IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`
`MAXELL, LTD.,
`
`Plaintiff,
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`
`
`
`
`
`
`vs.
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`APPLE INC.,
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`
`
`
`
`Defendant.
`
` Civil Action No. 5:19-cv-00036-RWS
`
`
`JURY TRIAL DEMANDED
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`
`
`DEFENDANT APPLE INC.’S INVALIDITY CONTENTIONS
`PURSUANT TO PATENT LOCAL RULES 3-3 AND 3-4
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`
`
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`
`Apple v. Maxell
`IPR2020-00408
`Maxell Ex. 2006
`
`Page 1 of 135
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`I.
`
`INTRODUCTION
`
`Pursuant to the Court’s Docket Control Order entered July 9, 2019 (D.I. 46) and Patent
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`Local Rules 3-3 and 3-4, Defendant Apple Inc. (“Apple”) provides these preliminary invalidity
`
`contentions (“Invalidity Contentions”) to Maxell, Ltd. (“Maxell”) for the asserted claims of U.S.
`
`Patent Nos. 6,748,317 (“the ’317 patent”); 6,580,999 (“the ’999 patent”); 8,339,493 (“the ’493
`
`patent”); 7,116,438 (“the ’438 patent”); 6,408,193 (“the ’193 patent”); 10,084,991 (“the ’991
`
`patent”); 6,928,306 (“the ’306 patent”); 6,329,794 (“the ’794 patent”); 10,212,586 (“the ’586
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`patent”); 6,430,498 (“the ’498 patent”) (collectively, the “Asserted Patents”).
`
`Based on Maxell’s Disclosure of Asserted Claims and Infringement Contentions
`
`(“Infringement Contentions”) served on June 12, 2019, Maxell is asserting claims 1-3, 5-15, 17,
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`and 18 of the ’317 patent; claims 1-6 of the ’999 patent; claims 1, 3-6, 10, and 11 of the ’493
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`patent; claims 1-7 of the ’438 patent; claims 1, 6, and 7 of the ’193 patent; claims 1-5 and 8-12 of
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`the ’991 patent; claims 2, 5, 6, and 12-15 of the ’306 patent; claims 1-3 and 5-14 of the ’794 patent;
`
`claims 1-2, 6-7, 9-10, 13-14, and 16-18 of the ’586 patent; and claims 1, 3-5, 7-11, and 13 of the
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`’498 patent (collectively, “the Asserted Claims”). Apple addresses the invalidity of the Asserted
`
`Claims in these Invalidity Contentions, and concludes with a description of its document
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`production and identification of additional reservations and explanations.
`
`These Invalidity Contentions are based on the claim constructions or interpretations likely
`
`to be advanced by Maxell (as reflected in Maxell’s Complaint and Infringement Contentions), and
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`are not necessarily based on what Apple contends are the proper constructions. By applying
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`Maxell’s apparent constructions and/or interpretations, Apple does not concede in any way that
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`those constructions are correct, and instead expressly reserves the right to oppose those
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`constructions. Apple expressly reserves the right to amend these Invalidity Contentions after the
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`Court has construed all relevant claim terms under P.R. 3-6. Furthermore, some of Apple’s
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`IPR2020-00408
`Maxell Ex. 2006
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`Page 2 of 135
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`contentions herein are based on infringement allegations made by Maxell. Apple does not concede
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`in any way that those infringement allegations are correct, but rather asserts the fundamental
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`principle that whatever infringes a claim if later in time must anticipate if earlier in time. These
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`Invalidity Contentions use the acronym “PHOSITA” to refer to a person having ordinary skill in
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`the art to which the alleged invention pertains around the respective priority dates alleged by
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`Maxell.
`
`Apple hereby incorporates by reference all Invalidity Contentions against any of the
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`Asserted Patents or their related patents from prior cases, including, but not limited to, the
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`Invalidity Contentions served by the defendants in Hitachi Maxell, Ltd. v. Huawei Device USA,
`
`Inc., Case No. 5:16-CV-00178-RWS (E.D. Tex.); Hitachi Maxell, Ltd. v. ZTE Corp., Case No.
