`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`
`GOOGLE LLC
`Petitioner
`
`
`v.
`
`NavBlazer, LLC
`Patent Owner
`
`__________________
`
`Case No. IPR2021-00502
`U.S. Patent No. 9,075,136
`
`__________________
`
`
`
`PETITION FOR INTER PARTES REVIEW
`OF U. S. PATENT NO. 9,075,136
`
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`

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`TABLE OF CONTENTS
`
`C. 
`
`
`
`I. 
`II. 
`
`
`INTRODUCTION ............................................................................................. 1 
`SUMMARY OF THE ’136 PATENT ............................................................... 1 
`A.  Description of the ’136 Patent’s Alleged Invention ................................ 1 
`B. 
`The ’136 Patent’s Prosecution ................................................................. 3 
`C.  A Person Having Ordinary Skill in the Art ............................................. 4 
`III.  REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37 C.F.R.
`§ 42.104 ............................................................................................................. 4 
`A.  Grounds for Standing Under 37 C.F.R. § 42,104(a) ............................... 4 
`B.  Discretionary Considerations – 35 U.S.C. § 314(a) ................................ 4 
`Parallel Petition ............................................................................. 4 
`i. 
`Identification of challenge under 37 C.F.R. § 42,104(b) and relief
`requested .................................................................................................. 5 
`D. 
`Claim construction under 37 C.F.R. § 42.104(b)(3) ............................... 6 
`IV.  THE CHALLENGED CLAIMS ARE UNPATENTABLE .............................. 9 
`A. 
`Brief Overview of the Prior Art .............................................................. 9 
`Behr ............................................................................................... 9 
`i. 
`Schreder ...................................................................................... 11 
`ii. 
`iii.  Hanchett ...................................................................................... 13 
`B.  Ground 1: Behr in view of Schreder renders obvious claims 23,
`24, 35-44, and 51-54 .............................................................................. 15 
`C.  Ground 5 ................................................................................................ 51 
`CONCLUSION ................................................................................................ 54 
`V. 
`VI.  MANDATORY NOTICES PURSUANT TO 37 C.F.R. § 42.8(a)(1) ......... 55 
`A. 
`37 C.F.R. § 42.8(b)(1): Real Parties-In-Interest .................................... 55 
`B. 
`37 C.F.R. § 42.8(b)(2): Related Matters ............................................... 55 
`C. 
`37 C.F.R. § 42.8(b)(3), (4): Lead And Back-Up Counsel And
`Service Information ............................................................................... 56 
`
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`-i-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
`
`
`I.
`
`INTRODUCTION
`
`Petitioner Google LLC (“Petitioner”) requests Inter Partes Review (“IPR”) of
`
`claims 23, 24, 35-44, 48, 51-54 (the “Challenged Claims”) of U.S. Patent No. 9,075,136
`
`(“the ’136 Patent”).
`
`II.
`
`SUMMARY OF THE ’136 PATENT
`
`A. Description of the ’136 Patent’s Alleged Invention
`The ’136 Patent generally relates to providing information to a user in a vehicle,
`
`including route guidance and pertinent travel information such as current weather,
`
`maintenance services, and traffic. ’136 Patent (Ex. 1001), 1:14-20, 5:20-22, 16:15-18.
`
`As illustrated below in Fig. 2, the ’136 Patent describes an apparatus 10 that includes
`
`standard computing components (e.g., CPU 11, ROM 12, RAM 13, input device 16,
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`display device 17, heads-up display 18, output device 19, and database 60), means by
`
`which information can be communicated to and from the apparatus (e.g., receiver 15
`
`and transmitter 14), and a global positioning device 50:
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`-1-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`Id. at Fig. 2, 8:60-67 (describing apparatus 10). Users interact with apparatus 10 via
`
`user input device 16, which can include a keypad and a pointing device, such as a
`
`mouse, a roll ball, or a touch pad. Id. at 9:18-20. Alternatively, a microphone coupled
`
`with voice recognition software allows users to interact with apparatus 10 in a hands-
`
`free mode. Id. at 18:14-18. Information is output via a display device 17, a head up
`
`display device 18, or a speaker. Id. at 9:26-34, 18:14-28.
