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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`
`Petitioner
`
`v.
`
`LBT IP I LLC,
`
`Patent Owner
`____________
`
`Case IPR2020-01192
`U.S. Patent No. 8,421,618
`____________
`
`
`
`PATENT OWNER’S MOTION TO AMEND
`
`
`
`
`
`
`

`

`Case IPR2020-01192
`U.S. Patent No. 8,421,618
`
`
`TABLE OF CONTENTS
`
`INTRODUCTION .......................................................................................... 1
`I.
`STATEMENT OF RELIEF REQUESTED ................................................. 2
`II.
`III. THE PROPOSED SUBSTITUTE CLAIMS MEET ALL THE
`REQUIREMENTS OF 37 C.F.R. § 42.121. ........................................................... 2
`IV. THE ORIGINAL NON-PROVISIONAL APPLICATION SUPPORTS
`EACH LIMITATION OF THE PROPOSED SUBSTITUTE CLAIMS. .......... 4
`V. LEVEL OF ORDINARY SKILL IN THE ART. ......................................18
`VI. CLAIM CONSTRUCTION .........................................................................19
`A. wherein the at least one portion of the transceiver circuitry and the
`location tracking circuitry is deactivated by placing the at least one portion
`of the transceiver circuitry and the location tracking circuitry in a low
`power mode in which the at least one portion of the transceiver circuitry
`and the location tracking circuitry consumes at least reduced power.
`(proposed substitute independent claims 25 and 39). ......................................19
`VII. THE PROPOSED SUBSTITUTE CLAIMS ARE PATENTABLE
`OVER THE PRIOR ART .....................................................................................20
`A. The Proposed Substitute Claims Are Patentable Over The Art At Issue
`In This Proceeding. .............................................................................................21
`B. The Proposed Substitute Claims Are Also Patentable Over The Alleged
`Material Prior Art At Issue During Prosecution. ............................................24
`VIII. CONCLUSION .............................................................................................25
`
`
`
`
`
`i
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`

`

`PATENT OWNER’S EXHIBIT LIST
`Exhibit Number Description
`2001
`Declaration of Brian S. Seal in support of Patent Owner’s
`Unopposed Motion For Pro Hac Vice Admission
`Revised Declaration of Brian S. Seal in support of Patent
`Owner’s Unopposed Motion For Pro Hac Vice Admission
`Transcript of deposition of Scott Andrews
`U.S. Pub. No. 2009/0174603 (Appl. No. 11/969,905)
`Sun, U.S. Patent Number 7,612,663
`Syrjarinne et al., U.S. Pub. No. 2005/0113124
`Suprun et al., U.S. Patent Number 7,292,223
`Croyle et al., U.S. Patent Number 5,862,511
`Lau et al., U.S. Patent Number 5,592,173
`Tsai, U.S. Pub. No. 2007/0057068
`Huang et al., U.S. Patent Number 7,826,968
`File history of U.S. Patent Number 8,421,619
`U.S. Pub. No. 2009/0189807 (Appl. No. 12/419,451)
`
`2002
`
`2003
`2004
`2005
`2006
`2007
`2008
`2009
`2010
`2011
`2012
`2013
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`Case IPR2020-01192
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`Case IPR2020-01192
`U.S. Patent No. 8,421,618
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`
`I.
`
`INTRODUCTION
`
`Patent Owner LBT IP I LLC (“Patent Owner”) respectfully moves under 35
`
`U.S.C. § 316(d) and 37 C.F.R. § 42.121 to amend U.S. Patent No. 8,421,618 (“the
`
`‘618 Patent”), contingent on the outcome of this trial. In the event the Board finds
`
`any of claims 1-24 unpatentable, Patent Owner respectfully requests that the Board
`
`grant this motion to amend and issue the corresponding proposed substitute claims
`
`presented herein.
`
`As this motion demonstrates, this motion and the proposed substitute claims
`
`meet all of the requirements of 37 C.F.R. § 42.121. Namely, each contingent
`
`amendment is responsive to a ground of unpatentability involved in this proceeding,
`
`none of the amendments seeks to enlarge the scope of the claims or introduce new
`
`subject matter, each amendment proposes only one proposed substitute claim for
`
`each conditionally canceled claim, and the motion clearly shows the changes sought
`
`and the support in the original disclosure of the patent for each claim that is added
`
`or amended.