`
`5:16-CV-00179-RWS (E.D. Tex.); Maxell, Ltd. v. ASUSTEK Computer Inc., Case No. 2:17-cv-
`
`7528-R-MRW (C.D. Cal.); and Maxell, Ltd. v. ASUSTEK Computer Inc., Case No. 3:18-cv-01788-
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`VD (N.D. Cal.). Maxell is already in possession of these Invalidity Contentions and associated
`
`claim charts. Apple further incorporates by reference all prior art cited during prosecution of the
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`Asserted Patents, and all inter partes review (IPR) petitions filed against the Asserted Patents and
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`the prior art cited in these IPR petitions, including, but not limited to, IPR2018-00235, IPR2019-
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`00071, IPR2018-00236, IPR2018-00904, IPR2018-00241, IPR2018-00237, and IPR2019-00640.
`
`II.
`
`’317, ’999, AND ’498 PATENTS
`
`The ’498 patent was filed with the United States Patent and Trademark Office on July 11,
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`2000. The ’999 patent was filed with the United States Patent and Trademark Office on June 18,
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`2002 as a continuation of Application No. 09/613,634 (filed on July 11, 2000; issued as the ’498
`
`patent). The ’317 patent was filed with the United States Patent and Trademark Office on May 5,
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`2000 as a continuation of Application No. 10/173,423 (filed on June 18, 2001; issued as the ’999
`
`patent), which in turn was filed as a continuation of Application No, 09/613,634 (filed on July 11,
`
`2
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`2000). In its Infringement Contentions, Maxell claims a priority date of July 12, 1999 for the ’317,
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`’999, and ’498 patents. Apple reserves the right to serve additional or modified invalidity
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`contentions should Maxell be permitted to amend or modify its claimed priority date.
`
`A.
`
`Prior Art
`
`Apple identifies the following prior art now known to Apple to anticipate and/or render
`
`obvious one or more claims of the ’317, ’999, and ’498 patents under at least 35 U.S.C. §§ 102(a),
`
`(b), (e), (g), and/or 103.
`
`1.
`
`Prior Art Patents and Publications
`
`The following patents and publications are prior art for the Asserted Claims of the ’317,
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`’999, and ’498 patents under at least 35 U.S.C. §§ 102(a), (b), (e), and/or (g). Invalidity claim
`
`charts for these references are attached as Exhibits A1 through A21.
`
`1. Japanese Patent Publication No. JPH08-285613 to Akiyama et al. (“Akiyama”),
`published on November 1, 1996.
`
`2. Japanese Patent Publication No. JPH10-197277 to Maruyama et al. (“Maruyama”),
`published on July 31, 1998.
`
`3. U.S. Patent No. 5,781,150 to Norris (“Norris”), filed on October 13, 1995 and
`issued on July 14, 1998.
`
`4. Cyberguide: A Mobile Context-Aware Tour Guide by Abowd et al. (“Abowd”),
`published on September 29, 1998.
`
`5. PCT Application US98/17237 (WO 99/09374) to Knockeart, et al. (“Knockeart”),
`published on February 25, 1999.
`
`6. U.S. Patent No. 6,067,502 to Hayashida et al. (“Hayashida”), filed on August 21,
`1997 and issued on May 23, 2000.
`
`7. U.S. Patent No. 5,815,411 to Ellenby, et al. (“Ellenby”), filed on September 10,
`1993 and issued on September 29, 1998.
`
`8. Japanese Patent Publication No. JPH09-311625 to Ikeda (“Ikeda”), published on
`December 2, 1997.
`
`9. Japanese Patent No. JPH05-264711 (“Yokoyama” or the “’711 Patent”), published
`on October 12, 1993.
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`10. U.S. Patent No. 5,589,835 to Gildea et al. (“Gildea”), filed on December 20, 1994
`and issued on December 31, 1996.
`
`11. U.S. Patent No. 6,525,768 to Obradovich (“Obradovich”), filed on October 21,
`1999 based on Provisional Application No. 60/105,050 (“the ’050 Application”)
`filed on October 21, 1998, and issued on February 25, 2003.1
`
`12. U.S. Patent No. 5,592,382 to Colley (“Colley”), issued on January 7, 1997.
