`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`HYUNDAI MOTOR COMPANY,
`
`Petitioner
`v.
`MEL NAVIP LLC,
`Patent Owner
`
`Patent No. 8,649,971
`Inter Partes Review No.
`IPR2024-00173
`
`
`DECLARATION OF SYLVIA HALL-ELLIS, PH.D.
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`Hyundai Exhibit 1012, Page 1 of 44
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`INTRODUCTION
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`1. My name is Sylvia D. Hall-Ellis. I have been retained as an expert on
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`I.
` 
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`behalf of Hyundai Motor Company (“Petitioner”).
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`2.
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`I have written this report on behalf of Petitioner to provide my expert
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`opinion regarding the authenticity and public availability of two publications. My
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`report sets forth my opinions in detail and provides the basis for my opinions
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`regarding the public availability of these publications.
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`3.
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`I reserve the right to supplement or amend my opinions, and bases for
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`them, in response any additional evidence, testimony, discovery, argument, and/or
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`other additional information that may be provided to me after the date of this
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`report.
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`4.
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`I am being compensated for my time spent working on this matter at
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`my normal consulting rate of $350 per hour, plus reimbursement for any additional
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`reasonable expenses. My compensation is not in any way tied to the content of this
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`report, the substance of my opinions, or the outcome of this litigation. I have no
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`other interests in this proceeding or with any of the parties.
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`5.
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`All of the materials that I considered are discussed explicitly in this
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`declaration.
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`1
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`II. QUALIFICATIONS
` 
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`6.
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`I am currently an Adjunct Professor in the School of Information at
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`San José State University. I obtained a Master of Library Science from the
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`University of North Texas in 1972 and a Ph.D. in Library Science from the
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`University of Pittsburgh in 1985. Over the last 50-plus years, I have held various
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`positions in the field of library and information resources. I was first employed as
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`a librarian in 1966 and have been involved in the field of library sciences since,
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`holding numerous positions.
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`7.
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`I am a member of the American Library Association (ALA) and its
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`Association for Library Collections & Technical Services (ALCTS) Division, and I
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`served on the Committee on Cataloging: Resource and Description (which wrote
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`the new cataloging rules) and as the chair of the Committee for Education and
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`Training of Catalogers and the Competencies and Education for a Career in
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`Cataloging Interest Group. I also served as the Chair of the ALCTS Division’s
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`Task Force on Competencies and Education for a Career in Cataloging.
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`Additionally, I have served as the Chair for the ALA Office of Diversity’s
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`Committee on Diversity, as a member of the REFORMA National Board of
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`Directors, as a member of the Editorial Board for the ALCTS premier cataloging
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`journal, Library Resources and Technical Services, as a Co-Chair of the Library
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`2
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`Research Round Table (LRRT) for the American Library Association, and as a
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`member of the LRRT Nominating Committee.
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`8.
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`I have also given over one hundred presentations in the field,
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`including several on library cataloging systems and Machine-Readable Cataloging
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`(“MARC”) standards. My current research interests include library cataloging
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`systems, metadata, and organization of electronic resources.
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`9. My full curriculum vitae is attached hereto as Exhibit 1013.
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`III. PRELIMINARIES
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`10.
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`Scope of this declaration. I am not an attorney and will not offer
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`opinions on the law. I am, however, rendering my expert opinion on the
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`authenticity of the documents referenced herein and on when and how each of
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`these documents was disseminated or otherwise made available to the extent that
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`persons interested and ordinarily skilled in the subject matter or art, exercising
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`reasonable diligence, could have located the documents before on or around the
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`listed dates of their respective publications below.
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`11.
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`I am informed by counsel that a printed publication qualifies as
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`publicly accessible as of the date it was disseminated or otherwise made available
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`such that a person interested in and ordinarily skilled in the relevant subject matter
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`could locate it through the exercise of ordinary diligence.
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`3
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`12. While I understand that the determination of public accessibility under
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`the foregoing standard rests on a case-by-case analysis of the facts particular to an
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`individual publication, I also understand that a printed publication is rendered
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`“publicly accessible” if it is cataloged and indexed by a library such that a person
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`interested in the relevant subject matter could locate it (i.e., I understand that
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`cataloging and indexing by a library is sufficient, though there are other ways that
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`a printed publication may qualify as publicly accessible). One manner of sufficient
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`indexing is indexing according to subject matter category. I understand that the
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`cataloging and indexing by a single library of a single instance of a particular
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`printed publication is sufficient, even if the single library is in a foreign country. I
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`understand that, even if access to a library is restricted, a printed publication that
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`has been cataloged and indexed therein is publicly accessible so long as a
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`presumption is raised that the portion of the public concerned with the relevant
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`subject matter would know of the printed publication. I also understand that the
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`cataloging and indexing of information that would guide a person interested in the
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`relevant subject matter to the printed publication, such as the cataloging and
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`indexing of an abstract for the printed publication, is sufficient to render the
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`printed publication publicly accessible.