`
`Moreover, although Patent Owner should not bear the burden of either
`
`persuasion or production regarding the patentability of the amended claims as a
`
`condition of allowance, and the Board may not sua sponte question the patentability
`
`of the proposed amended claims, see In re Aqua Products, Inc., 872 F.3d 1290, 1296
`
`(Fed. Cir. 2017), the instant motion demonstrates that the proposed amended claims
`
`
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`1
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`Case IPR2020-01192
`U.S. Patent No. 8,421,618
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`are patentable over the references at issue in this proceeding and the material prior
`
`art at issue during prosecution.
`
`
`
`II.
`
`STATEMENT OF RELIEF REQUESTED
`
`Patent Owner respectfully requests preliminary guidance from the Board
`
`regarding the proposed substitute claims.
`
`To the extent the Board finds any original claim unpatentable in this
`
`proceeding, Patent Owner respectfully requests that the Board grant this motion to
`
`amend with respect to each corresponding proposed substitute claim presented
`
`herein. The Board should not consider this motion for each original claim it finds
`
`patentable.
`
`III. THE PROPOSED SUBSTITUTE CLAIMS MEET ALL THE
`REQUIREMENTS OF 37 C.F.R. § 42.121.
`
`As shown in the attached claims appendix, proposed substitute independent
`
`
`
`claims 25 and 39 retain all features of the original claims and do not enlarge the
`
`scope of the claims in any way. Rather, the contingent amendments add only
`
`narrowing features. Specifically, the proposed substitute claims add the following
`
`limitation to the original claims: wherein the at least one portion of the transceiver
`
`circuitry and the location tracking circuitry is deactivated by placing the at least one
`
`portion of the transceiver circuitry and the location tracking circuitry in a low power
`
`mode in which the at least one portion of the transceiver circuitry and the location
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`tracking circuitry consumes at least reduced power in substitute independent claims
`
`25 and 39.
`
`For the same reasons, the proposed substitute dependent claims 26-38 and 40-
`
`48 likewise do not enlarge the scope of any original claim. See 37 C.F.R. §
`
`42.121(a)(2)(ii).
`
`The proposed substitute independent claims are responsive to one or more
`
`grounds of unpatentability at issue in this proceeding. See 37 C.F.R. §
`
`42.121(a)(2)(i). Specifically, Petitioner in this proceeding alleges that the alleged
`
`asserted prior art references disclose aspects of the original independent claims,
`
`which this motion conditionally seeks to amend. Compare Paper 1, at 12-13, 22-45,
`
`and 52 with Claims Appendix, infra.
`
`The proposed substitute dependent claims correspond to the original
`
`dependent claims and are amended only to reflect their new dependency from the
`
`proposed amended substitute independent claims and to be consistent with the
`
`proposed substitute independent claims.
`
`Because the dependent claims have not been substantively amended, the
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`proposed dependent claim amendments are also responsive to the § 103 grounds of
`
`unpatentability. See Western Digital Corp. v. SPEX Technologies Inc., IPR2018-
`
`00082, Paper 13 Decision at 8 (PTAB April 25, 2018).
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`For each original claim, Patent Owner proposes only one substitute claim.
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`The amended claims therefore fit the “presumption…that only one substitute claim
`
`would be needed to replace each challenged claim,” and thus presents a reasonable
`
`number of substitute claims. 37 C.F.R. § 42.121(a)(3).
`
`As demonstrated in the next section, the proposed substitute claims are
`
`supported by the original non-provisional application to which the ‘618 patent
`
`claims priority, so they do not introduce any new subject matter. See 37 C.F.R. §
`
`42.121(a)(2)(ii).
`
`IV. THE ORIGINAL NON-PROVISIONAL APPLICATION
`SUPPORTS EACH LIMITATION OF THE PROPOSED
`SUBSTITUTE CLAIMS.
`
`The ‘618 patent issued from Application Ser. No. 13/356,599, filed Jan. 23,
`
`
`
`2012, which is a divisional of the U.S. patent application entitled “Apparatus and
`
`Method For Determining Location And Tracking Coordinates Of A Tracking
`
`Device”, having Ser. No. 11/969,905, filed Jan. 6, 2008, now U.S. Pat. No.
`
`8,102,256.