`
`Database 60 stores information about roadways, points of interest near roadways,
`
`and other location-based information. Id. at 9:66-10:11. When the operator selects a
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`destination, the system can assist in selecting the “most optimal or the least congested
`
`route to [the] destination.” Id. at 16:36-37. The vehicle computer 10 can also detect
`
`when the operator deviates from the planned route and will recompute a new route to
`
`the destination. Id. at 18:64-19:4. A second embodiment relies on a central processing
`
`computer 20 to compute travel routes. Id. at 19:13-18.
`
`The ’136 Patent generally relates to providing users with information pertinent
`
`to travel. For example, apparatus 10 communicates wirelessly with external “central
`
`processing computer(s) 20” using available wireless data communications
`
`infrastructure such as telephone communications systems, personal communication
`
`services (PCS) systems, and satellite communication systems. Id. at 7:36-58. With this
`
`wireless connectivity, apparatus 10 can obtain “information regarding traffic
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`conditions, weather conditions…, and any other useful information or news regarding
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`-2-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`the selected location which may be of interest to the vehicle operator or occupant.” Id.
`
`at 16:5-10. See also, Braasch Decl. (Ex. 1003), ¶¶ 24-31.
`
`B.
`The ’136 Patent’s Prosecution
`The Application that resulted in the ’136 Patent was filed on March 1, 1999 as
`
`U.S. App. No. 09/259,957, claiming priority to a provisional application No.
`
`60/076,800 filed on March 4, 1998. ’136 Patent (Ex. 1001). For purposes of this
`
`proceeding, Petitioner applies March 4, 1998 as the priority date for the Challenged
`
`Claims, but reserves its right to challenge priority in this or other proceedings.
`
`The ’136 Patent did not issue until July 7, 2015—sixteen years after the
`
`application was filed. Id. From 1999 through 2011, the Examiner issued eight prior
`
`art-based office actions, including one that was affirmed on appeal, and a first Notice
`
`of Allowance issued on February 10, 2011. Excerpts of the ’136 Patent File History
`
`(Ex. 1002), at 172-75, 256-61, 307-11, 344-49, 418-22, 490-93, 978-90, 1053-65, 1074-
`
`81. Following this first Notice of Allowance, a total of nine additional Notices of
`
`Allowance issued before the ’136 Patent ultimately issued on July 7, 2015. Id. at 1153-
`
`76, 1182-94, 1364-78, 1387-1403, 1413-29, 1562-78, 1638-54, 1754-70, 1821-35. The
`
`claims were never again subject to a prior art-based office action. Instead, the Examiner
`
`repeatedly accepted claim amendments and new claims, each time issuing a “statement
`
`of reasons for allowance” that simply recited the full text of the independent claims. Id.
`
`at 1153-76, 1182-94, 1364-78, 1387-1403, 1413-29, 1562-78, 1638-54, 1754-70, 1821-
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`-3-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`35. Nearly all the Challenged Claims resulted from this time period during which the
`
`claims were no longer being subject to the level of scrutiny applied in the early years of
`
`review.
`
`C. A Person Having Ordinary Skill in the Art
`A person having ordinary skill in the art (PHOSITA) at the time of the ’136
`
`Patent would have been a person having at least a Bachelor’s Degree in an Engineering
`
`discipline such as Electrical or Computer Engineering, or a Bachelor’s Degree in
`
`Computer Science or equivalent degree, and at least two years of relevant experience
`
`in the research, design, development and/or testing of navigation systems, embedded
`
`systems or the equivalent, with additional education substituting for experience and vice
`
`versa. Braasch Decl. (Ex. 1003), ¶¶ 35-36.
`
`III. REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37 C.F.R.
`§ 42.104
`
`A. Grounds for Standing Under 37 C.F.R. § 42,104(a)
`Petitioner certifies that the ’136 Patent is available for IPR and that the Petitioner
`
`is not barred or estopped from requesting IPR challenging the claims of the ’136 Patent
`
`on the grounds identified herein.
`
`B. Discretionary Considerations – 35 U.S.C. § 314(a)
`
`i.