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`4
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`13.
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`I understand that routine business practices, such as general library
`
`cataloging and indexing practices, can be used to establish an approximate date on
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`which a printed publication became publicly accessible.
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`14. Persons of ordinary skill in the art. I am told by counsel that the
`
`subject matter of this proceeding generally relates to navigation systems.
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`15.
`
`I have been informed by counsel that a “person of ordinary skill in the
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`art at the time of the inventions” is a hypothetical person who is presumed to be
`
`familiar with the relevant field and its literature at the time of the inventions. This
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`hypothetical person
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`is also a person of ordinary creativity, capable of
`
`understanding the scientific principles applicable to the pertinent field.
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`16.
`
`I am told by counsel that persons of ordinary skill in this subject
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`matter or art would have had an undergraduate degree in electrical engineering,
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`computer engineering, computer science, or an equivalent degree, as well as at
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`least three years of experience in the design and implementation of navigation
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`systems.
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`17.
`
`It is my opinion that such a person would have been engaged in
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`research, learning, thorough study and practice in the field and possibly through
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`formal instruction the bibliographic resources relevant to his or her research. In
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`the 2008 timeframe, such a person would have had access to a vast array of long-
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`established print resources in the area of navigation systems.
`
`5
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`Hyundai Exhibit 1012, Page 6 of 44
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`IV. DOCUMENT 1: EXHIBIT 1007 (“RDX”)
`18. Exhibit 1007 is a copy of the document titled 2008 RDX Navigation
`
`Manual (Unlinked) prepared by the Honda Motor Company, Limited (hereafter
`
`“RDX”). The document is identified as P/N31STK810 (see EX1007, page 1). I
`
`downloaded the document from the Internet1 and made the copy that is Exhibit
`
`1007.
`
`19. The 2008 RDX Navigation Manual (Unlinked) is a true and accurate
`
`copy of the document that was issued and distributed to purchasers of automobiles
`
`with the navigation system. The document bears a 2007 copyright date (see
`
`EX1007, page 1). Specifically, the text of the 2008 RDX Navigation Manual
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`(Unlinked) document is complete; no pages are missing, and the text on each page
`
`appears to flow seamlessly from one page to the next; further, there are no visible
`
`alterations to the document. Exhibit 1007 was found within the custody of the
`
`issuing corporate entity – a place where, if authentic, a copy of this document
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`would likely be.
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`20. Attachment A is an official press release titled “2008 Acura RDX
`
`Press Kit” announcing the release of the 2008 Acura Sport Utility Vehicle with the
`
`Acura Navigation System with Voice Recognition™ on September 13, 2007,
`
`which was prepared and distributed by the Honda Motor Company, Limited on
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` 
`1 https://techinfo.honda.com/rjanisis/pubs/om/BOM352/BOM35224.pdf
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`6
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`Hyundai Exhibit 1012, Page 7 of 44
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`September 13, 2007. Attachment A is a true and correct copy of the press release
`
`which I also accessed from the Internet.2 Specifically, the text of Attachment A is
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`complete; no pages are missing, and the text on each page appears to flow
`
`seamlessly from one page to the next; further, there are no visible alterations to
`
`Attachment A compared to what is currently accessible on the Internet. Further,
`
`Attachment A was found within the custody of the archives for the issuing
`
`corporate entity (i.e., Honda Motor Company, Limited), a place where, if
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`authentic, a copy of this press release would likely be. Attachment A is a true and
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`correct copy in a condition that creates no suspicion about its authenticity.
`
`21. A press release exhibits the following characteristics: the press release
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`is attributed to a creator or author (in this case, Honda Motor Company, Limited)
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`which affixes a date of creation (in this case, September 13, 2007) and publishes
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`the document (in this case national press, Facebook, Twitter, and LinkedIn).
