UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________
`
`APPLE INC.
`Petitioner,
`
`v.
`
`TRAXCELL TECHNOLOGIES, LLC
`
`Patent Owner
`
`_______________
`
`IPR2022-00073
`U.S. Patent No. 10,820,147
`
`_______________
`
`DECLARATION OF MICHAEL BRAASCH, PH.D.,
`UNDER 37 C.F.R. § 1.68 IN SUPPORT OF PETITION
`FOR INTER PARTES REVIEW
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`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 ..................................................................................................... 14
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`VI. Overview of the ’147 Patent ........................................................................... 15
`
`Ground I: Claims 1-3, 5-7, 11-14, and 16-17 are obvious over Moles,
`VII.
`Sakarya, and Khavakh.............................................................................................. 17
`
`A. Summary of Moles ......................................................................................... 17
`B. Summary of Sakarya ...................................................................................... 20
`C. Summary of Khavakh ..................................................................................... 23
`D. Reasons to Combine Moles and Sakarya ....................................................... 24
`1. Generate and display a location of a mobile device on a map. ................... 24
`2. Provide directions to a destination. ............................................................. 26
`E. Reasons to Combine Moles, Sakarya, and Khavakh ...................................... 27
`1. Efficiently determine direction information ................................................ 28
`2. Access resources available in a network external to the wireless network. 29
`F. Detailed Analysis of Claims ........................................................................... 32
`Claim 1 ............................................................................................................... 32
`Claim 2 ............................................................................................................... 56
`Claim 3 ............................................................................................................... 63
`Claim 5 ............................................................................................................... 65
`Claim 6 ............................................................................................................... 67
`Claim 7 ............................................................................................................... 70
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`2
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`Claim 11 ............................................................................................................. 74
`Claim 12 ............................................................................................................. 76
`Claim 13 ............................................................................................................. 76
`Claim 14 ............................................................................................................. 77
`Claim 16 ............................................................................................................. 78
`Claim 17 ............................................................................................................. 78
`Claim 18 ............................................................................................................. 79
`VIII. Ground II: Claims 8-9, 19-20, 22-24 are obvious over Moles, Sakarya,
`Khavakh, and Zellner. .............................................................................................. 80
`
`A. Summary of Zellner ........................................................................................ 80
`B. Reasons to Combine Moles, Sakarya, Khavakh, and Zellner ........................ 81
`1. Controlling distribution of user and device information in a wireless
`network. ............................................................................................................. 81
`2. Provide a flexible approach to distributing location and user information
`available on the mobile device. ......................................................................... 83
`3. Distribute information to third parties. ........................................................ 85
`C. Detailed Invalidity Analysis ........................................................................... 86
`Claim 8 ............................................................................................................... 86
`Claim 9 ............................................................................................................... 88
`Claim 19 ............................................................................................................. 95
`Claim 20 ............................................................................................................. 96
`Claim 22 ............................................................................................................. 97
`Claim 23 ...........................................................................................................100
`Claim 24 ...........................................................................................................101
`IX. Ground III: Claims 5 and 15 are obvious over Moles, Sakarya, Khavakh and
`Tanibayashi ............................................................................................................102
`
`A. Summary of Tanibayashi ..............................................................................102
`B. Reasons to Combine Moles, Sakarya, Khavakh, and Tanibayashi ..............102
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`3
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`C. Detailed Invalidity Analysis .........................................................................104
`Claim 4 .............................................................................................................104
`Claim 15 ...........................................................................................................105
`Conclusion .............................................................................................................106
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`4
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`Apple Exhibit 1003
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`I, Michael Braasch, do hereby declare:
`
`1.
`
`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. 10,820,147 (“the
`
`’147 patent”).
`
`2.
`
`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.
`
`I have been asked by Apple’s counsel to provide my opinions
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`regarding whether the subject matter of claims 1-9, 11-20, and 22-24 (“the
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`Challenged Claims”) of the ’147 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 ’147 patent, Ex. 1001,
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`b) the prosecution history of the ’147 patent, Ex. 1002,
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`c) U.S. Patent 6,505,048 to Moles et al. (“Moles”), Ex. 1005;
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`d) WO2001/28270 to Sakarya (“Sakarya”), Ex. 1006;
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`e) U.S. Patent 6,716,101 to Meadows et al. (“Meadows”), Ex. 1007;
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`5
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`f) U.S. Patent 6,738,808 to Zellner et al. (“Zellner”), Ex. 1008;
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`g) U.S. Patent 7,010,306 to Tanibayashi et al. (“Tanibayashi”), Ex. 1009;
`
`h) U.S. Patent 6,192,314 to Khavakh et al. (“Khavakh”), Ex. 1010; and
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`i) U.S. Patent 6,202,023 to Hancock et al. (“Hancock”), Ex. 1011.