`
`For purposes of this Motion to Amend, Patent Owner identifies the following
`
`portions of the non-provisional ‘905 application (Ex. 2004) that provide § 112
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`support for the proposed substitute claims. As demonstrated below, one of ordinary
`
`skill in the art would have understood based on the disclosures of the non-provisional
`
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`‘905 application (Ex. 2004) that the inventors possessed the proposed substitute
`
`claims’ systems and methods at the time of the application.
`
`Claim Limitation
`
`Support in U.S. Patent Appl. 11/969,905 (Exhibit
`2004), filed Jan. 6, 2008
`
`25. A portable
`electronic tracking
`device to monitor
`location coordinates of
`one or more individuals
`or objects, the device
`comprising:
`
`transceiver
`circuitry to receive at
`least one portion of a
`receive communication
`signal comprising
`location coordinates
`information;
`
`accelerometer
`circuitry to measure
`displacements of the
`portable electronic
`tracking device;
`
`“Referring now to FIGS. 1-2 exemplary embodiments
`of the electronic tracking device of the invention are
`described in detail. Please note that the following
`discussions of electronics and components for an
`electronic tracking device to monitor and locate
`individuals are non-limiting…
`Furthermore, it will be appreciated that while
`described primarily in the context of tracking
`individuals or objects, at least portions of the
`apparatus and methods described herein may be used
`in other applications…”. ¶¶ [0026]-[0027].
`“In one non-limiting example, antennas 122a, 122b
`electrically couple to transceiver 102. In one variant,
`transceiver 102 includes one integrated circuit or, in
`another embodiment, may be multiple individual
`circuits or integrated circuits. Transceiver 102
`communicates a signal including location data
`between tracking device 100 and the monitoring
`station 110…”. ¶ [0030].
`“In another embodiment, an accelerometer 130, for
`example, a dual-axis accelerometer 130, e.g.
`ADXL320 integrated circuit manufactured by Analog
`Devices having two substantially orthogonal beams,
`may be utilized.” ¶ [0031].
`“In particular, external forces on electronic tracking
`device 100 cause, for example, internal structural
`movements, e.g., deflection of dual-axis beams, of the
`accelerometer 130. The deflection of dual-axis beams
`generates differential voltage(s).
`Differential voltage(s) are proportional to acceleration
`measurements, e.g., discrete acceleration
`
`
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`
`a battery power
`monitor configured to
`selectively activate and
`deactivate at least one
`portion of the
`transceiver circuitry and
`location tracking
`circuitry to conserve
`battery power in
`response to a signal
`level of the at least one
`portion of the receive
`communication signal,
`
`measurements, of electronic tracking device 100, for
`instance in x, y, and z directions. Differential
`voltage(s), in one instance, are relative to, for instance,
`a last known GPS location coordinates of electronic
`tracking device 100.” ¶¶ [0033]-[0034].
`“Battery level detection circuitry (e.g., battery level
`monitor 116) detects a battery level of battery 118,
`which contains one or more individual units or
`grouped as a single unit.” ¶ [0029].
`“In one variant of this embodiment, electrical circuitry
`associated with GPS signal acquisition, e.g., all or a
`portion of amplifier block 120, may be, for instance,
`placed on standby or in a sleep mode.” ¶ [0031].
`“In another variant of this embodiment, circuitry, such
`as amplifier block 120 or location tracking circuitry
`114, may be placed in a sleep or standby mode to
`conserve a battery level of the battery 118. In one
`variant, the tracking device 100 periodically checks
`availability of GPS signal, e.g., performs a GPS signal
`acquisition to determine if a receive communication
`signal is above a first level.” ¶ [0032].
`“Furthermore, in one embodiment, the present
`invention conserves battery power by placing on
`standby, low power mode, or disabling entirely GPS
`signal, acquisition, circuitry and other associated
`devices, e.g., all or a portion of amplifier block 120
`including power amplifiers, LNAs, switches, and the
`like. Furthermore, during supplemental location
`coordinates tracking, e.g., electronic device proximity
`measurements, the transceiver circuitry (e.g.,
`transceiver 102, location tracking circuitry 114, and
`signal, processing circuitry 104) consumes reduced
`battery power for GPS circuitry while the electronic
`tracking device 100 communicates displacement
`vectors (e.g., differential location coordinates) to
`monitoring station 110 (e.g., a mobile phone, a
`personal digital assistant) through a wireless network
`140.” ¶ [0036].
