Unified Patents Inc. v. Smart Authentication IP, LLC, IPR2017-02047 (PTAB Sept. 1, 2017)

IPR2017-02022
U.S. Patent 7,917,285
Filed on behalf of Unified Patents Inc.

By: Jason R. Mudd, Reg. No. 57,700
Eric A. Buresh, Reg. No. 50,394
ERISE IP, P.A.
6201 College Blvd., Suite 300
Overland Park, KS 66211
Tel: (913) 777-5600
Email: jason.mudd@eriseip.com
Jonathan Stroud, Reg. No. 72,518

Ashraf A. Fawzy, Reg. No. 67,914
Unified Patents Inc.
1875 Connecticut Ave. NW, Floor 10
Washington, D.C., 20009
Tel: (202) 805-8931
Email: jonathan@unifiedpatents.com
Email: afawzy@unifiedpatents.com
UNITED STATES PATENT AND TRADEMARK OFFICE

____________
BEFORE THE PATENT TRIAL AND APPEAL BOARD

____________
UNIFIED PATENTS INC.

Petitioner
v.
GEOGRAPHIC LOCATION INNOVATIONS, LLC

Patent Owner
____________
IPR2017-02022
Patent 7,917,285
____________
PETITION FOR INTER PARTES REVIEW

OF U.S. PATENT 7,917,285
IPR2017-02022
U.S. Patent No. 7,917,285
TABLE OF CONTENTS
I. INTRODUCTION ............................................................................................. 1
II. SUMMARY OF THE 285 PATENT ............................................................. 1
A. DESCRIPTION OF THE ALLEGED INVENTION OF THE 285 PATENT ...................... 1
B. SUMMARY OF THE PROSECUTION HISTORY OF THE 285 PATENT....................... 4
III. REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37 C.F.R.
42.104 .................................................................................................................... 5
A. GROUNDS FOR STANDING UNDER 37 C.F.R. 42.104(A) .................................. 5
B. IDENTIFICATION OF CHALLENGE UNDER 37 C.F.R. 42.104(B) AND RELIEF
REQUESTED ............................................................................................................. 5
C. LEVEL OF SKILL OF A PERSON HAVING ORDINARY SKILL IN THE ART ................. 7
D. CLAIM CONSTRUCTION UNDER 37 C.F.R. 42.104(B)(3) ................................. 7
IV. THERE IS A REASONABLE LIKELIHOOD THAT THE
CHALLENGED CLAIMS OF THE 285 PATENT ARE UNPATENTABLE 7
A. GROUND 1: OSHIZAWA IN VIEW OF IKEDA RENDERS CLAIMS 1-2, 5-7, AND 9
OBVIOUS ................................................................................................................. 7
B. GROUND 2: VAN BOSCH IN VIEW OF CHOWANIC RENDERS CLAIMS 13-14 AND 16
OBVIOUS ............................................................................................................... 43
C. GROUND 3: VAN BOSCH IN VIEW OF CHOWANIC IN FURTHER VIEW OF OSHIZAWA
RENDERS CLAIM 15 OBVIOUS ................................................................................ 69
D. GROUND 4: VAN BOSCH IN VIEW OF CHOWANIC IN FURTHER VIEW OF COOPER
RENDERS CLAIMS 17 AND 18 OBVIOUS .................................................................. 71
V. CONCLUSION ............................................................................................... 75
VI. MANDATORY NOTICES UNDER 37 C.F.R. 42.8(A)(1) ..................... 76
A. REAL PARTY-IN-INTEREST ............................................................................. 76
B. RELATED MATTERS ........................................................................................ 76
C. LEAD AND BACK-UP COUNSEL ....................................................................... 79
IPR2017-02022
I. INTRODUCTION
Petitioner Unified Patents Inc. (Petitioner) respectfully requests an inter
partes review (IPR) of claims 1, 2, 5-7, 9, and 13-18 (collectively, the
Challenged Claims) of U.S. Patent 7,917,285 (the 285 Patent).
II. SUMMARY OF THE 285 PATENT
A. Description of the alleged invention of the 285 Patent
The 285 Patent purports to address problems associated with requiring users
to manually program locations into conventional GPS devices. 285 Patent
(EX1001), at 1:15-2:13. To do so, the 285 Patent proposes devices, systems, and
methods for remotely entering location addresses into a users GPS device to
automatically program it with destinations for route guidance. Id. at Abstract, 2:25-
30, 3:53-67.
The system includes a GPS device 100, which may be any type of
navigation or positional information device including but not limited to a vehicle-
mounted device, a GPS receiver coupled to a desktop computer or laptop, etc. Id.
at 4:1-8. The GPS device determines its location using a location information
module, employing conventional location information processing technology,
such as GPS, Loran, or any other available locational technology. Id. at 5:5-
11. The GPS device also includes a communication module 112 for transmitting
stored data to another device, e.g., a personal computer, a personal digital assistant
(PDA), a server residing on the Internet, etc.
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As shown in the figure below, the GPS device 100 communicates via a
communications network 302 with a remote customer service center (CSC) having
a live operator 303 that has access to a server 304 for looking up address
information and for transmitting information to the GPS device:
Id. at Fig. 3, 9:13-20; see also id. at 8:13-16. The communications network may
be a telematics network that, for example, enables data and voice communications
using any known communication means, such as RF, satellite, CDMA, 3G, and
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more. Id. at 8:13-16. The system can also include a local computer 310 coupled to
the communications network 302. Id. at 9:64-10:33. The user may remotely
request entry of an address into the GPS device 100 for purposes of the GPS device
providing route guidance to the address.
When the user requests remote entry of an address into GPS device 100, the
user is connected to the customer service center (CSC) via analog or digital
communications or any other type of communication link. Id. at 8:62-9:3. The
vehicle or device is identified using an identifier, such as a cellular phone number
or IP address, which can be transmitted to the CSC or detected using conventional
techniques, such as using caller ID and a database lookup. Id. at 9:3-12. The
request for the address may be received by voice communications as the user
communicates with a live operator 303 who inputs the request into the server 304
or the request may be directly received electronically by the server. Id. at 9:17-39.
The live operator accesses the server 304 to look-up the requested location
information. Id. For example, the user may provide the name and city of a desired
location, which the operator uses to look-up the address and/or latitude/longitude
coordinates of the location. Id. at 12:12-52. The determined address or coordinate
information is then transmitted to the device 100, which uses it to generate route
guidance to the location. Id.
In certain embodiments, the user can also request location information using
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a local computer. Id. at 9:64-10:5. Specifically, the user connects the local
computer 310 to the server, which uses an identifier associated with the local
computer to identify the user. Id. at 10:21-27. The remote server then utilizes a
standard database lookup program, based on the received identifier, to find out
information on the users device including the transmission information for the
device which may be the cellular telephone number of the device or a vehicle or
the Internet address (e.g., the IP address) of the device or vehicle. Id. at 10:27-33.
The server then looks up the requested location information and transmits it to the
GPS device, which can then provide route guidance to the user. Id. at 10:34-49.
In other embodiments, the user can use the device interface or their voice to
tell the customer service center they need address information stored on another
registered device or vehicle, and that information can be remotely accessed and
entered into the users current device for obtaining route guidance. Id. at 10:62-
11:48.
B. Summary of the prosecution history of the 285 Patent
The application that resulted in the 285 Patent was filed on April 28, 2006.
285 Patent File History (EX1002), at 2. For purposes of this proceeding,
Petitioner assumes the priority date for the Challenged Claims is April 28, 2006.
During prosecution, the Examiner twice rejected as anticipated pending
claim 25, which subsequently issued as claim 1. Id. at 66, 97. To overcome these
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rejections, Applicant amended pending claim 25 to include the limitation wherein
the request is received from a remote computer with a first identifier and the server
being configured to determine a second identifier for identifying the positional
information device based on the received first identifier. Id. at 107. In this same
amendment, Applicant also added independent claim 45, which subsequently
issued as Claim 13 and included a limitation relating to the server receiving and
transmitting to the positional information device a time and date associated with
the requested at least one location. Id. at 109-110. The Examiner subsequently
issued a Notice of Allowance allowing independent claims 25 and 45 and their
dependent claims. Id. at 122. No reasons for allowance were given. Id. Claims 25
and 45 subsequently issued as claims 1 and 13, respectively. Id. at 128.
III. REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37 C.F.R.

42.104
A. Grounds for standing under 37 C.F.R. 42.104(a)
Petitioner certifies that the 285 Patent is available for IPR and that the
Petitioner is not barred or estopped from requesting IPR challenging the claims of
the 285 Patent.
B. Identification of challenge under 37 C.F.R. 42.104(b) and relief

requested
In view of the prior art and evidence presented, claims 1, 2, 5-7, 9, and 13-
18 of the 285 Patent are unpatentable and should be cancelled. 37 C.F.R.
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C. Level of skill of a person having ordinary skill in the art
A person having ordinary skill in the art at the time of the 285 Patent would
have been a person having the equivalent of a bachelors degree in electrical
engineering, computer engineering, computer science, or a similar discipline, and
at least one to two years of experience working with vehicle navigation systems or
vehicle telematics technologies, or an equivalent amount of similar work
experience or education, with additional education substituting for experience and
additional experience substituting for education. Decl. (EX1003) at 53.
D. Claim construction under 37 C.F.R. 42.104(b)(3)
In this proceeding, claim terms of an unexpired patent should be given their
broadest reasonable construction in light of the specification. 37 C.F.R.
42.100(b); Cuozzo Speed Techs., LLC v. Lee, 136 S. Ct. 2131, 2144-46 (2016).
Petitioner proposes that for purposes of this IPR, the claim terms of the 285 Patent
be given their ordinary and customary meaning that the term would have to one of
ordinary skill in the art in light of the specification.
IV. THERE IS A REASONABLE LIKELIHOOD THAT THE

