I understand that the claims of the patent define the limits of the patentees’
`
`exclusive rights. In order to determine the scope of the claimed invention, courts typically
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`construe (or define) claim terms, the meaning of which the parties dispute. My purpose in
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`submitting this declaration is to assist the Court in its construction of the disputed claims based
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`upon how a person of ordinary skill in the art at the time the patent applications were filed would
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`have understood those claims.
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`23.
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`I understand that claim terms should generally be given their plain and ordinary
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`meaning as understood by one of ordinary skill in the art at the time of the invention and after
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`reading the patent and its prosecution history. Claims must be construed, however, in light of
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`and consistent with the patent’s intrinsic evidence. Intrinsic evidence includes the claims
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`themselves, the written disclosure in the specification, and the patent’s prosecution history,
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`including the prior art that was considered by the United States Patent and Trademark Office
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`(“PTO”).
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`24.
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`The language of the claims helps guide the construction of claim terms. The
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`context in which a term is used in the claims can be highly instructive.
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`25.
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`The specification of the patent is the best guide to the meaning of a disputed claim
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`term. Embodiments disclosed in the specification help teach and enable those of skill in the art
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`to make and use the invention, and are helpful to understanding the meaning of claim terms. For
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`example, an inventor may attribute special meanings to a term by specifically defining it or
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`otherwise incorporating such a definition in the specification or file history. However,
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`limitations should not be imported from the specification into the claims.
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`26.
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`In the specification, a patentee may also define his own terms, give a claim term a
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`different meaning than it would otherwise possess, or disclaim or disavow claim scope. A claim
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`term is generally presumed to possess its ordinary meaning. This presumption, however, does
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`not arise when the patentee acts as his own lexicographer by explicitly defining or re-defining a
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`claim term. This presumption can also be overcome by statements, in the specification or
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`prosecution history of the patent, of clear disclaimer or disavowal of a particular claim scope.
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`27.
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`I understand that the specification may also resolve any ambiguity where the plain
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`and ordinary meaning of a claim term lacks sufficient clarity to permit the scope of the claim to
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`be ascertained from the claim words alone.
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`28.
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`I understand that the prosecution history is another important source of evidence
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`in the claim construction analysis. The prosecution history is the record of the proceedings
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`before the PTO, including communications between the patentee and the PTO regarding the
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`patent application. The prosecution history can inform the meaning of the claim language by
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`demonstrating how the patentee and the PTO understood the invention and whether the patentee
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`limited the invention in the course of prosecution, making the claim scope narrower than it
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`would otherwise be. I understand that a patentee may also define a term during the prosecution
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`of the patent. The patentee is precluded from recapturing through claim construction specific
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`meanings or claim scope clearly and unambiguously disclaimed or disavowed during
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`prosecution.
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`29.
`
`I understand that extrinsic evidence may also be considered when construing
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`claims. Extrinsic evidence is any evidence that is extrinsic to the patent itself and its prosecution
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`history. Examples of extrinsic evidence are technical dictionaries, treatises, and expert
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`testimony. I understand that extrinsic evidence is less significant than the intrinsic record in
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`determining the meaning of the claim language. I understand that extrinsic evidence can be
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`useful to provide background on the technology at issue, to explain how an invention works, to
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`ensure that the understanding of the technical aspects of a patent is consistent with that of a
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`person of ordinary skill in the art, or to establish that a particular term in the patent or prior art
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`has a particular meaning in the art.
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`B.
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`Indefiniteness claims under § 112, ¶ 2
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`30.
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`I understand that a claim limitation is indefinite if the claim, when read in light of
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`the specification and the prosecution history, fails to inform with reasonable certainty persons of
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`ordinary skill in the art about the scope of the invention at the time the patent application was
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`filed.
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`31.
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`I understand that the claim language might mean several different things, but even
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`if a definition is supported by the specification, the claim is still indefinite if a person skill in the
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`art cannot translate the definition into a precise claim scope.