`Parallel Petition
`Concurrently with this petition, Petitioner is filing a second IPR petition
`
`challenging claims 55, 56, 60-64, 66, 67, 69-71, 75-80, 82, 85-89, 91, and 93-98 of the
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`-4-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
`
`
`’136 Patent. See IPR2021-00503. The second IPR petition is being filed because the
`
`total number of challenged claims cannot reasonably be addressed within the required
`
`14000 word limit. The ’136 Patent includes 98 claims, 48 of which are being challenged
`
`by the combination of this petition and the second IPR petition. The claims addressed
`
`in the second IPR petition are directed to a different embodiment and are therefore
`
`challenged based on a different combination of prior art. Consequently, there is no
`
`overlap between either the challenged claims or the grounds for unpatentability
`
`addressed in this petition and in the second IPR petition. Petitioner therefore submits
`
`that institution of two parallel IPR petitions is reasonable under these circumstances.
`
`Further, Petitioner is unable to rank the two petitions in order of priority for
`
`consideration, as requested by the Trial Practice Guide, because the claims in each
`
`petition are of different scope, there is no overlap between the asserted grounds, and
`
`Petitioner has already reduced the number of challenged claims as much as possible by
`
`only challenging 48 of the 98 claims in the ’136 Patent.
`
`C.
`
`Identification of challenge under 37 C.F.R. § 42,104(b) and relief
`requested
`In view of the prior art and evidence presented, IPR of the Challenged Claims
`
`should be instituted and they should be found unpatentable and cancelled. 37 C.F.R. §
`
`42.104(b)(1-2).
`
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`-5-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`
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`Proposed Grounds of Unpatentability
`Ground 1: U.S. Patent No. 5,808,566 to Behr, et al. (“Behr”) in
`
`Exhibits
`
`view of U.S. Patent No. 5,504,482 to Schreder (“Schreder”)
`
`renders obvious claims 23, 24, 35-44, 48, and 51-54 under 35
`
`U.S.C. § 103
`
`Ground 51: Behr in view of Schreder and further in view of U.S.
`
`Patent No. 5,396,429 to Hanchett (“Hanchett”) renders obvious
`
`claims 23, 24, 35-44, 48, and 51-54 under 35 U.S.C. § 103
`
`Ex. 1004,
`Ex. 1005
`
`Ex. 1004,
`Ex. 1005,
`Ex. 1008
`
`
`
`
`
`Section IV identifies where each element of the Challenged Claims is found in
`
`the prior art. 37 C.F.R. § 42.104(b)(4). The exhibit numbers of the supporting evidence
`
`relied upon to support the challenges are provided above and the relevance of the
`
`evidence to the challenges raised are provided in Section IV. 37 C.F.R. § 42.104(b)(5).
`
`Ex. 1001–Ex. 1026 are also attached.
`
`D. Claim construction under 37 C.F.R. § 42.104(b)(3)
`In this proceeding, claims are interpreted under the same standard applied by
`
`Article III courts (i.e., the Phillips standard). See 37 C.F.R. § 42.100(b); see also 83
`
`
`
` 1
`
` Grounds 2-4 and 6-8 are included in the second IPR petition challenging the ’136
`Patent.
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`-6-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`Fed. Reg. 197 (Oct. 11, 2018); Phillips v. AWH Corp., 415 F.3d 1303, 1312 (Fed. Cir.
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`2005) (en banc). Under this standard, words in a claim are given their plain meaning,
`
`which is the meaning understood by a person of ordinary skill in the art in view of the
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`patent and file history. Phillips, 415 F.3d 1303, 1312-13.
`
`Petitioner understands that in related district court litigation, Patent Owner and
`
`certain Defendants (not party to this IPR petition) disagreed on the constructions of
`
`certain terms that are relevant to this Petition.2 In particular, the parties disclosed the
`
`following constructions:
`
`Term
`
`“information
`regarding the
`travel route”
`
`“maintenance
`information
`associated with
`
`Patent Owner’s
`Construction
`“Data associated with or
`representing a determined or
`identified path to a
`destination.”
`“Data associated with or
`representative of a work
`condition, a repair condition,
`
`Defendants’ Construction
`
`“information received from
`cameras or devices stationed
`at locations on the travel
`route”
`“information about
`maintenance services received
`from cameras or devices
`
`
`
` 2
`
` Samsung Electronics Co., Ltd. et al. and Samsung Electronics America, Inc. (No.
