UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________
`
`APPLE, INC
`Petitioner,
`
`v.
`
`TRAXCELL TECHNOLOGIES, LLC
`
`Patent Owner
`
`_______________
`
`IPR2021-01552
`U.S. Patent No. 9,918,196
`
`_______________
`
`DECLARATION OF MICHAEL S. BRAASCH, PH.D.,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION
`FOR INTER PARTES REVIEW
`
`1
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`Apple Exhibit 1003
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`Table of Contents
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`I. Qualifications and Professional Experience ........................................................ 6
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`II. Relevant Legal Standards ................................................................................. 9
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`III. Level of Ordinary Skill in the Art .................................................................. 11
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`IV. Claim Construction ......................................................................................... 12
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`V. Background ..................................................................................................... 13
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`VI. Overview of the ’196 Patent ........................................................................... 15
`
`Ground I: Claims 1, 4-5, 7-8, and 10-11 are obvious over Bruce and
`VII.
`Hancock .................................................................................................................... 18
`
`A. Summary of Bruce .......................................................................................... 18
`B. Summary of Hancock ..................................................................................... 20
`C. Reasons to Combine Bruce and Hancock ...................................................... 22
`1. Access information over the Internet. ......................................................... 23
`2. Provide a flexible interface for entering information. ................................. 25
`3. Provide a configurable way to format a request for information. ............... 26
`D. Detailed Analysis of Claims ........................................................................... 28
`Claim 1 ............................................................................................................... 28
`Claim 4 ............................................................................................................... 43
`Claim 5 ............................................................................................................... 44
`Claim 7 ............................................................................................................... 45
`Claim 8 ............................................................................................................... 50
`Claim 10 ............................................................................................................. 52
`Claim 11 ............................................................................................................. 57
`VIII. Ground II: Claims 2, 3, 12, and 29 are obvious over Bruce, Hancock, and
`Meadows .................................................................................................................. 61
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`2
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`A. Summary of Meadows .................................................................................... 61
`B. Reasons to Combine Bruce/Hancock and Meadows ...................................... 63
`1. Efficiently determine and store location of the communication device. .... 63
`2. Determine location of the communication device when the communication
`device first registers with the network. .............................................................. 66
`3. Provide a variety of services for the communication device. ..................... 67
`4. Provide a configurable way to format a request for information ................ 69
`C. Detailed Invalidity Analysis ........................................................................... 71
`Claim 2 ............................................................................................................... 71
`Claim 3 ............................................................................................................... 74
`Claim 12 ............................................................................................................. 78
`Claim 29 ............................................................................................................. 82
`IX. Ground III: Claims 6, 9, and 13-14 are obvious over Bruce, Hancock, and
`Knockeart ................................................................................................................. 86
`
`A. Summary of Knockeart ................................................................................... 86
`B. Reasons to Combine Bruce/Hancock and Knockeart .................................... 87
`1. Provide a variety of available criteria for entering a destination. ............... 87
`2. Access information over the Internet using a variety of criteria ................. 88
`C. Detailed Invalidity Analysis ........................................................................... 89
`Claim 6 ............................................................................................................... 89
`Claim 9 ............................................................................................................... 94
`Claim 13 ............................................................................................................. 98
`Claim 14 ...........................................................................................................101
`X. Ground IV: Claims 15, 18-20, 22, 24, and 25 are obvious over Bruce, Moles,
`and Hancock ...........................................................................................................102
`
`A. Summary of Moles .......................................................................................102
`B. Reasons to Combine Bruce/Hancock and Moles .........................................103
`C. Detailed Invalidity Analysis .........................................................................105
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`3
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`Apple Exhibit 1003
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`Claim 15 ...........................................................................................................105
`Claim 18 ...........................................................................................................109
`Claim 19 ...........................................................................................................110
`Claim 20 ...........................................................................................................110
`Claim 22 ...........................................................................................................111
`Claim 24 ...........................................................................................................111
`Claim 25 ...........................................................................................................112
`XI. Ground V: Claims 16, 17, 26 and 30 are obvious over Bruce, Moles,
`Hancock and Meadows ..........................................................................................113
`
`A. Reasons to Combine Bruce, Moles, Hancock and Meadows .......................113
`Claim 16 ...........................................................................................................113
`Claim 17 ...........................................................................................................114
`Claim 26 ...........................................................................................................114
`Claim 30 ...........................................................................................................115
`XII. Ground VI: Claims 21, 23, and 27-28 are obvious over Bruce, Moles,
`Hancock, and Knockeart ........................................................................................118
`
`A. Reasons to Combine Bruce, Moles, Hancock, and Knockeart ....................118
`Claim 21 ...........................................................................................................118
`Claim 23 ...........................................................................................................118
`Claim 27 ...........................................................................................................119
`Claim 28 ...........................................................................................................121
`Conclusion .............................................................................................................122
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`4
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`Apple Exhibit 1003
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`I, Michael Braasch, do hereby declare:
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`1.
