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`
`
`IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________
`
`
`META PLATFORMS, INC.,
`Petitioner
`
`v.
`
`SITNET, LLC,
`Patent Owner
`
`___________________
`
`Case IPR2024-00531
`U.S. Patent No. 11,470,682
`___________________
`
`DECLARATION OF DR. JEREMY COOPERSTOCK IN SUPPORT OF
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO.
`11,470,682
`
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`Meta EX1003
`IPR2024-00531
`U.S. Patent No. 11,470,682
`
`

`

`Case IPR2024-00531
`U.S. Patent No. 11,470,682
`
`TABLE OF CONTENTS
`
`I.
`
`INTRODUCTION .......................................................................................... 1
`
`II. MY BACKGROUND AND QUALIFICATIONS ......................................... 1
`
`III.
`
`SUMMARY OF OPINIONS .......................................................................... 5
`
`IV. MATERIALS CONSIDERED ....................................................................... 6
`
`V.
`
`LEGAL UNDERSTANDING ........................................................................ 7
`
`A. My Understanding of Claim Construction............................................ 7
`
`B. My Understanding of Obviousness....................................................... 8
`
`C.
`
`A Person of Ordinary Skill in the Art ................................................. 11
`
`VI. OVERVIEW OF THE ’682 PATENT .......................................................... 12
`
`VII. OVERVIEW OF THE TECHNOLOGY ...................................................... 13
`
`A.
`
`Sharing Information Items Related to Events ..................................... 14
`
`1.
`
`2.
`
`Emergency Warning Systems................................................... 15
`
`Event Planning Systems ........................................................... 19
`
`Roll Calls Related to an Event ............................................................ 20
`
`Sharing Situational Statuses with Concerned Parties using a Message
`Board ................................................................................................... 25
`
`B.
`
`C.
`
`VIII. PROSECUTION HISTORY ......................................................................... 29
`
`IX. LEVEL OF ORDINARY SKILL IN THE ART .......................................... 29
`
`X.
`
`CLAIM CONSTRUCTION .......................................................................... 30
`
`XI. OVERVIEW OF THE PRIOR ART ............................................................. 31
`
`A.
`
`B.
`
`C.
`
`D.
`
`E.
`
`Burfeind .............................................................................................. 31
`
`Crowley ............................................................................................... 35
`
`Smith ................................................................................................... 36
`
`Sinha ................................................................................................... 37
`
`Gage .................................................................................................... 38
`
`XII. GROUND 1: BURFEIND AND CROWLEY RENDERS OBVIOUS
`CLAIMS 1-20. .............................................................................................. 40
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`A. A POSA would have found it obvious to combine Burfeind and
`Crowley. .............................................................................................. 40
`
`B.
`
`Independent Claim 1. .......................................................................... 48
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`[1.P]: A server for providing roll call based information, the
`server comprising: .................................................................... 48
`
`[1.1] a network controller configured to: receive an information
`item from a user device, wherein the information item identifies
`a situation; ................................................................................ 49
`
`[1.2] make the information item available to a first plurality of
`user devices; ............................................................................. 53
`
`[1.3] a central processing unit, coupled to the network
`controller, configured to verify that the information item is
`related to the situation; ............................................................. 56
`
`[1.4] in response to the verifying, make a message board related
`to the situation available to a second plurality of user devices;
` .................................................................................................. 63
`
`[1.5] wherein the second plurality of user devices was identified
`based on
`the second plurality of user devices being
`geographically proximate to the situation; ............................... 68
`
`[1.6] wherein the message board comprises a roll call list that
`includes status responses to roll call queries that were provided
`to the second plurality of user devices in order to solicit the
`status responses. ....................................................................... 70
`
`C.
`
`D.
`
`E.
`
`F.
`
`G.
`
`H.
`
`I.
`
`J.
`
`K.
`
`L.