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`32.
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`I understand that the definiteness requirement mandates clarity but recognizes that
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`absolute precision is impossible.
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`C.
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`33.
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`“Means-plus-function” claims under § 112, ¶ 6
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`I understand that claim terms may be written in a means-plus-function format. I
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`understand that use of the word “means” followed by a recited function creates a presumption
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`that the claim limitation is in means-plus-function format. I understand that the presumption that
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`a claim limitation is a means-plus-function limitation can be rebutted by showing either (1) the
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`claim phrase sufficiently recites a definite structure for performing the function; or (2) “means”
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`claim language exists without recitation of a function.
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`34.
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`I understand that although the statute refers to the words “means for,” those words
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`are not required for a term to be subject to § 112, ¶ 6. The absence of these words in the claims
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`of a patent creates a rebuttable presumption that § 112, ¶ 6 does not apply. However, such
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`presumption can be overcome if the claim term fails to recite sufficiently definite structure or
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`recites function for performing that function. Stated another way, the presumption may be
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`overcome by using a term instead of “means” that is “a nonce word or a verbal construct that is
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`not recognized as the name of structure.” The words of the claim must be understood by person
`
`skill in the art to have definite meaning as the name for structure.
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`35.
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`I understand that, where there is no corresponding structure for a means-plus-
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`function claim limitation disclosed in the specification of a patent, that claim limitation is
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`indefinite. I understand that the absence of structure from the patent’s specification cannot be
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`cured by resorting to the knowledge of a person of ordinary skill in the art.
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`36.
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`I understand that for means-plus-function limitations that are performed on a
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`computer, the simple disclosure of a general purpose computer is not sufficient structure to
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`render the claim limitation definite. Rather, a patent claim that includes a computer-
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`implemented means-plus-function limitation must disclose an algorithm for performing the
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`claimed function; in the absence of a disclosed algorithm for performing the claimed function,
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`the claim limitation is indefinite. Because general purpose computers can be programmed to
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`accomplish a function in multiple ways, merely disclosing a general purpose computer does not
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`provide a sufficient limit on the scope of the claim when a means-plus-function limitation is
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`used. The corresponding structure for a computer-implemented means-plus-function limitation
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`is not a general purpose computer, but rather an algorithm that turns the general purpose
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`computer into special-purpose computer or microprocessor that is programmed to perform the
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`claimed function. I understand that the claimed limitation will be indefinite if the specification
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`does not disclose an algorithm in sufficient detail for performing the claimed function.
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`V.
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`OPINIONS ON CLAIM CONSTRUCTION
`
`A.
`
` “walking navigation”
`
`Defendant’s Proposed Construction
`“display of information to assist a user
`in walking, not driving, in a system that
`is not usable in an object car that is
`running on a road”
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`
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`9
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`Plaintiff’s Proposed Construction
`“information to navigate a user who is
`walking”
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`37.
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`The ‘317 patent specification repeatedly and exclusively describes its system as
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`one for walking navigation. The term “walking” is used multiple times in the specification; in
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`contrast the term “driving” is never used. The closest is the statement that the invention is
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`different from navigation systems for an object car “running on a road.” Specifically, in the
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`background section of the patent, the inventors assert there “are also many systems under
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`development to be used for supplying the GPS (Global Positioning System). For example, a car
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`navigation system is to be mounted on a car is too large for a walker to carry around. In
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`addition, because the [car] navigation system premises that the system is used while the object
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`car is running on a road, it cannot be used as a walker’s navigation system as is.” ‘317 Patent at
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`1:31-38.
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`38.
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`I understand that words in a claim are to preferably to be given some meaning and
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`there are not generally superfluous words in claims. Here, “walking” means something. As an
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`ordinary meaning, one would expect it to exclude non-walking (e.g., driving, flying, etc.).
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`However, the specification does not fully set out the contours of what the inventors believe to be
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`excluded from the term walking. That is, are all non-walking activities excluded? Flying?
