UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD.,
`SAMSUNG ELECTRONICS AMERICA, INC., and
`GOOGLE LLC,
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`Petitioners
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`v.
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`RYAN HARDIN and ANDREW HILL,
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`Patent Owners.
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`Case IPR2022-01330
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`Case IPR2022-01331
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`Case IPR2022-01332
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`U.S. Patent No. 9,779,418
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`DECLARATION OF DAVID H. WILLIAMS
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`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW
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`OF U.S. PATENT NO. 9,779,418
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`Exhibit 1003
`Page 001 of 238
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`IPR2022-01330, IPR2022-01331, and IPR2022-01332
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`U.S. Patent No. 9,779,418
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`Table of Contents
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`I.
`Introduction and Compensation ....................................................................... 1
`Qualifications ................................................................................................... 1
`II.
`Summary of Opinions ...................................................................................... 8
`III.
`IV. Materials Reviewed ......................................................................................... 8
`V.
`Legal Principles ............................................................................................... 9
`A.
`Priority Date .......................................................................................... 9
`B.
`Claim Interpretation ............................................................................ 11
`C.
`Prior Art ............................................................................................... 11
`D. Obviousness ......................................................................................... 11
`VI. Level of Ordinary Skill in the Art ................................................................. 15
`VII. Technical Background and the ’418 Patent ................................................... 16
`A.
`Background of the Relevant Technology ............................................ 16
`1.
`Geofencing had been Well-Known by the priority date ........... 16
`2.
`Geofencing was Enabled by a Variety of Architectures prior to
`the priority date ......................................................................... 19
`Numerous Applications for Utilizing Geofencing Were Well-
`Known by the priority date ....................................................... 25
`The ’418 Patent and the Shared Specification .................................... 28
`Prosecution History of the ’418 Patent ............................................... 37
`1.
`U.S. Patent Application No. 12/434,094 (“the ’094
`application”) .............................................................................. 37
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`B.
`C.
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`3.
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`i
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`Exhibit 1003
`Page 002 of 238
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`2.
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`IPR2022-01330, IPR2022-01331, and IPR2022-01332
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`U.S. Patent No. 9,779,418
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`U.S. Patent Application No. 13/856,392 (“the ’392
`application”) .............................................................................. 43
`U.S. Patent Application No. 14/292,204 (“the ’204
`application”) .............................................................................. 49
`U.S. Patent Application No. 14/608,285 (“the ’285
`application”) .............................................................................. 52
`U.S. Patent Application No. 15/009,961 (“the ’961
`application”) .............................................................................. 54
`VIII. The Claims of the ’418 Patent Are Not supported by the Disclosure of the
`’094 or ’392 Application ............................................................................... 61
`IX. Detailed Explanation of the Unpatentability Grounds .................................. 70
`A. Hardin ’665 in view of Salmre Discloses Each Limitation of the
`Challenged Claims .............................................................................. 70
`A POSA Would Have Been Motivated to Combine Hardin ’665 and
`Salmre ................................................................................................227
`Conclusion ...................................................................................................234
`X.
`XI. Oath ..............................................................................................................234
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`3.
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`4.
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`5.
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`B.
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`ii
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`Exhibit 1003
`Page 003 of 238
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`IPR2022-01330, IPR2022-01331, and IPR2022-01332
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`U.S. Patent No. 9,779,418
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`
`I, DAVID H. WILLIAMS, declare as follows:
`INTRODUCTION AND COMPENSATION
`I.
`I have been retained by Samsung Electronics Co., Ltd., Samsung
`1.
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`Electronics America, Inc., and Google LLC (“Petitioners”) as an independent expert
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`consultant in this inter partes review (“IPR”) proceeding before the United States
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`Patent and Trademark Office (“PTO”).
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`2.
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`I have been asked by Counsel for Petitioners (“Counsel”) to consider
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`whether certain references teach or suggest the features recited in claims 1-25 of
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`U.S. Patent No. 9,779,418 (“the ’418 patent”) (Ex. 1001).1 My opinions, and the
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`bases for those opinions, are set forth below.