`
`Independent Claim 11 ......................................................................... 71
`
`Claim 2 ................................................................................................ 72
`
`Claim 3 ................................................................................................ 74
`
`Claim 4 ................................................................................................ 77
`
`Claim 5 ................................................................................................ 81
`
`Claim 6 ................................................................................................ 83
`
`Claim 7 ................................................................................................ 84
`
`Claim 8 ................................................................................................ 86
`
`Claims 9 and 10 .................................................................................. 88
`
`Dependent Claims 12-20 .................................................................... 89
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`- ii -
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`

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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`XIII. GROUND 2: SMITH IN VIEW OF SINHA RENDERS OBVIOUS
`CLAIMS 1-8 AND 11-18. ............................................................................ 90
`
`A. A POSA would have found it obvious to combine Smith and Sinha. 90
`
`B.
`
`Independent Claim 1 ........................................................................... 99
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`[1.P]: A server for providing roll call based information, the
`server comprising: .................................................................... 99
`
`[1.1] a network controller configured to: receive an information
`item from a user device, wherein the information item identifies
`a situation; .............................................................................. 101
`
`[1.2] make the information item available to a first plurality of
`user devices; ........................................................................... 102
`
`[1.3] a central processing unit, coupled to the network
`controller, configured to verify that the information item is
`related to the situation; ........................................................... 103
`
`[1.4] in response to the verifying, make a message board related
`to the situation available to a second plurality of user devices;
` ................................................................................................ 105
`
`[1.5] wherein the second plurality of user devices was identified
`based on
`the second plurality of user devices being
`geographically proximate to the situation; ............................. 108
`
`[1.6] wherein the message board comprises a roll call list that
`includes status responses to roll call queries that were provided
`to the second plurality of user devices in order to solicit the
`status responses. ..................................................................... 110
`
`C.
`
`D.
`
`E.
`
`F.
`
`G.
`
`H.
`
`I.
`
`J.
`
`Independent Claim 11 ....................................................................... 114
`
`Claim 2 .............................................................................................. 115
`
`Claim 3 .............................................................................................. 116
`
`Claim 4 .............................................................................................. 117
`
`Claim 5 .............................................................................................. 122
`
`Claim 6 .............................................................................................. 122
`
`Claim 7 .............................................................................................. 125
`
`Claim 8 .............................................................................................. 126
`
`K. Dependent Claims 12-18 .................................................................. 128
`
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`XIV. GROUND 3: SMITH IN VIEW OF SINHA AND FURTHER IN VIEW OF
`GAGE RENDERS OBVIOUS CLAIMS 9-10 AND 19-20. ...................... 128
`
`ITS
`IS ENTITLED TO THE PRIORITY DATE OF
`XV. SINHA
`PROVISIONAL. ......................................................................................... 132
`
`XVI. CONCLUSION ........................................................................................... 144
`
`
`
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`- iv -
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
`
`I, Jeremy Cooperstock, hereby declare as follows.
`
`I.
`
`INTRODUCTION
`
`1.
`
`I have been retained as an expert witness on behalf of Petitioner Meta
`
`Platforms, Inc. (“Petitioner”) for the above-captioned inter partes review (IPR). I
`
`am being compensated for my time in connection with this IPR at my standard
`
`consulting rate.
`
`2.
`
`I understand that this declaration accompanies a petition for IPR
`
`involving U.S. Patent No. 11,470,682 (“the ’682 patent”) (EX1001), which
`
`resulted from U.S. Patent Application No. 16/730,339 (“the ’339 application”),
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`filed on December 30, 2019. I understand that the ’339 patent alleges a priority
`
`date of February 2, 2007. I refer to this date throughout this declaration.
`
`3.
`
`In preparing this declaration, I have reviewed the ’682 patent and each
`
`of the documents cited herein, in light of general knowledge in the art before
`
`February 2, 2007. In formulating my opinions, I have relied upon my experience,
`
`education, and knowledge in the relevant art. In formulating my opinions, I have
`
`also considered the viewpoint of a person of ordinary skill in the art (“POSA”)
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`(i.e., a person of ordinary skill in the field of telecommunications and computer
`
`networking prior to February 2, 2007.