`6:20-cv-00089), LG Electronics Inc. and LG Electronics U.S.A., Inc. (No. 6:20-cv-
`00095), and Motorola Mobility LLC
`(No. 6:20-cv-00100)
`(collectively,
`“Defendants”) collectively proposed the constructions identified as “Defendants’
`Constructions” in their respective district court cases. The competing constructions
`for Defendants and Patent Owner are attached to this Petition at Exhibits 1011 and
`1012, respectively. The parties proposed additional constructions in the district court
`cases that are not discussed in this Petition, but Petitioner submits that these
`constructions do not affect the invalidity analysis.
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`-7-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`[the travel route /
`a second travel
`route]”
`
`
`
`or a maintenance condition
`on, of, associated with, or
`involving a travel route
`(defined herein) or a second
`travel route (defined herein).”
`
`stationed at locations on the
`travel route / a second travel
`route”
`
`Defendants’ constructions are derived from and supported by the intrinsic record.
`
`See, e.g., ’136 Patent (Ex. 1001) at 2:47-54 (“The apparatus further comprises a
`
`plurality of video cameras and location computers which are associated with each of
`
`the video cameras…. Video information, which is recorded by the respective video
`
`camera, is provided to the location computer which services the respective video
`
`camera.) (emphasis added); 3:44-53 (each device “is stationed” at appropriate locations
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`“on, near, or at a location for viewing roadways, at entrances and exits to roadways, on
`
`highways….”) (emphasis added); see also id. 3:60-4:5, 14:41-54.
`
`This claim construction dispute, however, does not alter resolution of this
`
`Petition because the Challenged Claims are unpatentable under each of Patent Owner’s
`
`and Defendants’ proffered constructions. Indeed, Petitioner addresses each of these
`
`constructions herein under Grounds for Unpatentability 1 (Patent Owner’s
`
`constructions) and 5 (Defendants’ constructions), respectively. As discussed below,
`
`each of the Challenged Claims are invalid if the PTAB adopts either of Patent Owner’s
`
`or Defendants’ proffered constructions.
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`-8-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`IV. THE CHALLENGED CLAIMS ARE UNPATENTABLE
`
`A. Brief Overview of the Prior Art
`
`i.
`Behr
`Behr was filed on June 23, 1995, issued on September 15, 1998, and is prior art
`
`to the ’136 Patent under at least 35 U.S.C. § 102(e) (pre-AIA). Behr was not cited or
`
`considered during the prosecution of the ’136 Patent.
`
`Behr describes an “electronic navigation system and method” for “providing
`
`route guidance and other information from a base unit to a remote unit in response to a
`
`request from the remote unit.” Behr (Ex. 1004) at Abstract. “Requested route guidance
`
`information is calculated at the base unit in response to the query, using a large up-to-
`
`date database located at the base unit… The response is then transmitted from the base
`
`unit to the remote unit for display.” Id. An example of the Behr navigation system is
`
`shown in Fig. 1, set forth below:
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`-9-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`Id. at Fig. 1.
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`The Behr navigation system provides centralized route calculation using a
`
`powerful computer, such as “IBM RS/6000 series”, as the base unit. Id. at 7:23-28.
`
`Mobile units are equipped with microprocessors, location indicators, and modems and
`
`antennas for communicating with the base unit. Id. at 8:27-55. A request for route
`
`guidance information is initiated at one of the mobile units, and transmitted to the
`
`centralized base unit over a communication network. Id. at 7:34-10:51 (describing a
`
`plurality of modes of operation of Behr system). Route calculation is then performed
`
`by a route calculator at the base unit, and route guidance information is transmitted back
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`to the mobile unit where the information is displayed to the user. Id. In addition, the
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`-10-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`Behr navigation system allows mobile units to access third-party “on-line yellow page
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`information or news, weather and/or traffic advisory information.” Id. at 6:57-60,
`
`11:18-21. See also, Braasch Decl. (Ex. 1003), ¶¶ 40-41.
`
`ii.
`Schreder
`Schreder issued on April 2, 1996 and is prior art to the ’136 Patent under at least
`
`35 U.S.C. § 102(b) (pre-AIA). Schreder was not cited or considered during the
`
`prosecution of the ’136 Patent.
`
`Schreder describes an automobile navigation system that includes GPS and a
`
`digitized street map system “for precise electronic positioning and route guidance,” and
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`which includes RF receivers for receiving “updated traffic condition information” used
`
`to provide “dynamic rerouting.” Schreder (Ex. 1005), Abstract. The system
`
`components are illustrated below:
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`-11-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`Id. at Fig. 1.
