Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 1 of 120 PageID #: 12543
`Case 5:19-cv-00036—RWS Document 348-12 Filed 06/18/20 Page 1 of 120 PageID #: 12543
`
`EXHIBIT 29
`
`EXHIBIT 29
`
`

`

`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 2 of 120 PageID #: 12544
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`Invalidity of U.S. Patent No. 6,748,317
`by
`U.S. Patent No. 6,067,502 to Hayashida (“Hayashida”)
`
`U.S. Patent No. 6,748,317 (the “’317 Patent”) was filed May 5, 2003 and issued June 8, 2004. The ’317 Patent claims priority to JP11-
`197010, filed July 12, 1999. For the purposes of these invalidity contentions, Defendant applies the July 12, 1999 priority date for the
`’317 Application. However, Defendant reserves the right to contest Plaintiff’s reliance on the July 12, 1999 priority date should the
`priority date become an issue in this proceeding.
`
`The excerpts cited herein are exemplary. For any claim limitation, Defendant may rely on excerpts cited for any other limitation and/or
`additional excerpts not set forth fully herein to the extent necessary to provide a more comprehensive explanation for a reference’s
`disclosure of a limitation. Where an excerpt refers to or discusses a figure or figure items, that figure and any additional descriptions
`of that figure should be understood to be incorporated by reference as if set forth fully therein.
`
`Except where specifically noted otherwise, this chart applies the apparent constructions of claim terms as used by Plaintiff in its
`infringement contentions; such use, however, does not imply that Defendant adopts or agrees with Plaintiff’s constructions in any way.
`
`U.S. Patent No. 6,067,502 to Hayashida (“Hayashida”) was filed August 21, 1997 and issued May 23, 2000. Hayashida therefore
`qualifies as prior art with regard to the ’317 patent under 35 U.S.C. § 102(e) (pre-AIA).
`
`JPH05-264711 (“the ’711 Patent”) published on October 12, 1993 and therefore qualifies as prior art with regard to the ’317 patent
`under 35 U.S.C. § 102(b).1
`
`JPH10-197277 to Maruyama et al. (“Maruyama”) published on July 31, 1998 and therefore qualifies as prior art with regard to the
`’317 Patent under at least 35 U.S.C. § 102(a).
`
`Upon information and belief, the Cyberguide system was made publicly available at least as early as September of 1996. The features
`and functionalities of the NavTalk product are described in A Mobile Context-Aware Tour Guide by Abowd et al. (“Abowd”). Because
`the Cyberguide product itself was known and used by others prior to the ‘317 Patent’s priority date, it constitutes prior art under 35
`
`
`OMM_US:77143848.1
`
`
`1 Defendant relies on a machine translation of this foreign reference, but will supplement these contentions upon receipt of a certified
`English translation.
`
`1
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 3 of 120 PageID #: 12545
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`U.S.C. § 102(a) (pre-AIA). Defendant reserves the right to supplement its theories with additional discovered details describing the
`features and functionalities of the Cyberguide product that were known or used by others prior to the ‘317 Patent’s priority date.
`Additionally, because Abowd published on September 23, 1996, it independently constitutes prior art under 35 U.S.C. § 102(b).
`
`Upon information and belief, the Garmin NavTalk (the “NavTalk”) was made publicly available in January of 1999. The features and
`functionalities of the NavTalk product are described in the NavTalk Owner’s Manual and Reference Guide (Rev. A). Because the
`NavTalk product itself was known and used by others prior to the ‘317 Patent’s priority date, it constitutes prior art under 35 U.S.C. §
`102(a) (pre-AIA). Defendant reserves the right to supplement its theories with additional discovered details describing the features and
`functionalities of the NavTalk product that were known or used by others prior to the ‘317 Patent’s priority date. Additionally, because
`the NavTalk Owner’s Manual and Reference Guide is a printed publication that was publicly available prior to the ‘317 Patent’s priority
`date, it independently constitutes prior art under 35 U.S.C. § 102(a) (pre-AIA).
`
`Upon information and belief, the Seiko Epson Locatio (the “Locatio”) was made publicly available in June of 1999. Therefore, the
`Locatio qualifies as prior art with regard to the ’317 patent under 35 U.S.C. § 102(a).