`
`5.
`
`In forming the opinions expressed below, I have considered: the
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`documents listed above; the relevant legal standards, including the standard for
`
`obviousness; and my own knowledge and experience based upon my work in the
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`field relevant to the ’147 patent as described below.
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`6.
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`Unless otherwise noted, all emphasis in any quoted material has been
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`added. Claim terms are italicized.
`
`I.
`
`Qualifications and Professional Experience
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`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.
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`I am currently the Thomas Professor of Engineering in the School of
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`Electrical Engineering and Computer Science at Ohio University, Athens, Ohio.
`
`9.
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`I received my Bachelor of Science and Master of Science degrees in
`
`Electrical Engineering from the Ohio University in 1988 and 1989 respectively. In
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`1992, I received a Ph.D. in Electrical Engineering also from Ohio University.
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`6
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`During that time, my post-baccalaureate and doctoral work focused on aircraft
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`navigation systems with an emphasis in GPS.
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`10. From 1989 to 1993, I was a research engineer in the Avionics
`
`Engineering Center at Ohio University. I became an adjunct assistant professor in
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`the Department of Electrical and Computer Engineering at Ohio University in 1993
`
`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
`
`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
`
`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
`
`displays; and analysis of safety-certification issues in unmanned aerial vehicle
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`7
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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
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`electronics publication.
`
`13.
`
`I have published over 80 journal articles, book chapters, conference
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`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 Exhibit 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
`
`and publish in connection with conference proceedings on the navigation systems
`
`at venues around the world. Additional contributions of mine to the field are set
`
`8
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`forth in my current curriculum vitae, which is attached as Exhibit 1004 to this
`
`declaration.
`
`15.
`
`In addition to gaining expertise via my academic training, professional
`
`experiences, and research accomplishments described above, I have kept abreast of
`
`the field of navigation systems by reading technical literature, attending and
`
`presenting at conferences, and attending and presenting at symposia. I have been
`
`invited to participate in the peer review process for various technical journals and
`
`conferences and have reviewed manuscripts submitted by other engineers relating
`
`to the navigation system technology. Furthermore, I have collaborated with or have
`
`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 ’147 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 ’147
`
`patent includes patents and printed publications in the relevant art that predate the
`
`priority date of the ’147 patent. For purposes of this Declaration, I am applying
`
`October 4, 2001, as the priority date of the ’147 patent.
`
`18.
`
`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
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`9
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`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
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`counsel that the obviousness analysis considers factual inquiries, including the
`
`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
`
`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)
`
`applying a known technique to a known device (method, or product) ready for
`
`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.
`
`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
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`alleged invention.
`
`III. Level of Ordinary Skill in the Art
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`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, permission settings, and
`
`navigations systems in mobile devices and wireless networks that are pertinent to
`
`the ’147 patent. I am also aware of the state of the art at the time the application
`
`resulting in the ’147 patent was filed. I have been informed by Apple’s counsel
`
`that the earliest claimed priority date for the ’147 patent is October 4, 2001. Based
`
`on the technologies disclosed in the ’147 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, mobile devices and
`
`wireless networks, and approximately two years of experience working with same.
`
`Additional work experience can substitute 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 ’147 patent.
`
`IV. Claim Construction
`
`24.
`
`It is my understanding that in order to properly evaluate the ’147
`
`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.
`
`25.
`
`I have reviewed the entirety of the ’147 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, all terms,
`
`except the term below, recited in the Challenged Claims do not require express
`
`construction and I have analyzed them consistent with their ordinary and
`
`customary meaning as would have been understood by a POSITA.
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`26.