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`Skipping? To be conservative, I have focused on the specific activity the specification does in
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`fact distinguish from walking – operation of car. As shown above, the specification makes plain
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`that the invention is different from (and does not include) driving. In my opinion, a person of
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`ordinary skill in the art, reading the specification and other intrinsic evidence, would conclude
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`that the inventors have expressly disavowed driving systems from the scope their invention.
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`39.
`
` In my opinion the term “walking navigation” concerns “display of information to
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`assist a user in walking, not driving, in a system that is not usable in an object car that is running
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`on a road”.
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`40.
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`The specification makes clear that a walking navigation system is for
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`walkers/users to carry around while walking. A driving navigation system associated with a car
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`comes up only in one example in the background of the invention section, and the example
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`clearly identifies that the invention is designed to overcome the problems associated with such a
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`system. For example, that such systems cannot be used as a walker’s navigation system. ‘317
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`Patent at 1:31-38.
`
`41.
`
`The patent nowhere describes a navigation system that is designed be used for
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`both walking and driving navigation. In fact, using the navigation system of the patent for
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`driving is not described or discussed in the patent specification. Maxell states: “For example, the
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`’317 Patent describes several specific examples of “walking navigation,” and each example
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`entails providing information that navigates a user that is walking.”, except this provides no
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`insight as to how this navigation process or the need of the user would be different if walking or
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`driving.
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`42.
`
`In my opinion, none of the examples the plaintiff asserts about ‘Walking
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`Navigation” apply only to walking as opposed to driving or other activities. The three examples
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`cited by the plaintiff, “Neighborhood Guidance Service”, “Meeting by Appointment Guidance
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`Service”, and “Present Place Guidance Service” are all features that have been provided in
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`vehicle based systems since well before the application filing data of the ‘317 patent. For
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`example, the 1996 Acura RL navigation system, a vehicle based navigation system, provided a
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`point of interest search function, wherein the system would present a list of facilities meeting the
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`user’s specification (e.g. restaurants, hotels, hospitals, parks, etc.) ranked by distance from the
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`vehicle’s current location. This is equivalent to the referenced “Neighborhood Guidance
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`Service”, and “Present Place Guidance Service”. As for the “Meeting by Appointment Service”
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`the 1998 Toyota MONET system, available in 1999 Toyota vehicles in Japan provided a feature
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`wherein a user could send a destination for a meeting from their PC, via email, to the in-vehicle
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`MONET navigation system, so that the driver could set that location as the destination and
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`subsequently be guided to that location to meet the sender.
`
`B.
`
`[a device connected to a server,] “said device connected to said server
`outputting said location information and said direction information and
`receiving retrieved information based on said outputted information at said
`server.”
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning
`
`Defendant’s Proposed Construction
`
`Indefinite
`This is a means-plus-function element to be
`construed in accordance with 35 U.S.C. § 112, ¶
`6.
`Function: outputting said location information
`and said direction information and receiving
`retrieved information based on said outputted
`information at said server
`Structure: insufficient corresponding structure is
`disclosed
`
`
`
`43.
`
`This claim term was not discussed in Plaintiff’s Opening Claim Construction
`
`Brief, and thus I do not know what the basis for their position is and thus cannot, at this time,
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`fully rebut any position Plaintiff may have on the construction. .
`
`44.
`
`In my opinion, this phrase is a means-plus-function limitation because it does not
`
`connote sufficiently definite structure to one of skill in the art. In addition, a person of ordinary
`
`skill in the art reading the specification would not be able to identify any corresponding structure
`
`in the specification for outputting said location information and said direction information and
`
`receiving retrieved information based on said outputted information at said server. Accordingly,
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`it is my opinion that a person would not understand with reasonable certainty what structure is
`
`being claimed.
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`45.