CHALLENGED CLAIMS OF THE 285 PATENT ARE
UNPATENTABLE
A. Ground 1: Oshizawa in view of Ikeda renders claims 1-2, 5-7, and 9

obvious
Oshizawa issued on November 16, 1999 and thus qualifies as prior art with
regard to the 285 Patent under 35 U.S.C. 102(b) (pre-AIA). Oshizawa
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(EX1004). Oshizawa was not cited or substantively discussed during prosecution
of the 285 Patent. Oshizawa describes [a]n on-board automobile navigation
system . . . us[ing] destination data downloaded from a remote transmission
source. Id. at 2:53-55; see also id. at 4:49-50 (The present invention simplifies
the process of entering a desired destination for the user.).
The 285 Patent is broadly directed to the field of navigational or positional
information systems. 285 Patent (EX1001), at 1:9-13. Oshizawa similarly
relates to the field of on-board navigation systems for street vehicles. Oshizawa
(EX1004), at 1:5-6. As such, Oshizawa is in the same field of endeavor and is
analogous to the claimed invention of the 285 Patent. Oshizawas general system,
including a communications center housing a human operator and computer
system, a communication device (such as a mobile telephone), and an on-board
vehicle navigation system is depicted below:
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. . H0 L 9/0
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field of endeavor and is analogous to the claimed invention of the 285 Patent.
J y H Maioli
Ikedas general
21 A system,0 including a navigation system having a navigation ID, a
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pu chas d by a u er, a rvice server t at r vides services
I 088 148 s d t em Wh th du t
mobile phone having

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Id. at Fig. 1. Like the embodiment described above in Oshizawa, Ikedas general
system includes separate communications links for the navigation system and the
mobile phone. Id.
i. Claim 1
1. A system for remotely entering location information into a positional

information device, the system comprising:
To the extent it is deemed limiting, Oshizawa discloses the preamble.
Oshizawa teaches a system for remotely entering a desired destination (i.e.,
location information) into an on-board vehicle navigation device (i.e.,
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positional information device) by a user using a mobile telephone (i.e., remote
computer) to contact an operator in a remote communications center so as to
simplif[y] the process of entering a desired destination for the user:
A user of the navigation system in a vehicle utilizes a cellular

telephone or any other wireless, two-way audio communications link
to contact an operator in a remote communications center. The user
informs the operator of his desired destination. The operator in the
communications center accesses a computer database to determine the
exact location of the desired destination in terms of latitude/longitude,
street address, or other similar information. The operator then
causes the information specifying the exact location to be
transmitted from the communications center to the on-board
vehicle navigation system over a data link. The on-board vehicle
navigation system receives the location information and uses it to
compute a route from the vehicle's current position to the desired
destination.
Oshizawa (EX1004), at Abstract (emphases added), 4:49-50.
[1(a)(i)] a server configured to receive a request for an address of at least one

location not already stored in the positional information device,
The 285 Patent discloses an embodiment where a server being operated by
a live operator in a customer service center receives the users location request via
voice communications from the userthe operator inputs the request into the
server to lookup the address of the requested location and then causes the address
to be wirelessly transmitted from the server to the device:
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Once connected to the customer service center, the user can
communicate with the customer service center with voice
communications or with a vehicle user interface (VUI) including but
not limited to keyboard, voice recognition, or mouse or pointer. In one
embodiment, the customer service center includes a live operator 303
that has access to server 304 for looking up address information and
transmitting the information to the device. In this embodiment, the
user will interact with the live operator via voice communications.
285 Patent (EX1001), at 9:13-21; see also id. at 3:27-29 (In a further aspect, the
server is operated by a live operator and the request for the at least one
location is received by voice communications.), 2:48-49, 3:6-8 (emphases
added).
Furthermore, Claim 9, which depends from Claim 1, recites wherein the
server is operated by a live operator and the request for the at least one location is
received by voice communications. Therefore, the BRI of this limitation in Claim
1 must at least include the embodiment of Claim 9.
Oshizawa discloses this exact embodiment. Specifically, Oshizawa teaches
that a server (i.e., computer system 165) operated by a human operator in a
communication center 150 receives the users location request (i.e., a request for a
desired destination address) via voice communications from the users cellular
telephone (i.e., communication device 172). Oshizawa (EX1004) at Abstract;
see also, id. at 5:1-19, 6:31-44, Figs. 2A-B, 3 (steps 301-302). [T]he user states
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the desired destination to the operator. For example, the user may provide the name
of a business as the desired destination. Id. at 6:41-44. The operator then enters
the desired destination information into the computer system 165 (i.e., server) to
look up the coordinates of the desired destination, such as by accessing a
database 174. Id. at 6:44-54 (In step 303, the operator uses the computer system
165 to access the database 174 to determine the exact coordinates of the desired
destination in terms that are usable by the navigation system 100), Fig. 3 (step
303). Oshizawa teaches that the coordinates can be a street address. Id. at
6:44-54, Abstract. Therefore, Oshizawa teaches that a server (computer system
165) receives a request for an address of a desired destination via voice
communications transmitted by a remote computer (the users cellular telephone
172).1
1
Petitioner notes, as discussed immediately above, that claim 1 does not require
the server to directly receive the request from the remote computer, and instead,
encompasses embodiments, such as recited in claim 9, where the request is
received via voice communications to a live operator who then enters the request
into the server.
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Id. at Fig. 2B.
Hence, in step 301 he first uses communication device 172 (which

may be a cellular telephone) to establish two-way audio
communication with the operator in the communication center 150,
who is using communication device 171; the user of navigation
system 100 thereby initiates the communication link 161. In step 302,
the user states the desired destination to the operator. For
example, the user may provide the name of a business as the desired
destination. In step 303, the operator uses the computer system 165
to access the database 174 to determine the exact coordinates of the
desired destination in terms that are usable by the navigation system
100; for example, the navigation system may require that
coordinates be provided in terms of latitude/longitude, street
address, link (street segment) identifier, node (intersection) identifier,
or other type of location information.
Id. at 6:36-51 (emphases added).
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Id. at Fig. 3 (excerpt); see also id. at 5:1-8, Fig. 2A.
The claimed an address of at least one location not already stored in the
positional information device is met by Oshizawa, at least because Oshizawa does
not require the recited negative limitation (i.e., does not require the address to
already be stored in the positional information device). A negative limitation may
be satisfied by silence in the prior art where the prior art does not require the
presence of the element recited in the negative limitation. See Sd-Chemie, Inc. v.
Multisorb Technologies, Inc., 554 F.3d 1001, 1004-05 (Fed. Cir. 2009) (affirming
determination that claim limitation of uncoated film was met by prior art that
disclosed film without mention of any coating and without description of any
requirement of a coating); Palo Alto Networks, Inc. v. Juniper Networks, Inc.,
IPR2013-00466, Paper 17, at 18 (January 28, 2014) ([A] negative limitation
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requiring the absence of an element may be adequately described by a cited prior
art reference if that reference does not otherwise require the presence of the
element recited in the negative limitation.) (emphasis in original); see also Google
Inc. et al. v. Core Wireless Licensing S.A.R.L., IPR2015-01715, Paper 8, at 14
(February 18, 2016) (same).
Here, Oshizawa does not require the users requested destination
coordinates/address to be already stored on the on-board vehicle navigation
device prior to the users request for remote input of the destination. Instead,
Oshizawa teaches a navigation system which uses destination data downloaded
from a remote transmission source. Oshizawa (EX1004) at 7:25-27 (emphasis
added); see also id. at 1:8-9, 4:19-22 (describing inputting a desired destination
in the remote manner described), 4:49-50 (process of entering a desired
destination). Indeed, Oshizawas purpose in requesting remote input of
destination data (e.g., address/coordinates) is to download and use a destination
address that the user has not already entered in their device so as to simplify
destination entry, just like the 285 Patent. Id. Therefore, a PHOSITA would have
understood Oshizawa does not require its disclosed on-board navigation system to
already store the users desired destination address locallyand that doing so
would render moot the primary objective of Oshizawa. Decl. (EX1003) at 60.
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Further, to the extent Oshizawas silence is not found to teach this element,
it would have nonetheless been obvious to a PHOSITA from Oshizawa that the
users desired destination address would not be already stored on the users on-
board vehicle navigation device, as Oshizawa teaches using a remotely
downloaded destination address, as discussed above, and there would be no reason
to download the address to the device if it had already been previously stored.
Decl. (EX1003) at 61. A PHOSITA would have appreciated from Oshizawa that
it would be beneficial to remotely download the users desired destination address
rather than having it already be stored locally because Oshizawa teaches that this
simplifies destination entry for the user. Id. at 62; see also Oshizawa (EX1004) at
1:38-53, 2:10-23, 2:53-55, 4:49-5:15. A PHOSITA also would have appreciated
that not already storing the address locally would have furthered Oshizawas stated
desire to reduce system cost, such as by eliminating the need for additional
memory to locally store locations and their respective addresses. Decl. (EX1003) at
62; see also Oshizawa (EX1004) at 1:57-59.
[1(a)(ii)] to determine the address of the least one location
Oshizawas server is configured to determine the address of the requested
destination/locationspecifically, the operator causes the server (computer system
165) to access a database 174 to determine the address of the requested
destination/location:
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exact location of the desired destination in terms of
latitude/longitude, street address, or other similar information.
Id. at Abstract (emphasis added).
In step 303, the operator uses the computer system 165 to access the
database 174 to determine the exact coordinates of the desired
destination in terms that are usable by the navigation system 100; for
example, the navigation system may require that coordinates be
provided in terms of latitude/longitude, street address, link (street
segment) identifier, node (intersection) identifier, or other type of
location information.
Id. at 6:44-51 (emphasis added).
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Id. at Fig. 3 (excerpt); see also, id. at 5:58-6:9.
[1(a)(iii)] and to transmit the determined address to the positional information

device,
The operator then causes the server (computer system 165) to transmit the
determined coordinates, which may be an address, to the on-board navigation
system:

exact location of the desired destination in terms of latitude/longitude,
street address, or other similar information. The operator then
causes the information specifying the exact location to be
transmitted from the communications center to the on-board
vehicle navigation system over a data link.
Id. at Abstract (emphasis added).
In step 304, the operator enters a command into the computer system
165 to cause the coordinates to be encoded and transmitted on from
the communications center 150 to the on-board navigation system
100 via the non-audio data channel of link 161.
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the users vehicle navigation system to determine the correct navigation system for
the user. Ikeda (EX1005) at Abstract ([A] service server that provides services
accesses a specified navigation system, which is the product purchased by the user,
using a device ID that is uniquely assigned to the navigation system . . . .), [0012],
[0166], [0208], [210], Figs. 1, 5. Ikedas server provides support services to an in-
vehicle navigation system 100 based on a request received from a mobile phone
200. Id. at Abstract, [0166], [0208], Fig. 8 (step S401 Security request sent to
application server together with terminal ID and password). For the first
identifier, the mobile device has a unique terminal ID, which is also referred to
as a mobile ID and may be, e.g., a telephone number for the mobile phone. Id.
at [0012], [0133], Fig. 5. For the second identifier, the navigation system 100 has a
navigation ID that uniquely identifies the navigation system 100 and that may also
be a telephone number, e.g., a telephone number for the navigation systems
communication terminal apparatus 50, which enables the navigation system to
wirelessly access the Internet. Id. at [0098], [0135]; see also id. at [0083]. The
server includes a user database 410 storing and associating the users user
information, mobile ID for the mobile phone, navigation ID for the navigation
system, and password. Id. at [0133]; see also id. at Fig. 5.
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Id. at Fig. 5 (annotated to highlight user database associating mobile ID with
navigation ID).
Ikeda teaches receiving the first identifier with the request for services from
the mobile phone and determining the second identifier for the navigation system
from the first identifier using the user database on the server. For example, Ikeda
teaches several services that may be provided to users of navigation systems
including security services, map updates, and a variety of other services. Id. at
[0351]; see also, id. at [0028]-[0031], Figs. 7-10. [T]he user may operate the
mobile phone 200 to access the application server 303 on the wireless telephone
communication network 300. Id. at [0166]; see also id. at [0208]. Upon
receiving a request for a service from the mobile phone, the server accesses the
user database 410 and searches the user database 410 to find the navigation ID
that is associated with the verified terminal ID [for the mobile device] and
password. Id. at [0210], Fig. 8 (Step S503); see also, id. at [0166]. Thus, Ikeda
teaches a server receiving a service request from a mobile phone with a first
identifier (the mobile/terminal ID) and then determining (by looking up in the user
database) an associated second identifier (the navigation ID) for identifying the
associated positional information device (vehicle navigation system) based on the
received first identifier (mobile/terminal ID).
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As one example, the user may operate the mobile phone 200 to access
the application server 303 on the wireless telephone communication
network 300. The user accesses the application server 303 in this case
since the server that allows the user to perform the security-related
control over the vehicle is part of the application server 303. By
performing a predetermined operation, the user can enquire whether
the vehicle is locked. In response to this request, the security server in
the application server 303 finds the navigation ID of the navigation
system 1 owned by the same user as the mobile phone 200 that has
made the access, and then sends a command to the navigation
system 1 that has this navigation ID to enquire about the state of the
locks of the vehicle.
Id. at [0166] (emphasis added).
When the user has been successfully verified, the application server
303 proceeds to step S503 where it searches the user database 410
to find the navigation ID that is associated with the verified
terminal ID and password. Next, in step S504, the application server
303 transmits a security request to the navigation system 1 that has the
navigation ID (telephone number) obtained from the user database
410.
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techniques, which the 285 Patent admits were well-known. Id. at 79; see also
EX1001 at 9:7-12. A PHOSITA would have also understood that in Oshizawa, the
users on-board vehicle navigation system could similarly be uniquely identified
via a navigation ID as taught by Ikeda. Id. at 77. As suggested by Ikeda, using a
telephone number as the navigation ID, too, would have ma[de] it easy for
Oshizawas computer system 165 to uniquely identify and communicate with the
on-board navigation system over the wireless network to transmit the desired
destination address. Id. at 77; see also Ikeda (EX1005), at [0135].
Based on the teachings of Ikeda, it would have been obvious to a PHOSITA
for Oshizawas communications center to receive the users cellular telephone
number as a mobile/terminal ID (i.e., a first identifier), such as by using caller ID
or other conventional techniques, and for Oshizawas server (computer system
165) to be used to look up a navigation ID (i.e., a second identifier for identifying
the positional information device) based on the received telephone number of the
users cellular telephone (i.e., remote computer) used by the user to make the
request. Decl. (EX1003) at 79-80. Specifically, it would have been obvious to
include a user database including a table associating the users cellular telephone
number with the telephone number of the on-board navigation system. Id. at 75,
78.
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A PHOSITA would have appreciated that the user database taught by Ikeda
could simply be incorporated into Oshizawas database 174, which is accessed by
Oshizawas computer system 165 when the operator is handling a user request. Id.
at 75, 78. As taught by Ikeda, it would have also been obvious to configure
Oshizawas computer system to search the database in order to determine the
telephone number of the appropriate corresponding on-board navigation system
based on the telephone number of the users cellular telephone from which the
request was received. Id. at 79-80. This combination of familiar elements
(phone numbers and databases) would have yielded the predictable result of
allowing Oshizawas computer system to easily identify and subsequently transmit
the requested address information to the correct on-board navigation system
without requiring further input from the user. Id. at 80. One of the stated goals of
Oshizawas system is to minimize manual user input. Oshizawa (EX1004), at
1:38-53. Therefore, a PHOSITA would have been motivated to enable Oshizawas
computer system to automatically determine the users on-board navigation system
in the manner taught by Ikeda to remove any need for the user to manually identify
his or her on-board navigation system whenever making a destination request.
Decl. (EX1003) at 81.
[1(c)(i)] the positional information device including a locational information

module for determining location information of the positional information
device;
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stored map data and, if necessary, to revise the position determination
accordingly (e.g., if the dead-reckoned position does not coincide with
a street segment). In certain instances, data from the GPS receiver 121
may be used to correct, supplement, or replace the position
determination made using dead-reckoning and map-matching.
Id. at 4:3-18.
[1(c)(ii)] a communication module for receiving the determined address of the at

least one location from the server;
Oshizawas on-board navigation device also includes an antenna 130 and
receiver/decoder circuitry (i.e., communication module) for receiving the
determined address of the desired location from the computer system 165:
Computer system 165 is coupled to a separate data communication

device 180, which provides non-audio data communication with the
on-board navigation system 100. Hence, link 162 includes only non-
audio data communication between communication device 180 and
the on-board navigation system 100. The on-board navigation
system 100 includes a separate antenna 130 and receiver/decoder
circuitry (not shown) suitable for receiving non-audio data from
communication device 180. It will be recognized that various other
embodiments are also possible.
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[1(c)(iii)] a processing module configured to receive the determined address from
the communication module and determine route guidance based on the location
of the positional information device and the determined address; and
Oshizawas on-board navigation device includes a processing module
including a central processing unit (CPU) 110, read-only memory (ROM) 111,
random access memory (RAM) 112, and a mass storage medium 113, each
coupled to a bus 124. Id. at 2:66-3:2, Fig. 1. The processing module receives the
determined coordinate/address information from the antenna 130 and
receiver/decoder circuitry and determines route guidance based on the vehicles
current position as determined by the sensor subsystem and the received desired
destination address. Id. at 2:11-23, 3:65-4:46, 7:3-17, Fig. 3 (step 305). Route
guidance may take the form of turn-by-turn instructions, for example. Id. at 7:11-
14.
The present invention pertains to a method of enabling an on-board

vehicle navigation system to a compute a route from a current position
of the vehicle to a desired destination. . . . The data transmission
includes information specifying the location of the desired destination,
which can be used by the on-board vehicle navigation system to
compute the route.
Id. at 2:11-23.
The on-board navigation system 100, after inputting a desired

destination in the manner which is described below, uses the stored
map data to compute a route from the current position of the vehicle
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to the desired destination. Various techniques are known in the art for
computing a route based on such data. As the vehicle travels, the
system 100 outputs audible navigation instructions to the user via the
speaker 116 in the form of recorded (e.g., digitized) or synthesized
speech, to guide the user along the computed route to the destination.
Generally, an audible instruction prompts each significant action (i.e.,
each turn) that the driver must perform.
Id. at 4:19-4:30; see also id. at 3:65-4:18, 4:31-4:46, 7:3-17, Figs. 1, 3 (step 305).
[1(c)(iv)] a display module for displaying the route guidance; and
Oshizawa teaches an embodiment where text-based route guidance is
displayed on a display device:
It must be noted that, although many on-board navigation systems

include a visual display subsystem, the system 100 of FIG. 1 does not
include such a subsystem, according to one embodiment of the present
invention. As will be described below, a visual display subsystem can
be omitted without sacrificing the performance of the navigation
system. Note, however, that in alternative embodiments, a simple
display subsystem with minimal functionality (e.g. text only
display) may be included in the on-board navigation system 100.
In that case, the display device and any associated hardware can be
coupled to bus 24 in a manner that is well within the capabilities of
those skilled in the art and need not be described herein.
An on-board navigation system may include a computer, a stored