`
`“navigation information” – claims 1-2, 5-7, 11-13, 16-18, and 22-23
`
`of the ’147 patent recite “navigation information.” This term, however, is not
`
`described anywhere in the ’147 patent specification. The ’147 patent describes
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`different items that may constitute navigation information as a user travels along a
`
`route:
`
`The user could also select for the route to be continually checked
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`and updates sent to the wireless device 104 until the feature is
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`disabled (by the user reaching the destination) or the feature is timed
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`out by the user entering a time limit. The system knows the
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`identification of the wireless device 104 of the user 102 and then
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`could access the primary embodiment to access the mobile
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`location and travel direction and speed. It could then recalculate
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`the routing information if the user of the wireless device 104 were
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`to get off the primary route. Updates could then be sent to the phone
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`alerting of the change.
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`’147 patent, 63:34-44.
`
`27. Based on the disclosure of the ’147 patent the term “navigation
`
`information” should be construed to include “one or more of a route, travel
`
`direction, speed, and mobile location.”
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`V. Background
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`28. By early 2000 more and more people were using cellular telephones
`
`and other mobile devices. In fact, there were more than 300,000,000 cellular users
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`worldwide. Moles, 1:13-14. Due to bandwidth constraints, which were offered at
`
`only a few tens of kilobits per second (Kbps), users used their mobile devices
`
`mainly for voice conversations. Moles, 1:29-34.
`
`29. The 3G wireless communication technology was a game changer.
`
`With the 3G technology, wireless networks providers were able to offer
`
`bandwidths to users that were 125kpbs or greater. Because the wireless networks
`
`were connected to the Internet, the higher bandwidths made Internet applications
`
`for mobile devices more accessible and more common. Moles, 1:37-45; Hancock,
`
`Figure 13. Prior to the 3G technology, navigation, location, and mapping
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`applications were typically pre-installed on mobile devices. With the 3G
`
`technology, these applications were now accessible to mobile devices over a
`
`wireless network connected to the Internet. The applications provided users with
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`their real-time data, including location data, navigation data, traffic data, and
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`tracking information. See Moles, Sakarya, and Hancock.
`
`30. While applications provided services and data to the users, the
`
`applications also requested access to user and location information. See Zellner,
`
`Meadows. Not all users, however, wanted to make their location and user
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`information available. Many users wanted to control which applications, services,
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`other users, etc., could access their information. Because the users wanted to
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`control who could access their information, the mobile devices began to include
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`configurable permission flags. The users could set those flags to control which
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`applications, services, etc., could access all, none or a subset of their information.
`
`See Zellner, Moles.
`
`31. All these concepts were well-known in the art before the ’147 patent
`
`was filed.
`
`VI. Overview of the ’147 Patent
`
`32. The ’147 patent is generally related to wireless devices in a “generic
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`radio tower network 108, consisting of a plurality of radio towers with base-station
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`transceiver subsystem (BTS)(’s) 110-A, 110-B, 110-C, 110-D, 110-E.” ’147
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`patent, 51:65-52:1. The wireless devices of the ’147 patent may be tracked using
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`“device location software 2802.” ’147 patent, 52:25-33. The ’147 patent describes
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`“three primary ways to track wireless devices 104-A, 104-B, 104-C, 104D.” ’147
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`patent, 52:1:2. A “BTS” approach, a “sector on a BTS” approach, and a “wireless
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`device” approach. ’147 patent, 52:4-18.
`
`33. The ’147 patent relates to “providing navigation using mobile wireless
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`devices.” ’147 patent, 1:49-50. The directional assistance network (DAN) receives
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`“a starting location and a destination location.” ’147 patent, 63:18-19. The starting
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`location, which is “wireless devices[’] current location,” is determined by a
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`wireless network. ’147 patent, 52:25-33, 115:19-20. The DAN “calculates the
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`route” from the starting location to the destination and sends the route to the
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`mobile device. ’147 patent, 115:23, 63:28-30. The mobile device can also “quer[y]
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`the wireless network for the destination information” and “alert[] the user” if the
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`information is not found. ’147 patent, 117:61-118:4.
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`34. The ’147 patent also relates to flags for limiting the transmission of
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`location and identity information. “Wireless devices 104 should be able to submit
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`preference flags that will control access to the tracking and access of their
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`accounts.” ’147 patent, 61:47-49. For example, a privacy flag 1170 is “intended to
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`allow the user to choose whether or not his/her location can be monitored.” ’147
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`patent, 23:17-19. In another example, an “Anonymous Privacy Flag” allows the
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`user’s location, but not the “user information,” to “be accessed by external
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`applications as part of an anonymous location query.” ’147 patent, 23:23-27.