`
`U.S. Patent No. 5,781,150 to Norris (“Norris”) was filed on October 13, 1995 and issued on July 14, 1998 and therefore qualifies as
`prior art with regard to the ’317 patent under at least 35 U.S.C. § 102(e) and (a).
`
`U.S. Patent No. 6,525,768 to Obradovich (“Obradovich”) was filed on October 21, 1999 and issued February 25, 2003. Obradovich
`claims the benefit of Provisional Application 60/105/050 and therefore qualifies as prior art to the ’317 Patent under 35 U.S.C. § 102(e).
`
`Akiyama published on November 1, 1996. Akiyama therefore qualifies as prior art with regard to the ’317 patent under 35 U.S.C. §
`102(b) (pre-AIA).
`
`Hayashida anticipates Claims 1, 2, 3, 5-9, 15, and 17 under 35 U.S.C. § 102.
`
`Hayashida (or Hayashida in view of Want/the Cyberguide) renders Claims 6-9 obvious 35 U.S.C. § 103.
`
`Hayashida (or Hayashida in view of Want/the Cyberguide) in view of the Cyberguide/Maruyama renders Claims 6-9 obvious 35 U.S.C.
`§ 103.
`
`Hayashida (or Hayashida in view of Want/the Cyberguide) renders Claims 1, 2, 3, 5, 15, and 17 obvious 35 U.S.C. § 103.
`
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`OMM_US:77143848.1
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 4 of 120 PageID #: 12546
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`Hayashida (or Hayashida in view of Want/the Cyberguide) in view of Akiyama renders Claim 5 obvious 35 U.S.C. § 103.
`
`Hayashida (or Hayashida in view of Want/the Cyberguide) in view of the Locatio/Maruyama renders Claims 15 and 17 obvious 35
`U.S.C. § 103.
`
`Hayashida (or Hayashida in view of Want/the Cyberguide) in view of the Locatio/Maruyama in further view of the ’711 Patent renders
`Claim 17 obvious 35 U.S.C. § 103.
`
`Hayashida (or Hayashida in view of Want/the Cyberguide) in view of Norris/Maruyama/the Locatio/the Cyberguide/the
`NavTalk/Obradovich renders Claims 10, 11, 12, 13, 14, and 18 obvious 35 U.S.C. § 103.
`
`Hayashida (or Hayashida in view of Want/the Cyberguide) in view of Norris/Maruyama/the Locatio/the Cyberguide/the
`NavTalk/Obradovich in further view of Akiyama renders Claim 14 obvious 35 U.S.C. § 103.
`
`Hayashida (or Hayashida in view of Want/the Cyberguide) in view of Norris/Maruyama/the Locatio/the Cyberguide/the
`NavTalk/Obradovich in further view of the NavTalk/Maruyama renders Claim 18 obvious 35 U.S.C. § 103.
`
`
`U.S. Patent No. 6,748,317
`Claim 1
`1[P]. A portable
`comprising:
`
`terminal,
`
`OMM_US:77143848.1
`
`
`Hayashida
`
`To the extent the preamble is limiting, Hayashida discloses a portable terminal.
`
`
`This invention is related to a map display device to guiding and searching a
`movement route of a vehicle based on a map information, especially this
`invention is relate with the improvement of the display of the map information.
`Hayashida at 1:5-8.
`
`
`Then this navigation processing can be also executed by this computer device,
`if the device which can detect the present position by GPS reception device 25
`and this information memory part 37 are connected with the carrying-type
`computer device. Moreover this invention can be applied as the vehicle except
`the car and the navigation device of the shipping, the aircraft and the map
`which is used for the navigation may be a chart and a submarine map and so
`on in addition to the road map. Moreover again this invention may be applied
`3
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`

`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 5 of 120 PageID #: 12547
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`to the carrying-type navigation device in addition to the navigation device
`which is attached to the movement bodies such as the car. In other words, this
`invention may be applied to the small navigation device which can be
`accompanied by the human and which is used in a cycling, a travel, a
`mountaineering, a hike, a fishing or so on.