`
`13. USRE42,927 to Want et al. (“Want”) reissued from U.S. Patent No. 6,122,520, filed
`on February 13, 1998 and issued on September 19, 2000.
`
`Apple’s investigation into prior art patent and publication references remains ongoing and
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`Apple reserves the right to identify and rely on additional patent or publication references that
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`describe or are otherwise related to the prior art systems identified below based on information
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`obtained through discovery.
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`2.
`
`Prior Art Systems
`
`The following systems are anticipatory prior art for the Asserted Claims of the ’317, ’999,
`
`and ’498 patents under at least 35 U.S.C. §§ 102(a), (b) and/or (g):
`
`1. Products, components, systems, and methods invented, designed, developed,
`reduced to practice, and/or in public use or on sale related to the Seiko Epson
`Locatio (“Locatio”), as exemplified in claim charts in Exhibits A13-A15. As part
`of these Invalidity Contentions, Apple has produced documents relating to Locatio.
`Based on information available to Apple, Apple believes that this system was
`conceived and/or reduced to practice by engineers at Seiko Epson at least before
`
`1 The ’050 Application is substantively identical to Obradovich, including the same written
`description of the invention and figures illustrating the same. Where, as here, “the specification
`of the provisional” satisfies 35 U.S.C. § 112 ¶ 1 for the “invention claimed in the non-provisional
`application,” the non-provisional patent qualifies as prior art under 35 U.S.C. § 102(e) as of the
`date of the filing date of its provisional application. Dynamic Drinkware, LLC v. Nat’l Graphics,
`Inc., 800 F.3d 1375, 1378 (Fed. Cir. 2015); see also New Railhead Mfg., L.L.C. v. Vermeer Mfg.
`Co., 298 F.3d 1290, 1294 (Fed. Cir. 2002) (“[F]or the non-provisional utility application to be
`afforded the priority date of the provisional application, ... the written description of the provisional
`must adequately support the claims of the non-provisional application.”). Additionally, because
`the disclosures are substantively identical, all disclosures from Obradovich cited in these Invalidity
`Contentions are also contained in the ’050 Application. Accordingly, Obradovich qualifies as
`prior art to the ’317, ’498, and ’999 patents under at least 35 U.S.C. § 102(e) as of the ’050
`Application’s filing date of October 21, 1998.
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`May 17, 1999, without being abandoned, suppressed, or concealed, and was in
`public use or on sale in or before June 1999.
`
`2. Products, components, systems, and methods invented, designed, developed,
`reduced to practice, and/or in public use or on sale related to the CyberGuide system
`(“CyberGuide”), as exemplified in claim charts in Exhibits A10-A12. As part of
`these Invalidity Contentions, Apple has produced documents relating to
`CyberGuide. Based on information available to Apple, Apple believes that this
`system was conceived and/or reduced to practice in researchers at the Georgia
`Institute of Technology (including, for example, Gregory Abowd, Christopher
`Atkeson, Jason Hong, Rob Kooper, Jason Bennett, Derek Adams, Matt Howser,
`and others) at least before September 23, 1996, without being abandoned,
`suppressed, or concealed, and was in public use or on sale in the U.S. in or before
`September 1996.
`
`3. Products, components, systems, and methods invented, designed, developed,
`reduced to practice, and/or in public use or on sale related to the Garmin NavTalk
`(“NavTalk”), as exemplified in claim charts in Exhibits A16-A18. As part of these
`Invalidity Contentions, Apple has produced documents relating to NavTalk. Based
`on information available to Apple, Apple believes that this system was conceived
`and/or reduced to practice by engineers at Garmin at least before January 1999,
`without being abandoned, suppressed, or concealed, and was in public use or on
`sale in the U.S. on or before January 31, 1999.