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`Schreder’s system calculates routes and provides turn-by-turn navigation
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`instructions. Id. at 7:33-36, 8:37-39 (providing an example of turn-by-turn navigation
`
`prompts such as “turn left in 300 feet”), 8:66-9:2 (describing various route calculation
`
`algorithms). Schreder also receives traffic flow information via digitally encoded
`
`messages that are received by radio data system 28. Id. at 10:35-39. The encoded
`
`messages are decoded by the “radio data system message decoder processor 76,” which
`
`processes the messages and sends the decoded information to the route planning
`
`processor 70, which incorporates the traffic flow data into its route calculation and
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`provides display or audible alerts to the driver. Id. at 13:14-36. Traffic flow data that
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`-12-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`may be processed and provided to the user as described, includes “road construction,
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`detours, congestion levels, traffic flow rates, hazardous material spills, parking
`
`capabilities, [and] weather conditions.” Id. at 6:48-53. See also, Braasch Decl. (Ex.
`
`1003), ¶¶ 42-43.
`
`iii.
`Hanchett
`Hanchett filed on June 30, 1992 and issued on March 7, 1995, is prior art to the
`
`’136 Patent under at least 35 U.S.C. §§ 102 (a), (b) and (e) (pre-AIA). Hanchett was
`
`not cited or considered during the prosecution of the ’136 Patent.
`
`Hanchett describes a “traffic condition information system” that includes “[a]
`
`series of image sensors” … “spaced along a roadway at particular intervals to provide
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`images of the traffic” to mobile user units in vehicles travelling the roadway. Hanchett
`
`(Ex. 1008), Abstract. The mobile user units “include a receiver which displays the
`
`images so that the user may preview the roadway ahead to make route choices.” Id.
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`The traffic condition information system is illustrated below:
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`-13-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`Id. at Fig. 1.
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`The mobile user unit of Hanchett’s system receives video/image traffic
`
`information about a route using a TV receiver. Id. at 8:54-9:4, Fig. 4 (schematically
`
`illustrating a user unit of Fig. 1 with a television receiver). Each Hanchett monitor
`
`station has a camera to obtain video images of traffic along the roadway. Id. at 4:54-
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`56, 5:37-68, Fig. 2. The video is transmitted to Hanchett mobile user units via a main
`
`station. Id. at 6:67-7:17, 7:18-8:53. Hanchett mobile units provide the user an
`
`“opportunity … to look ahead at the roadway to be traveled” and “view the display to
`
`see the images from the monitor station closest to the user and continue viewing to see
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`traffic conditions at monitor stations ahead on the roadway.” Id. at 10:64-11:5, Fig. 5
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`(reproduced below) (illustrating a video display format of Hanchett traffic information
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`signal).
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`Id. at Fig. 5. See also, Braasch Decl. (Ex. 1003), ¶¶ 47-48.
`
`
`
`B. Ground 1: Behr in view of Schreder renders obvious claims 23, 24,
`35-44, and 51-54
`Ground 1 addresses unpatentability of the Challenged Claims under the claim
`
`constructions proposed by Patent Owner in district court litigation, as detailed above in
`
`Section III.D. Unpatentability under the claim constructions proposed by Defendants
`
`in district court litigation is shown in Ground 5, set forth below in Section IV.C. As
`
`demonstrated,
`
`the Challenged Claims are unpatentable under either claim
`
`interpretation.
`
`(a) Claim 23
`23[P] An apparatus, comprising:
`
`To the extent that the preamble is limiting, Behr discloses “an apparatus.” For
`
`example, Behr discloses “an apparatus and method for providing to a mobile unit route
`
`guidance and tracking information and other information which has been calculated
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`-15-
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`and/or stored at a base unit in response to a query from the mobile unit.” Behr (Ex.
`
`1004), 1:23-26 (emphasis added). An example of Behr’s system is illustrated in Fig. 1,
`
`set forth below with annotations added.
`
`
`
`Id. at Fig. 1 (annotations added). As shown in Fig. 1, Behr’s system “includes a base
`
`unit 12 and a plurality 14 of remote units arranged to communicate with the base unit
`
`12.” Id. at 7:20-23. At least the “base unit 12” in Fig. 1 is “an apparatus.” See Braasch
`
`Decl. (Ex. 1003), ¶¶ 51-52.