`Hayashida at 76:5-20.
`
`To the extent this limitation is governed by 35 U.S.C. § 112(6), and based on Defendant’s
`understanding of Plaintiff’s infringement contentions, Hayashida discloses a device (i.e., CPU 2
`and present position detector 20, including GPS receiver unit 25 and beacon receiver unit 26) that
`perform the claimed function of getting location information denoting a present place of said
`portable terminal.
`
`
`FIG. 1 illustrates the overall circuitry of the navigation device. A central
`processor 1 controls the operation of the whole navigation device. The central
`processor 1 is comprised with a CPU 2, a flush memory 3, a RAM 5, a ROM 4,
`a sensor input interface 7, a communication interface 8, an image (picture)
`processor 9, a image (picture) memory 10, a voice processor 11 and a clock
`(clock generator) 6. The CPU 2 and the devices through up to the clock 6 are
`connected together through a CPU local bus 15, and the data are exchanged
`among these devices.
`Hayashida at 2:46-55.
`
`
`The sensor input interface 7 comprises an A/D converter circuit or a buffer
`circuit. The sensor input interface 7 receives analog or digital sensor data from
`the sensors 21 to 24 of a present position detector 20. The present position
`detector 20 includes an absolute direction sensor 21, a relative direction sensor
`22, a distance sensor 23 and a vehicle speed sensor 24.
`Hayashida at 7:24-30.
`
`
`[1(a)] a device for getting
`location information denoting
`a resent2 place of said portable
`terminal;
`
`
`OMM_US:77143848.1
`
`
`2 Based on Plaintiff’s Infringement Contentions (p. 7) and subsequent claim limitations referring to a present place, Defendant
`understands this to mean “present.”
`
`4
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 6 of 120 PageID #: 12548
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`An I/O data bus 28 is connected to the communication interface 8 of the central
`processor 1. To the I/O data bus 28 are connected the GPS receiver unit 25, the
`beacon receiver unit 26 and the data transmitter/receiver unit 27 of the present
`position detector 20. To the I/O data bus 28 are further connected a touch
`switch 34 and a printer 35 of the input/output unit 30, and an information
`memory unit 37. That is, a variety of data are exchanged between the external
`accessory equipment and the CPU local bus 15 through the communication
`interface 8.
`
`The present position detector 20 outputs data for detecting the present position
`of the car. In other words, the absolute direction sensor 21 detects the absolute
`direction. The relative direction sensor 22 detects the relative direction with
`respect to the absolute direction. Furthermore, the distance sensor 23 detects
`the distance travelled. The vehicle speed sensor 24 detects the running speed of
`the car. The GPS receiver unit 25 receives GPS (Global Positioning System)
`signals to detect position data such as longitude and latitude of the car. The
`GPS signals are microwaves transmitted from a plurality of satellites orbiting
`round the earth.
`
`Similarly the beacon receiver unit 26 receives beacon from a data offering
`system such as VICS (Vehicle Information and Communication System) or the
`like, and the received data and the corrected data of GPS are output to the I/O
`data bus 28.
`
`The data transmitter/receiver unit 27 exchanges a variety of information related
`to the present position or the road conditions near the car relative to the bi-
`directional present position information offering system or the ATIS (advanced
`traffic information service), etc. by utilizing a cellular phone, FM multiplex
`signals or a telephone circuit. These information are used as a detecting
`information of the car position or a support information of movement. The
`beacon receiver unit 26 and the data transmitter/receiver unit 27 may not be
`provided. As for this data sending and the data transmitter/receiver unit 27, a
`
`OMM_US:77143848.1
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 7 of 120 PageID #: 12549
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`radio receiver, a television receiver, a carrying telephone, a pager or the other
`radio communication machine are used.
`Hayashida at 7:50-8:21.
`
`
`Id. at Fig. 1.
`
`
`
`
`FIG. 3 illustrates some of a group of data stored in the RAM 5. The present
`position data MP represent the present position of the vehicle and are detected
`by a present position detector 20. The absolute direction data ZD represents
`the south-north direction relying upon the terrestrial magnetism and are found
`based upon the data from an absolute direction sensor 21. The relative
`direction angle data Dθ represent an angle of the direction in which the vehicle
`is traveling with respect to the absolute position data ZD and are found based
`upon the data from a relative direction sensor 22.