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`35. 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 1-3, 5-7, 11-14, and 16-18 are obvious over Moles,
`Sakarya, and Khavakh
`A. Summary of Moles
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`36. U.S. Patent 6,505,048 to Moles et al. (“Moles”) was filed on
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`December 30, 1999 and issued on January 7, 2003.
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`37. Moles is directed to “wireless communication systems.” Moles, 1:6-7.
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`The “wireless telephone network 100 comprises a plurality of cell sites 121-123,
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`each containing one of the base stations, BS 101, BS 102, or BS 103” that are
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`“operable to communicate with a plurality of wireless mobile stations (MS) 111-
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`114.” Moles, 4:45-49. The wireless communication system is depicted in Figure 1,
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`below.
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`Moles, Figure 1.
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`38. Moles also describes hardware components that are typically included
`
`in the wireless mobile stations 111-114. Wireless mobile station 112 in Moles
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`“comprises radio frequency (RF) transceiver 210 coupled to antenna 205” for
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`communicating with BS 103. Moles, 5:57-61. The “RF transceiver 210 is coupled
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`to receiving processing circuitry 225 which, in turn, is coupled to speaker 230 and
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`main controller 240.” Moles, 5:63-65. The “[m]ain controller 240 is coupled to
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`transmission processing circuitry 215 which, in turn, is coupled to microphone 220
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`and RF transceiver 210.” Moles, 5:65-67. The “main controller 240 controls the
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`reception of forward channel signals and the transmission of reverse channel
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`signals” to and from BS 103 “in accordance with well known principles.” Moles,
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`5:65-67, 6:1-3. The hardware components of the mobile station are depicted in
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`Figure 2, below:
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`
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`Moles, Figure 2.
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`39. Moles describes “a position locating system that is capable of locating
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`a wireless mobile station.” Moles, 6:26-27. The position locating system (1)
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`“requires the wireless mobile station to determine its position” or (2) “requires the
`
`wireless mobile station to send at least some information to the wireless network in
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`order for the wireless network to be able to determine the position of the wireless
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`mobile station.” Moles, 6:41-46.
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`40. Moles also discloses “selectively disabling the transmission of
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`information concerning the location of the wireless mobile station.” Moles, 2:61-
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`63. A wireless mobile station has “a controller and memory unit having a location
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`privacy flag.” Moles, 2:65-67. “Location privacy flag 272 may be selectively set to
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`cause wireless mobile station 112 to not transmit information concerning the
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`location of wireless mobile station 112.” Moles, 6:57-60. The wireless mobile
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`station also includes a code authorization unit 276 “capable of overriding the
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`location privacy feature” with a code. Moles, 8:65-67. The code “is capable of
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`causing wireless mobile station 112 to transmit its location to the nearest base
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`station” even “if the value of location privacy flag 272 indicates that the location of
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`wireless mobile station 112 is not to be transmitted.” Moles, 9:2-8.
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`B. Summary of Sakarya
`
`41. WO 01/28270 to Sakarya (“Sakarya”) was published on April 19,
`
`2001.
`
`42. Sakarya also relates to a “mobile station” operating in a “mobile
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`communication network system.” Sakarya, 3:15-20. The “display 25 of the mobile
`
`station 1 display[s] an extract of the city map 24 and additionally names and
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`locations of streets and characteristic buildings.” Sakarya, 15:17-18. Further, “[a]
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`field comprising the geographical position 24c of the Mobile Station 1 can be
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`marked on the display 25 in any appropriate manner.” Sakarya, 15:22-24. To
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`determine the geographical position 24c, the “global positioning system GPS
`
`module” or a “GSM/UMTS localising system for mobile stations” may be used.
`
`Sakarya, 4:1-4. The display 25 is depicted in Figure 2, below:
`
`Sakarya, Figure 2.