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`3.
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`I am being paid at my ordinary and customary consulting rate of $710
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`per hour, and I am being reimbursed for actual expenses. My compensation in no
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`way depends on the outcome of this matter. I have no other financial interest in this
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`proceeding.
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`II. QUALIFICATIONS
`All of my opinions stated herein are based on my own personal
`4.
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`knowledge, professional judgment, and analysis of the materials and information I
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`considered in preparing this Declaration. In forming my opinions, I have relied on
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`1 Where appropriate, I refer to exhibits I understand will be attached to the petitions
`for inter partes review of the ’418 patent (the “Petitions”).
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`1
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`Exhibit 1003
`Page 004 of 238
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`IPR2022-01330, IPR2022-01331, and IPR2022-01332
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`U.S. Patent No. 9,779,418
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`my knowledge and experience in designing, developing, researching, and teaching
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`the technology referenced in this Declaration.
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`5.
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`I am over 18 years of age and, if I am called upon to do so, I would be
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`competent to testify as to the matters set forth herein. I understand that a copy of
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`my current curriculum vitae, which details my education and professional and
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`academic experience, is being submitted as Ex. 1004. The following provides a brief
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`overview of some of my experience that is relevant to the matters set forth in this
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`Declaration.
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`6.
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`I have over 30 years of experience in wireless location services,
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`including experience designing, implementing, and managing numerous location-
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`based service (LBS) applications such as mobile social networking, family tracking,
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`mobile resource management, and fleet and asset management, as well as working
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`in all fields within the location services ecosystem including all forms of location
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`determination technologies, map data, handset technologies, and associated
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`Information Technology systems including identification, authentication, privacy,
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`security, and other related capabilities such as network engineering and operations.
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`7.
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`I am the President and founder of E911-LBS Consulting, and I have
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`been with the company since 2002. As the President of E911-LBS Consulting, I
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`provide services across the entire wireless value chain, particularly with respect to
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`technology and business strategic planning and product design and development
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`2
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`Exhibit 1003
`Page 005 of 238
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`IPR2022-01330, IPR2022-01331, and IPR2022-01332
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`U.S. Patent No. 9,779,418
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`associated with LBS, Global Positioning Satellite (GPS) systems, E911, Real-Time
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`Location Systems (RTLS), Radio Frequency Identification (RFID), Bluetooth, Near
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`Field Communications
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`(NFC),
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`beacon-based
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`and
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`other
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`short-range
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`communications/location systems, and other location determination and sensing
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`technologies and services.
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`8.
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`I have extensive expertise in all aspects of LBS delivery across the
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`wireless location ecosystem including enabling network, map data, geospatial
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`platform, chipset, data management, device, and
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`location determination
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`infrastructure and integration providers. I am an expert in all related aspects of LBS,
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`including data privacy and security management.
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`9.
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`For example, in the 1995 to 2000 timeframe, as an Associate Partner in
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`the Communications & High Technology Practice of Accenture (one of the world’s
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`leading technology companies), I focused on using wireless location technologies to
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`provide services to the public sector and commercial markets. In particular, from
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`1998 to 2000, I led the development of the LBS product/technology strategy and
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`roadmap for Nextel Communications, Inc. My work with Nextel resulted in some
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`of the earliest LBS applications in the U.S. market and included extensive research
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`into the potential use of various technologies in providing and enabling a wide array
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`of location-based services. Many of the Nextel products selected for development
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`and implementation included various forms of worker and asset tracking,
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`3
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`Exhibit 1003
`Page 006 of 238
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`IPR2022-01330, IPR2022-01331, and IPR2022-01332
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`U.S. Patent No. 9,779,418
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`matching—based on their location—workers with other workers, or workers with
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`assets (e.g., field equipment, vehicles, etc.). This work also included leading the
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`development of the underlying network and Information Technology architectures
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`that would be required to support the LBS applications product strategy and
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`roadmap.