`
`OMM_US:77143848.1
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`6
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 8 of 120 PageID #: 12550
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`The traveled distance data ML represent a distance traveled by the vehicle and
`are found based on the data from a distance sensor 23. The present position
`data PI are related to the present position and are input from a beacon receiver
`26 or the data transmitter-receiver 27. The VICS data VD and ATIS data AD
`are input from the beacon receiver 26 or the data transmitter-receiver 27. The
`VICS data VD are used for correcting an error in the position of the vehicle
`detected by a GPS receiver 25. The ATIS data AD are used for determining
`traffic regulations and traffic jamming in the areas.
`Hayashida at 10:55-11:8.
`
`
`Then a processing for detecting the present position (step SA2) and the
`subsequent processing are executed. The processing for detecting the present
`position (step SA2) detects the geographical coordinates (latitude, longitude,
`altitude, etc.) of an overland moving body, i.e., of a vehicle mounting the
`navigation device. That is, a GPS receiver 25 receives signals from a plurality
`of satellites orbiting around the earth, detects coordinate positions of the
`satellites, times at which the electromagnetic waves are emitted from the
`satellites and the time at which the electromagnetic waves are received by the
`GPS receiver 25, and calculates the distances to the satellites. The coordinate
`position of the vehicle is calculated from the distances to the satellites, to detect
`the present position of the vehicle. The thus found geographical coordinate data
`of the vehicle are stored in the RAM 5 as present position data MP. The present
`position data MP are often corrected by the data input through a beacon
`receiver 26 or the data transmitter/receiver 27.
`Hayashida at 13:16-33; see also id. at Fig. 5.
`
`Alternatively, to the extent required by the claims, it would have been obvious to a PHOSITA to
`modify Hayashida’s device for getting location information denoting a present place of said
`portable terminal to utilize an infrared ray sensor in addition to GPS receiver and antenna and CPU
`to perform the function of getting location information denoting a present place of said portable
`terminal as suggested by the Cyberguide. See corresponding claim limitation of Exhibit A10. A
`PHOSITA would have been motivated to modify Hayashida with the teachings of the Cyberguide
`in order to allow the device to function indoors as well as outdoors. At least because Hayashida
`7
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 9 of 120 PageID #: 12551
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`already includes beacon receiver hardware to support such functionality, the proposed combination
`is the application of a known technique to improve a similar device in the same way and would not
`have required undue experimentation and would have yielded predictable results.
`
`Alternatively, to the extent required by the claims, it would have been obvious to a PHOSITA to
`modify Hayashida’s device for getting location information denoting a present place of said
`portable terminal to utilize an IR beacon in addition to GPS receiver and antenna and CPU to
`perform the function of getting location information denoting a present place of said portable
`terminal as suggested by Want.
`
`
`A location information system uses a positioning system, such as the civilian
`Navstar Global Positioning System (GPS), in combination with a distributed
`network. The location information system includes a radio transceiver for
`communicating to the distributed network and a GPS receiving system. The
`GPS receiving system receives a signal from the GPS and converts it into a
`coordinate entry. The coordinate entry is transmitted to the distributed network
`for retrieval of corresponding location specific information. The location
`specific information may reside on a web page. The coordinate entry may be
`incorporated into the web page address that supports the coordinate entry or
`linked to an existing web page associated with the coordinate entry. The web
`page and associated information is displayed. Bar code labels, infrared
`beacons and other labeling systems may also be used in the location
`information system in place of or in addition to the GPS receiving system to
`supply location identification information.
`Want at Abstract.