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`22. Based on finding a digital copy of Attachment A on the Internet, it is
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`my opinion that the press release titled “2008 Acura RDX Press Kit” was available
`
`to the public on September 13, 2007, as indicated on the document. It is also my
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`opinion that there is no reason to doubt the authenticity of Attachment A given its
` 
`2 https://acuranews.com/en-US/releases/release-
`91835d2fe2f4151ae54b37004c34bdfc-2008-acura-rdx-
`introduction#:~:text=2008%20Acura%20RDX%20%2D%20Overview&text=The
`%20first%20ever%20Acura%20RDX,the%20Acura%20TSX%20sports%20sedan
`
`7
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`Hyundai Exhibit 1012, Page 8 of 44
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`appearance, contents, and the web address from which it was obtained.
`
`23. Exhibit 1007 is a true and correct copy of the document titled 2008
`
`RDX Navigation Manual (Unlinked) in a condition that creates no suspicion about
`
`its authenticity. Based on the date recorded in the document and the Honda Motor
`
`Company, Limited press release (Attachment A), it is my opinion that the
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`document titled 2008 RDX Navigation Manual (Unlinked) was available to the
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`public on September 13, 2007, or shortly thereafter.
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`V. DOCUMENT 2: EXHIBIT 1016 (“AVIC-Z1”)
`24. Exhibit 1016 is a copy of the document titled AVIC-Z1 Operation
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`Manual prepared by the Pioneer Corporation (hereafter “AVIC-Z1”). The
`
`document is identified as CRB2184-A> UC (see EX1016, page 207A). I
`
`downloaded the document from the Internet3 and made the copy that is Exhibit
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`1016.
`
`25. The AVIC-Z1 Operation Manual is a true and accurate copy of the
`
`document that was issued and distributed to purchasers of automobiles with the
`
`navigation system. The document bears a 2006 copyright date (see EX1016, page
`
`207). Specifically, the text of the AVIC-Z1 Operation Manual document is
`
`complete; no pages are missing, and the text on each page appears to flow
`
` 
`3https://www.pioneerelectronics.com/pio/pe/images/portal/cit_11221/308223015A
`VICZ1OperationManual.pdf 
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`8
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`Hyundai Exhibit 1012, Page 9 of 44
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`seamlessly from one page to the next; further, there are no visible alterations to the
`
`document. Exhibit 1016 was found within the custody of the issuing corporate
`
`entity – a place where, if authentic, a copy of this document would likely be.
`
`26. Attachment A is a product review of the Pioneer AVIC-Z1 titled
`
`“Pioneer AVIC Z-1 Review: Pioneer AVIC Z-1” written by Kevin Massy which
`
`appeared on the America media website, CNET,4 on August 10, 2006. Attachment
`
`B is a true and correct copy of the product review which I also accessed from the
`
`Internet.5 Specifically, the text of Attachment B is complete; no pages are missing,
`
`and the text on each page appears to flow seamlessly from one page to the next;
`
`further, there are no visible alterations to Attachment B compared to what is
`
`currently accessible on the Internet. Further, Attachment B was found within the
`
`custody of the archives for the issuing corporate entity (i.e., CNET), a place where,
`
`if authentic, a copy of this product review would likely be. Attachment B is a true
`
`and correct copy in a condition that creates no suspicion about its authenticity.
`
`27. A product review exhibits the following characteristics: the product
`
`review is attributed to a creator or author (in this case, Kevin Massy) which affixes
`
`a date of creation (in this case, August 10, 2006) and publishes the document (in
`
`this case CNET).
`
` 
`
`4 https://www.cnet.com/
`5 https://www.cnet.com/roadshow/reviews/pioneer-avic-z-1-review/
`
`9
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`28. Based on finding a digital copy of Attachment B on the Internet, it is
`
`my opinion that the product review titled “Pioneer AVIC Z-1 Review: Pioneer
`
`AVIC Z-1” was available to the public on August 10, 2006, as indicated on the
`
`document. It is also my opinion that there is no reason to doubt the authenticity of
`
`Attachment B given its appearance, contents, and the web address from which it
`
`was obtained.
`
`29. Exhibit 1016 is a true and correct copy of the document titled AVIC-
`
`Z1 Operation Manual in a condition that creates no suspicion about its
`
`authenticity. Based on the date recorded in the document and the CNET product
`
`review (Attachment B), it is my opinion that the document titled AVIC-Z1
`
`Operation Manual was available to the public on August 10, 2006, or shortly
`
`thereafter.