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`10.
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`In 2003, I led the development of part of AT&T Wireless’s E911
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`infrastructure, including the development of systems, processes, and reporting
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`infrastructure to manage and track the deployment of time difference of arrival-
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`based location determination technologies. I managed the testing and Federal
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`Communications Commission reporting of network location inaccuracies, with a
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`particular focus on detecting and
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`troubleshooting out-of-norm
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`technology
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`deployment and inaccurate location conditions.
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`11. From 2005 to 2007, I worked with NAVTEQ—the leading provider of
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`map data and services essential to creating LBS applications—to develop the
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`company’s web developer website content and tools. Specifically, I designed and
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`managed the site map and overall content, including the development of
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`comprehensive technical and business web content for all NAVTEQ map product
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`and service lines. Through the developer site, application developers and business
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`managers became intimately familiar with map data, Geographical Information
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`System (GIS) platforms, and location-based services to successfully develop and
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`4
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`Page 007 of 238
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`IPR2022-01330, IPR2022-01331, and IPR2022-01332
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`U.S. Patent No. 9,779,418
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`launch their LBS applications. For example, I developed the content to highlight
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`key types of map data and to provide technical details on how NAVTEQ tools can
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`be used in LBS design for various consumer and business applications.
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`12.
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`I also have extensive LBS application product design and
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`implementation experience, which includes data privacy and security management.
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`For example, from 2007 to 2010, I managed the design, development, and launch of
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`several consumer and business-oriented LBS applications for AT&T Mobility.
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`These LBS application included mobile social networking, family tracking, local
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`search, 411-with-LBS, mobile resource management, and asset tracking. I also
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`developed corporate-wide location data privacy policies and associated system
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`implementation for all LBS customers.
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`13. My AT&T work extensively involved authentication of location-
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`related use of LBS applications. In particular, I was the Product Realization
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`Manager (the person responsible for implementation of a product) for several LBS
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`applications that allowed the sharing of location information, including between
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`multi-device applications. One of these applications was the Loopt social networks
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`application. This role and work required extensive knowledge of how the
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`application worked (including its use of geofences), and even required design
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`modifications in order for it to “fit into” AT&T’s network and IT infrastructure, as
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`well as to implement AT&T’s privacy and security policies. The work also included
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`5
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`Exhibit 1003
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`IPR2022-01330, IPR2022-01331, and IPR2022-01332
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`U.S. Patent No. 9,779,418
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`designing/modifying AT&T’s network and IT infrastructure to allow/enable the
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`Loopt application to work seamlessly with AT&T’s location infrastructure and
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`various IT systems used for functions including Sales, Customer Care, Fulfillment,
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`Billing/Accounts Receivable, and various network and IT operations. The work also
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`included extensive work with AT&T Legal to develop and implement AT&T’s
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`location privacy policies. The integration of the application into the above required
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`extensive authorization-related design work to ensure that a given user could
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`appropriately access the various AT&T systems and subsystems, as well as the
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`application, under the appropriate conditions/circumstances, including appropriately
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`authorizing the use of and the sharing of a user’s location with other users and/or
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`systems. This work in location-related data security and privacy networking resulted
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`in a patent: U.S. Patent No. 8,613,109, titled “Method and Apparatus for Providing
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`Mobile Social Networking Privacy,” that issued on December 17, 2013, of which I
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`was the only non-employee inventor.
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`14. Much of the above work was replicated in various forms for other LBS
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`applications for which I was the Lead Product Realization Manager, including
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`AT&T FamilyMap (tracking and controlled sharing of family/children location
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`information), Slifter Local Search, 411-with-LBS, AT&T Navigator, and Telenav
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`Mobile Resource Management and Asset Management products. I also served as
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`the Lead Product Realization Manager for an early LBS-based golfing game system
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`6
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`Exhibit 1003
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`IPR2022-01330, IPR2022-01331, and IPR2022-01332
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`U.S. Patent No. 9,779,418
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`(called CaddyHawk), which enabled the use of location to track and improve a
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`golfer’s game based on their position on the course relative to the hole and/or other
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`obstacles/constraints on the golf course.