`
`
`FIG. 1 shows one embodiment of a location information system 100. As seen
`in FIG. 1, the location information system 100 includes a computer or personal
`(PDA) 110,
`receiver 120 and
`digital
`assistant
`a GPS
`a
`radio
`transmitter/receiver, e.g., transceiver 130. The GPS receiver 120 receives
`signals from three or more GPS transmitters 200 and converts the signals to a
`specific latitude and longitude (and in some cases altitude) coordinate entry, as
`described above. The GPS receiver 120 provides the coordinate entry to the
`8
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 10 of 120 PageID #:
` 12552
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`transceiver 130transmits
`computer 110 and
`the coordinate entry,
`the
`preferably via a radio network, to a predetermined node 300 or other node on
`a distributed network 305. Alternatively, the coordinate entry is transmitted to
`the distributed network 305 over a wired connection to the computer 110 (not
`shown).
`
`Information associated with the coordinate entry defining a specific location is
`then transmitted to the computer 110 via the transceiver 130 (i.e., by either a
`radio network or other wireless or wire communication link) and displayed on
`the display 140. Information about various locations is organized and stored
`on the distributed network 305 and is preferably organized as “web pages.”
`The web pages or pointers to them are preferably stored on the predetermined
`node 300 of the distributed network 305. However, the web pages may also be
`stored at various other nodes on the distributed network 305 and may be
`associated with one or more coordinate entries corresponding to physical
`locations. The web pages may have, for example, an already existing URL, e.g.,
`a proprietary pre-existing URL. Alternatively, coordinate information may be
`incorporated into an existing URL to form a unique URL. Further, the
`coordinate entry may also be the entire URL of the web pages. A client, either
`local or remote, may access the web pages preferably via a server on the
`predetermined node 300 of the distributed network 305.
`Want at 4:3-35
`
`The radio transceiver 130 of the location information system 100 is preferably
`a cellular modem radio. The radio transceiver 130 may work with a Ricochet™
`Wireless Network system manufactured by Metricom, Inc. The Ricochet™
`Wireless Network is a wide-area wireless system using spread-spectrum packet
`switching data technology operating in the 902-928 MHz RF spectrum. The
`radio transceiver 130 may also comprise other systems, such as a cellular
`digital packet data (CDPD) type radio transceiver.
`Want at 5:29-37
`
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 11 of 120 PageID #:
` 12553
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`It should be appreciated that the GPS receivers 120 need to receive signals
`from the GPS transmitters 200. Thus, if the signals are blocked, the GPS
`receiver 120may not be able to determine the coordinate entry. In order to
`avoid this problem, other techniques for providing a coordinate entry may be
`used by the location information system 100. These techniques may include, for
`example, printed ID labels (e.g., bar codes, vericodes, and other similar labels),
`infrared beacons or RF tags).
`
`FIG. 4 shows an embodiment of the location information system 100 using bar
`code labels to obtain location information. Other coding systems, such as the
`Vericode system, two-dimensional bar coding system and the like, are also
`contemplated for use with the present invention. In the embodiment of FIG. 4,
`a bar code label 212 may be placed on or in a building 210 or other location
`of interest. In preferred embodiments, the bar code label 212 encodes either the
`same longitudinal and latitudinal information that would be obtained from the
`GPS system or may directly encode a unique URL. The computer 110 also has,
`in place of or in addition to the GPS receiver 120, a bar code scanner 160 for
`scanning and decoding the bar code label 212. The bar code scanner 160 can
`be provided on a tether. The bar code scanner 160 reads the coordinate entry
`or unique URL from the bar code label 212. The coordinate entry or unique
`URL is transmitted to the distributed network 305 via the transceiver 130 and
`provided to the predetermined node 300, or to another node of the distributed
`network 305, and processes the location specific identification information as
`described above. The computer 110downloads the web page(s) associated with
`the coordinate entry or unique URL for displaying on the display 140.
`
`FIG. 5 shows an embodiment of the location information system 100 using as
`the location information source infrared beacons. Infrared beacons 220 may be
`used in a manner similar to the bar code labeling system described above.