`
`II. MY BACKGROUND AND QUALIFICATIONS
`
`4.
`
`I am a professor in the Department of Electrical and Computer
`
`
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`- 1 -
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`Engineering at McGill University. My Curriculum Vitae is attached as Exhibit
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
`
`1018.
`
`5.
`
`I received my B.A.Sc. in Electrical Engineering (with Honors) from
`
`the University of British Columbia in 1990, my M.Sc. in Computer Science from
`
`the University of Toronto in 1992, and my Ph.D. in Electrical and Computer
`
`Engineering from the University of Toronto in 1996.
`
`6.
`
`I have been employed at McGill University since November 2017,
`
`where I am currently a Full Professor in the Department of Electrical and
`
`Computer Engineering. In this capacity, I conduct and supervise research activities,
`
`and teach courses at the upper undergraduate and graduate level on human-
`
`computer interaction, artificial intelligence, embedded systems, and haptic
`
`interaction design.
`
`7.
`
`I am a member of the Centre for Intelligent Machines, a founding
`
`member of the Centre for Interdisciplinary Research in Music Media and
`
`Technology, a member of the International Laboratory on Learning System, a
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`member of the McGill Institute for Aerospace Engineering, and an associate
`
`member of Biomedical Engineering at McGill University. I presently direct a
`
`group of approximately 50 researchers at the Shared Reality Lab at McGill, which
`
`focuses on computer mediation to facilitate high-fidelity human communication
`
`and the synthesis of perceptually engaging, multimodal, immersive environments.
`
`
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`Among other projects, I led the development of the Intelligent Classroom, a high-
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`fidelity orchestra rehearsal simulator, a simulation environment that renders
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`graphic, audio, and vibrotactile effects in response to footsteps, and a mobile game
`
`treatment for amblyopia.
`
`8.
`
`I have been developing and working with network media distribution
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`technologies since 1990, and I led the world’s first demonstrations of high-fidelity
`
`multichannel audio streaming over the Internet in 1999 and 2000, followed by
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`multiple simultaneous streams of uncompressed high-definition video in 2005. My
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`work on the Ultra-Videoconferencing system was recognized by an award for Most
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`Innovative Use of New Technology from ACM/IEEE Supercomputing and a
`
`Distinction Award from the Audio Engineering Society. The research I supervised
`
`on the Autour project earned the Hochhausen Research Award from the Canadian
`
`National Institute for the Blind and an Impact Award from the Canadian Internet
`
`Registry Association, and my Real-Time Emergency Response project won the
`
`Gold Prize (brainstorm round) of the Mozilla Ignite Challenge. I am also a
`
`recipient of several “best paper” awards from scholarly societies for my research.
`
`9.
`
`I have carried out significant research involving network
`
`communication protocols, including wireless communication employing IEEE
`
`802.11 (WiFi) and IEEE 802.15 (Bluetooth). My experience in these areas includes
`
`development of the Adaptive File Distribution Protocol (AFDP, 1995), analysis of
`
`
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`the tradeoffs between bandwidth, power demands, and latency for audio streaming
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`over WiFi, Bluetooth, and ultra-wideband protocols (2007), and assessment of the
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`performance and scalability of wireless audio streaming for applications requiring
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`latency-optimized multimedia streaming (2008).
`
`10.
`
`I have led all aspects of development and experimentation in the
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`Autour project (2009-2016), which employs a combination of wireless
`
`communication protocols, and manages authentication for communication between
`
`clients and server, in addition to third-party information services. I have supervised
`
`a variety of projects that require sharing of WiFi network access credentials across
`
`multiple devices. I led a research project (MIMIC), which communicates sensor
`
`data between two coupled smartwatches using Bluetooth for local communication
`
`between the smartwatches and their peered smartphones, and the public Internet
`
`between the smartphones. I also led a project that uses both Bluetooth and WiFi
`
`communication between smartphones, a GPU-based physics engine, and a
`
`microelectronics architecture that renders vibrotactile effects on mobile footwear.