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`15. The above AT&T work included the development of corporate-wide
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`location data privacy policies and their systemic implementation for all LBS
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`customers. My work in both data privacy and mobile social networking resulted in
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`my co-inventing a patent in this field titled “Method and Apparatus for Providing
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`Mobile Social Networking Privacy.” (U.S. Patent No. 8,613,109, issued on
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`December 17, 2013.)
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`16.
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`I have authored multiple books on wireless location, including:
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`• The Definitive Guide to GPS, RFID, Wi-Fi, and Other Wireless
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`Location-Based Services (2005 and 2009 versions);
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`• The Definitive Guide to Wireless E911; and
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`• The Definitive Guide to Mobile Positioning and Location Management
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`(coauthor).
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`17.
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`I received a B.S. degree in Electrical Engineering from Purdue
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`University in 1983. I received an MBA degree in Information Systems Management
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`from The University of Texas at Austin in 1987.
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`7
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`Exhibit 1003
`Page 010 of 238
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`IPR2022-01330, IPR2022-01331, and IPR2022-01332
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`U.S. Patent No. 9,779,418
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`III. SUMMARY OF OPINIONS
`It is my opinion that claims 1-25 of the ’418 patent are not supported
`18.
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`by the disclosures of U.S. Patent Application Nos. 12/434,094 (“the ’094
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`application”) or 13/856,392 (“the ’392 application”).
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`19.
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`It is also my opinion that claims 1-25 of the ’418 patent are unpatentable
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`under 35 U.S.C. § 103 on the following grounds:
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`• Ground 1: Claims 1-25 are rendered obvious by U.S. Patent
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`Publication No. US 2010/0279665 A1 (“Hardin ’665”) (Ex. 1005) in
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`view of U.S. Patent Publication No. US 2006/0116817 A1 (“Salmre”)
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`(Ex. 1006).
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`IV. MATERIALS REVIEWED
`20. My opinions contained in this Declaration are based on the documents
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`I reviewed, my professional judgment, as well as my education, experience, and
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`knowledge of the field.
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`21.
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`I have reviewed and considered the ’418 patent (Ex. 1001), related
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`patents and publications (Ex. 1007; Ex. 1009; Ex. 1011; Ex. 1013), the
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`accompanying prosecution histories (Ex. 1002; Ex. 1008; Ex. 1010; Ex. 1012;
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`Ex. 1014), and various background articles and materials referenced in this
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`Declaration. I have also reviewed the materials cited herein, including the following
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`prior art:
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`8
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`Exhibit 1003
`Page 011 of 238
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`IPR2022-01330, IPR2022-01331, and IPR2022-01332
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`U.S. Patent No. 9,779,418
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`• U.S. Patent Publication No. US 2010/0279665 A1 (“Hardin ’665”)
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`(Ex. 1005); and
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`• U.S. Patent Publication No. US 2006/0116817 A1 (“Salmre”)
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`(Ex. 1006).
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`All citations to Exhibits in this Declaration refer to Exhibits filed with the Petitions
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`filed concurrently herewith. A list of the Exhibits can be found in the accompanying
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`Petitions.
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`22. Based on my experience and expertise, it is my opinion that Hardin ’665
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`in view of Salmre disclose and/or suggest all the features recited in claims 1-25
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`(“challenged claims”) of the ’418 patent, as I discuss in detail below.
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`V. LEGAL PRINCIPLES
`I am not an attorney and offer no legal opinions, but in the course of
`23.
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`my work, I have had experience studying and analyzing patents and patent claims
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`from the perspective of a person skilled in the art.
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`24. For the purposes of this Declaration, I have been informed about certain
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`aspects of the law that are relevant to my analysis, as summarized below.