`
`Apple’s investigation into prior art systems remains ongoing and Apple reserves the right
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`to identify and rely on systems that represent different versions or are otherwise related variations
`
`of the systems identified above. Apple further reserves the right to revise, amend, update, and/or
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`supplement the information provided in these Invalidity Contention (including the attached claim
`
`charts) based on additional information and evidence obtained through discovery. Apple also
`
`reserves the right to rely on any system, product, or public knowledge or use that embodies or
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`otherwise incorporates any of the prior art patents and publications listed above. In addition to the
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`prior art products, components, systems, and methods described above, Apple also reserves the
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`right to rely on documents and publications relating to the prior art listed above as prior art
`
`publications.
`
`B.
`
`Anticipation
`
`Apple contends that each prior art reference and system (collectively, “references”)
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`anticipates one or more claims of the ’317, ’999, and ’498 patents under at least 35 U.S.C. §§
`
`102(a), (b), (e), and/or (g), either expressly or inherently as understood by a PHOSITA:
`
`1. Japanese Patent Publication No. JPH08-285613 to Akiyama et al. (“Akiyama”),
`published on November 1, 1996. See Exs. A1-A3.
`
`2. Japanese Patent Publication No. JPH10-197277 to Maruyama et al. (“Maruyama”),
`published on July 31, 1998. See Exs. A4-A6.
`
`3. U.S. Patent No. 5,781,150 to Norris (“Norris”), filed on October 13, 1995 and
`issued on July 14, 1998. See Exs. A7-A9.
`
`4. The Cyberguide system, made publicly available at least as early as September
`1996 and described in at least (1) Abowd, Gregory D., A Mobile Context-Aware
`Tour Guide, Baltzer Journals (September 23, 1996) (“Abowd”); (2) Long, Sue,
`Cyberguide: Prototyping Context-Aware Mobile Applications, Future Computing
`Environments,
`https://www.cc.gatech.edu/fce/cyberguide/pubs/chi96-
`cyberguide.html (“Cyberguide Prototyping”); and (3) CyBARguide Project Notes
`by Mike
`Pinkerton,
`Gregory
`Abowd,
`and
`Sue
`Long,
`https://www.cc.gatech.edu/fce/cyberguide/cybarguide/CyBARguide.html
`(“CyBARguide”) (collectively, “Cyberguide”). See Exs. A10-A12.
`
`5. Products, components, systems, and methods invented, designed, developed,
`reduced to practice, and/or in public use or on sale related to the Seiko Epson
`Locatio (“Locatio”). See Exs. A13-A15.
`
`6. Products, components, systems, and methods invented, designed, developed,
`reduced to practice, and/or in public use or on sale related to the Garmin NavTalk
`(“NavTalk”). See Exs. A16-A18.
`
`7. U.S. Patent No. 6,067,502 to Hayashida (“Hayashida”), filed on August 21, 1997
`and issued on May 23, 2000. See Exs. A19-A21.
`
`C.
`
`Obviousness
`
`Apple contends that each prior art reference disclosed in the preceding Anticipation section
`
`may be combined with (1) information known to persons skilled in the art at the time of the alleged
`
`invention, (2) the applicant-admitted prior art in the specification, (3) any of the other anticipatory
`
`prior art references, and/or (4) any of the additional prior art references identified in this section to
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`render these claims invalid as obvious.
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`1.
`
`Exemplary Combinations
`
`Below is a listing of exemplary combinations of references that render obvious the Asserted
`
`Claims of the ’317, ’999, and ’498 patents. For at least the reasons described below, it would have
`
`been obvious to a PHOSITA to combine any of a number of prior art references, including any
`
`combination of those identified below, to meet the limitations of the Asserted Claims of the ’317,
`
`’999, and ’498 patents. These exemplary combinations are alternatives to Apple’s anticipation
`
`and single-reference obviousness contentions, and, thus, they should not be interpreted as
`
`indicating that any of the individual references included in the exemplary combinations are not by
`
`themselves invalidating prior art under §§ 102 and/or 103. Apple reserves the right to identify
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`additional combinations during expert discovery and later stages of the case.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of
`Hayashida/Ellenby/Ikeda/the ’711 Patent/the NavTalk. See Ex. A1.
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in further view of Hayashida/Ellenby/Ikeda/the
`’711 Patent/the NavTalk. See Ex. A1.