`
`VI. SUMMARY OF OPINIONS
`30.
`In view of the foregoing, it is my opinion that the publications
`
`described above were publicly available no later than the corresponding date listed
`
`in the table below:
`
`Exhibit
`
`Publication
`
`1007 Honda Motor Co., Ltd., 2008 RDX Navigation
`Manual (Unlinked), P/N 31STK810, Honda
`Motor Co., Ltd., c2007.
`Pioneer Corporation, AVIC-Z1 Operation
`Manual, <CRB2184-A> UC, Tokyo, Japan:
`Pioneer Corporation, c2006.
`
`1016
`
`10
`
`Publicly Available
`No Later Than
`September 13, 2007
`
`August 10, 2006
`
`Hyundai Exhibit 1012, Page 11 of 44
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`31.
`
`In signing this Declaration, I recognize that the Declaration will be
`
`filed as evidence in a case before the Patent Trial and Appeal Board of the United
`
`States Patent and Trademark Office. I also recognize that I may be subject to
`
`cross-examination in the case and that cross-examination will take place within the
`
`United States. If cross-examination is required of me, I will appear for cross-
`
`examination within the United States during the time allotted for cross-
`
`examination.
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`32.
`
` I hereby declare that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true, and further that these statements were made with the
`
`knowledge that willful false statements and the like so made are punishable by fine
`
`or imprisonment, or both, under Section 1034 of Title 18 of the United States
`
`Code.
`
`
`DATED: November 14, 2023
`
`
`
`
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`11
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`Hyundai Exhibit 1012, Page 12 of 44
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`ATTACHMENT A
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`Hyundai Exhibit 1012, Page 13 of 44
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`10/12/23, 12:18 PM
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`2008 Acura RDX Press Kit
`
`2008 Acura RDX Press Kit
`
` (https://www.facebook.com/sharer.php?u=http%3A%2F%2Facuranews.com%2Fen-US%2Freleases%2F20
` (https://www.twitter.com/intent/tweet?text=2008+Acura+RDX+Press+Kit+http%3A%2F%2Facuranew
` (https://www.linkedin.com/shareArticle?mini=true&url=http%3A%2F%2Facuranews.com%2Fen-US%2F
`
`
`
`    
`
`SECTIONS
`
`September 13, 2007 — Torrance, Calif.
`
`2 0 0 8 A c u r a R D X P r e s s K i t
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`2 0 0 8 A c u r a R D X - O v e r v i e w
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`OVERVIEW
`
`The rst ever Acura RDX burst on to the Sport Utility Vehicle scene in 2007. For 2008 the RDX returns with as an advanced 5-passenger Entry
`Premium SUV with handling and performance that positions it as the SUV soul mate of the Acura TSX sports sedan.
`
`The RDX concept was initiated in California and then developed in Japan. It features precedent-setting engineering features for Acura, including the
`luxury division's rst turbocharged and intercooled engine, the rst adaptation of the Super Handling All-Wheel Drive™ (SH-AWD™) system to an
`SUV, and Acura's rst standard 18-inch wheels and tires. Likewise, the RDX continues Acura's "Safety Through Innovation" with the application of
`cutting edge standard safety technologies. True to form for Acura, the RDX also offers a class-leading array of sophisticated electronic technologies
`that are seamlessly integrated to keep its passengers informed, in touch and entertained.
`
`ENTRY PREMIUM SUV MARKET
`
`The Entry Premium SUV segment is relatively new, at present populated by only a few vehicles including the Acura RDX, BMW X3 and Land Rover
`LR2. This segment is expected to grow ve-fold in the next few years and the RDX positions Acura strongly within it, with a host of unique and
`attractive features.
`
`TARGET CUSTOMER
`Do not sell
`RDX targets young professionals that are upwardly mobile, who work hard and play hard too. The typical buyer enjoys playing a sport, lives in the
`city, and on the weekends often travels to the mountains, country or coast. This customer wants an emotional and stylish vehicle that offers a higher
`"eye-point" (driving position) and more cargo exibility than a sedan - but with the style, handling and performance of a great sports sedan. Thus, the
`transformable utility of the RDX, along with its engaging performance and handling, is a perfect t.