street map database, and various sensors to detect vehicle movement.
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The system is designed to compute a route to a selected destination
and generate guidance instructions to guide the user along the
computed route. The system may include a visual display device,
such as a liquid crystal display (LCD), by which navigation
information and other information are provided to the user. For
example, the system might display a moving vehicle symbol on an
image of a street map to indicate the movement of the vehicle through
a given area. The system might also display symbolic or textual
navigation instructions, such as a directional arrow to indicate the
next turn, or the instruction, Right turn on Innsbruck Drive.
Visual navigation instructions may be accompanied by audible
instructions generated as digitized or synthesized speech.
Thus, Oshizawa teaches this limitation. Further, to the extent Patent Owner
contends certain embodiments of Oshizawa do not teach displaying route guidance
instructions to the user, it would have nonetheless been obvious to a PHOSITA to
display the computed route guidance to the user, as taught and suggested by
Oshizawa, because it was well-known for conventional vehicle navigation systems
at the time to display computed route guidance from the vehicles position to the
users desired destination. Decl. (EX1003) at 44-46, 84-85. A PHOSITA
would have appreciated that it would have improved Oshizawas system in a
predictable and known way to display route guidance instructions in addition to
providing audible instructions so as to allow a user to view instructions for future
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turns the user has not yet reached and to allow the user to confirm an instruction
that they may not have heard clearly. Id. at 86.
[1(c)(v)] a communications network for coupling the positional information

device to the server.
Oshizawas system teaches establishing wireless links/connections over a
wireless communications network for coupling the on-board navigation device (the
recited positional information device) to the computer system 165 (the recited
server).
The link 161 may be any suitable form of wireless communication

link. A substantial distance may exist between the vehicle 140 and the
communications center 150 (i.e., many miles). Therefore, the link 161
may be a radio frequency (RF) link, such as a cellular telephone link,
citizens band (CB) radio, or any other suitable type of wireless
communication link. The link 161 may include satellites,
microwave towers, or other similar devices functioning as signal
relay points, repeaters, amplifiers, and the like.
Id. at 5:29-38 (emphases added); 6:10-30 (describing wireless communication
links 162 and 163 in Fig 2B).
Specifically, a wireless communication link 162 established over a wireless
communications network couples the on-board navigation device (positional
information device) to the computer system 165 (server), as shown in Fig. 2B:
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CDMA technology, PCS, and 3G technology, etc. Id. at 8:16-29 (emphasis
added).
A PHOSITA, therefore, would have understood that Oshizawa teaches a
communications network coupling the navigation system to the server consistent
with the 285 Patent in that Oshizawa teaches coupling a plurality of devices via
one or more wireless links that can use a radio frequency (RF) link, such as a
cellular telephone link, citizens band (CB) radio, or any other suitable type of
wireless communication link, which would be understood to be across a wireless
network that includes satellites, microwave towers, or other similar devices
functioning as signal relay points, repeaters, amplifiers, and the like in the
network. Decl. (EX1003) at 90; see also Oshizawa at 5:29-38, 6:10-30.
ii. Claim 2
2. The system as in claim 1, wherein the communications network is a telematics

network.
As described above, Oshizawa in view of Ikeda teaches Claim 1. The 285
Patent describes a telematics communications network 302 and states that the
network 302 may be a local area network (LAN), wide area network (WAN),
global area network (GAN) in accordance with IEEE 802.20, the Internet or any
known network that couples a plurality of computing devices to enable various
modes of communication via network messages. EX1001 at 8:11-40.
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Further, the 285 Patent provides that an example of telematics
communications network 302 is e.g., a network that enables data and voice
communications, without requiring it to enable both data and voice. 285 Patent
(EX1001), at 8:13-16, 8:50-53 (For example.); see also id. at 8:48-50 ([T]he
device 100 and server 304 may use any single communication method described
above or any combination thereof to provide telematics service, i.e., a combination
of telecommunications and data transfer.). Further, a PHOSITA would have
understood a telematics network in the automotive field at this time to mean a
network that provides location-based services for a vehicle over a wireless
telecommunications network. Decl. (EX1003) at 91-94; see also Zhao (EX1009)
at 1; Cho (EX1010) at 1. A PHOSITA, therefore, would have understood
Oshizawas wireless links (e.g, wireless link 162) to teach use of a telematics
network because it wirelessly transmits (over a distance) location data for a
destination using an RF, cellular, or any other suitable wireless network to an on-
board automotive navigation system. Decl. (EX1003) at 94; see also Oshizawa
(EX1004) at 5:15-57, 6:10-30, Fig. 2B. Further, while not required to, Oshizawas
communications network also supports both data and voice communications
(which aligns with an example provided by the 285 Patent) and provides
audio/voice channels and data channels, whether over the same or separate
wireless connections. Oshizawa (EX1004) at 5:15-57, 6:10-30, Fig. 2B.
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iii. Claim 5
5. The system as in claim 1, wherein the server retrieves the address from a
database residing on the server.
As described above, Oshizawa in view of Ikeda teaches Claim 1. Oshizawa
teaches that the operator causes computer system 165 (the recited server) to
retrieve the address from a database 174 (the recited database), which is
accessible to the computer system 165, prior to the computer system 165 wirelessly
transmitting the address to the navigation system. Oshizawa (EX1004), at Abstract;
5:58-61.
In step 303, the operator uses the computer system 165 to access the
database 174 to determine the exact coordinates of the desired
destination in terms that are usable by the navigation system 100; for
example, the navigation system may require that coordinates be
provided in terms of latitude/longitude, street address, link (street
segment) identifier, node (intersection) identifier, or other type of
location information.
Id. at 6:44-51 (emphases added).
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Further, to the extent Oshizawa is found to not expressly teach that the
database 174 resid[es] on the computer system 165, this would have nonetheless
also been obvious. A PHOSITA would have understood that a server accessing a
database residing locally in server memory was well known in the art at the time of
the 285 Patent, as taught in, for instance, Ikeda. Id. at 98-99. To wit, Ikeda
teaches an embodiment where a database 410 resides on the storage unit 401 of a
server 303:
In the illustrated example, the application server 303 is composed of a

storage unit 401, interfaces 402 and 403, and a control unit 404.
The storage unit 401 stores a variety of information that is required to

realize the functions of the application server 303. In the present case,
a user database 410 and executable applications 411 are representative
examples of the data stored in the storage unit 401.
Ikeda (EX1005), at [0132]-[0133]; see also, id. at Fig. 5, [0145]-[0149] (storage
unit 501 storing user database 510 (having same content as database 410) on
service server 500), Fig. 6.
It would have been an obvious and routine design choice for Oshizawas
database 174 to reside on the memory of computer system 165. Decl. (EX1003) at
99. As demonstrated by Ikeda, this was a well-known architecture for many years
prior to the 285 Patent that would have predictably resulted in enabling
Oshizawas operator to access the database 174 via computer system 165. Id.
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Oshizawas teachings that [i]n another embodiment, the entire database 174
may be located on a remote server, would have nonetheless, at a minimum,
suggested local storage as an option to a PHOSITA. Id. at 100. And, a
PHOSITA would have appreciated that locally storing a database would provide
benefits in faster retrieval times, easier database maintenance, and enhanced
security, such as in the example of Ikedas database, which may also store users
personal information. Id.; see also Ikeda at [0133]-[0136].
iv. Claim 6
6. The system as in claim 1, wherein the server resolves the address of the at least
one location into latitude and longitude coordinates.
As described above, Oshizawa in view of Ikeda teaches Claim 1. In
addition, Oshizawa teaches that the computer system 165 accesses the database to
resolve the location information in terms that are usable by the navigation system
100; for example, the navigation system may require that coordinates be provided
in terms of latitude/longitude, street address, link (street segment) identifier, node
(intersection) identifier, or other type of location information. Id. at 6:44-51
(emphasis added); see also, id. at Abstract.
v. Claim 7
7. The system as in claim 6, wherein the address is determined by information

associated to the address.
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addition, Oshizawa teaches that the address may be determined by information
associated to the address, such as the name of a business. Id. at 6:41-44 (In step
302, the user states the desired destination to the operator. For example, the user
may provide the name of a business as the desired destination.).
vi. Claim 9
9. The system as in claim 1, wherein the server is operated by a live operator and
the request for the at least one location is received by voice communications.
addition, Oshizawa teaches this limitation. See supra Claim [1(a)(i)].
B. Ground 2: Van Bosch in view of Chowanic renders claims 13-14 and

16 obvious
Van Bosch was filed on April 5, 2004 and published on October 6, 2005.
Van Bosch (EX1006). Van Bosch therefore qualifies as prior art with regard to the
285 Patent under 35 U.S.C. 102(e) (pre-AIA) as of its April 5, 2004 filing date.
Van Bosch was not cited or substantively discussed during prosecution of the 285
Patent. Van Bosch describes a wireless communication device in a vehicle that can
send and receive location-based messages to other users via a wireless
communications network. Van Bosch (EX1006) at Abstract, [0029], [0037]-
[0038], [0048]-[0049], [0060]-[0061], Figs. 1-3. The wireless communication
device includes a navigation unit, such as a GPS navigation unit, and is able to
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display the vehicles present position on a map. Id. at [0030]-[0031], [0053],
[0058], Figs. 2-3, 8-9, 12. The location-based messages include posting dates/times
that are used to determine when to display an address associated with the message
on the display. Id. at [0039], [0058], Figs. 4a, 4c. Thus, like the 285 Patent, Van
Bosch is also directed to a navigational or positional information system. Van
Bosch is therefore in the same field of endeavor and is analogous to the claimed
invention of the 285 Patent.
Chowanic issued on January 16, 2001 and therefore qualifies as prior art
with regard to the 285 Patent under 35 U.S.C. 102(b) (pre-AIA). Chowanic
(EX1007). Chowanic was not cited or substantively discussed during prosecution
of the 285 Patent. Chowanic describes [a] navigation system for automotive
vehicles that generates navigation routes between an initial location and a desired
destination. Id. at Abstract. The navigation system includes a display for
presenting route guidance which may include a navigation map and/or turn-by-
turn navigation instructions as the vehicle progresses along the determined
navigation route. Id. at 3:41-45. Thus, like the 285 Patent, Chowanic is also
directed to a navigational or positional information system. Chowanic is
therefore in the same field of endeavor and is analogous to the claimed invention
of the 285 Patent.
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i. Claim 13
13. A system for remotely entering location information into a positional

information device, the system comprising:
To the extent the preamble is limiting, Van Bosch teaches a system enabling
a first user in a first vehicle (or house) to cause a server to remotely enter location
information associated with a location-based message into a second users wireless
communication device 22 (i.e., positional information device), which includes a
navigation unit 62, and is installed in a second vehicle:
A system and procedure for posting and receiving location-based

messages in a wireless communication based network. The system
allows messages to be posted to specified users and to be
associated with a particular location for which the message is
pertinent. The messages can be left when a user passes a particular
location, or the user can specify the location for the message even if
not present at that location. The messages can then be displayed at a
user interface of the recipient either when the recipient nears that
location, or they can be reviewed in advance. . . . Regardless, the
disclosed system and methods allow messages to be associated with
particular locations of interest.
Van Bosch (EX1006), at Abstract (emphasis added).
FIG. 1 shows an exemplary vehicle-based communication system 10.