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`A.
`25.
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`Priority Date
`I understand that, to gain benefit of the filing date of an earlier patent
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`application, each application in the chain leading back to the earlier application must
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`comply with the statutory written description requirement.
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`9
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`Exhibit 1003
`Page 012 of 238
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`IPR2022-01330, IPR2022-01331, and IPR2022-01332
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`U.S. Patent No. 9,779,418
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`I understand that, to satisfy the written description requirement, a
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`26.
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`patent’s specification must reasonably convey to a person of ordinary skill in the art
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`(“POSA”) that the inventor had possession of the claimed subject matter when the
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`patent application was filed. I understand that, to show “possession” of the
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`invention, the disclosure must describe the invention, including all its claimed
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`limitations. It is not enough that a claimed invention is an obvious variant of that
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`which is disclosed in the specification. While the meaning of terms, phrases, or
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`diagrams in a disclosure is to be explained or interpreted from the vantage point of
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`a POSA, all the limitations must appear in the specification.
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`27.
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`I further understand that entitlement to a filing date extends only to
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`subject matter that is disclosed and not to subject matter that is not disclosed but
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`would be obvious over what is expressly disclosed. Thus, a prior application itself
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`must describe an invention, and do so in sufficient detail that a POSA can clearly
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`conclude that the inventor invented the claimed invention as of the filing date sought.
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`28.
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`I also understand that a patent’s priority date is a legal determination
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`based on underlying factual issues. For that reason, I am not rendering a legal
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`opinion on the ultimate legal question of priority date. Rather, my testimony
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`addresses the underlying facts and factual analysis that would support a legal
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`determination of the priority date.
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`B. Claim Interpretation
`I understand from Counsel that during an IPR proceeding, claims are to
`29.
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`be construed in light of the specification as would be read by a person of ordinary
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`skill in the relevant art at the time the application was filed. I understand that claim
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`terms are given their ordinary and customary meaning as would be understood by a
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`person of ordinary skill in the relevant art in the context of the entire disclosure. A
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`claim term, however, will not receive its ordinary meaning if the patentee acted as
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`his own lexicographer and clearly set forth a definition of the claim term in the
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`specification. In that case, the claim term will receive the definition set forth in the
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`patent.
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`C.
`30.
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`Prior Art
`I understand from Counsel that certain patents and printed publications
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`can be considered prior art in an IPR proceeding. I understand that prior art must
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`predate the effective filing date of the claims of the patent-at-issue.
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`D. Obviousness
`I understand that a claim is unpatentable if the claim limitations, as
`31.
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`arranged in a claim, would have been obvious to a POSA as of the date of invention.
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`For example, a combination of familiar elements according to known methods is
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`likely to be obvious if the combination does no more than produce predictable
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`results.
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`In determining obviousness, I understand that the analysis may take into
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`32.
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`account multiple prior art references as well as the common knowledge possessed
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`by a POSA (as discussed below). I further understand that the POSA is not an
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`automaton but one having common sense and ordinary creativity. I also understand
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`that a claim is not obvious simply because a combination of prior art references
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`discloses each claim element collectively.
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`33.
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`In determining obviousness, I understand that one should consider the
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`following:
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`• The scope and content of the prior art;
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`• The differences between the claimed invention and the prior art;
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`• The level of ordinary skill in the pertinent art; and
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`• Secondary considerations of non-obviousness.
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`34.
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`I understand that a POSA is assumed to have knowledge of all prior art
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`references. I also understand that when considering the obviousness of a patent
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`claim, one should consider whether a teaching, suggestion, or motivation to combine
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`the references exists so as to avoid impermissibly applying hindsight when
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`considering the prior art. I understand this test should not be rigidly applied, but that
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`the test can be important to avoiding such hindsight.
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`35.