`
`11.
`
`I have worked with IBM at the Haifa Research Center, Israel, and the
`
`Watson Research Center in Yorktown Heights, New York, the Sony Computer
`
`Science Laboratory in Tokyo, Japan, and was a visiting professor at Bang &
`
`Olufsen, Denmark, where I conducted research on telepresence technologies as
`
`part of the World Opera Project. I led the theme of Enabling Technologies for a
`
`
`
`- 4 -
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`Networks of Centres of Excellence on Graphics, Animation, and New Media
`
`(GRAND) and I am an associate editor of the Frontiers Journal in Virtual Reality,
`
`and the Institute of Electrical and Electronics Engineers (IEEE) Transactions on
`
`Haptics, and previously, the Journal of the AES.
`
`III. SUMMARY OF OPINIONS
`
`12.
`
`In forming my opinions about the ’682 patent, I have considered the
`
`following grounds of unpatentability. Based on my review of the prior art
`
`references that form the basis of these grounds, it is my opinion that claims 1-20 of
`
`the ’682 patent would have been obvious to a POSA prior to February 2, 2007.
`
`Ground
`
`Basis
`
`Claims
`
`References
`
`1
`
`2
`
`3
`
`§103
`
`§103
`
`§103
`
`1-20
`
`Burfeind-Crowley
`
`1-8, 11-18
`
`Smith-Sinha
`
`9-10, 19-20
`
`Smith-Sinha-Gage
`
`13.
`
`I have been asked to consider how a POSA would have understood
`
`the challenged claims in light of the disclosures of the ’682 patent. I have also been
`
`asked to consider how a POSA would have understood the prior art references
`
`Burfeind, Crowley, Smith, Sinha, and Gage.
`
`14. Further, I have been asked to consider and provide my technical
`
`review, analysis, insights, and opinions regarding whether a POSA would have
`
`understood that the combinations of the prior art references listed in the table
`
`
`
`- 5 -
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`above render obvious claims 1-20 of the ’682 patent.
`
`IV. MATERIALS CONSIDERED
`
`15.
`
`In formulating my opinions, I have relied upon my training,
`
`knowledge, and experience that are relevant to the ’682 patent. I have also
`
`reviewed and am familiar with the following documents and materials in addition
`
`to any other documents cited in this declaration:
`
`Exhibit No.
`
`Description
`
`1001
`
`U.S. Patent No. 11,470,682 to Cona et al. (“’682 patent”)
`
`1002
`
`1004
`
`1005
`
`1006
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`Prosecution History of U.S. Patent No. 11,470,682 (“’682 File
`History”)
`
`U.S. Publication No. 2007/0233635 to Burfeind et al. (“Burfeind”)
`
`U.S. Publication No. 2006/0270419 to Crowley et al. (“Crowley”)
`
`U.S. Publication No. 2005/0197775 to Smith (“Smith”)
`
`U.S. Publication No. 2008/0208605 to Sinha et al. (“Sinha”)
`
`U.S. Provisional Application No. 60/862,365 to Sinha et al.
`(“Sinha Provisional”)
`
`U.S. Publication No. 2008/0139165 to Gage et al. (“Gage”)
`
`U.S. Publication No. 2003/0197615 to Roche et al. (“Roche”)
`
`U.S. Patent Application Publication No. 2007/0194938 to Mitchell
`(“Mitchell”)
`
`1012
`
`U.S. Publication No. 2006/0273893 to Warner (“Warner”)
`
`1013
`
`1014
`
`1015
`
`1016
`
`1017
`
`Japanese Patent Application Publication 2005-80211 to Ikeda
`(with certified English translation) (“Ikeda”)
`
`U.S. Publication No. 2003/0162557 to Shida (“Shida”)
`
`U.S. Patent No. 8,024,330 to Franco et al. (“Franco”)
`
`U.S. Patent No. 7,817,982 to Chu et al. (“Chu”)
`
`U.S. Publication No. 2006/0047825 to Steenstra et al. (Steenstra”)
`
`
`
`- 6 -
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`Exhibit No.