In this system, vehicles 26 are equipped with wireless communication
devices 22, which will be described in further detail below.
Id. at [0029].
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Id. at Fig. 1; see also id. at [0030]-[0031] (describing that wireless communication
device 22 includes a telematics control unit 40 and a head unit 50, which includes a
navigation unit 62 that includes a GPS system for associating the vehicles location
with mapping information the system provides); Figs. 2-3, 6; see also infra Claim
13(a)(i) (describing remote entry of location information by a first user into a
second users positional information device).
[13(a)(i)] a server configured to receive a request for an address of at least one

location not already stored in the positional information device,2
Van Bosch teaches a server 24 configured to receive a request from a first
user in a vehicle 26b or house 100 for a location-based message and accompanying
2
Petitioner notes that claim 13 does not specify where the request originates.
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location information, such as an address, to be sent by the server to a second user
in a vehicle 26a via server 24. Id. at [0029], [0037]-[0038], [0048]-[0049], [0060]-
[0061], Figs. 1, 3. To create a message, the first user enters the second users
identification information (e.g., system ID code, phone number, VIN, etc.), the
message text, a posting date/time for when the message should be displayed, and
the location information. Id. at [0048]-[0049], Figs. 4a-d; see also id. at [0039],
[0063]. The location information may be associated with the message in a variety
of ways. For example, the location information may be the latitude/longitude
coordinates of the first users current location, the first user may identify a specific
intersection, or the first user may use a mouse pointer of computer 101 to select a
location on a displayed map, such as for sending a message for the second user
regarding another location (e.g., for the location of a grocery store to pick up a
gallon of milk). Id. at [0043], [0049], [0064], [0066]. The server can receive the
message location information (e.g., lat/long coordinates) and convert it into a street
address. Id. at [0061].
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Id. at Fig. 1.
Thus, device 22 can wirelessly transmit or receive any of these types

of information to a transceiver or base station coupled to a wireless
network 28. Moreover, the wireless communication device may
receive information from satellite communications. Ultimately, the
network may be coupled to a public switched telephone network
(PSTN) 38, the Internet, or other communication network on route to
a server 24, which ultimately acts as the host for communications
on the communication system 10 and may comprise a
communications server.
The second vehicles messages can also be displayed in simple text

form along with their location data, as shown at Fig. 10. Because
displaying raw location information (longitude/latitude data) in this
circumstance is less informative than when a map is used (FIG. 9),
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location information may be simplified by the server 24 by displaying,
for example, a street address. In this regard, a mapping program can
be implemented on the server 24 to effectuate a location data-to-
street address conversion, as one skilled in the art understands.
Id. at [0061].
Id. at Fig. 10; see also id. at [0048]-[0049], [0060].
For the reasons discussed above, the claim limitation an address of at least
one location not already stored in the positional information device is a negative
claim limitation that may be adequately described by a cited prior art reference if
that reference does not otherwise require the presence of the element recited in the
negative limitation. See supra Sec. IV.A.i at claim [1(a)(i)]. Van Bosch does not
require the second vehicles wireless communication device 22 to already store the
address (or any other location data for the location-based message) prior to
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IPR2017-02022
receiving the location-based message from the server; a PHOSITA would
understand the same. Van Bosch (EX1006); see also Decl. (EX1003) at 108.
Indeed, neither does Van Bosch require the first vehicles device store the
addressparticularly where the first user simply selects a location on a map using
a mouse pointer and the server then determines the address for the requested
location. Decl. (EX1003) at 108. Van Bosch does affirmatively teach that after a
message is received by the second vehicle, it can remain stored in the memory 64
of the second vehicles 26b head unit 50 for some time to allow it again to be
reviewed again by the second vehicle if necessary, Van Bosch (EX1006) at
[0056], but Van Bosch is silent and does not require the address of a location-based
message be already stored in the second vehicles wireless communication device
prior to receiving the location-based message. Decl. (EX1003) at 108. As such,
Van Bosch discloses the limitation an address of at least one location not already
stored in the positional information device.
To the extent Van Boschs silence is not found to teach this element, it
would have nonetheless been obvious to a PHOSITA from Van Bosch that the
location/address information of the location-based message sent by a first user
would not already be stored on the second vehicles wireless communication
device prior to it even receiving the location-based message. Id. at 109. That is, it
would have been obvious that the location/address would not already be stored in
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the second device prior to it being sent. Id. Further, Van Boschs teaching that the
map may be sent by the server instead of the second vehicle pre-storing its own
map, Van Bosch (EX1006) at [0058], would have expressly suggested to a
PHOSITA that the second vehicle also does not pre-store addresses. Id. at 109. A
PHOSITA would have appreciated that it would be beneficial to not presume to
pre-store any address for the location-based message in the second users device
until it is actually received to ensure the correct address sent by the first user is
used. Id. Further, a PHOSITA would have appreciated that not locally pre-storing
a map or addresses would reduce memory requirements and potentially lower
system cost. Id.
[13(a)(ii)] to determine the address of the least one location
Van Boschs server includes a mapping program that determines the street
address of the received location data:
The second vehicles messages can also be displayed in simple text

form along with their location data, as shown at FIG. 10. Because
displaying raw location information (longitude/latitude data) in this
circumstance is less informative than when a map is used (FIG. 9),
location information may be simplified by the server 24 by displaying,
for example, a street address. In this regard, a mapping program
can be implemented on the server 24 to effectuate a location data-
to-street address conversion, as one skilled in the art understands.
Id. at [0061] (emphases added).
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[13(a)(iii)] and to transmit the determined address to the positional information
device;
Van Boschs server transmits the location-based message to the second
vehicle:
Alternatively, the server 24 can immediately transmit the message

to the second vehicle and the second vehicle 26b would then be
responsible for determining when the second vehicle 26b has
approached the stored location X1 and/or the message area (125)
around it, and if the time and or date are appropriate as specified with
the message, the message can be displayed within the second vehicle
accordingly.
Id. at [0055] (emphasis added). As discussed with regard to the limitation above
(i.e., [13(a)(ii)]), the location information may include the determined street
address of the requested location. Id. at [0061]. Further, as discussed earlier, the
second vehicle 26b receives the message via its wireless communication device
22b (positional information device), which includes the navigation unit 62. Id. at
[0029]-[0031], Figs. 1-2.
[13(b)(i)] the positional information device including a locational information

module for determining location information of the positional information
device;
Van Boschs wireless communication device 22 (i.e., positional information
device) includes a locational informational module, i.e., a navigation unit 62,
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which typically includes a Global Positioning Satellite (GPS) system for allowing
the vehicles location to be pinpointed. Id. at [0031].
Such location information may be automatically included with the

posting by having the controller 56 query the navigation unit 62 (see
FIG. 2) to receive the location of the first vehicle (i.e., its
latitude/longitude coordinates).
Id. at [0049] (emphasis added). The first and second vehicles wireless
communication devices 22a and 22b use the same type of wireless communication
device 22 and, thus, the second vehicles communication device 22b similarly
includes an identical navigation unit 62, which determines the location of the
second vehicle and its wireless communication device 22b. Id. at [0029]-[0031],
[0049], Figs. 1-2.
Location information for the devices present location is provided by
the navigation unit 62 (FIG. 2). Id. at [0053].
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60 and displays the messages, including the addresses determined by the server.
Id. at [0032]-[0033], [0055]-[0057], [0061], Figs. 2, 10. The controller 56 may
also display the location-based messages on a map showing the current position of
the vehicle relative to the locations associated with the received messages. Id. at
[0058], [0060], Figs. 8-9.
Although it is particularly beneficial to display or broadcast the

message to the second vehicle 26b when it is in the vicinity of the
location specified in the message, the second vehicle 26b may wish to
know what messages have been posted to him even prior to his arrival
at those locations. Accordingly, messages posted for the second
vehicle can be sent even in advance of the second vehicle approaching
the location of interest (e.g., X1), as shown in FIGS. 9-11.
Id. at [0060].
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Id. at Fig. 10; see also, id. at [0057], [0061], Figs. 2, 8-9.
Van Bosch teaches mapping a vehicles progress along a route (id. at
[0031]) and a program that generates and displays a directional map (id. at
[0058]). In addition, in order to display the vehicles progress along a route (Van
Bosch (EX1006) at [0031]), a PHOSITA would understand that the system would
need to have information about the planned route of the vehicle, otherwise there
would be no way to ascertain the progress of the vehicle along that route. Decl.
(EX1003) at 113. A PHOSITA would, at a minimum, have found these
disclosures to be highly suggestive of a system that determines route guidance
based on the devices present location and the determined address. Id.
Thus, even though Van Bosch does not expressly disclose that controller 56
determines route guidance from the vehicles current position to the address
associated with the received location-based message (i.e., the determined address),
it would be obvious to a PHOSITA to include such functionality, such as described
in Chowanic, as discussed below. Vehicle navigation systems, including
processing modules that determined route guidance from the current location of the
vehicle to a destination address, were extremely well-known for many years prior
to the 285 Patent, and a PHOSITA would have appreciated the benefit of
including this well-known functionality, as set forth below. Id. at 44, 114-115;
see also Chowanic (EX1007) at 1:13-30 (describing such systems as well
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known). Chowanic, for example, teaches such a vehicle navigation system
having a navigation controller that generates route guidance to a destination
address. Chowanic (EX1007), at Abstract, 2:35-37, 2:53-58, Figs 1-2. A vehicle
position locator 17, such as a GPS receiver, supplies the current vehicle position to
the navigation controller. Id. at 2:45-49, Fig. 1. Then, the user selects a desired
destination address and the navigation controller determines a route for traveling
from the current location to the destination address. Id. at 2:54-58, 3:4-9, Figs, 2-
3. Route guidance, such as turn-by-turn instructions are also generated as part of
the route. Id. at 2:58-60, Fig. 3. Further, the navigation system may also include a
wireless communication link 18 coupled to navigation controller 10 for receiving
remotely supplied navigation or traffic data, for example. Id. at 2:49-52.
Id. at Fig. 1, 2:35-60.
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Id. at Fig. 2.
Next, a DESTINATION INPUT menu 26 appears where the format of