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`I understand that a POSA can combine various prior art references
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`based on the teachings of those prior art references, the general knowledge present
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`in the art, or common sense. I understand that a motivation to combine the references
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`may be implicit in the prior art, and there is no requirement that there be an actual
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`or explicit teaching to combine two references. Thus, one may take into account the
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`inferences and creative steps that a POSA would employ to combine the known
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`elements in the prior art in the manner claimed by the patent-at-issue. I understand
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`that one should avoid “hindsight bias” and ex post reasoning in performing an
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`obviousness analysis. This does not mean, however, that a POSA for purposes of
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`the obviousness inquiry does not have recourse to common sense.
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`36.
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`I understand that the following are examples of approaches and
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`rationales that may be considered in determining whether a prior art reference could
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`have been combined with other prior art or with other information within the
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`knowledge of a POSA:
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`• Combining prior art elements according to known methods to yield
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`predictable results;
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`• Simple substitution of one known element for another to obtain
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`predictable results;
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`• Use of known techniques to improve similar devices, methods, or
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`products in the same way;
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`• Applying a known technique to a known device, method, or product
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`ready for improvement to yield predictable results;
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`• That it was “obvious to try”—i.e., that it was one choice from a finite
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`number of identified, predictable solutions, with a reasonable
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`expectation of success;
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`• Known work in one field of endeavor may prompt variations of it for
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`use in either the same field or a different one based on design incentives
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`or other market forces if the variations are predictable to one of ordinary
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`skill in the art; and
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`• Some teaching, suggestion, or motivation in the prior art that would
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`have led a POSA to modify the prior art reference or to combine
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`multiple prior art reference teachings to arrive at the claimed invention.
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`37.
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`I also understand that “obviousness” is a legal conclusion based on the
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`underlying factual issues of the scope and content of the prior art, the differences
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`between the claimed invention and the prior art, the level of ordinary skill in the art,
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`and any objective indicia of non-obviousness. For that reason, I am not rendering a
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`legal opinion on the ultimate legal question of obviousness. Rather, my testimony
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`addresses the underlying facts and factual analysis that would support a legal
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`conclusion of obviousness, and when I use the term obvious, I am referring to the
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`perspective of a POSA at the time of invention.
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`VI. LEVEL OF ORDINARY SKILL IN THE ART
`I understand that a POSA is a hypothetical person who is presumed to
`38.
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`have known the relevant art at the time of the invention. To determine the level of
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`skill held by a POSA, I understand that a number of factors may be considered,
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`including the following:
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`• The type of problems encountered in the art;
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`• Prior art solutions to those problems;
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`• Rapidity with which innovations are made;
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`• Sophistication of the technology; and
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`• Educational level of active workers in the field.
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`39.
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`I understand that not all of the above factors will be present in every
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`case and one or more factors may predominate.
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`40.
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`In view of the above factors, it is my opinion that a POSA as of either
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`May 1, 2009 or January 29, 2015 would have had at least a bachelor’s degree in
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`computer science or a comparable field of study and at least five years of
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`professional experience in mobile or location-based computing or other relevant
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`academic experience.
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`41.
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`I would have qualified as a POSA as of the effective filing date of the
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`claims of the ’418 patent. My opinions are offered from this perspective, even if
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`they do not specifically refer to the perspective of a POSA.
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`VII. TECHNICAL BACKGROUND AND THE ’418 PATENT
`A. Background of the Relevant Technology
`42. The technology at issue, at the time of the alleged priority date of
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`May 1, 2009 and certainly by January 29, 2015, was well known. In particular, each
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`of the components/disciplines involved had been well known. These include:
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`• Geofencing;
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`• Various architectures to support geofencing, including client-server and
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`client-based; and
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`• Numerous geofencing-related applications,
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`including providing
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`content delivery.
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`1. Geofencing had been Well-Known by the priority date
`43. Geofencing is “a technology that defines a virtual boundary around a
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`real-world geographical area.” (Ex. 1020, 1.) Geofencing has been used in the
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`modern communications era for everything from controlling aircraft to 911 systems
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`for determining and controlling which ground controller would handle an aircraft as
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`they fly through multiple control jurisdictions, or which PSAP (Public Safety
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`Answering Point) should handle a 9-1-1 caller, respectively.