`
`Description
`
`1018
`
`Curriculum Vitae of Dr. Jeremy Cooperstock
`
`16. To the best of my knowledge, the above-mentioned documents and
`
`materials are true and accurate copies of what they purport to be. An expert in the
`
`field would reasonably rely on them to formulate opinions such as those set forth
`
`in this declaration.
`
`V. LEGAL UNDERSTANDING
`
`17.
`
`I have also relied upon various legal principles (as explained to me by
`
`counsel) in formulating my opinions. My understanding of these principles is
`
`summarized below.
`
`A. My Understanding of Claim Construction
`
`18.
`
`I understand that during an inter partes review proceeding, claims are
`
`to be construed in light of the specification as would be read by a person of
`
`ordinary skill in the relevant art at the time the application was filed. I understand
`
`that claim terms are given their ordinary and customary meaning as would be
`
`understood by a person of ordinary skill in the relevant art in the context of the
`
`entire disclosure. A claim term, however, will not receive its ordinary meaning if
`
`the patentee acted as his own lexicographer and clearly set forth a definition of the
`
`claim term in the specification. In this case, the claim term will receive the
`
`definition set forth in the patent.
`
`19.
`
`I also understand that claims may be expressed as a means or step for
`
`
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`performing a specified function without the recital of structure, material, or acts
`
`that support this function. These claims are construed to cover the corresponding
`
`structure, material, or acts described in the specification, and equivalents.
`
`Construing these so-called “means-plus-function” claims requires looking to the
`
`specification and interpreting the claim language in light of the corresponding
`
`structure, material, or acts described in the specification.
`
`20.
`
`I further understand that the use of the phrases “means for” or “step
`
`for” followed by a function triggers a presumption that the relevant term falls
`
`under means-plus-function claiming. I also understand that the absence of these
`
`terms triggers a presumption that the relevant term does not recite a means-plus-
`
`function term. This presumption can be overcome if the claim term does not recite
`
`sufficient structure, material, or acts to perform the relevant function.
`
`B. My Understanding of Obviousness
`
`21.
`
`I understand that a patent claim is invalid if the claimed invention
`
`would have been obvious to a POSA at the time the application was filed. This
`
`means that even if all of the requirements of the claim cannot be found in a single
`
`prior art reference that would anticipate the claim, the claim can still be invalid.
`
`22. To obtain a patent, a claimed invention must have, as of the priority
`
`date, been nonobvious in view of the prior art in the field. I understand that an
`
`invention is obvious when the differences between the subject matter sought to be
`
`
`
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`patented and the prior art are such that the subject matter as a whole would have
`
`been obvious to a POSA at the time the invention was made.
`
`23.
`
`I understand that to prove that prior art or a combination of prior art
`
`renders a patent obvious, it is necessary to:
`
`(1) identify the particular references that, singly or in combination, render
`
`the patent obvious;
`
`(2) specifically identify which elements of the patent claim appear in each of
`
`the asserted references; and
`
`(3) explain how the prior art references could have been combined in order
`
`to create the inventions claimed in the asserted claim.
`
`24.
`
`I also understand that prior art references can be combined under
`
`several different circumstances. For example, it is my understanding that one such
`
`circumstance is when a proposed combination of prior art references results in a
`
`system that represents a predictable variation, which is achieved using prior art
`
`elements according to their established functions.
`
`25.
`
`I also understand that when considering the obviousness of a patent
`
`claim, one should consider whether a teaching, suggestion, or motivation to
`
`combine the references exists so as to avoid impermissibly applying hindsight
`
`when considering the prior art. I understand this test should not be rigidly applied,
`
`but that the test can be important to avoid such hindsight.