`
`To the extent Patent Owner argues Behr’s system is not an “apparatus” because
`
`it comprises multiple components, such a narrow interpretation of “apparatus” is
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`inconsistent with the ’136 intrinsic record. Indeed, the ’136 Patent notes that “apparatus
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`100 includes a vehicle computer 10” and explains that vehicle computer 10 “should . .
`
`. have its display and user input device located on, in, or adjacent to, the vehicle
`
`dashboard or console.” ’136 Patent (Ex. 1001), 7:13-26. The ’136 Patent further notes
`
`that its disclosed “apparatus 100” not only includes the various computing components
`
`located within the vehicle, but also “may contain any number of central processing
`
`computer 20,” noting the “central processing computer(s) 20 and the vehicle computer
`
`10 can communicate with one another over a wireless communication network.” Id. at
`
`7:27-47. Based at least on these teachings, a PHOSITA would have understood that the
`
`claimed “apparatus” is not limited to a single, self-contained device, but must instead
`
`be interpreted broadly enough to capture systems comprising multiple different
`
`components. See Braasch Decl. (Ex. 1003), ¶ 53.
`
`[23(a)(i)] a receiver, wherein the receiver receives a request for information
`regarding a travel route to a destination to which the vehicle can travel on at least
`one of a road, a roadway, a highway, a parkway, and an expressway,
`Behr discloses this claim element. For example, the I/O interface 62, along with
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`one or more of the telephone interface 74, network interface 75, and RF interface 76,
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`shown in Fig. 1 of Behr provide a receiver that receives a request for information
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`regarding a travel route to a destination. Fig. 1 of Behr is set forth below with the
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`receiver outlined in red.
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`Behr (Ex. 1004), Fig. 1 (emphasis added). Behr discloses the “[t]he I/O interface 62,
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`including the telephone interface 74 and the RF interface 76, provide a means for
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`coupling the base unit 12 with communications media such as the commercial
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`telephone system and other wireline and wireless devices,” and that the “I/O interface
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`62 may further include a network interface 75 for coupling the base unit 12 to one or
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`more wireless or wireline communication networks such as CDPD (cellular digital
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`packet data).” Id. at 9:38-41, 57-61. “The I/O interface 62 therefore provides a
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`receiving means at the base unit for receiving the origin and destination.” Id. at 9:63-
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`67 (emphasis added).
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`The queries received by the I/O interface 62 (i.e., receiver) request route guidance
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`information for a travel route to a destination to which the vehicle can travel. See, e.g.,
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`id. at 8:39-40 (”[t]he request may be, for example, for the route between an origin and
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`a destination”). In response to a request for route guidance, the base unit communicates
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`a response that “may include, for example, textual navigational directions and/or
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`maneuver arms showing graphical representations of street intersections and the
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`calculated route through the intersection.” Id. at 5:30-35 (emphasis added). At least
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`because Behr discloses that the navigational directions provided in response to a request
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`for route guidance may include street intersections, a PHOSITA would have understood
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`that Behr’s route to the destination is along various types of roads. See Braasch Decl.
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`(Ex. 1003), ¶¶ 54-57.
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`[23(a)(ii)] wherein the request for information is transmitted to the receiver from a
`communication device located at the vehicle,
`Behr discloses this claim element. For example, Behr discloses that requests for
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`navigation information are transmitted from remote units 14 to the base unit 12 shown
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`in Fig. 1. See id. at 9:61-63 (“The I/O interface 62 thus receives queries from the
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`plurality 14 of remote units”). Fig. 1 is set forth below with the remote units 14 outlined
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`in red.
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`Id. at Fig. 1 (emphasis added). The remote units 14 shown in Fig. 1 may be mobile or
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`transportable, which Behr refers to as a “mobile unit.” See id. at 7:33-42. Behr further
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`discloses that a mobile unit (i.e., a communication device) may be located in a vehicle,
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`such as “an armored vehicle.” See id. at 9:51-52; see also id. at 1:19-30; 15:63. See
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`also, Braasch Decl. (Ex. 1003), ¶¶ 58-59.
