UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Unified Patents Inc.
`Petitioner
`
`V.
`
`Location Based Services, LLC
`Patent Owner
`
`IPR2017-.01965
`U.S. Patent 7,860,648
`
`DECLARATION OF CHRISTOPHER K. WILSON
`
`Page 1 of 97
`
`UNIFIED PATENTS EXHIBIT 1004
`
`Bradium Exhibit 2045
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 1 of 6
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`Unified Patents Inc.
`Petitioner
`
`V.
`
`Location Based Services, LLC
`Patent Owner
`
`IPR2017-.01965
`U.S. Patent 7,860,648
`
`DECLARATION OF CHRISTOPHER K. WILSON
`
`Page 1 of 97
`
`UNIFIED PATENTS EXHIBIT 1004
`
`Bradium Exhibit 2045
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 1 of 6
`
`
`
`Contents
`
`I.
`
`INTRODUCTION
`
`.1
`
`II. QUALIFICATIONS ........................................................................................1
`
`III. MATERIALS CONSIDERED........................................................................3
`
`IV. RELEVANT LEGAL STANDARDS.............................................................4
`
`A.
`
`B.
`
`C.
`
`Prior Art.................................................................................................5
`
`Anticipation: 35 U.S.C. § 102 ...............................................................5
`Obviousness: 35 U.S.C. § 103...............................................................6
`
`V.
`
`SUMMARY OF MY OPINIONS ...................................................................7
`
`VI. THE '648 PATENT .......................................................................................... 8
`
`A.
`
`B.
`
`C.
`
`Overview of the Disclosure...................................................................8
`
`State of the Art ....................................................................................12
`
`Level of Ordinary Skill in the Art.......................................................14
`
`VII. MEANING OF CERTAIN CLAIM TERMS ...............................................14
`
`A.
`
`B.
`
`C.
`
`"Map" (Claims 1 and 9)......................................................................15
`
`"Location Interaction Rules" (Claims 1 and 9)...................................16
`
`"Monitoring Device" (Claims 1 and 9)...............................................16
`
`VIII. EACH ELEMENT OF CLAIMS 1-4, 6, 7, 9, 10, 13, AND 141S
`TAUGHT OR RENDERED OBVIOUS BY THE PRIOR ART..................17
`
`A. Grounds 1 and 2: Gellberg anticipates or render obvious claims
`1-4,6,9,10, and 13 .............................................................................17
`
`1.
`
`Overview of Gellberg...............................................................17
`
`Page 2 of 97
`
`11
`
`Bradium Exhibit 2045
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 2 of 6
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`Gel/berg Discloses or Suggests the Elements of
`Independent Claim 1.................................................................23
`
`Gel/berg Discloses or Suggests the Elements of Claim 2........43
`
`Gel/berg Discloses or Suggests the Element of Claim 3..........44
`
`Gel/berg Discloses or Suggests the Features of Claim 4..........47
`
`Ge/lberg Discloses or Suggests the Features of Claim 6..........49
`
`Gel/berg Discloses or Suggests the Elements of Claims 9,
`10, and l3. ................................................................................. 54
`
`B.
`
`C.
`
`Ground 3: Gel/berg and Schroeder render obvious claims 7 and
`14.........................................................................................................57
`
`Ground 4: DeKock Renders Obvious Claims 1-4, 6, 7, 9, 10, 13,
`and14..................................................................................................60
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`Overview of DeKock.................................................................60
`
`DeKock Discloses or Suggests the Elements of Claim 1..........64
`
`DeKock Discloses or Suggests the Elements of Claim 2..........82
`
`DeKock Discloses or Suggests the Elements of Claim 3..........83
`
`DeKock Discloses or Suggests the Elements of Claim 4..........83
`
`DeKock Discloses or Suggests the Elements of Claims 6
`and7. ......................................................................................... 85
`
`DeKock Discloses or Suggests the Element of Claims 9,
`10, 13, and 14............................................................................87
`
`IX. CONCLUSION..............................................................................................90
`
`Page 3 of 97
`
`111
`
`Bradium Exhibit 2045
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 3 of 6
`
`
`
`U.S. Patent 7,860,648
`Declaration of Christopher K. Wilson
`
`I, Christopher K. Wilson, declare as follows:
`
`I.