`
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`
`wherein the at least one
`portion of the
`transceiver circuitry and
`the location tracking
`circuitry is deactivated
`by placing the at least
`one portion of the
`transceiver circuitry and
`the location tracking
`circuitry in a low power
`mode in which the at
`least one portion of the
`transceiver circuitry and
`the location tracking
`circuitry consumes at
`least reduced power;
`and
`
`processor
`circuitry configured to
`process the at least one
`portion of the receive
`communication signal.
`26. The device of claim
`25, wherein the at least
`one portion of the
`receive communication
`signal comprises a
`snapshot of the receive
`communication signal.
`27. The device of claim
`25, wherein the
`processor circuitry is
`further configured to
`compute the location
`coordinates of the
`portable electronic
`tracking device from the
`at least one portion of
`the receive
`
`“Furthermore, in one embodiment, the present
`invention conserves battery power by placing on
`standby, low power mode, or disabling entirely GPS
`signal, acquisition, circuitry and other associated
`devices, e.g., all or a portion of amplifier block 120
`including power amplifiers, LNAs, switches, and the
`like. Furthermore, during supplemental location
`coordinates tracking, e.g., electronic device proximity
`measurements, the transceiver circuitry (e.g.,
`transceiver 102, location tracking circuitry 114, and
`signal, processing circuitry 104) consumes reduced
`battery power for GPS circuitry while the electronic
`tracking device 100 communicates displacement
`vectors (e.g., differential location coordinates) to
`monitoring station 110 (e.g., a mobile phone, a
`personal digital assistant) through a wireless network
`140.” ¶ [0036].
`“In one embodiment, a signal detecting circuitry 115
`detects and measures signal power level. In another
`embodiment, the signal processing circuitry 104
`processes and measures signal power level.” ¶ [0029].
`
`“In step 302, antenna 122a associated with electronic
`tracking device 100 acquires a snapshot of receive
`communication signal including location coordinates
`data. In step 304, processing unit 104 processes the
`snapshot of receive communication signal including
`location coordinates data.” ¶ [0040].
`
`“In step 310, processing unit 104 computes current
`location coordinates using acceleration measurements.
`In step 312, all or a portion of amplifier block 120 and
`associated circuitry, e.g., location tracking circuitry,
`are activated at selected time intervals to determine if
`receive communication signal is of sufficient signal
`strength. In one variation of step 312, upon
`determining receive communication signal of
`sufficient signal strength, location tracking circuitry
`114 are activated, and processing unit 104 determines
`
`
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`
`communication signal
`and the displacements
`of the portable
`electronic tracking
`device in response to
`the signal level of the at
`least one portion of the
`receive communication
`signal.
`28. The device of claim
`25, wherein the
`accelerometer
`comprises a multi-beam
`structure having at least
`one beam of the multi-
`beam structure
`comprising a directional
`orientation substantially
`orthogonal to at least
`one other beam of the
`multi-beam structure.
`29. The device of claim
`28, wherein the
`directional orientation
`substantially orthogonal
`to at least one other
`beam of the multi-beam
`structure comprises a
`multi-directional
`orientation to measure
`differential
`displacement
`accelerations in x, y,
`and z orientation
`directions utilized to
`compute differential
`location coordinates
`information in response
`to the portable
`
`
`
`location coordinates from the receive communication
`signal. In another variation of step 312, upon
`determining receive communication signal of
`sufficient signal strength, accelerometer 130 is
`deactivated and location tracking circuitry 114 are
`activated, and processing unit 104 determines location
`coordinates from the receive communication signal.”
`¶ [0042].
`
`“In another embodiment, an accelerometer 130, for
`example, a dual-axis accelerometer 130, e.g.
`ADXL320 integrated circuit manufactured by Analog
`Devices having two substantially orthogonal beams,
`may be utilized.” ¶ [0031].
`
`“In particular, external forces on electronic tracking
`device 100 cause, for example, internal structural
`movements, e.g., deflection of dual-axis beams, of the
`accelerometer 130. The deflection of dual-axis beams
`generates differential voltage(s).
`Differential voltage(s) are proportional to acceleration
`measurements, e.g., discrete acceleration
`measurements, of electronic tracking device 100, for
`instance in x, y, and z directions. Differential
`voltage(s), in one instance, are relative to, for instance,
`a last known GPS location coordinates of electronic
`tracking device 100.” ¶¶ [0033]-[0034].
`
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`electronic tracking
`device detection of a
`signal level less than a
`first signal level.