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`I am making this Declaration at the request of Apple, Inc., in the
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`matter of the Inter Partes Review (“IPR”) of U.S. Patent No. 9,918,196 (“the ’196
`
`patent”).
`
`2.
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`I am being compensated for my work in this matter at my standard
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`hourly rate. I am also being reimbursed for reasonable and customary expenses
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`associated with my work and testimony in this proceeding. My compensation is
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`not contingent on the outcome of this proceeding or the specifics of my testimony.
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`3.
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`I have been asked by Apple’s counsel to provide my opinions
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`regarding whether the subject matter of claims 1-30 (“the Challenged Claims”) of
`
`the ’196 patent would have been obvious to a person having ordinary skill in the
`
`art (“POSITA”) at the time of the alleged invention, in light of the prior art. It is
`
`my opinion that the Challenged Claims would have been obvious to a POSITA.
`
`4.
`
`In the preparation of this declaration, I have studied:
`
`a) the ’196 patent, Ex. 1001,
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`b) the prosecution history of the ’196 patent, Ex. 1002,
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`c) U.S. Patent No. 6,505,048 to Moles et al. (“Moles”), Ex. 1005;
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`d) U.S. Patent No. 6,539,080 to Bruce et al. (“Bruce”), Ex. 1006;
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`e) U.S. Patent No. 6,716,101 to Meadows et al. (“Meadows”), Ex. 1007;
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`5
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`f) U.S. Patent No. 6,680,694 to Knockeart et al. (“Knockeart”), Ex.
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`1008;
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`g) U.S. Patent No. 6,591,242 to Karp et al. (“Karp”), Ex. 1009;
`
`h) WO 01/28270 to Sakarya (“Sakarya”), Ex. 1010; and
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`i) U.S. Patent No. 6,202,023 to Hancock (“Hancock”), Ex. 1011;
`
`j) Federal Communications Commission Record, FCC 96-264 (“FCC
`
`96-264”), Ex. 1012.
`
`5.
`
`In forming the opinions expressed below, I have considered: the
`
`documents listed above; the relevant legal standards, including the standard for
`
`obviousness; and my own knowledge and experience based upon my work in the
`
`field relevant to the ’196 patent as described below.
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`6.
`
`Unless otherwise noted, all emphasis in any quoted material has been
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`added. Claim terms are italicized.
`
`I.
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`Qualifications and Professional Experience
`
`7. My complete qualifications and professional experience are described
`
`in my Curriculum Vitae, a copy of which can be found in Ex.1004. The following
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`is a brief summary of my relevant qualifications and professional experience.
`
`8.
`
`I am currently Thomas Professor of Engineering in the School of
`
`Electrical Engineering and Computer Science at Ohio University, Athens, Ohio.
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`6
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`9.
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`I received my Bachelor of Science and Master of Science degrees in
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`Electrical Engineering from the Ohio University in 1988 and 1989 respectively. In
`
`1992, I received a Ph.D. in Electrical Engineering also from Ohio University.
`
`During that time, my post-baccalaureate and doctoral work focused on aircraft
`
`navigation systems with an emphasis in GPS.
`
`10. From 1989 to 1993, I was a research engineer in the Avionics
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`Engineering Center at Ohio University. I became an adjunct assistant professor in
`
`the Department of Electrical and Computer Engineering at Ohio University in 1993
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`and have been on the faculty at Ohio University since that time. I have held the
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`title of Professor in the School of Electrical Engineering and Computer Science
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`since 2003 and was appointed as the Thomas Professor of Electrical Engineering in
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`2004. As a professor of Electrical Engineering, I have taught courses in navigation
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`and real-time positioning including courses specifically on the use of GPS.
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`11.
`
`I am a Licensed Professional Engineer (P.E.) in the State of Ohio. In
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`my professional career, I have specialized in the areas of electronic navigation
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`receiver design, electronic navigation system engineering, satellite-based
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`navigation systems, inertial navigation systems, and integrated navigation systems.