`
`The term “a device connected to a computer” does not have an accepted and
`
`ordinary meaning in the art. It does not refer to specific structure and a person of skill in the art,
`
`would just consider “device” as a generic term like “means.” The term “device” is a non-
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`structural, nonce word that is tantamount to using the word ‘means’ because it does not connote
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`sufficiently definite structure.
`
`46.
`
`Although the phrase does not use the word “means,” the phrase also does not
`
`recite sufficiently definite structure for performing the claimed function of outputting said
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`location information and said direction information and receiving retrieved information based on
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`said outputted information at said server. For example, Claim 6 requires a “device for getting
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`location information denoting a present place of said portable terminal” and “a device for getting
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`direction information denoting an orientation of said portable terminal.” These devices are
`
`identified, for example in Figure 10 of the patent specification as items 78 and 77 respectively.
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`They are described, minimally, in the specification (see, e.g., Col. 9, lines 40-59). I note that
`
`while these devices are described as potentially being external to the portable device itself (see
`
`e.g., Col. 9, lines 59-63), there is no mention that these functions might be performed by a
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`remote server, and no description of how such a remote server might obtain any information
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`relating to the present position or orientation of the portable device.
`
`47.
`
`The “said device connected to said server” is claimed (e.g., claim 6) as outputting
`
`this location and direction information, and receiving “retrieved information based on said
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`outputted information” yet there is no description of how this location and direction information
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`is outputted, what element receives it, and what element subsequently retrieves it and provides it
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`to the device. To be sure, there is, in Figure 10, an identified “device for data communication”,
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`but nowhere in the patent is there described a “device connected to a server”, and nowhere is the
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`composite of the “device for data communication”, the “device for getting location information”
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`and the “device for getting direction information” described as comprising a “device connected
`
`to a server”, nor is the overall portable terminal described as somehow fulfilling this structure. In
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`fact, the description that one of the location, communication and direction functions may be
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`external to the portable terminal further confuses what specific structure is being referenced by
`
`this claim term.
`
`48.
`
`One of ordinary skill in the art would not understand the term “a device,” standing
`
`alone, to provide sufficiently definite structure, because much like a generic term, “a device” is
`
`merely a construct that is often used by person skill in the art that is equivalent to the word
`
`“means.” The term “a device” is generic that could be anything from a computer device to a
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`display device.
`
`49.
`
`Furthermore, the claim term includes software steps, such as outputting location
`
`and direction information and receiving retrieved information and the specification does not
`
`specify any corresponding algorithm or structure, nor does it reference any industry standards
`
`that a practitioner might apply to implement these steps. Figures 2, 6, and 7 all provide various
`
`descriptions of internal algorithms for performing some claimed functions, but none of these
`
`describe the steps or logical operations required to output location and direction information, or
`
`to what entity this information is outputted, and they also do not describe the steps associated
`
`with retrieving information based on this outputted information, or where it is retrieved from.
`
`50.
`
`Thus, it is my opinion that this phrase is a means-plus-function limitation, and the
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`claim does not itself recite sufficient structure to peform the recited functions. .
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`51. Moreover, no specific structure – aside from the generic description – is provided
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`in the specification for performing the recited functions. Nor is there an algorithm disclosed for
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`performing any of the software steps.
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`52.
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`Thus, in my opinion the claim term is a means-plus-function term and there is
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`insufficient structure disclosed in the specification to support the recited functions. As such, it is
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`my opinion that the claims that recite this term (both independent and dependent claims) are
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`invalid.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct to the best of my knowledge and that this declaration was executed
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`on October 23, 2017.