`
`INTRODUCTION
`
`I have been retained by Unified Patents Inc. ("Unified" or "Petitioner") as an
`
`independent expert consultant in this proceeding before the United States Patent
`
`and Trademark Office. Although I am being compensated at my usual rate of $350
`
`per hour for the time I spend on this matter, no part of my compensation depends
`
`on the outcome of this proceeding, and I have no other interest in this proceeding.
`
`II. QUALIFICATIONS
`
`1.
`
`I have a bachelor's degree in Physics from Princeton University and
`
`one year of graduate school in Physics at the University of California, San Diego.
`
`My qualifications and professional experienced are described in my curriculum
`
`vitae, attached to my declaration as Appendix A.
`
`2.
`
`I am currently an independent consultant to the transportation industry
`
`focused on the use of vehicle data and analytics to provide cloud services in
`
`support of safety systems in automated and semi-automated vehicles.
`
`3.
`
`I have 23 years of experience in the automotive safety technology
`
`field working for tier 1 suppliers (TRW and TomTom) and vehicle manufacturers
`
`(Mercedes Benz), as well as working with other vehicle manufacturers and
`
`government in consortia developing pre-competitive technologies and performance
`
`metrics for vehicle safety systems, and consulting.
`
`Page 4 of 97
`
`1
`
`Bradium Exhibit 2045
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 4 of 6
`
`
`
`U.S. Patent 7,860,648
`Declaration of Christopher K. Wilson
`
`4.
`
`I worked on the development of traffic management systems in San
`
`Francisco, Atlanta and Houston where I advocated the use of vehicle data for
`
`managing the system.
`
`5.
`
`In the early 2000s, I was a nationally recognized advocate for
`
`connected vehicle technology within transportation businesses, and have been
`
`working with transportation departments on deployment models as recently as
`
`2014. I worked closely with traffic engineers throughout this period, specifically
`
`identifying vehicle data that could be shared with traffic engineers to improve a
`
`transportation system.
`
`6.
`
`As related to this case, I developed one of the first telematics systems
`
`intended for a production vehicle ca. 1993. This system used a paging network to
`
`send the vehicle's location to emergency responders in the event of an airbag
`
`deployment, as well as supporting text based navigation customers. The system
`
`was very similar to GM's OnStar. As part of this effort I worked with standards
`
`organizations to develop standards for vehicle location to support both emergency
`
`response and navigation, and the dissemination of vehicle location and speed to
`
`traffic providers. Our system, and others at the time, were developed to both
`
`provide information to drivers and to collect information on traffic that could
`
`improve the information sent to drivers. My work on traffic management systems
`
`was attempting to deploy such feedback systems in various metropolitan systems.
`
`Page 5 of 97
`
`2
`
`Bradium Exhibit 2045
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 5 of 6
`
`
`
`U.S. Patent 7,860,648
`Declaration of Christopher K. Wilson
`
`7.
`
`I am the named inventor on five US and several international patents
`
`related to various aspects of navigation including improving a vehicle positioning
`
`system and methods for creating maps and uses for map content.
`
`III. MATERIALS CONSIDERED
`
`8.
`
`I understand that this proceeding involves U.S. Patent 7,860,648 ("the
`
`'648 patent," EX1001). I understand that the '648 patent granted from U.S. patent
`
`application no. 12/406,478, filed March 18, 2009. I understand that the '648 patent
`
`application claims priority as a continuation to U.S. application no. 11/124,626,
`
`filed April 30, 2005 (now U.S. Patent 7,522,996).
`
`9.
`
`I have been asked to consider whether certain prior art references
`
`disclose or suggest the features recited in certain '648 patent claims. I have also
`
`been asked to consider the state of the art of mapping and navigations systems in
`
`the 2005 timeframe, and to compare the claimed systems and methods of the '648
`
`patent to the prior art available at that time. My opinions are provided below.
`
`10.
`
`In forming my opinions, I have considered:
`
`Exhibit
`EX 1001
`EX1002
`EX1003
`EX1005
`
`EX1006
`
`EX1007
`
`Description
`U.S. Patent No. 7,860.648 (the '648 patent").
`File History of the '648 patent.
`File History of U.S. Patent No. 7,522,996 ("the '996 patent").
`International Patent Application Publication No. WO 0 1/55994 to
`Gellberg ("Gellberg").
`U.S. Patent Application Publication No. 2003/0069691 to Schroeder
`("Schroeder").
`U.S. Patent No. 6,574,548 to DeKock et at. ("DeKock").
`
`Page 6 of 97
`
`3
`
`Bradium Exhibit 2045
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`Page 6 of 6
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