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`12. Since the early 1990s, I have been involved with research related to
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`navigation and transportation systems including navigation system computer
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`modeling and validation; characterization of GPS error sources and development
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`of mitigation strategies; design, development and testing of software-defined GPS
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`receiver architectures; design, development and flight testing of advanced cockpit
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`displays; and analysis of safety-certification issues in unmanned aerial vehicle
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`operations. I have been the recipient of over 65 research grants and contracts,
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`including awards from the U.S. Department of Transportation, Federal Aviation
`
`Administration, Air Force Office of Scientific Research and NASA. In 1992, I
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`received the RTCA (formerly known as the Radio Technical Commission for
`
`Aeronautics) William E. Jackson Award in recognition of an outstanding aviation
`
`electronics publication.
`
`13.
`
`I have published over 80 journal articles, book chapters, conference
`
`papers, and workshop papers, most of which were related to navigation systems. I
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`have authored or co-authored over 20 academic publications in the areas of
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`graphical display systems, electronic navigation system engineering, satellite-based
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`navigation systems with emphasis in GPS, and integrated navigation systems.
`
`These publications include book chapters in Global Positioning System: Theory
`
`and Applications, American Institute of Aeronautics and Astronautics,
`
`Washington, D.C. (1996). A complete list of my publications is included in my
`
`curriculum vitae, which is attached as Ex. 1004 to this declaration.
`
`14.
`
`I have given numerous presentations at various conferences and
`
`universities worldwide on these topics. In particular, I have been invited to speak
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`8
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`and publish in connection with conference proceedings on the navigation systems
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`at venues around the world. Additional contributions of mine to the field are set
`
`forth in my current curriculum vitae, which is included in Ex. 1004.
`
`15.
`
`In addition to gaining expertise via my academic training, professional
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`experiences, and research accomplishments described above, I have kept abreast of
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`the field of navigation systems by reading technical literature, attending and
`
`presenting at conferences, and attending and presenting at symposia. I have been
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`invited to participate in the peer review process for various technical journals and
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`conferences and have reviewed manuscripts submitted by other engineers relating
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`to navigation system technology. Furthermore, I have collaborated with or have
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`communicated with many of the engineers in the field of navigation systems.
`
`II. Relevant Legal Standards
`
`16.
`
`I am not an attorney. In preparing and expressing my opinions and
`
`considering the subject matter of the ’196 patent, I am relying on certain legal
`
`principles that Apple’s counsel has explained to me.
`
`17.
`
`I have been informed by Apple’s counsel that prior art to the ’196
`
`patent includes patents and printed publications in the relevant art that predate the
`
`priority date of the ’196 patent. For purposes of this Declaration, I am applying
`
`October 4, 2001, as the priority date of the ’196 patent. I have not evaluated
`
`whether all claims have priority to this date.
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`18.
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`I have been informed by Apple’s counsel that a claimed invention is
`
`unpatentable as obvious if the differences between the claimed invention and the
`
`prior art are such that the subject matter as a whole would have been obvious at the
`
`time the invention was made to a POSITA. I have also been informed by Apple’s
`
`counsel that the obviousness analysis considers factual inquiries, including the
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`level of ordinary skill in the art, the scope and content of the prior art, and the
`
`differences between the prior art and the claimed subject matter.
`
`19.
`
`I have been further informed by Apple’s counsel that there are several
`
`recognized rationales for combining references or modifying a reference to show
`
`obviousness. These rationales include: (a) combining prior art elements according
`
`to known methods to yield predictable results; (b) simple substitution of one
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`known element for another to obtain predictable results; (c) use of a known
`
`technique to improve a similar device (method, or product) in the same way; (d)
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`applying a known technique to a known device (method or product) ready for
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`improvement to yield predictable results; (e) choosing from a finite number of
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`identified, predictable solutions, with a reasonable expectation of success; and (f)
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`some teaching, suggestion, or motivation in the prior art that would have led a
`
`POSITA to modify the prior art or to combine multiple prior art teachings to arrive
`
`at the claimed invention.
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`20. Also, I have been informed by Apple’s counsel that obviousness does
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`not require physical combination/bodily incorporation, but rather consideration of
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`what the combined teachings would have suggested to a POSITA at the time of the
`
`alleged invention.
`
`III. Level of Ordinary Skill in the Art
`
`21.