`30. The device of claim
`28, wherein the
`directional orientation
`substantially orthogonal
`to at least one beam of
`the multi-beam
`structure comprises a
`multi-directional
`orientation to measure
`differential
`displacement
`accelerations in x, y,
`and z orientation
`directions to compute
`differential location
`coordinates information
`in response to the
`portable electronic
`tracking device
`detection of a signal
`level less than a first
`signal level.
`31. The device of claim
`25, wherein the
`displacements are
`transmitted to a
`monitoring station to
`determine current
`location coordinate
`information of the
`portable electronic
`tracking device based in
`part on the
`displacements and at
`least one of last known
`
`
`
`“In particular, external forces on electronic tracking
`device 100 cause, for example, internal structural
`movements, e.g., deflection of dual-axis beams, of the
`accelerometer 130. The deflection of dual-axis beams
`generates differential voltage(s).
`Differential voltage(s) are proportional to acceleration
`measurements, e.g., discrete acceleration
`measurements, of electronic tracking device 100, for
`instance in x, y, and z directions. Differential
`voltage(s), in one instance, are relative to, for instance,
`a last known GPS location coordinates of electronic
`tracking device 100.” ¶¶ [0033]-[0034].
`
`“In one embodiment, the monitoring station 110
`performs an integration of the acceleration
`measurements as a function of time to compute
`electronic tracking device velocity at time intervals,
`e.g., T1, T2, and T3 … TN. By referencing prior
`location coordinates, e.g., last known accurate location
`data of the electronic tracking device 100 or last
`known location data of nearby electronic tracking
`device (e.g., second tracking device 101 in proximity
`to electronic tracking device 100), monitoring station
`110 computes a current location of electronic tracking
`device 100 utilizing electronic tracking device velocity
`computations.” ¶ [0035].
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`location coordinates of
`the portable electronic
`tracking device, last
`known location
`coordinates of another
`electronic tracking
`device, and landmark
`location coordinates.
`32. The device of claim
`31, wherein the battery
`power monitor is
`configured to deactivate
`the location tracking
`circuitry while the
`displacements are
`transmitted to the
`monitoring station.
`
`33. The device of claim
`25, wherein the location
`tracking circuitry is
`configured to calculate
`location data based on
`the at least one portion
`of the receive
`communication signal.
`34. The device of claim
`33, wherein the battery
`power monitor is
`configured to deactivate
`the location tracking
`circuitry when a
`
`“…while the electronic tracking device 100
`communicates displacement vectors (e.g., differential
`location coordinates) to monitoring station110 (e.g., a
`mobile phone, a personal digital assistant) through a
`wireless network 140.” ¶ [0036].
`
`“Furthermore, in one embodiment, the present
`invention conserves battery power by placing on
`standby, low power mode, or disabling entirely GPS
`signal, acquisition, circuitry and other associated
`devices, e.g., all or a portion of amplifier block 120
`including power amplifiers, LNAs, switches, and the
`like. Furthermore, during supplemental location
`coordinates tracking, e.g., electronic device proximity
`measurements, the transceiver circuitry (e.g.,
`transceiver 102, location tracking circuitry 114, and
`signal, processing circuitry 104) consumes reduced
`battery power for GPS circuitry while the electronic
`tracking device 100 communicates displacement
`vectors (e.g., differential location coordinates) to
`monitoring station 110 (e.g., a mobile phone, a
`personal digital assistant) through a wireless network
`140.” ¶ [0036].
`“In one embodiment, location tracking circuitry 114,
`calculates location data received and sends the data to
`signal processing circuitry 104. Memory 112 stores
`operating software and data, for instance,
`communicated to and from signal processing circuit
`104 and or location tracking circuitry 114, e.g., GPS
`logic circuitry.” ¶ [0029].
`
`“In one variant of this embodiment, electrical circuitry
`associated with GPS signal acquisition, e.g., all or a
`portion of amplifier block 120, may be, for instance,
`placed on standby or in a sleep mode.” ¶ [0031].
`“In another variant of this embodiment, circuitry, such
`as amplifier block 120 or location tracking circuitry
`
`
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`
`communication signal is
`below a predefined
`level.
`
`35. The device of claim
`33, wherein the battery
`power monitor is
`configured to activate
`the location tracking
`circuitry when the at
`least one portion of the
`receive communication
`signal is above a
`predefined level.