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of
`Hayashida/Ellenby/Ikeda/the
`’711 Patent/the NavTalk
`in
`further view of
`Hayashida/Akiyama. See Ex. A1.
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in view of Hayashida/Ellenby/Ikeda/the ’711
`Patent/the NavTalk in further view of Hayashida/Akiyama. See Ex. A1.
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want). See Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart. See Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of
`Maruyama/the Locatio/the Cyberguide/Knockeart. See Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in further view of view of Maruyama/the
`Locatio/the Cyberguide/Knockeart. See Ex. A1.
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`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of
`Maruyama/the Locatio/the Cyberguide/Knockeart in further view of Knockeart. See
`Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in view of Maruyama/the Locatio/the
`Cyberguide/Knockeart in further view of Knockeart. See Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of
`Hayashida/Ellenby/Ikeda/the ’711 Patent/the NavTalk in further view of Norris/the
`NavTalk/the Locatio/Maruyama/the Cyberguide/Obradovich. See Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in view of Hayashida/Ellenby/Ikeda/the ’711
`Patent/the NavTalk in further view of Norris/the NavTalk/the Locatio/Maruyama/the
`Cyberguide/Obradovich. See Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of
`Hayashida/Ellenby/Ikeda/the ’711 Patent/the NavTalk in view of Norris/the
`NavTalk/the Locatio/Maruyama/the Cyberguide/Obradovich in further view of the
`’711 Patent. See Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in view of Hayashida/Ellenby/Ikeda/the ’711
`Patent/the NavTalk in view of Norris/the NavTalk/the Locatio/Maruyama/the
`Cyberguide/Obradovich in further view of the ’711 Patent. See Ex. A1.
`
` •
`
` •
`
` Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of
`Hayashida/Ellenby/Ikeda/the ’711 Patent/the NavTalk in view of Norris/the
`NavTalk/the Locatio/Maruyama/the Cyberguide/Obradovich in further view of
`Hayashida/Akiyama. See Ex. A1.
`
` Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in view of Hayashida/Ellenby/Ikeda/the ’711
`Patent/the NavTalk in view of Norris/the NavTalk/the Locatio/Maruyama/the
`Cyberguide/Obradovich in further view of Hayashida/Akiyama. See Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of
`Hayashida/Ellenby/Ikeda/the ’711 Patent/the NavTalk in further view of
`Maruyama/the Locatio/the Cyberguide. See Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in view of Hayashida/Ellenby/Ikeda/the ’711
`Patent/the NavTalk in further view of Maruyama/the Locatio/the Cyberguide. See
`Ex. A1.
`
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`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of
`Hayashida/Ellenby/Ikeda/the ’711 Patent/the NavTalk in view of Maruyama/the
`Locatio/the Cyberguide in further view of the ’711 Patent. See Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in view of Hayashida/Ellenby/Ikeda/the ’711
`Patent/the NavTalk in view of Maruyama/the Locatio/the Cyberguide in further view
`of the ’711 Patent. See Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of
`Hayashida/Ellenby/Ikeda/the ’711 Patent/the NavTalk in view of Norris/the
`NavTalk/the Locatio/Maruyama/the Cyberguide/Obradovich in further view of
`Maruyama/the Locatio/the Cyberguide. See Ex. A1.
`
`• Akiyama (or Akiyama in view of Gildea/the Cyberguide/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in view of Hayashida/Ellenby/Ikeda/the ’711
`Patent/the NavTalk in further view of Norris/the NavTalk/the Locatio/Maruyama/the
`Cyberguide/Obradovich in further view of Maruyama/the Locatio/the Cyberguide.
`See Ex. A1.
`
` •
`
` Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide). See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of the
`Cyberguide/Maruyama/Knockeart. See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of
`Hayashida/the ’711 Patent. See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of the
`Cyberguide/Maruyama/Knockeart in further view of Hayashida/the ’711 Patent. See
`Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of
`Norris/Maruyama/Ikeda/the ’711 Patent. See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of the
`Cyberguide/Maruyama/Knockeart in further view of Norris/Maruyama/Ikeda/the ’711
`Patent. See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of
`Hayashida/the ’711 Patent in further view of Norris/Maruyama/Ikeda/the ’711 Patent.