`
`
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`26.
`
`I understand that certain objective indicia can be important evidence
`
`as to whether a patent is obvious or nonobvious. Such indicia include:
`
`(1) commercial success of products covered by the patent claims; (2) a long-felt
`
`need for the invention; (3) failed attempts by others to make the invention;
`
`(4) copying of the invention by others in the field; (5) unexpected results achieved
`
`by the invention as compared to the closest prior art; (6) praise of the invention by
`
`the infringer or others in the field; (7) the taking of licenses under the patent by
`
`others; (8) expressions of surprise by experts and those skilled in the art at the
`
`making of the invention; and (9) the patentee proceeded contrary to the accepted
`
`wisdom of the prior art.
`
`27. At this point, I am not aware of any secondary indicia of non-
`
`obviousness. But, I reserve the right to review and opine on any evidence of
`
`objective indicia of nonobvious that may be presented during this proceeding.
`
`28.
`
`I also understand that “obviousness” is a legal conclusion based on the
`
`underlying factual issues of the scope and content of the prior art, the differences
`
`between the claimed invention and the prior art, the level of ordinary skill in the
`
`prior art, and any objective indicia of non-obviousness.
`
`29. For that reason, I am not rendering a legal opinion on the ultimate
`
`legal question of obviousness. Rather, my testimony addresses the underlying facts
`
`and factual analysis that would support a legal conclusion of obviousness or non-
`
`
`
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`

`

`obviousness, and when I use the term obvious, I am referring to the perspective of
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`one of ordinary skill at the time of invention.
`
`C. A Person of Ordinary Skill in the Art
`
`30.
`
`I understand that a person of ordinary skill in the relevant art
`
`(“POSA”) is presumed to be aware of all pertinent art, thinks along conventional
`
`wisdom in the art, and is a person of ordinary creativity—not an automaton.
`
`31.
`
`I have been asked to consider the level of ordinary skill in the field
`
`that someone would have had at the time the claimed invention was made. In
`
`deciding the level of ordinary skill, I considered the following:
`
`• the levels of education and experience of persons working in the
`
`field;
`
`• the types of problems encountered in the field; and
`
`• the sophistication of the technology.
`
`32. My opinion below explains how a POSA would have understood the
`
`technology described in the references I have identified herein around the February
`
`2, 2007 timeframe, which I have been advised is the earliest possible effective
`
`filing date for the ’682 patent. However, my opinions herein would not be affected
`
`if the ’682 patent is found to only be entitled to a later effective filing date.
`
`33. Regardless of whether I use “I” or a “POSA” during my technical
`
`analysis below, all of my statements and opinions are always to be understood to
`
`
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`be based on how a POSA would have understood or read a document at the time of
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`Case IPR2024-00531
`U.S. Patent No. 11,470,682
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`the alleged invention.
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`VI. OVERVIEW OF THE ’682 PATENT
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`34. The ’682 patent is directed to a “network system for accessing
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`situation related information.” EX1001, Abstract. The claimed embodiments are
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`directed to a “system [that] includes a network connection for receiving an
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`indication of an occurrence of a situation.” EX1001, Abstract. The ’682 patent
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`describes the claimed “situation” broadly, stating that situations include social
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`events, emergency events, weather phenomena, natural disasters, etc. E.g.,
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`EX1001, 5:1-16, 31:55-65. Situations also include “weather related activities, such
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`as skiing or surfing.” EX1001, 5:1-16.
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`35. The system then “present[s] a roll call query” to a “plurality of
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`participant devices” located proximate to the situation, “soliciting a reply related to
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`a status of the participant.” EX1001, Abstract. The participant devices provide
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`“status responses” to the system, which aggregates the status responses “into a roll
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`call list” that specifies statuses of the participant devices located proximate to the
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`event. EX1001, Abstract.