`
`POWERTRAIN FEATURES
`
`Turbocharged and intercooled 2.3-liter 16-valve, DOHC i-VTEC® inline-four engine
`240 horsepower at 6000 rpm
`260 lb-ft of torque at 4500 rpm
`i-VTEC® (Intelligent Variable Valve Timing and Lift Electronic Control)
`Dual balance shafts
`Sequential SportShift 5-speed automatic transmission with F1®-style paddle shifters
`Super Handling All-Wheel Drive™ (SH-AWD™)
`Drive-by-Wire Throttle System™
`EPA estimated 17/22 mpg* (city/highway)
`CARB-certied LEV II ULEV and EPA-certied Tier-2 Bin-5 emissions
`
`BODY & CHASSIS FEATURES
`
`Advanced Compatibility Engineering™ (ACE™) unit body structure with extensive use of high-tensile steel
`Independent MacPherson strut front suspension
`Independent multi-link rear suspension
`Torque-sensing, variable power-assist rack-and-pinion steering
`18 x 7.5-inch aluminum alloy wheels
`
`https://acuranews.com/en-US/releases/release-91835d2fe2f4151ae54b37004c34bdfc-2008-acura-rdx-introduction#:~:text=2008 Acura RDX - Overvi… 1/23
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`Hyundai Exhibit 1012, Page 14 of 44
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`2008 Acura RDX Press Kit
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`P235/55R18 99V M+S all-season high-performance tires
`4-wheel anti-lock braking system (ABS) with Electronic Brake Distribution (EBD) and brake assist
`Vehicle Stability Assist™ (VSA®) with traction control
`1,500-pound tow rating
`Xenon High-Intensity Discharge (HID) low-beam headlights
`Heated outside mirrors with passenger reverse gear tilt-down and integrated directional signals
`
`INTERIOR FEATURES
`
`Luxurious cockpit designed for performance driving
`Perforated leather-trimmed seats
`LED backlit gauges with progressive illumination
`Leather-wrapped 3-spoke steering wheel with ngertip controls
`and F1®-style paddle shifters
`Multi-Information Display
`Power moonroof with tilt, auto-open/close, auto-reverse and key-off operation
`Dual-mode cargo system
`Supportive sport-type front seating
`Dual-zone automatic climate control system with air ltration
`Briefcase-sized, locking center front console with dual-level storage
`60/40 split-folding at-folding rear seating
`7-speaker Acura Premium Sound System with multi-format 6-disc changer, AM/FM tuner, and XM® Satellite Radio receiver
`Driver's 8-way power seat with power-adjustable lumbar support
`Heated front seats
`Manual tilt and telescoping steering column
`HomeLink®
`MP3/auxiliary input jack
`Bluetooth® HandsFreeLink® connectivity
`2-position memory seat
`Auto-dimming rear view mirror
`
`Optional Technology Package
`
`Acura Navigation System with Voice Recognition™
`Rearview camera
`AcuraLink™ Satellite Communication System with real-time trafc
`10-speaker Acura/ELS Surround® Premium Sound System with multi-format DVD-Audio 6-disc changer, AM/FM tuner, and XM® Satellite
`Radio
`Multi-Information Display (MID) with steering wheel controls
`GPS-linked, solar-sensing, dual-zone, automatic climate control system
`
`SAFETY FEATURES
`
`Advanced Compatibility Engineering™ (ACE™) body structure
`Side impact door beams
`Impact-absorbing crumple zones (front/rear)
`Dual stage, dual threshold front airbags (SRS)
`Front side airbags with passenger-side Occupant Position Detection System (OPDS)
`Side curtain airbags for front and rear outboard seats with rollover sensor
`Active front head restraints
`3-point adjustable-height front seat belts with pretensioners and load limiters
`3-point seat belts at all three rear seating positions
`Automatic Locking Retractor/Emergency Locking Retractors (ALR/ELR) (excluding driver)
`LATCH (Lower Anchors and Tethers for Children) child-seat mounting system
`Tire Pressure Monitoring System (TPMS) with optional pressure readout
`4-wheel anti-lock braking system (ABS) with Electronic Brake Distribution (EBD) and Brake Assist
`Vehicle Stability Assist™ (VSA®) with traction control
`Mirror integrated LED directional signals
`All around visibility (276 degrees)
`Theft-deterrent system with electronic immobilizer
`
`ENGINE & POWERTRAIN
`
`The RDX is engineered to be a technical tour de force within the emerging Entry Premium SUV segment. Its engine and powertrain feature a host of
`new and updated technologies for Acura that deliver strong driving performance with good fuel economy and low emissions.