`
`I understand from Apple’s counsel that there are multiple factors
`
`relevant to determining the level of ordinary skill in the pertinent art, including (1)
`
`the levels of education and experience of persons working in the field at the time of
`
`the invention; (2) the sophistication of the technology; (3) the types of problems
`
`encountered in the field; and (4) the prior art solutions to those problems.
`
`22.
`
`I am familiar with location technologies, navigations systems in wired
`
`and wireless communication devices, wireless networks and the Internet that are
`
`pertinent to the ’196 patent. I am also aware of the state of the art at the time the
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`application resulting in the ’196 patent was filed. I have been informed by Apple’s
`
`counsel that the earliest claimed priority date for the ’196 patent is October 4,
`
`2001. Based on the technologies disclosed in the ’196 patent, it is my opinion that
`
`a POSITA would include someone who had a bachelor’s degree in Electrical or
`
`Computer engineering, or equivalent training in locating technologies, navigation
`
`systems, and wired and wireless communication devices, and approximately two
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`years of experience working with same. Additional work experience can substitute
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`for specific educational background, and vice versa.
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`23. For purposes of this Declaration, in general, and unless otherwise
`
`noted, my statements and opinions, such as those regarding my experience and
`
`what a POSITA would have understood or known generally (and specifically
`
`related to the references I consulted herein), reflect the knowledge that existed in
`
`the relevant field as of the priority date of the ’196 patent.
`
`IV. Claim Construction
`
`24.
`
`It is my understanding that in order to properly evaluate the ’196
`
`patent, the terms of the claims must first be interpreted. It is my understanding that
`
`for the purposes of this IPR, the claims are to be construed under the so-called
`
`Phillips standard, under which claim terms are given their ordinary and customary
`
`meaning as would have been understood by a POSITA in light of the specification
`
`and prosecution history, unless the inventor has set forth a special meaning for a
`
`term. I have also been informed by Apple’s counsel that claim terms only need to
`
`be construed to the extent necessary to resolve the obviousness inquiry.
`
`25.
`
`I have reviewed the entirety of the ’196 patent, as well as its
`
`prosecution history. It is my opinion that for purposes of applying the prior art
`
`presented herein to evaluate the patentability of the Challenged Claims that all
`
`terms recited in the Challenged Claims do not require express construction and I
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`have analyzed them consistent with their ordinary and customary meaning as
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`would have been understood by a POSITA.
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`V. Background
`
`26.
`
`In 1996, the Federal Communication Commission issued an order,
`
`FCC 96-264, requiring wireless carriers to determine locations of wireless devices
`
`operating in their networks and relay the locations to 911 operators for safety
`
`reasons. FCC 96-264, 11-12. Unlike the switched networks (e.g., PSTN) that
`
`determined the phone callers’ locations using a reverse lookup of the callers’
`
`telephone numbers into a Name, Address and Telephone number Database
`
`(‘NATD’) or a similar database, FCC determined that wireless networks lacked the
`
`locating technology. FCC 96-264, 3-4, Bruce, 6:8-19. This posed a safety hazard
`
`because more and more users were using mobile phones and needed access to
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`emergency services. FCC 96-264, 3-4. For example, in 1996, there were over 33
`
`million wireless users and in 1994, almost 18 million wireless calls were made to
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`911 or other public services. FCC 96-264, 5.
`
`27. The FCC ruling was an impetus for wireless carriers to provide
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`locating technology in the wireless networks. FCC required wireless carriers to
`
`design their systems such that 1) within one year of the order, the location of the
`
`base station or cell site receiving the wireless call was made available to the 911
`
`operator, 2) within three years of the order, the wireless provider would include an
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`13
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`approximate location and distance of the mobile device from the base station or
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`cell site, and 3) within five years of the order, the location of the mobile device
`
`was identified within a radius of no more than 125 meters. FCC 96-264, 11-12.
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`28. Navigation systems that determined directions to a destination and
`
`provided interfaces for entering various criteria for selecting a destination were
`
`also well-known. Example criteria could be a category, such as a restaurant, hotel,
`
`or another business, the name of a business, or even another mobile device. See
`
`Bruce, Hancock, and Knockeart. In the late 1990s, navigation systems were
`
`primarily installed in vehicles or on a devices carried by a user. This was because
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`data bandwidths offered by the wireless carriers were insufficient for accessing the
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`navigation information in real time. The navigation systems of the 1990s had
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`several drawbacks: the maps would eventually become obsolete, navigation
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`directions based on real-time traffic updates were unavailable, and the size of the
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`navigation systems was constrained by the memory available on the
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`communication devices. See WO 01/28270. Advances in the 3G wireless
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`technology, however, increased available bandwidths to 125kpbs or greater. Moles,
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`1:38-46. The higher bandwidth made navigation systems and navigation
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`information accessible over the Internet and the wireless networks, while solving
`
`problems inherent to the navigation systems of 1990s. Moles, 1:37-45. To make
`
`navigation systems user-friendly, the navigation systems also took advantage of the
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`locating technology that was available in the switched and wireless networks.