the destination input is chosen from choices of address, cross-street, or
points of interest. Assuming that the address choice is selected, an
ADDRESS menu 27 is presented for allowing textual input of a
country/state, city, and/or address of the destination.
Id. at 3:4-9.
Id. at Fig. 3.
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It would have been obvious to a PHOSITA to enable Van Boschs controller
56 to determine route guidance to an address associated with a wirelessly received
location-based message based on the location of the vehicle as determined by the
navigation unit 62. Decl. (EX1003) at 116. As demonstrated by Chowanic, route
guidance generation was a common feature of on-board navigation systems well
before the alleged invention of the 285 Patent. Id. Given that Van Boschs
wireless communication device may be equipped with a mapping program used to
generate a directional map and is able to be used for mapping a vehicles
progress along a route, a PHOSITA would have expected Van Boschs on-board
device to similarly provide route guidance and would have been motivated by
these express teachings to have it do so. Id. (citing Van Bosch (EX1006), at
[0058]).
Van Bosch teaches that a location-based message (and its associated address)
may be displayed at a specific posting date/time specified by the message sender or
when in close proximity to the location associated with the message. Van Bosch
(EX1006), at Abstract, [0060]. Van Bosch also teaches that the location-based
messages and their addresses can be displayed in advance of arrival to the locations
associated with the messages. Id. at [0060]-[0061], Fig. 10. A PHOSITA would
have appreciated that when the message is displayed at the posting date/time and
the user has not arrived at the location, it would have been beneficial and obvious
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to enable Van Boschs controller 56 to determine route guidance from the vehicles
current location to the messages determined address. Decl. (EX1003) at 117. For
example, it would have been obvious to allow the user to select the displayed
address from the message display screen depicted in Fig. 10. Id. Including well-
known and familiar route guidance features, as taught in Chowanic, in Van Boschs
wireless communication device 22, which already includes a map database and
map display, would have predictably resulted in enabling the user to generate a
route to an address associated with a received location-based message, and a
PHOSITA would have appreciated that incorporating this well-known feature
would have improved Van Boschs device by making it a more full-featured
navigation system capable of providing route guidance. Id. at 118.
[13(b)(iv)] a display module for displaying the route guidance; and
Van Boschs wireless communication device 22 includes a display 79. Van
Bosch (EX1006), at [0032], Fig. 2. Van Bosch also teaches mapping a vehicle's
progress along a route and a mapping program generating a directional map, but
does not expressly teach displaying route guidance to a received address. Id. at
[0031], [0058], Figs. 8-9.
As discussed above, vehicle navigation systems that displayed route
guidance were commonplace for many years prior to the 285 Patent. Decl.
(EX1003) at 44-46, 120. For instance, Chowanics vehicle navigation system
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includes a display present[ing] a GUIDANCE DISPLAY 29 which may include a
navigation map and/or turn-by-turn navigation instructions as the vehicle
progresses along the determined navigation route. Chowanic (EX1007), at 3:41-
45; see also, id. at 2:35-39 (LCD matrix display), Figs. 2-3.
For the reasons discussed with regard to the previous limitation, it would
have been obvious to a PHOSITA to enable Van Boschs controller 56 to
determine route guidance to an address associated with a received location-based
message based on the location of the vehicle as determined by the navigation unit
62. See supra Claim [13(b)(iii)]. It would have also been obvious to a PHOSITA
to enable Van Boschs controller 56 to display the route guidance on the display 79
as taught by Chowanic. Decl. (EX1003) at 121. A PHOSITA would have
appreciated that visually displaying route guidance was one of a finite number of
well-known ways to present route guidance to a user of a vehicle navigation
system. Id. at 122. Specifically, a PHOSITA would have known that route
guidance could be provided to the user visually on a display and/or audibly via a
speaker. Id. As such, a skilled artisan could have enabled Van Boschs wireless
communication device 22s display 79 to provide visual route guidance, such as
turn-by-turn directions, on the display 79 with a reasonable expectation of success.
Id. And a PHOSITA would have appreciated that displaying the route guidance
visually would have predictably improved Van Boschs navigation unit by making
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it easier for the user to navigate to an address associated with a location-based
message. Id.
[13(b)(v)] a communications network for coupling the positional information

device to the server,
Van Boschs system includes a communications network 28/38 for coupling
the wireless communications devices 22a, 22b in the vehicles 26a, 26b to the
server 24:
Id. at Fig. 1.
The communication device 22 is capable of sending and receiving

voice (i.e., speech), data (such as textual or SMS data), and/or video.
Thus, device 22 can wirelessly transmit or receive any of these types
of information to a transceiver or base station coupled to a wireless
network 28. Moreover, the wireless communication device may
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IPR2017-02022
receive information from satellite communications. Ultimately, the
network may be coupled to a public switched telephone network
(PSTN) 38, the Internet, or other communication network on
route to a server 24, which ultimately acts as the host for
communications on the communication system 10 and may comprise
a communications server.
[13(c)] wherein the server receives a time and date associated with the requested
at least one location and transmits the associated time and date with the
determined address to the positional information device and the positional
information device displays the determined address at the associated time and
date.
Van Bosch teaches that when the server receives the request from the first
user for the server to transmit the location-based message, including the
determined address, to the second users wireless communication device (i.e.
positional information device), the server can receive a posting date/time (i.e.,
associated time and date) from the first user that determines when their message,
with the address, will be displayed by the second users wireless communication
device:
The first vehicle 26 a can leave the message for the second vehicle
26b in a number of different ways using the user interface 51 in the
first vehicle. . . . Because the message may also have pertinence to a
particular time of day, or time period during the day, or a
particular day, or day of the week, the first vehicle 26 a can also
specify the dates and times at which the message should be
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IPR2017-02022
transmitted to the second vehicle 26b. For example, if the message
refers to an item that the second vehicle needs to pick up at a store
after work, receipt of the message at a particular time of day (3:00-
4:00 pm) may be the only pertinent time at which the message need be
transmitted, and the first vehicle can so designate. Accordingly, the
posting and expiration dates, time, periods, are specifiable.
Id. at Fig. 4a; see also, id. at Fig. 4c.
Van Boschs server receives the message data from the first users device.
Id. at [0048]-[0049], Fig. 6. The message data received by the server is a data
stream including the message text, and a header containing the user IDs, the
posting data/time, etc., in predictable formats so they will be easily interpreted by
the server 24. Once at the server 24, the information is preferably decompiled to
65
IPR2017-02022
understand the various pieces of information, and is stored in a file 122 as shown
in FIG. 6. Id. at [0049] (emphasis added).
Id. at Fig. 6 (post time/date).
In one embodiment, the server determines when to transmit the message to
the second users device based on the posting date/time. Id. at [0054]. However,
in an alternate embodiment, the server 24 can immediately transmit the message
to the second vehicle and the second vehicle 26b would then be responsible for
determining when the second vehicle 26b has approached the stored location X1
and/or the message area (125) around it, and if the time and or date are
appropriate as specified with the message, the message can be displayed
within the second vehicle accordingly. Id. at [0055] (emphasis added); see also,
id. at Fig. 6. When it is time to display the message per the posting date/time, the
66
IPR2017-02022
second users device displays the message and its determined address as shown in
Figure 10:
Id. at Fig. 10; see also, id. at [0061]-[0062], Fig. 11.
ii. Claim 14
14. The system as in claim 13, wherein the communications network is a

telematics network.
Van Bosch in view of Chowanic teaches Claim 13, as discussed above.
Further, Van Bosch teaches a communications network that is a telematics network
because its network provides location-based services for a vehicle over a wireless
telecommunications network. Decl. (EX1003) at 91-94; see also Zhao (EX1009)
at 1; Chao (EX1010) at 1. Van Bosch expressly teaches that the wireless
communication devices 22 in the users vehicles include a Telematics control
67
IPR2017-02022
unit 40 [that] is essentially responsible for sending and receiving voice or data
communications to and from the vehicle, i.e., wirelessly to and from the rest of the
communications system 10. As such, it comprises a Telematics controller 46 to
organize such communications, and a network access device (NAD) 42 which
include a wireless transceiver. Van Bosch (EX1006) at [0033] (emphases added);
see also id. at [0029], [0035]-[0037], Figs. 1-2; see also supra Claim 13(a)(i). The
285 Patent describes that an example of a telematics network is e.g., a network
that enables data and voice communications. 285 Patent (EX1001) at 8:13-16.
Thus, Van Boschs network also aligns with a disclosed embodiment of the 285
Patents telematics network. Van Bosch (EX1006) at [0029] (The communication
device 22 is capable of sending and receiving voice (i.e., speech), data (such as
textual or SMS data), and/or video. Thus, device 22 can wirelessly transmit or
receive any of these types of information to a transceiver or base station coupled to
a wireless network 28. Moreover, the wireless communication device may receive
information from satellite communications.) (emphasis added).
iii. Claim 16
16. The system as in claim 13, wherein the server is further configured to
transmit an appropriate map related to the determined address to the positional
information device.
As described above, Van Bosch in view of Chowanic teaches Claim 13. In
addition, Van Bosch teaches an embodiment where the server 24 is configured to
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IPR2017-02022
transmit a map displaying the location/address associated with the message to the
wireless communication device:
Otherwise, a map displaying the location can be formulated by the

server 24 and sent along with the message, which saves the trouble of
the second vehicle having to formulate a map and to associate it with
the location in the message.
Id. at [0058]; see also, id. at Figs. 8-9.
C. Ground 3: Van Bosch in view of Chowanic in further view of