`
`RDX features Acura's rst application of a forced-induction engine. The all-new 2.3-liter aluminum engine features an advanced variable ow
`turbocharger designed to provide quick response at low rpm as well as strong high-rpm power. The advantage is immediate acceleration that drivers
`want in the city environment, together with 240 horsepower for the passing and hill-climbing ability of a traditional 6-cylinder engine. The RDX's
`
`https://acuranews.com/en-US/releases/release-91835d2fe2f4151ae54b37004c34bdfc-2008-acura-rdx-introduction#:~:text=2008 Acura RDX - Overvi… 2/23
`
`Hyundai Exhibit 1012, Page 15 of 44
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`2008 Acura RDX Press Kit
`
`turbocharged inline four produces 260 lb-ft. of torque. It also returns an EPA estimated 17/22* mpg (city/highway), while meeting tough CARB LEV
`II ULEV and EPA Tier-2 Bin-5 emissions standards.
`
`Acura's commitment to making the RDX fun to drive continues with a Sequential SportShift 5-speed automatic transmission with F1®-style paddle
`shifters. But perhaps the most breathtaking feature of the RDX is its Super Handling All-Wheel Drive™ (SH-AWD™). First introduced in the 2005
`Acura RL and then specially adapted for the RDX, the system deters understeer by shifting power to the outside rear wheel to help boost cornering
`power and steering precision. The level of handling response and driver control provided by SH-AWD puts the RDX in a class by itself.
`
`*Based on 2008 EPA mileage estimates, reecting new EPA fuel economy methods beginning with 2008 models. Use for comparison purposes only.
`Do not compare to models before 2008. Your actual mileage will vary depending on how you drive and maintain your vehicle.
`
`BODY & CHASSIS
`
`Betting its concept as an urban sports vehicle for young professional singles or couples, the RDX body design is powerful and athletic with
`muscular bodylines that impart a sense of command and control. Key styling elements include body sides that rake upward front to rear, large wheel
`arches that emphasize the big 18-inch wheels and tires, a short rear overhang, and a cargo door that's positioned ush with the bumper.
`
`Highlights include:
`
`Compact size that is well proportioned for maneuvering through city trafc and parking structures
`A high eye-point that allows an excellent outward eld of view
`Rigid unit body structure and independent suspension enhance steering precision and ride quality
`Low Noise, Vibration and Harshness (NVH) levels betting a luxury SUV
`
`Widespread use of high-tensile steel provides the rigidity necessary for the 4-wheel independent suspension system to work optimally while helping
`to reduce NVH. The RDX uses 39-percent (by weight) high-tensile steel to provide increased strength at a lower weight. Other engineering features
`include precise aerodynamic tuning that reduces drag and improves quietness inside the cabin. This tailoring includes a tailgate spoiler, rear wheel
`strakes, and aerodynamic side mirrors.
`
`The RDX rides on 4-wheel independent suspension with specially tuned MacPherson struts in front and a multi-link design in back. The mounting
`points for the suspension were carefully engineered to reduce the transmission of NVH into the passenger cabin. Standard 18-inch tires and wheels
`are a rst for Acura, and the 4-wheel disc brakes include a 4-wheel Anti-lock Braking System (ABS) with Electronic Brake Distribution (EBD) and
`Brake Assist. Torque-sensing power rack-and-pinion steering provides quick steering response with outstanding feel.
`
`INTERIOR
`
`A nely appointed urban loft apartment is the feel that Acura designers sought when crafting the RDX interior. The contemporary styling and high-
`quality materials are condent, functional and upscale. The driver-oriented cockpit includes a leather-wrapped steering wheel, LED backlit gauges
`with progressive illumination and a Multi-Information Display (MID) that allows access to multiple electronic functions. Among the advanced
`electronic technologies in the RDX is a standard 7-speaker Acura Premium Sound System with a multi-format 6-disc changer, AM/FM tuner and
`XM® Satellite Radio. A convenient auxiliary input jack makes it easy to connect an iPod® or other similar electronic devices to the audio system.
`
`The RDX seats ve and caters to the driver and front passenger rst and foremost. The RDX has an elevated eye-point that enhances the outward
`view. Its standard leather seating surfaces and ergonomically designed seat contours are designed to provide sedan-like comfort. The power driver's
`seat is 8-way adjustable with power adjustable lumbar support for a custom t.