`
`36. The device of claim
`33, wherein the battery
`power monitor is
`configured to deactivate
`
`114, may be placed in a sleep or standby mode to
`conserve a battery level of the battery 118. In one
`variant, the tracking device 100 periodically checks
`availability of GPS signal, e.g., performs a GPS signal
`acquisition to determine if a receive communication
`signal is above a first level.” ¶ [0032].
`“Furthermore, in one embodiment, the present
`invention conserves battery power by placing on
`standby, low power mode, or disabling entirely GPS
`signal, acquisition, circuitry and other associated
`devices, e.g., all or a portion of amplifier block 120
`including power amplifiers, LNAs, switches, and the
`like. Furthermore, during supplemental location
`coordinates tracking, e.g., electronic device proximity
`measurements, the transceiver circuitry (e.g.,
`transceiver 102, location tracking circuitry 114, and
`signal, processing circuitry 104) consumes reduced
`battery power for GPS circuitry while the electronic
`tracking device 100 communicates displacement
`vectors (e.g., differential location coordinates) to
`monitoring station 110 (e.g., a mobile phone, a
`personal digital assistant) through a wireless network
`140.” ¶ [0036].
`“In one variant, the tracking device 100 periodically
`checks availability of GPS signal, e.g., performs a
`GPS signal acquisition to determine if a receive
`communication signal is above a first, signal level.
`Referring to embodiment depicted in FIG. 2,
`electronic tracking device 100 exits an opening 150 in
`partially enclosed structure 210; thus, electronic
`tracking device 100 may resume GPS signal
`acquisition using GPS satellite 143 (e.g., in response
`to a periodic check by the tracking device 100 of a
`receive communication signal level above a first signal
`level).” ¶ [0032].
`“In another variation of step 312, upon determining
`receive communication signal of sufficient signal
`strength, accelerometer 130 is deactivated and location
`tracking circuitry 114 are activated.” ¶ [0042].
`
`
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`
`the accelerometer
`circuitry when the at
`least one portion of the
`receive communication
`signal is above the
`predefined level.
`37. The device of claim
`33, wherein the battery
`power monitor is
`configured to activate
`the accelerometer
`circuitry when the at
`least one portion of the
`receive communication
`signal is below the
`predefined level.
`38. The device of claim
`25, wherein the
`transceiver is
`configured to receive
`the at least one portion
`of the receive
`communication signal
`from a GPS satellite and
`from a wireless
`communication
`network.
`39. A method to
`monitor location
`coordinates of one or
`more individuals or
`objects, the method
`comprising:
`
`“In one embodiment, the accelerometer 130 activates
`upon one or more designated antenna(s), e.g., antennas
`122a, 122b, detecting a first signal level, e.g., a low
`signal level or threshold value.” ¶ [0031].
`
`“In one embodiment, location tracking circuitry 114,
`calculates location data received and sends the data to
`signal processing circuitry 104. Memory 112 stores
`operating software and data, for instance,
`communicated to and from signal processing circuit
`104 and or location tracking circuitry 114, e.g., GPS
`logic circuitry.” ¶ [0029].
`
`“Referring now to FIGS. 1-2 exemplary embodiments
`of the electronic tracking device of the invention are
`described in detail. Please note that the following
`discussions of electronics and components for an
`electronic tracking device to monitor and locate
`individuals are non-limiting…
`Furthermore, it will be appreciated that while
`described primarily in the context of tracking
`individuals or objects, at least portions of the
`apparatus and methods described herein may be used
`in other applications…”. ¶¶ [0026]-[0027].
`
`
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`Case IPR2020-01192
`U.S. Patent No. 8,421,618
`
`
`receiving at
`transceiver circuitry of a
`portable electronic
`tracking device at least
`one portion of a receive
`communication signal
`comprising location
`coordinates
`information;
`measuring
`displacements of the
`portable electronic
`tracking device;
`
`activating and
`deactivating at least one
`portion of the
`transceiver circuitry and
`location tracking
`circuitry to conserve
`battery power in
`response to a signal
`level of the at least one
`
`
`
`“Referring to FIG. 3, a flow chart 300 illustrates
`battery conservation for electronic tracking device 100
`as described in FIGS. 1, 2 in accordance with one
`embodiment of the present invention.” ¶ [0040].