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`Bruce, 5:53-7:41, The locating technology would automatically determine the
`
`user’s location as mandated by the FCC and would also save the user from entering
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`additional input, the user’s own location, into the navigation system.
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`29. The ’196 patent claims these concepts, which were well-known in the
`
`art before the ’196 patent was filed.
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`VI. Overview of the ’196 Patent
`
`30. The ’196 patent relates generally to navigation. ’196 patent, Abstract.
`
`The user begins the Directional Assistance Network (DAN) query process by
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`“dialing a specified phone number.” ’196 patent, 100:16-27. The user may use
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`either a landline or wireless device. Id. When “the DAN 8100 receives the user’s
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`call”, the DAN queries “a user location database (ULD) to determine the user’s
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`location and logs to user’s location within the DAN.” ’196 patent, 100:16-31.
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`31. The user’s location can be determined when the user is calling from a
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`wireless or landline communication device. ’196 patent, 101:20-24. The DAN can
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`query “a wireless network’s ULD 900 in order to determine the user’s location
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`with the wireless network.” ’196 patent, 100:36-38. Alternatively, the ULD can
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`include location information “obtained from the wireless network through querying
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`the wireless network’s e-mobility services, switch, and/or base station controller.”
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`’196 patent, 100:38-43. Alternatively, the DAN may also determine the wireless
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`device’s location by using “latitude/longitude coordinates obtained by GPS
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`systems on the wireless device.” ’196 patent, 115:3-7. To locate a user’s landline
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`device, the DAN queries “the PSTN [(public-switched telephone network)] phone
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`location database.” ’196 patent, 110:36-38.
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`32. Once the user’s location is determined, the DAN offers the user a
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`“menu of services”, allowing the user to get directions to a destination based on
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`options including the destination telephone number, the name/category of the
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`business, or the destination address, amongst other inputs. ’196 patent, 101:25-60,
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`Figures 71-74. The DAN also allows the user to track and navigate to another
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`wireless device. ’196 patent, 101:62-66.
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`33. The process for the user accessing the DAN and its services is also
`
`depicted in Figure 70, replicated below:
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`’196 patent, Figure 70.
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`34. Notably, as I demonstrate in this Declaration, there is nothing novel
`
`about the Challenged Claims as all of the elements were taught in the prior art and
`
`it would have been obvious to combine the relevant teachings of the asserted prior
`
`art references as claimed.
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`VII. Ground I: Claims 1, 4-5, 7-8, and 10-11 are obvious over Bruce and
`Hancock
`A. Summary of Bruce
`
`35. U.S. Patent 6,539,080 to Bruce et al., (“Bruce”) was filed on July 14,
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`1998, and issued on March 25, 2003.
`
`36. Bruce relates to a system for “providing a telephone caller information
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`assistance such as driving directions from a starting location to a destination
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`location.” Bruce, Abstract. The system is depicted in Figure 1, replicated below:
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`
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`Bruce, Figure 1.
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`37. A “telephone caller or user 12 desiring assistance with a variety of
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`services such as travel directions, maps, weather, traffic travel times, directory
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`assistance white page listings, and road conditions originates a telephone call to a
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`dial-in telephone access number to access the system 13.” Bruce, 3:43-48.
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`Alternatively, a user using a portable-computing device can access system 13
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`through a computer interface connected to a dial-up telephone line. Bruce, 8:56-60.
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`After the telephone call is answered “the geographical location of the telephone
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`caller is determined using an appropriate caller location system 17 capable of
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`identifying the geographical location of the caller.” Bruce, 5:62-65. Different
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`techniques for identifying the location can be used “depending on the particular
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`telephone (i.e., landline or mobile telephone) originating the call.” Bruce, 5:65-6:3.