`See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of the
`Cyberguide/Maruyama/Knockeart in view of Hayashida/the ’711 Patent in further
`view of Norris/Maruyama/Ikeda/the ’711 Patent. See Ex. A2.
`
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`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of
`Maruyama/Norris/the Cyberguide/the Locatio/the NavTalk/Obradovich. See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of the
`Cyberguide/Maruyama/Knockeart in further view of Maruyama/Norris/the
`Cyberguide/the Locatio/the NavTalk/Obradovich. See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of
`Maruyama/Norris/the Cyberguide/the Locatio/the NavTalk/Obradovich in further
`view of Hayashida/the ’711 Patent. See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of the
`Cyberguide/Maruyama/Knockeart in view of Maruyama/Norris/the Cyberguide/the
`Locatio/the NavTalk/Obradovich in further view of Hayashida/the ’711 Patent. See
`Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of
`Maruyama/Norris/the Cyberguide/the Locatio/the NavTalk/Obradovich in further
`view of Maruyama/Ikeda/the ’711 Patent. See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of the
`Cyberguide/Maruyama/Knockeart in view of Maruyama/Norris/the Cyberguide/the
`Locatio/the NavTalk/Obradovich in further view of Maruyama/Ikeda/the ’711 Patent.
`See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of
`Maruyama/Norris/the Cyberguide/the Locatio/the NavTalk/Obradovich in view of
`Hayashida/the ’711 Patent in further view of Maruyama/Ikeda/the ’711 Patent. See
`Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of the
`Cyberguide/Maruyama/Knockeart in view of Maruyama/Norris/the Cyberguide/the
`Locatio/the NavTalk/Obradovich in view of Hayashida/the ’711 Patent in further
`view of Maruyama/Ikeda/the ’711 Patent. See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of
`Maruyama/Norris/the Cyberguide/the Locatio/the NavTalk/Obradovich in further
`view of Norris/Maruyama/Ikeda/the ’711 Patent. See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of the
`Cyberguide/Maruyama/Knockeart in view of Maruyama/Norris/the Cyberguide/the
`Locatio/the NavTalk/Obradovich in further view of Norris/Maruyama/Ikeda/the ’711
`Patent. See Ex. A2.
`
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`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of
`Maruyama/Norris/the Cyberguide/the Locatio/the NavTalk/Obradovich in view of
`Hayashida/the ’711 Patent in further view of Norris/Maruyama/Ikeda/the ’711 Patent.
`See Ex. A2.
`
`• Akiyama (or Akiyama in view of Gildea/Want/the Cyberguide) in view of the
`Cyberguide/Maruyama/Knockeart in view of Maruyama/Norris/the Cyberguide/the
`Locatio/the NavTalk/Obradovich in view of Hayashida/the ’711 Patent in further
`view of Norris/Maruyama/Ikeda/the ’711 Patent. See Ex. A2.
`
` Akiyama (or Akiyama in view of the Cyberguide/Gildea/Want) in view of
`Norris/Maruyama/the Locatio/the Cyberguide/the NavTalk/Obradovich. See Ex. A3.
`
`• Akiyama (or Akiyama in view of the Cyberguide/Gildea/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in further view of Norris/Maruyama/the
`Locatio/the Cyberguide/the NavTalk/Obradovich. See Ex. A3.
`
`• Akiyama (or Akiyama in view of the Cyberguide/Gildea/Want) in view of
`Norris/Maruyama/the Locatio/the Cyberguide/the NavTalk/Obradovich in further
`view of Hayashida/Maruyama. See Ex. A3.
`
`• Akiyama (or Akiyama in view of the Cyberguide/Gildea/Want) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in view of Norris/Maruyama/the Locatio/the
`Cyberguide/the NavTalk/Obradovich in further view of Hayashida/Maruyama. See
`Ex. A3.
`• Maruyama (or Maruyama in view of Gildea/Want/the Cyberguide). See Exs. A4-A6.
`• Maruyama (or Maruyama in view of Gildea/Want/the Cyberguide) in view of
`Knockeart. See Ex. A4.