`“In one non-limiting example, antennas 122a, 122b
`electrically couple to transceiver 102. In one variant,
`transceiver 102 includes one integrated circuit or, in
`another embodiment, may be multiple individual
`circuits or integrated circuits. Transceiver 102
`communicates a signal including location data
`between tracking device 100 and the monitoring
`station 110…”. ¶ [0030].
`
`“In another embodiment, an accelerometer 130, for
`example, a dual-axis accelerometer 130, e.g.
`ADXL320 integrated circuit manufactured by Analog
`Devices having two substantially orthogonal beams,
`may be utilized.” ¶ [0031].
`“In particular, external forces on electronic tracking
`device 100 cause, for example, internal structural
`movements, e.g., deflection of dual-axis beams, of the
`accelerometer 130. The deflection of dual-axis beams
`generates differential voltage(s).
`Differential voltage(s) are proportional to acceleration
`measurements, e.g., discrete acceleration
`measurements, of electronic tracking device 100, for
`instance in x, y, and z directions. Differential
`voltage(s), in one instance, are relative to, for instance,
`a last known GPS location coordinates of electronic
`tracking device 100.” ¶¶ [0033]-[0034].
`“Battery level detection circuitry (e.g., battery level
`monitor 116) detects a battery level of battery 118,
`which contains one or more individual units or
`grouped as a single unit.” ¶ [0029].
`“In one variant of this embodiment, electrical circuitry
`associated with GPS signal acquisition, e.g., all or a
`portion of amplifier block 120, may be, for instance,
`placed on standby or in a sleep mode.” ¶ [0031].
`
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`Case IPR2020-01192
`U.S. Patent No. 8,421,618
`
`
`portion of the receive
`communication signal,
`
`wherein the at least one
`portion of the
`transceiver circuitry and
`the location tracking
`circuitry is deactivated
`by placing the at least
`one portion of the
`transceiver circuitry and
`the location tracking
`circuitry in a low power
`mode in which the at
`least one portion of the
`transceiver circuitry and
`the location tracking
`
`“In another variant of this embodiment, circuitry, such
`as amplifier block 120 or location tracking circuitry
`114, may be placed in a sleep or standby mode to
`conserve a battery level of the battery 118. In one
`variant, the tracking device 100 periodically checks
`availability of GPS signal, e.g., performs a GPS signal
`acquisition to determine if a receive communication
`signal is above a first level.” ¶ [0032].
`“Furthermore, in one embodiment, the present
`invention conserves battery power by placing on
`standby, low power mode, or disabling entirely GPS
`signal, acquisition, circuitry and other associated
`devices, e.g., all or a portion of amplifier block 120
`including power amplifiers, LNAs, switches, and the
`like. Furthermore, during supplemental location
`coordinates tracking, e.g., electronic device proximity
`measurements, the transceiver circuitry (e.g.,
`transceiver 102, location tracking circuitry 114, and
`signal, processing circuitry 104) consumes reduced
`battery power for GPS circuitry while the electronic
`tracking device 100 communicates displacement
`vectors (e.g., differential location coordinates) to
`monitoring station 110 (e.g., a mobile phone, a
`personal digital assistant) through a wireless network
`140.” ¶ [0036].
`“Furthermore, in one embodiment, the present
`invention conserves battery power by placing on
`standby, low power mode, or disabling entirely GPS
`signal, acquisition, circuitry and other associated
`devices, e.g., all or a portion of amplifier block 120
`including power amplifiers, LNAs, switches, and the
`like. Furthermore, during supplemental location
`coordinates tracking, e.g., electronic device proximity
`measurements, the transceiver circuitry (e.g.,
`transceiver 102, location tracking circuitry 114, and
`signal, processing circuitry 104) consumes reduced
`battery power for GPS circuitry while the electronic
`tracking device 100 communicates displacement
`vectors (e.g., differential location coordinates) to
`
`
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`Case IPR2020-01192
`U.S. Patent No. 8,421,618
`
`
`circuitry consumes at
`least reduced power;
`and
`
`processing the at
`least one portion of the
`receive communication
`signal using processor
`circuitry.
`40. The method of
`claim 39, wherein the
`processing further
`comprises computing
`the location coordinates
`of the portable
`electronic tracking
`device from the at least
`one portion of the
`receive communication
`signal and the
`displacements of the
`portable electronic
`tracking device in
`response to the signal
`level of the at least one
`portion of the receive
`communication signal.
`41. The method of
`claim 39, further
`comprising transmitting
`the displacements to a
`monitoring station to
`determine cur