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`44.
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`911 call handling—and geofences—became more prominent with the
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`passage of the 1996 Telecommunications Act, which resulted in an FCC mandate to
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`be able to find the location of wireless phone 9-1-1 callers. It got a further boost in
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`2000 with the discontinuing of Selective Availability (“SA”), which had deliberately
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`introduced errors into GPS signals, thereby causing inaccuracies. Since determining
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`a geofence (and associated calculations) is a highly mathematical process (e.g.,
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`comparing latitude and longitude values of the location of a phone to a mathematical
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`shape/formula of a geofence), this removal of SA greatly increased the accuracy and
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`precision of geofence-related calculations, and thus their overall utility and potential
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`use cases.
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`45. The use of geofencing accelerated in the early 2000s as geofencing
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`capabilities and key enablers became available. For example, a 2002 IBM Research
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`Center article, Location-Based Notification as a General-Purpose Service, describes
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`how a company named Cell-Loc “provides location-based notification services
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`known as GeoFenceTM and GeoLassoTM. GeoFence is a virtual geographic boundary
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`such as one surrounding a factory. GeoFence events are generated whenever one of
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`a specified list of devices are detected entering and/or exiting the area.” (Ex. 1021,
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`41.) These capabilities supported a wide variety of applications, such as shown by
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`a 2003 excerpt from Cell-Loc’s website, below:
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`(Ex. 1022.)
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`46. A 2004 PC Magazine article describes location “enhancements” by a
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`company called uLocate where “users can set up ‘geofences’ around specific
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`locations; when a phone enters or leaves that area, an alert is triggered. This could
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`be used to let parents know, by e-mail or SMS, when a child reaches school.”
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`(Ex. 1023, 82.)
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`47. These were by no means
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`the only such
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`innovations
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`in
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`geofences/geofencing; a patent search of “location,” “geofence or geofencing,” and
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`“mobile or wireless,” before May 1, 2009 yields 2,670 results, while the same search
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`before January 29, 2015 yields 17,813 results.2 These capabilities had a variety of
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`designs and underlying architectures, discussed next.
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`2. Geofencing was Enabled by a Variety of Architectures prior
`to the priority date
`48. A key issue in this matter is how geofencing was implemented. At the
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`time of the alleged priority date of May 1, 2009, geofencing was enabled not just
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`using server-based architectures, but also client-based architectures.
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`49. The original mobile device geofencing capabilities were enabled by
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`server-based architectures. The Cell-Loc and uLocate systems above utilized a
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`server that would acquire coordinates either from the network (Cell-Loc) or from the
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`device via GPS (uLocate), compare the coordinates with geofencing parameters, and
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`then trigger as appropriate the applicable functionality (alerts, notifications, related
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`content, etc.), either back to the client or to other users.
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`50. A patent example of client-server geofencing systems was by
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`Openwave Systems, Inc., an early player in LBS tools and applications (and
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`geofencing). One of their patents, U.S. Patent No. 7,133,685 (“the ’685 patent”),
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`https://patents.google.com/?q=location&q=geofence,geofencing&q=mobile,
`2
`wireless&before=priority:20090501;
`https://patents.google.com/?q=location&q=geofence,geofencing&q=mobile,wirele
`ss&before=priority:20150129.
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`titled Monitoring Boundary Crossings in a Wireless Network3 discusses a variety of
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`geofence concepts.4 For example, the ’685 patent’s abstract describes:
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`A method of providing location-based services for a
`mobile unit operating in a wireless network including
`network structures. The method includes receiving an
`identifier associated with the mobile unit. The method
`also includes monitoring a location of the mobile unit
`using the identifier and a network-assisted location finding
`system to identify a crossing of a service zone boundary
`by the mobile unit. The service zone boundary is defined
`by reference to at least one of the network structures. The
`servic