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`[23(a)(iii)] wherein the request for information contains information regarding a
`location of the vehicle and the destination;
`Behr discloses this claim element. For example, Behr discloses that requests for
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`navigation information that are transmitted from the remote units 14 to the base unit 12
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`in Fig. 1 include both “an origin” and “a destination” for the requested navigation route.
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`See id. at 8:1-2 (“[t]he request may, for example, seek the route between an origin and
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`a destination”); see also, id. at 8:39-40. Behr further discloses that “[t]he origin may be
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`specified either by manipulating the keyboard 44 or by providing the latitude and
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`longitude information produced by the position locator 42.” Id. at 8:41-45. The
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`position locator 42 “may be responsive to GPS (Global Positioning System),” and “thus
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`provides a position determining means for determining the geographical position of the
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`mobile unit.” Id. at 8:28-36. Behr thus discloses that the “origin” information
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`transmitted from the remote units 14 includes a location (i.e., the geographical position)
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`of the vehicle and a destination. See Braasch Decl. (Ex. 1003), ¶ 60.
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`[23(b)] a processing device, wherein the processing device processes the request for
`information, wherein the processing device identifies a first travel route on which the
`vehicle can travel to the destination, and further wherein the processing device
`generates a first message containing information regarding the first travel route;
`and;
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`Behr discloses this claim element. For example, the route calculator 66 and I/O
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`interface 62 shown in Fig. 1 of Behr are part of a processing device that processes
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`requests for navigation information received from the remote units 14. Fig. 1 is set
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`forth below with the route calculator 66 and I/O interface 62 outlined in red.
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`Id. at Fig. 1 (emphasis added). With reference to Fig. 1, Behr explains that the “base
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`unit 12 includes a central processing unit (CPU) and a program memory which stores
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`programs for performing the functions described below.” Id. at 7:23-26. The identified
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`program functions performed by the base unit CPU (i.e., a processing device) include
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`the route calculator 66 and I/O interface 62 shown in Fig. 1. See, id. at 9:19-23. The
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`route calculator 66 processes navigation queries received from the remote units 14 to
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`“determine[] a route between a specified origin and destination using [a] map database
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`72.” Id. at 10:13-15. Behr therefore discloses that the base unit CPU (i.e., a processing
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`device) processes a request for information (i.e., navigation queries processed by the
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`route calculator 66) to identify a first travel route on which the vehicle can travel to the
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`destination (i.e., the route between a specified origin and destination).
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`Behr further discloses that “[a]fter a route has been calculated, the route is
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`conveyed from the route calculator 66 to the I/O interface 62,” which “formats a
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`response to the query.” Id. at 10:44-47. “The response includes the route guidance
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`information determined by the route calculator 66.” Id. at 10:47-49. “The I/O interface
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`62 then communicates the response from the base unit 62 to the mobile unit which
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`originally requested the information.” Id. at 10:49-51. Behr therefore discloses that the
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`base unit CPU (i.e., the processing device) generates a first message (i.e., the response
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`generated by the I/O interface 62) containing information regarding the first travel route
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`(i.e, the route guidance information determined by the route calculator 66). See Braasch
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`Decl. (Ex. 1003), ¶¶ 61-63.
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`[23(c)] a transmitter, wherein the transmitter transmits the first message to the
`communication device,
`Behr discloses this claim element. For example, the I/O interface 62, along with
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`one or more of the telephone interface 74, network interface 75, and RF interface 76,
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`shown in Fig. 1 of Behr provide a transmitter that transmits the first message to the
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`communication device (i.e, a mobile remote unit 14). Fig. 1 of Behr is set forth below
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`with the transmitter highlighted in red.
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`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 9,075,136
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`Id. at Fig. 1 (emphasis added). As detailed above, Behr discloses that after a response
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`with route guidance information is generated by the route calculator 66 and I/O interface
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`62, the I/O interface 62 “communicates the response from the base unit 62 to the mobile
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`unit which originally requested the information.” See supra at Claim 23(b); see also,
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`Behr (Ex. 1004) at 10:44-51.
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`Behr further discloses the “[t]he I/O interface 62, including the telephone
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`interface 74 and the RF interface 76, provide a means for coupling the base unit 12 with
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`communications media such as the commercial telephone system and other wireline
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`and wireless devices,” and that the “I/O interface 62 may further include a network
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`interface 75 for coupling the base unit 12 to one or more wireless or wireline
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`PETITION FOR INTER P