`However, the infrared beacons 220 may be read from a much greater distance,
`and preferably approximately at least 25 feet. The IrDa standard can also be
`used, but a range of only approximately one meter may be obtained due to the
`limitations of such a system. The infrared beacons 220 are preferably placed
`10
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 12 of 120 PageID #:
` 12554
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`on or in a building 210 or other location of interest. An IrDa or other
`interface 170, which is well known in the art, is provided on the
`computer 110 for
`infrared beacons 220. The
`sensing
`the
`infrared
`beacons 220 transmit either the coordinate entry or the unique URL that would
`otherwise be obtained from the bar code label 212. The information received
`from the infrared beacons 220 is used in the same manner as the information
`received from the bar codes 212. Additionally, radio frequency beacons could
`be used in place of the infrared beacons 220 to further extend the read distance.
`When using radio frequency beacons, the interface 170 is designed for the
`particular frequency and modulation techniques, well known in the art, used by
`the particular radio frequency beacons.
`Want at 6:15-7:3
`
`
`The control routine starts at step S100. At step S110,
`the GPS
`receiver 120receives signals from the GPS transmitters 200. Then, at step S120,
`a coordinate entry associated with the GPS signal is downloaded to the
`computer 110 by the GPS receiver 120. Next, at step S130, the coordinate entry
`is transmitted to the distributed network 305 via the transceiver 130.
`Want at 7:44-51
`
`
`In preferred embodiments, the bar code labels and infrared beacons may also
`use the method as disclosed in FIG. 7. That is, the bar code labels and infrared
`beacons may provide the location information system 100 with signals that are
`converted to coordinate entries. Also, the infrared beacons may be substituted
`with radio beacons, as described above.
`
`As shown in FIGS. 1-6, the location information system 100 is preferably
`implemented on a programmed general purpose computer. However, the
`location information system can also be implemented on a special purpose
`computer, a programmed microprocessor or microcontroller and peripheral
`integrated circuit elements, an ASIC or other integrated circuit, a hardwired
`electronic or logic circuit such as a discrete element circuit, a programmable
`logic device such as a PLD, PLA, FPGA or PAL, or the like. In general, any
`11
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 13 of 120 PageID #:
` 12555
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`device on which a finite state machine capable of implementing the flowcharts
`shown in FIGS. 7 and 8 can be used to implement the location information
`system 100.
`Further,
`it
`should
`be
`appreciated
`that
`the
`transceiver 130 connecting the predetermined node 300 and/or the distributed
`network 305 to the computer 110 can be a wired link to a network (not shown)
`as well as the illustrated wireless link. The predetermined node 300 and/or the
`distributed network 305 can be a local area network, a wide area network, an
`intranet, the Internet, or any other distributed processing and/or storage
`network. It may also be used with protocols such as the World Wide Web or any
`other protocol system. It is also appreciated from the above description that the
`predetermined node 300 and/or distributed network 305 can be either a local
`or remote node depending on a particular application.
`Want at 9:13-42; see also Figs. 1-6.
`
` A
`
` PHOSITA would have been motivated to modify Hayashida with the teachings of Want in order
`to provide more accurate position information to a user, especially in situations where a GPS signal
`may be weak, such as indoors. And because Want can be implemented on any general purpose or
`special purpose computer, such a modification is straightforward, requiring no undue
`experimentation and yielding predictable results.
`
`To the extent this limitation is governed by 35 U.S.C. § 112(6), and based on Defendant’s
`understanding of Plaintiff’s infringement contentions, Hayashida discloses a device (i.e., present
`position detector 20, including absolute direction sensor 21 (terrestrial magnetism sensor) and
`relative direction sensor 22 (gyroscope), and CPU 2) that performs the claimed function of getting
`direction information denoting an orientation of said portable terminal. A PHOSITA would have
`understood geomagnetic sensor as taught by Hayashida to refer to a compass.
`
`
`FIG. 1 illustrates the overall circuitry of the navigation device. A central
`processor 1 controls the operation of the whole navigation device. The central
`processor 1 is comprised with a CPU 2, a flush memory 3, a RAM 5, a ROM 4,
`a sensor input interface 7, a communication interface 8, an image (picture)
`processor 9, a image (picture) memory 10, a voice processor 11 and a clock
`(clock generator) 6. The CPU 2 and the devices through up to the clock 6 are
`12
`
`[1(b)] a device for getting a
`direction
`information
`denoting an orientation of said
`portable terminal;
`
`
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 14 of 120 PageID #:
` 12556
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`connected together through a CPU local bus 15, and the data are exchanged
`among these devices.