`• Maruyama (or Maruyama in view of Gildea/Want/the Cyberguide) in view of
`Norris/Colley. See Exs. A4-A6.
`• Maruyama (or Maruyama in view of Gildea/Want/the Cyberguide) in view of the
`NavTalk/the Cyberguide/the Locatio/Obradovich. See Exs. A4, A6.
`• Maruyama (or Maruyama in view of Gildea/Want/the Cyberguide) in view of the
`NavTalk/the Cyberguide/the Locatio/Obradovich in further view of Norris/Colley. See
`Exs. A4, A6.
`• Maruyama (or Maruyama in view of Gildea/Want/the Cyberguide) in view of Colley.
`See Ex. A5.
`• Maruyama (or Maruyama in view of Gildea/Want/the Cyberguide) in view of the
`NavTalk/the Cyberguide/the Locatio/Obradovich. See Ex. A5.
`
` •
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`• Maruyama (or Maruyama in view of Gildea/Want/the Cyberguide) in view of
`Norris/Colley in further view of in view of the NavTalk/the Cyberguide/the
`Locatio/Obradovich. See Ex. A5.
`• Maruyama (or Maruyama in view of Gildea/Want/the Cyberguide) in view of Colley
`in further view of in view of the NavTalk/the Cyberguide/the Locatio/Obradovich. See
`Ex. A5.
`• Norris (or Norris in view of the Cyberguide/Want). See Exs. A7-A9.
`• Norris (or Norris in view of the Cyberguide/Want) in view of Maruyama/Colley. See
`Exs. A7-A9.
`• Norris (or Norris in view of the Cyberguide/Want) in view of the Locatio/Maruyama.
`See Exs. A7, A9.
`• Norris (or Norris in view of the Cyberguide/Want) in view of the Locatio/Maruyama
`in further view of Maruyama/Colley. See Exs. A7, A9.
`• Norris (or Norris in view of the Cyberguide/Want) in view of the Locatio/Maruyama
`in view of Maruyama/Colley in further view of Colley. See Ex. A7.
`• Norris (or Norris in view of the Cyberguide/Want) in view of Maruyama. See Ex. A8.
`• Norris (or Norris in view of the Cyberguide/Want) in view of Maruyama/Colley in
`further view of Maruyama. See Ex. A8.
`• Norris (or Norris in view of the Cyberguide/Want) in view of Colley. See Ex. A8.
`• Norris (or Norris in view of the Cyberguide/Want) in view of Maruyama in further
`view of Colley. See Ex. A8.
`• The Cyberguide (or the Cyberguide in view of Want). See Ex. A10-A12.
`
`• The Cyberguide (or the Cyberguide in view of Want) in view of Maruyama/the
`Locatio. See Ex. A10, A12.
`
` •
`
` The Cyberguide (or the Cyberguide in view of Want) in view of
`Hayashida/Ellenby/Ikeda. See Ex. A10.
`
`• The Cyberguide (or the Cyberguide in view of Want) in view of
`Hayashida/Ellenby/Ikeda in further view of Hayashida/the ’711 Patent. See Ex. A10.
`
`• The Cyberguide (or the Cyberguide in view of Want) in view of
`Hayashida/Ellenby/Ikeda in view of Maruyama/the Locatio in further view of
`Hayashida/Norris/Maruyama. See Ex. A10.
`
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`
`• The Cyberguide (or the Cyberguide in view of Want) in view of
`Hayashida/Ellenby/Ikeda in further view of Hayashida/the ’711 Patent/Akiyama. See
`Ex. A10.
`
`• The Cyberguide (or the Cyberguide in view of Want) in view of
`Hayashida/Ellenby/Ikeda in view of Maruyama/the Locatio. See Ex. A10.
`
`• The Cyberguide (or the Cyberguide in view of Want) in view of
`Hayashida/Ellenby/Ikeda in view of Maruyama/the Locatio in further view of
`Hayashida/the ’711 Patent /Akiyama. See Ex. A10.
`
` The Cyberguide (or the Cyberguide in view of Want) in view of
`Hayashida/Ellenby/Ikeda in view of Maruyama/the Locatio in further view of
`Hayashida/the ’711 Patent. See Ex. A10.