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`
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`43. Sakarya also relates to navigation. The mobile station can “give
`
`directional information based on destination information and information
`
`concerning its present location.” Sakarya, 11:15-17. For example, Sakarya
`
`discloses a “navigational algorithm” that calculates “the direction to go from the
`
`location of the mobile station and indicate this direction on the mobile station
`
`display.” Sakarya, 17:28-18:1. In some cases, the mobile station may update the
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`directional information based on “information concerning [traffic] jam, rerouting,
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`speed limits etc.,” that is received from the network. Sakarya, 18:16-19.
`
`44. Sakarya also relates to managing and updating data, e.g. map data,
`
`stored in the mobile station. In Sakarya, the “[l]atest mobile available data are
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`stored at said mobile station.” Sakarya, 3:11-12. The “mobile station 1 can inform
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`the network antenna 13 whether it has already stored map data information of cell
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`14 and/or second local area 16.” Sakarya, 15:1-4. If “not or if the version number
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`or date of the map data in the mobile station 1 indicates that the map data in the
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`mobile station 1 is obsolete, i.e. a new version for the map data exists, the network
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`antenna 13 transmits 17 map data or updated map data.” Sakarya, 15:4-9. In this
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`way, “[o]nly the data not already available in the mobile station are loaded and
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`stored in the mobile station.” Sakarya, 5:24-25.
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`22
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`Apple Exhibit 1003
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`C. Summary of Khavakh
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`45. U.S. Patent No. 6,192,314 to Khavakh et al. (“Khavakh”) was filed on
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`March 25, 1998 and it issued on February 20, 2001.
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`46. Khavakh is directed to a navigation system implemented on a hand-
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`held portable system or “a networked environment or a client-server platform.”
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`Khavakh, 3:32-37. The navigation system includes a route calculation program.
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`Khavakh Abstract. The “route calculation program is adapted to find at least one
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`solution route between a first location on a road network and a second location on
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`the road network.” Khavakh, Abstract.
`
`47. Specifically, in “the navigation software program 18” the “route
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`calculation tool 40 determines routes between specified locations.” Khavakh, 5:29-
`
`31. The “route calculation tool 40 comprises a route calculation object 50.”
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`Khavakh, 6:6-7. The route calculation object 50 generates an “output route object
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`60” that “includes a single route.” Khavakh, 6:62-64. The “route is comprised of a
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`list 60(1) of road segment data records” that “represent portions of roadways that
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`together comprise the calculated route.” Khavakh, 6:64-67.
`
`48. The route calculation object 50 also determines “the time of travel
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`416.” Khavakh, 12:53-55. The “time of travel 416 holds a value that indicates the
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`cumulative total time to travel a route.” Khavakh, 12:58-60. The time of travel
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`23
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`Apple Exhibit 1003
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`

`value 416 “is determined by adding the times of travel of the road segments that
`
`comprise a solution route.” Khavakh, 12:61-65.
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`D. Reasons to Combine Moles and Sakarya
`
`49. A POSITA would have been motivated to combine Moles and
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`Sakarya to display the location of a wireless device on a map and provide
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`navigation capabilities as taught by Sakarya, and doing so would have been within
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`the POSITA’s skillset and would produce beneficial, predictable results.
`
`50. When considering the teachings of Moles, a POSITA would have
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`considered the teachings of Sakarya since they are analogous prior art in the same
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`field of endeavor as the ’147 patent—wireless communication systems and devices
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`receiving location-based services. ’147 patent, Abstract, 111:57-112:5; Moles,
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`4:42-50, 6:12-46; Sakarya, 3:15-20, 11:15-23.
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`1. Generate and display a location of a mobile device on a
`map.
`
`51. A POSITA, when considering Moles, would have found it obvious to
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`consider other references describing in further detail how the location of the
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`mobile device can be usefully displayed on a mobile device. Moles describes that
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`the “latitude and longitude of wireless mobile station 112 may then be displayed on
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`display unit 255 for the user.” Moles, 6:17-19. Moles further explains known and
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`useful benefits of displaying the location, such as when a user is lost or is in an
`
`24
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`Apple Exhibit 1003
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`

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`unknown area. Moles, 1:57-2:4. When considering Moles, a POSITA would have
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`looked to art that describe how location can be beneficially displayed. Sakarya
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`provides further context for usefully displaying the location of the mobile device
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`together with map information. Sakarya, 1:7-13. Sakarya’s mobile station display
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`25, for example, displays “the geographical position 24c of the Mobile Station”
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`together with “an extract of