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`38. An “automatic location identification (“ALI”) technology is
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`preferably used to determine the location of wireless telephone callers.” Bruce,
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`6:61-66. The “most common type of ALI technology 17 for mobile wireless
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`telephones utilizes a network-based approach that applies mathematical algorithms
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`to the attributes of the wireless telephone radio frequency (“RF”) signals received
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`at a base station of the wireless network.” Bruce, 6:61-7:4.
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`39. The location of landline telephone callers is identified “using the
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`automatic number identification (“ANI”) of the originating calling telephone
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`number to index into a directory listing database or Name, Address and Telephone
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`number database (“NATD”),” to obtain the address associated with the telephone
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`number. Bruce, 6:8-19.
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`B. Summary of Hancock
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`40. U.S. Patent No. 6,202,023 to Hancock et al., (“Hancock”) was filed in
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`February 25, 1999 and issued on March 13, 2001.
`
`41. Hancock relates to “automatically providing services over a computer
`
`network, such as the Internet, for users in a mobile environment based on their
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`geographic location.” Hancock, Abstract. Similar to Bruce, Hancock describes
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`locating both “portable-computing devices” and “land-line telephone devices.”
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`Hancock, 23:43-46, 24:1-4. To determine location of the portable-computing
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`device, the automatic location identification (“ALI”) uses “triangulation techniques
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`in conjunction with at least two cellular base stations, or distance measuring
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`techniques from three cellular base stations.” Hancock, 23:50-65. To determine
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`location of the land-line devices, a “telephone number identification system (ANI)
`
`can be used in conjunction with a database lookup table to determine predefined
`
`fixed positions of users based on an assigned telephone number.” 26:19-22.
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`Hancock, Figure 13.
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`42. After the location of the portable or non-portable device is
`
`determined, the users in Hancock, like the users in Bruce, can obtain access to
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`services. Hancock 27:27-49. Hancock’s user interface (U/I) module “present[s] the
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`user with one or more selectable menu choices, such as “restaurants; banks; ATM
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`machines; hotels; copy centers; libraries; museums; gas stations; weather reports;
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`car dealers; auto repair shops; maps; directory assistance; police stations; hospitals
`
`and the like.” Hancock, 27:27-30, 28:58-65. The user “may wish to formulate a
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`database query for finding all fast-food restaurants within a five-mile radius” of the
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`current location, as well as obtain driving directions to the restaurants.” Hancock,
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`21
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`Apple Exhibit 1003
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`

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`27:38-40, 32:35-41. The database query is stored in a “data packet” which is
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`transmitted from the device to the primary server 1314 connected to the Internet.
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`Hancock, 27:63-28:8; 24:39. The “results from the database query” are sent back
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`to the device. Hancock, 28:4-7.
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`C. Reasons to Combine Bruce and Hancock
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`43. A POSITA would have been motivated to combine Bruce and
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`Hancock to provide a communication device with access to information over the
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`Internet as taught in Hancock. Also, a POSITA would have also been motivated to
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`combine Bruce and Hancock to provide a flexible user interface for requesting the
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`information. Finally, a POSITA would have also been motivated to combine Bruce
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`and Hancock to provide a configurable way to format a request for information.
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`Doing so would have been within the POSITA’s skillset and would produce
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`beneficial, predictable results.
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`44. When considering the teachings of Bruce, a POSITA would have
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`considered the teachings of Hancock since they are analogous prior art in the same
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`field of endeavor as the ’196 patent – wireless communication systems and devices
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`receiving location-based services. ’196 patent, Abstract, 100:16-31, 101:24-25;
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`Bruce, Abstract, 2:23-34; Hancock, Abstract, 23:41-24:61.
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`22
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`Apple Exhibit 1003
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`

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`1.
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`Access information over the Internet.
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`45. Bruce discloses a landline or a mobile cellular telephone user
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`“desiring assistance with a variety of services such as travel directions, maps,
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`weather, traffic travel times, directory assistance white page listings, and road
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`conditions originates a telephone call to a dial-in telephone access number to
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`access the system 13.” Bruce, 3:42-51. Bruce also discloses a user accessing
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`system 13 via a user interface of a portable or handheld computer equipped with a
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`TCP/IP compatible modem. Bruce, 8:42-60, Figure 1.
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`46. A POSITA considering Bruce would have understood that a TCP/IP
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`compatible modem establishes access to the Internet and would have found it
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`obvious to consider other references that describe in detail how the information in
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`system 13 can be accessed over the Internet. Hancock provides these further details
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`and would have been an obvious source of information to a POSITA. Hancock
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`describes “one use of the wireless c