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`Executed: October 23, 2017
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`______________________________
`Scott Andrews
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`APPENDIX A
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`Case 5:16-cv-00178-RWS Document 100-6 Filed 10/23/17 Page 18 of 29 PageID #: 2284
`Scott Andrews
`scott@cogenia.com
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`Petaluma, CA
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`(650) 279-0242
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`Summary
`Creative, energetic, and innovative internationally recognized technical executive
`experienced
`in general management, systems engineering, advanced product
`development, advanced technology, business development, strategic planning, and
`program management
`
`• Enterprise Software
`• Multimedia/Internet Computing
`• Vehicle Safety and Control Systems
`• Spacecraft Electronics
`• Mobile Information Technology
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` •
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` Vehicle Electrical/Electronics Systems
`• Vehicle Information Systems
`• Communications Systems
`• ITS and Related Industries
`• Program and Project Management
`
`
`Experience
`Cogenia Partners, LLC
`12/2001-Present
`Systems engineering, business development and technical strategy consulting supporting
`automotive and information technology.
`Current Engagements:
`• Technical consultant for connected vehicle security credential management
`system deployment; Sponsored by US DOT FHWA
`• Technical consultant for mobile device integration with connected vehicle
`systems. DOT Research and Innovative Technologies Admin. (RITA)
`• Expert witness for:
`o ZTE, related to cell phone navigation systems
`o VW/Audi, related to vehicle WiFi Hotspots
`o Unified Patents, related to mobile device navigation systems
`o Wasica, related to tire pressure monitor systems
`Prior Engagements/Projects:
`• Developed systems engineering methodology for vehicle E/E systems; Applied
`methodology on project for Yazaki to reverse engineer the E/E architecture for a
`2004 BMW 5 series vehicle.
`• Designed novel super capacitor based high performance hybrid vehicle as part of
`an early stage startup company; Developed performance requirements, conceptual
`designs and patented integrated electrical system architecture concept.
`• Chief System Architect for the Vehicle Infrastructure Integration (VIIC) program
`(BMW, Chrysler, Daimler Benz, Ford, GM, Honda, Nissan, Toyota, VW); A
`connected vehicle research program funded by U.S. DOT FHWA.
`• Co-Principal investigator for Integrated Advanced Transportation System; A 30+
`year future technical feasibility assessment and strategy for U.S. DOT Federal
`Highway Admin. (FHWA).
`• Technical consultant to American Association of State Highway Transportation
`Officials (AASHTO) for connected vehicle deployment analysis and strategy.
`• Technical consultant to Michigan State DOT (Enterprise Pooled Fund) to develop
`a system architecture and deployment strategy for Rural ITS.
`• Telematics delivery architecture development for a Fortune 100 service provider
`• Technical consultant to the Vehicle Safety Consortium developing Dedicated
`Scott Andrews
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`Case 5:16-cv-00178-RWS Document 100-6 Filed 10/23/17 Page 19 of 29 PageID #: 2285
`Short Range Communications (DSRC) standards for safety systems;
`• Toyota Motor Sales – 10 year technology survey;
`• Connected Vehicle Trade Association- Transferred AMI-C specifications to ISO
`TC 22, TC 204 AND OSGi. Developed OSGi Vehicle Interface Specification;
`• Expert witness for:
`o ATT vs. Vehicle IP relating to cell phone navigation systems
`o VW/Audi vs. Beacon, relating to traffic information systems
`o VW/Audi vs. Blitzsafe relating to mobile device integration and mobile
`audio systems
`o T-Mobile vs. TracBeam relating to wireless location technologies
`o VW/Audi vs. Joao relating to remote service architecturesApple Computer
`vs. Porto relating to cell phone navigation systems
`o Mercedes vs. Adaptive Headlamp Technologies relating to adaptive
`headlamps
`o Liberty Mutual, Geico and Hartford vs. Progressive Insurance relating to
`usage based insurance systems
`o Toyota vs. American Vehicular Sciences (AVS) relating to occupant
`sensing systems
`o Lenovo and Amazon vs. Pragmatus relating to device tracking
`o Ford in a patent vs. Eagle Harbor Holdings relating to Bluetooth systems
`and mobile device integration in the vehicle
`o Bentley vs. Cruise Control Technologies relating to adaptive cruise control
`o Google vs. Walker Digital relating to 3D navigation displays
`o Volkswagen/Sirius-XM vs. case relating to traffic information systems
`o Volk