`
`Besides exemplary comfort, interior roominess and cargo carrying were high priorities for RDX designers. The rear seats are highly versatile and
`permit a wide range of storage capabilities. With the 60/40 split-folding rear seats folded at, the rear cargo area offers up to 60.6 cubic feet of
`storage. Numerous interior storage compartments include a large lockable dual-level center console between the front seats. For greater passenger
`comfort, a dual-zone automatic climate control system is standard.
`
`Optional Technology Package
`
`The RDX is so well equipped that only one optional package is available. Appealing to audiophile and computer-savvy customers, the Technology
`Package makes the RDX truly "wired." The Technology Package includes a 10-speaker Acura/ELS Surround® Premium Sound System with multi-
`format 6-disc DVD-Audio changer, AM/FM tuner, and XM® Satellite Radio. The Technology Package also includes AcuraLink™ Satellite
`Communication System with real-time trafc, the Acura Navigation System with Voice Recognition™, rearview camera and a GPS-linked, solar-
`sensing, dual-zone, automatic climate control system. In total, these technologies put the RDX at the cutting edge of the Entry Premium SUV
`segment.
`
`SAFETY
`
`The 2008 RDX breaks ground in a number of important safety areas. Its ACE™ body structure makes the RDX compatible with smaller vehicles if a
`car-to-car frontal collision should occur, and it has a specially engineered hood and other components to reduce the chance of injury in the event of a
`collision with a pedestrian.
`
`Passive safety features include the latest dual-stage, dual-threshold airbag technology for the driver and front passenger, side airbags for the driver
`and front passenger, and side curtain airbags with rollover sensors for all outboard occupants. LATCH (Lower Anchors and Tethers for Children), a
`child-seat mounting system, makes it easy to quickly secure a child seat in the rear seats (see Safety section for more details).
`
`ENGINEERING & MANUFACTURING
`
`The RDX is the rst Acura light truck to be assembled in Honda of America Manufacturing's facility in Marysville, Ohio, the same factory that
`produces the Acura TL. As a result, it now brings light-truck production capacity and even greater versatility to the Marysville, Ohio plant. In
`addition, RDX represents the rst time that an American engineer has headed a Japanese development team in developing a new Acura vehicle.
`https://acuranews.com/en-US/releases/release-91835d2fe2f4151ae54b37004c34bdfc-2008-acura-rdx-introduction#:~:text=2008 Acura RDX - Overvi… 3/23
`
`Hyundai Exhibit 1012, Page 16 of 44
`Hyundai Motor Company v. Mel Navip LLC
`IPR2024-00173
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`

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`10/12/23, 12:18 PM
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`2008 Acura RDX Press Kit
`
`Producing both an SUV and a sedan on the same assembly line requires additional exibility because of dimensional differences (in particular the
`height and width of the RDX rear section). The assembly process in Marysville was optimized for workers installing the overhead rear hatch, to
`minimize overhead lifting and reaching. In addition, the assembly plant was modied to accommodate the installation of the RDX's SH-AWD™
`system. This was necessary due to the additional components such as the rear propeller shaft and rear differential.
`
`ACCESSORIES
`
`A host of attractive Genuine Acura Accessories were developed simultaneously with the RDX. Like all Genuine Acura Accessories, the upgrades are
`covered by the RDX's 4-year, 50,000-mile basic warranty when purchased with the vehicle or 12 months/12,000 miles when purchased separate
`from the vehicle.
`
`2 0 0 8 A c u r a R D X - P o w e r t r a i n
`
`POWERTRAIN
`
` Acura's new RDX shares much in concept with the TSX. Though one is an SUV and the other is a sports sedan, both
`
`vehicles are designed to blend strong performance with agility and precise handling. The unique positioning of this new Entry Premium SUV within
`the Acura product line guided the development of a special powertrain for the RDX. A conventional 4-cylinder engine would lack the horsepower
`and torque needed to make the RDX a strong performer. On the other hand, a 6-cylinder would add extra weight.
`
`A perfect solution came in the form of a turbocharger - a rst for an Acura production vehicle. The RDX has an innovative new variable ow
`turbocharger that overcomes the shortcomings of conventional turbo designs and delivers an unusually broad powerband with little or no lag in
`throttle response. In addition, Acura's turbo design provides this benet with high reliability. This is because airow is controlled before it enters the
`turbocharger, rather than within the turbocharger as in traditional variable-ow designs. Acura's variable ow turbo design thus eliminates moving
`components that work directly in the stream of hot exhaust gases.
`
`Architecturally similar to th