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`36. The system also “provide[s] a searchable message board” to the
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`participant devices “as well [as] visitors.” EX1001, 27:38-44. The message board
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`“allows sharing of information about individuals,” such as by “post[ing] comments
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`viewable by the participants.” EX1001, 27:38-50. The “message board [] may be
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`accessible by a website on the internet.” EX1001, 27:53-55. “A visitor to the
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`website can search [] the message board for information related to a specific
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`situation or event.” EX1001, 27:55-57. As shown in Figure 33 below, the website
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`providing the message board also includes a “link” to “the most recent roll-call
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`list” for the situation. EX1001, 27:67-28:2.
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`EX1001, FIG. 33.
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`
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`VII. OVERVIEW OF THE TECHNOLOGY
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`37. As I explained above, the ’682 patent describes systems and
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`techniques “for accessing situation related information.” EX1001, Abstract. The
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`claims of the ’682 patent recite general concepts, such as receiving “an information
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`item” that “identifies a situation,” making the information item available to a “first
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`plurality of user devices,” and making a “message board related to the situation
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`available to a second plurality of devices” based on the geographic proximity of
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`those user devices to the situation. The message board includes “a roll call list that
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`includes status responses to roll call queries that were provided to the second
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`plurality of user devices.” These concepts were well known before the ’682
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`patent’s earliest possible priority date. For instance, systems for sharing
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`information items related to situations or events were well known. Similarly, it was
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`known to make message boards available to users so that the users could share
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`additional information related to the situation.
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`A.
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`Sharing Information Items Related to Events
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`38. As I explained, the ’682 patent claims broadly require receiving an
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`information item that identifies a situation, and making the information item
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`available to a plurality of user devices. I note that the claims do not require any
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`particular manner in which the information item is received or made available to
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`the user devices. These broad, conceptual claim elements were well known prior to
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`the ’682 patent. For instance, such claimed elements were commonly found in
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`emergency warning systems and event planning systems.
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`1.
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`Emergency Warning Systems
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`39.
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`It was known for emergency warning systems to receive information
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`items describing emergency events from users near the events, and to use that
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`information to warn other nearby users of the event. For instance, Franco discloses
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`an “incident alert system” in which “[a] user uses a networked mobile phone with
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`geo-positioning capability to communicate with a server to report incidents…
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`based on the user’s current geographic position.” EX1015, Abstract. “Reports of
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`incidents are transmitted to the server accompanied by the current position of the
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`user/mobile phone.” EX1015, Abstract. The server then reports the information
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`related to the incident to certain users within a “zone of interest” near the incident.
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`EX1015, 2:17-25, 3:7-28, FIG. 1.
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`EX1015, FIG. 1.
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`
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`40. Franco thus capitalized on the intuitive idea that “facilitating
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`information sharing based on users’ geographic locations… significantly opens the
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`opportunities for individuals to be Good Samaritans by informing others of hazards
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`or by responding to urgent requests for assistance by others in need.” EX1015,
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`1:53-58. Indeed, this confirms my opinion that the claimed concepts of sharing
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`information items related to situations were well known and would have been
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`readily appreciable by a POSA in the relevant time frame.
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`41. As another example, Shida is directed to a system for confirming the
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`safety of persons upon the occurrence of a disaster. EX1014, Abstract. When a
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`disaster occurs, a reporting subscriber terminal (e.g., user device) generates and
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`transmits a disaster occurrence report to a “carrier server,” which in turn transmits
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`“disaster information included in the disaster occurrence report” to a “center
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`server.” EX1014, ¶¶33, 37, FIG. 1. The center server then determines “the
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`subscribers… who should be informed of the occurred disaster.” EX1014, ¶46.
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`Specifically, “the subscribers to be notified are subscribers who exist in the disaster
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`occurring region,” as specified by a “disaster region subscriber table” stored at the
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`center server. EX1014, ¶¶39, 46.
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`EX1014, FIG. 1.
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`
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`42. The center server “generates notice information” related to the
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`disaster “and transmits it to the subscribers to be notified.” EX1014, ¶46. “The
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`subsc