Oshizawa renders claim 15 obvious
iv. Claim 15
15. The system as in claim 13, wherein the server is operated by a live operator
and the request for the at least one location is received by voice communications.
As described above, Van Bosch in view of Chowanic teaches Claim 13. Van
Bosch teaches, the server 24 can be part of a service center that provides other
services to the vehicles 26, such as emergency services 34 or other information
services 36 (such as restaurant services, directory assistance, etc.). Van Bosch
(EX1006) at [0029]. Van Bosch also teaches that the first user may use a voice
recognition module to generate the location-based message for the second user. Id.
at [0043]. However, Van Bosch does not expressly disclose that a live operator
operates the server or that the request for the at least one location is received by
voice communications.
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IPR2017-02022
As discussed above, Oshizawa teaches a human operator in a
communication center 150 receives the users location request via a cellular
telephone or any other wireless, two-way audio communications link and accesses
a computer system 165 to look up the address of the requested location. Oshizawa
(EX1004), at Abstract; see also, id. at 5:1-19, 5:15-19, 6:31-44, Figs. 2A-B, 3
(steps 301-302). Oshizawa teaches that a human operator is preferable over voice
recognition technology because while voice recognition technology has improved
substantially in recent years, it is believed that such technology has not yet
developed to the extent necessary to allow this information to be input vocally with
sufficient consistency and accuracy. Id. at 4:63-67.
A PHOSITA implementing Van Boschs system would have been motivated
to ensure that the user was able to accurately input message/location data. Decl.
(EX1003) at 125. Based on Oshizawas explicit suggestion, a PHOSITA would
have understood that Van Boschs server could similarly be operated by a human
operator as taught by Oshizawa in order to allow location-based message
information to be input accurately by the users, rather than using inaccurate voice
recognition technology and especially given that the users in vehicles would be
likely to be driving while inputting messages. Id.
Van Bosch teaches that an occupant in the first vehicle 26a can call the
server 24 to receive services. Van Bosch (EX1006), at [0036]. It would have
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IPR2017-02022
been obvious to a PHOSITA to enable the user to call the server 24 to create a
location-based message and include a human operator to receive the users
location-based message request via voice communications. Decl. (EX1003) at
126. This modification to Van Boschs system would have predictably enabled
the user to accurately input message/location data thereby increasing user
satisfaction as compared to voice recognition and, thus, also enhancing a users
safety in using the system while driving; and a PHOSITA, therefore, would have
been motivated to combine Oshizawa with Van Bosch. Id.
D. Ground 4: Van Bosch in view of Chowanic in further view of Cooper

renders claims 17 and 18 obvious
Cooper was filed on September 5, 2005 claiming priority to provisional
applications filed on September 7, 2004 and November 12, 2004. Cooper
(EX1008). Cooper, therefore, qualifies as prior art with regard to the 285 Patent
under 35 U.S.C. 102(e) (pre-AIA). Cooper discloses a system enabling portable
electronic devices, such as mobile wireless telephones, GPS units, PDAs, and
automobile navigation systems to share point of interest or pushpin data with other
devices over a network. Id. at Abstract, [0062], [0069]-[0070], Fig. 2. The
portable electronic device includes a GPS receiver 120 or other device configured
to identify at least approximately the location of the device 100. Id. at [0067].
The device also displays navigational and positional information such as map data.
Id. at [0078]. Thus, like the 285 Patent, Cooper is also directed to a navigational
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IPR2017-02022
or positional information system. Cooper (EX1008), at Abstract, [0006]. Cooper
is therefore in the same field of endeavor and is analogous to the claimed invention
of the 285 Patent.
v. Claim 17
17. The system as in claim 13, wherein if the processing module of the positional
information device determines that a map corresponding to the determined
address is not available, the communication module transmits a second request
for an appropriate map associated to the determined address.
As described above, Van Bosch in view of Chowanic teaches Claim 13.
Further, as described in Section IV.B.iii for claim 16, Van Bosch teaches an
embodiment where the server is configured to transmit a map displaying the
location/address associated with the message to the wireless communication
device, which is particular[ly] beneficial if the second vehicle 26b is unable to
formulate its own map. Van Bosch (EX1006) at [0058]; see also, id. at Figs. 8-9.
However, Van Bosch is silent with regard to whether or not the wireless
communication device must first determine that a map corresponding to the
determined address for the message is not available and then request this map data
from the server.
Cooper, however, teaches the same. Cooper teaches a portable electronic
device that stores map data in a cache and downloads additional map segments
from a server as needed by a mapping application. Cooper (EX1008), at [0076].
In one embodiment, a mapping application module 202 identifies the map
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IPR2017-02022
segments index numbers (from one or more of the different zoom levels)
which are not already stored in cache and requests such segments from the
server. Id. at [0115] (emphases added); see also, id. at Fig. 17B. Cooper teaches
that this intelligent map caching method has the benefits of reducing map
processing time and processor power. Id. at [0106].
In one embodiment, the mapping application module 202 is

configured to communicate with one or more map and geographic
based content servers to download map data and geographic based
content as needed. In one embodiment, the mapping application
module 202 maintains a local cache or store of map data.
The method includes intelligently downloading and storing map

segments on the electronic device 100 to ensure that newly requested
map segments get downloaded and cached and previously
downloaded and cached map segments get retrieved and instantly
displayed. In addition, map segments which have not been viewed
recently get discarded from the map cache first, map segments which
are rarely viewed get discarded first, and segments with low
significance (based on last view date and time and number of views)
and lowest zoom level get deleted first, such that the memory
available to the device does not tend to get over-filled.
Id. at [0106].
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IPR2017-02022
Based on the teachings of Van Bosch and Cooper, it would have been
obvious to a PHOSITA to enable the controller of Van Boschs wireless
communication device to determine that a map associated with a received location-
based message is not available and transmit a request for an appropriate map to the
server, as taught by Cooper, via Van Boschs telematics control unit 40. Decl.
(EX1003) at 129. A PHOSITA would have been motivated by Van Boschs
teaching that it is particular[ly] beneficial for the server to send map data for the
location/address if the second vehicle 26b is unable to formulate its own map to
look to known ways to determine whether the second vehicle is unable to
formulate its own mapsuch as Coopers teaching that the device determines if
needed map segments are not already stored and requesting those segments from
the server. Id. at 130. A PHOSITA would have appreciated that locally caching
the map data used the most and requesting additional map data on an as-needed
basis would have predictably reduced memory and processing demands as taught
by Cooper, and a PHOSITA would, therefore, also have been motivated to
combine Cooper with Van Bosch to improve Van Boschs system in this same
manner. Id.
vi. Claim 18
18. The system as in claim 17, wherein the server is further configured to
transmit an appropriate map related to the determined address to the positional
information device.
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IPR2017-02022
As described above, Van Bosch in view of Chowanic in further view of
Cooper teaches Claim 17. In addition, Van Bosch teaches that the server can
transmit an appropriate map associated with the determined address to the
positional information device. See supra Section IV.B.iii (Van Bosch applied to
Claim 16); Van Bosch (EX1006) at [0058].
V. CONCLUSION
For the forgoing reasons, Petitioner respectfully requests inter partes review
of claims 1, 2, 5-7, 9, and 13-18 of the 285 Patent.
Respectfully submitted,
BY: /s/ Jason R. Mudd