`Hayashida at 2:46-55.
`
`
`The sensor input interface 7 comprises an A/D converter circuit or a buffer
`circuit. The sensor input interface 7 receives analog or digital sensor data from
`the sensors 21 to 24 of a present position detector 20. The present position
`detector 20 includes an absolute direction sensor 21, a relative direction sensor
`22, a distance sensor 23 and a vehicle speed sensor 24.
`
`
`
`The absolute direction sensor 21 is, for example, a terrestrial magnetism sensor
`and detects terrestrial magnetism. The absolute direction sensor 21 outputs
`data indicating a south-and-north direction which serves as the absolute
`direction. The relative direction sensor 22 is, for example, a steering angle
`sensor and detects the steering angle of the wheel based upon a gyroscope such
`as optical fiber gyroscope or piezo-electric vibration gyroscope. The relative
`direction sensor 22 outputs a relative angle of a direction of progress of the car
`with respect to the absolute direction detected by the absolute direction sensor
`21.
`Hayashida at 7:24-42.
`
`
`OMM_US:77143848.1
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`13
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 15 of 120 PageID #:
` 12557
`Defendant’s Invalidity Contentions
`Exhibit A19
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`
`
`Id. at Fig. 1.
`
`
`
`
`The present position detector 20 outputs data for detecting the present position
`of the car. In other words, the absolute direction sensor 21 detects the absolute
`direction. The relative direction sensor 22 detects the relative direction with
`respect to the absolute direction. Furthermore, the distance sensor 23 detects
`the distance travelled. The vehicle speed sensor 24 detects the running speed of
`the car. The GPS receiver unit 25 receives GPS (Global Positioning System)
`signals to detect position data such as longitude and latitude of the car. The
`GPS signals are microwaves transmitted from a plurality of satellites orbiting
`round the earth.
`Hayashida at 7:60-8:3.
`
`
`FIG. 3 illustrates some of a group of data stored in the RAM 5. The present
`position data MP represent the present position of the vehicle and are detected
`14
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`OMM_US:77143848.1
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`Case 5:19-cv-00036-RWS Document 348-12 Filed 06/18/20 Page 16 of 120 PageID #:
` 12558
`Defendant’s Invalidity Contentions
`Exhibit A19
`
`
`
`by a present position detector 20. The absolute direction data ZD represents
`the south-north direction relying upon the terrestrial magnetism and are found
`based upon the data from an absolute direction sensor 21. The relative
`direction angle data Dθ represent an angle of the direction in which the vehicle
`is traveling with respect to the absolute position data ZD and are found based
`upon the data from a relative direction sensor 22.
`Hayashida at 10:55-64.
`
`
`In the processing for detecting the present position (step SA2), furthermore the
`absolute direction data ZD, relative direction angle data D θ and the traveled
`distance data ML are simultaneously found by using an absolute direction
`sensor 21, a relative direction sensor 22 and a distance sensor 23. The absolute
`direction data ZD, relative direction angle data Dθ and traveled distance data
`ML are operated to determine the position of the vehicle. The thus determined
`position of the vehicle is collated with map data stored in a data 38c of the
`information memory unit 37, and the present position on the map screen is
`corrected and is indicated more correctly. Therefore, the present position of the
`vehicle is correctly indicated even when the GPS signals are not received such
`as traveling through a tunnel.
`Hayashida at 13:34-47; see also id. at Fig. 5.
`
`Hayashida teaches this limitation under Plaintiff’s interpretation. Specifically, Hayashida discloses
`an input device (e.g., input/output device 30) for inputting a destination.
`
`Hayashida also teaches this limitation if governed by 35 U.S.C. § 112(6). Specifically, Hayashida’s
`input/output unit 30, including a display 33 and transparent touch panel 34, is the structure
`performing the function of inputting a destination.
`
`
`The input/output device 30 comprises a display 33, a transparent touch panel
`34, a printer 35 and a speaker 13. The display 33 displays guide data during
`the navigation operation. The touch panel 34 is constituted by a plurality of
`transparent touch switches that are arra