`
` The Cyberguide (or the Cyberguide in view of Want) in view of
`Hayashida/Akiyama/the ’711 Patent. See Ex. A11-A12.
`
` The Cyberguide (or the Cyberguide in view of Want) in view of
`Hayashida/Akiyama/the ’711 Patent in further view of Norris/Maruyama/Ikeda/the
`’711 Patent. See Ex. A11.
`
` The Cyberguide (or the Cyberguide in view of Want) in view of Akiyama/Knockeart
`in further view of Hayashida/Akiyama/the ’711 Patent. See Ex. A11.
`
` The Cyberguide (or the Cyberguide in view of Want) in view of
`Norris/Maruyama/Ikeda/the ’711 Patent. See Ex. A11.
`
` The Cyberguide (or the Cyberguide in view of Want) in view of Akiyama/Knockeart.
`See Ex. A11.
`
` The Cyberguide (or the Cyberguide in view of Want) in view of Maruyama/Ikeda/the
`’711 Patent. See Ex. A11.
`
` The Cyberguide (or the Cyberguide in view of Want) in view of Akiyama/Knockeart
`in further view of Maruyama/Ikeda/the ’711 Patent. See Ex. A11.
`
` The Cyberguide (or the Cyberguide in view of Want) in view of
`Hayashida/Akiyama/the ’711 Patent in further view of Maruyama/Ikeda/the ’711
`Patent. See Ex. A11.
`
` The Cyberguide (or the Cyberguide in view of Want) in view of Akiyama/Knockeart
`in view of Hayashida/Akiyama/the ’711 Patent in further view of
`Maruyama/Ikeda/the ’711 Patent. See Ex. A11.
`
`13
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`• The Cyberguide (or the Cyberguide in view of Want) in view of Akiyama/Knockeart
`in further view of Norris/Maruyama/Ikeda/the ’711 Patent. See Ex. A11
`
` •
`
` The Cyberguide (or the Cyberguide in view of Want) in view of Akiyama/Knockeart
`in view of Hayashida/Akiyama/the ’711 Patent in further view of
`Norris/Maruyama/Ikeda/the ’711 Patent. See Ex. A11.
`
`
`
` •
`
` •
`
` The Cyberguide (or the Cyberguide in view of Want) in view of Maruyama/the
`Locatio in further view of Hayashida/Akiyama/the ’711 Patent. See Ex. A12.
`
` The Locatio (or the Locatio in view of Gildea/Want/the Cyberguide) in view of
`Norris/the Cyberguide/Maruyama/Knockeart in further view of the ’711 Patent/the
`NavTalk/Hayashida. See Ex. A13.
`
`• The Locatio (or the Locatio in view of Gildea/Want/the Cyberguide) in view of
`Norris/the Cyberguide/Maruyama/Knockeart in view of the ’711 Patent/the
`NavTalk/Hayashida. See Ex. A13.
`
`• The Locatio (or the Locatio in view of Gildea/Want/the Cyberguide) in view of
`Norris/the Cyberguide/Maruyama/Knockeart. See Ex. A13.
`
` •
`
` The Locatio (in view of Gildea/Want/the Cyberguide) in view of Norris/the
`Cyberguide/Maruyama/Knockeart. See Ex. A14.
`
`• The Locatio (in view of Gildea/Want/the Cyberguide) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in further view of the
`NavTalk/Hayashida/Akiyama. See Ex. A14.
`
`• The Locatio (in view of Gildea/Want/the Cyberguide) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in further view of the NavTalk/Hayashida. See Ex.
`A14.
`
`• The Locatio (in view of Gildea/Want/the Cyberguide) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in further view of Hayashida/Akiyama/the ’711
`Patent. See Ex. A14.
`
`• The Locatio (in view of Gildea/Want/the Cyberguide) in view of Norris/the
`Cyberguide/Maruyama/Knockeart in further view of the Norris/Maruyama/Ikeda.
`See Ex. A14.
`
`• The Locatio (in view of Gildea/Want/the Cyberguide) in view of Norris/the
`Cyberguide/Maruyama/K