Jason R. Mudd, Reg. No. 57,700
Eric A. Buresh, Reg. No. 50,394
Jonathan Stroud, Reg. No. 72,518
Ashraf Fawzy, Reg. No. 67,914
ATTORNEYS FOR PETITIONER
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IPR2017-02022
VI. MANDATORY NOTICES UNDER 37 C.F.R. 42.8(A)(1)
A. Real Party-In-Interest
The Petitioner is the real party-in-interest. 37 C.F.R. 42.8(b)(1). No other
party exercised control or could exercise control over Petitioners participation in
this proceeding, the filing of this petition, or the conduct of any ensuing trial.
B. Related Matters
Pursuant to 37 C.F.R. 42.8(b)(2), Petitioner is aware of the following
pending patent infringement lawsuits involving the 285 Patent:
Geographic Location Innovations LLC v. Capital One, National
Association, Case No. 2:17-cv-00490 (E.D. Texas);
Geographic Location Innovations LLC v. Choice Hotels International,
Inc., Case No. 2:17-cv-00491 (E.D. Texas);
Geographic Location Innovations LLC v. Gym-Mark, Inc., Case No.
2:17-cv-00492 (E.D. Texas);
Geographic Location Innovations LLC v. The Kroger Co., Case No.
2:17-cv-00493 (E.D. Texas); and
Geographic Location Innovations LLC v. Phillips 66 Company, Case No.
2:17-cv-00494 (E.D. Texas).
Petitioner is also aware of the following terminated patent infringement
lawsuits involving the 285 Patent:
76
IPR2017-02022
Qaxaz LLC v. Ford Motor Company et al., Case No. 1:11-cv-00491
(Delaware);
Qaxaz LLC v. Alpine Electronics of America Inc. et al., Case No. 1:11-
cv-00492 (Delaware);
Rothschild GPS Sharing Innovations, LLC v. Nissan North America, Inc.,
Case No. 3:14-cv-00819 (S.D. California);
Rothschild Location Technologies LLC v. Calamp Corp., Case No. 1:14-
cv-00632 (Delaware);
Rothschild Location Technologies LLC v. Discrete Wireless Inc., Case
No. 1:14-cv-00634 (Delaware);
Rothschild Location Technologies LLC v Teletrac Inc., Case No. 1:14-cv-
00639 (Delaware);
Rothschild Location Technologies LLC v. Nissan North America Inc.,
Case No. 1:14-cv-00879 (Delaware);
Rothschild Location Technologies LLC v. Hyundai Motor America, Case
No. 1:14-cv-01128 (Delaware);
Rothschild Location Technologies LLC v. Volkswagen Group of America
Inc., Case No. 1:14-cv-01129 (Delaware);
Rothschild Location Technologies LLC v. Volvo Cars of North America
77
IPR2017-02022
LLC, Case No. 1:14-cv-01130 (Delaware);
Rothschild Location Technologies LLC v. American Honda Motor
Company Inc., Case No. 1:14-cv-01351 (Delaware);
Geographic Location Innovations LLC v. Discount Tire Co. d/b/a
Discount Tire d/b/a America's Tire, Case No. 2:16-cv-01327 (E.D. Texas);
Geographic Location Innovations LLC v. Dollar Tree Stores, Inc., Case
No. 2:16-cv-01329 (E.D. Texas);
Geographic Location Innovations LLC v. Bridgestone Americas Tire,
Operations LLC, Case No. 2:16-cv-01330 (E.D. Texas);
Geographic Location Innovations LLC v. Nordstrom, Inc., Case No.
2:16-cv-01332 (E.D. Texas);
Geographic Location Innovations LLC v. Safeway Inc. d/b/a Tom Thumb,
Case No. 2:16-cv-01333 (E.D. Texas);
Geographic Location Innovations LLC v. U-Haul International, Inc.,
Case No. 2:16-cv-01335 (E.D. Texas);
Geographic Location Innovations LLC v. United Parcel Service, Inc. et
al., Case No. 2:16-cv-01336 (E.D. Texas); and
Geographic Location Innovations LLC v. BB&T Corporation, Case No.
2:17-cv-00489 (E.D. Texas).
Petitioner is also aware that Volkswagen Group of America, Inc. filed an
78
IPR2017-02022
Overland Park, Kansas 66211
Telephone: (913) 777-5600
Ashraf A. Fawzy (Reg. No. 67,914)
afawzy@unifiedpatents.com
Postal and Hand-Delivery Address:
Unified Patents Inc.
1875 Connecticut Ave. NW, Floor 10
Washington, D.C. 20009
Telephone: (202) 871-0110
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IPR2017-02022
APPENDIX OF EXHIBITS
Exhibit 1001 U.S. Patent 7,917,285 B2 to Rothschild (285 Patent)

Exhibit 1002 File History of U.S. Patent 7,917,285 B2 to Rothschild (285
Patent File History)
Exhibit 1003 Expert Declaration of Scott Andrews (Decl.)
Exhibit 1004 U.S. Patent No. 5,987,381 to Oshizawa (Oshizawa)
Exhibit 1005 U.S. Patent Application Publication No. 2002/0174360A1 to
Ikeda (Ikeda)
Exhibit 1006 U.S. Patent Application Publication No. 2005/0221876A1 to Van
Bosch et al. (Van Bosch)
Exhibit 1007 U.S. Patent No. 6,175,803 to Chowanic et al. (Chowanic)
Exhibit 1008 U.S. Patent Application Publication No. 2006/0058953A1 to
Cooper et al. (Cooper)
Exhibit 1009 Zhao, Y., Telematics: Safe and Fun Driving, IEEE Intelligent
Systems, pp. 10-14, 2002 (Zhao)
Exhibit 1010 Cho, K.Y., et al., Overview of Telematics: A System Architecture
Approach, Intl Journal of Automotive Technology, Vol 7, No. 4,
pp. 509-517, 2006 (Cho)
Exhibit 1011 U.S. Patent No. 4,502,123 to Minami et.al. (Minami)
Exhibit 1012 Robert L. French, Automobile Navigation: Where is it Going?,
IEEE Aerospace and Electronic Systems Magazine, Volume: 2,
Issue: 5, May 1987 (French 1987)
Exhibit 1013 Robert L. French, Historical overview of automobile navigation
technology, 36th IEEE Vehicular Technology Conference (1986)
(French 1986)
Exhibit 1014 V.W. Imnan and J.I. Peters, TravTek Global Evaluation and
Executive Summary, U.S. Department of Transportation Federal
Highway Administration, Pub. No. FHWA-RD-96-031, March
1996 (Imnan)
Exhibit 1015 C. Blumentritt, K. Balke, E. Symour, R. Sanchez, TravTek System
Architecture Evaluation, U.S. Department of Transportation
Federal Highway Administration, Pub. No. FHWA-RD-94-141
(July 1995) (Blumentritt)
Exhibit 1016 R. Lind, R. Schumacher, R. Reger, R. Olney, H. Yen, and R.
Freeman, The network vehicle-a glimpse into the future of mobile
IPR2017-02022
multi-media, The AIAA/IEEE/SAE Digital Avionics Systems
Conference Proceedings, 17th DASC., 1998 (Lind)
Exhibit 1017 Network Vehicle Screenshots (Network Vehicle Screenshots)
Exhibit 1018 Curriculum Vitae of Scott Andrews
Exhibit 1019 Takao Kamai, Hayami Encho, Ichiro Kugo, Katsuharu
Yokoyama, and Masato Maruoka, MONET Compatible Car-
mounted Information Terminal, Fujitsu Ten Tech. J., No. 11
(1998) (Kamai)
IPR2017-02022
CERTIFICATION OF WORD COUNT
The undersigned certifies pursuant to 37 C.F.R. 42.24 that the foregoing

Petition for Inter Partes Review, excluding any table of contents, mandatory
notices under 37 C.F.R. 42.8, certificates of service or word count, or appendix of
exhibits, contains 13,984 words according to the word-processing program used to
prepare this document (Microsoft Word).
Dated: September 1, 2017

ATTORNEY FOR PETITIONER

IPR2017-02022
CERTIFICATE OF SERVICE ON PATENT OWNER

UNDER 37 C.F.R. 42.105
Pursuant to 37 C.F.R. 42.6(e) and 42.105, the undersigned certifies that

on September 1, 2017, a complete and entire copy of this Petition for Inter Partes
Review including exhibits was provided via Federal Express to the Patent Owner
by serving the correspondence address of record for the 285 Patent as listed on
PAIR:
Hespos & Porco LLP

110 West 40th Street
Suite 2501
New York, NY 10018
Further, a courtesy copy of this Petition for Inter Partes Review was sent via
e-mail to Patent Owners litigation counsel:
Jay Johnson
D. Bradley Kizzia
Kizzia Johnson, PLLC
1910 Pacific Ave., Suite 13000
Dallas, Texas 75201
jay@kjpllc.com
bkizzia@kjpllc.com

ATTORNEY FOR PETITIONER

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IPR2017-02022

U.S. Patent 7,917,285

Filed on behalf of Unified Patents Inc.

Jonathan Stroud, Reg. No. 72,518

UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE PATENT TRIAL AND APPEAL BOARD

UNIFIED PATENTS INC.

GEOGRAPHIC LOCATION INNOVATIONS, LLC

PETITION FOR INTER PARTES REVIEW

Petitioner Unified Patents Inc. (Petitioner) respectfully requests an inter

partes review (IPR) of claims 1, 2, 5-7, 9, and 13-18 (collectively, the

Challenged Claims) of U.S. Patent 7,917,285 (the 285 Patent).

II. SUMMARY OF THE 285 PATENT

A. Description of the alleged invention of the 285 Patent

to manually program locations into conventional GPS devices. 285 Patent

navigation or positional information device including but not limited to a vehicle-

module, employing conventional location information processing technology,

(PDA), a server residing on the Internet, etc.

information and for transmitting information to the GPS device:

providing route guidance to the address.

communications or any other type of communication link. Id. at 8:62-9:3. The

vehicle or device is identified using an identifier, such as a cellular phone number

or IP address, which can be transmitted to the CSC or detected using conventional

coordinates of the location. Id. at 12:12-52. The determined address or coordinate

guidance to the location. Id.

B. Summary of the prosecution history of the 285 Patent

285 Patent File History (EX1002), at 2. For purposes of this proceeding,

During prosecution, the Examiner twice rejected as anticipated pending

being configured to determine a second identifier for identifying the positional

amendment, Applicant also added independent claim 45, which subsequently

issued a Notice of Allowance allowing independent claims 25 and 45 and their

and 45 subsequently issued as claims 1 and 13, respectively. Id. at 128.

III. REQUIREMENTS FOR INTER PARTES REVIEW UNDER 37 C.F.R.

A. Grounds for standing under 37 C.F.R. 42.104(a)

the 285 Patent.

B. Identification of challenge under 37 C.F.R. 42.104(b) and relief

18 of the 285 Patent are unpatentable and should be cancelled. 37 C.F.R.

have been a person having the equivalent of a bachelors degree in electrical

engineering, computer engineering, computer science, or a similar discipline, and

vehicle telematics technologies, or an equivalent amount of similar work

experience or education, with additional education substituting for experience and

additional experience substituting for education. Decl. (EX1003) at 53.

D. Claim construction under 37 C.F.R. 42.104(b)(3)

In this proceeding, claim terms of an unexpired patent should be given their

broadest reasonable construction in light of the specification. 37 C.F.R.

ordinary skill in the art in light of the specification.

IV. THERE IS A REASONABLE LIKELIHOOD THAT THE

A. Ground 1: Oshizawa in view of Ikeda renders claims 1-2, 5-7, and 9

regard to the 285 Patent under 35 U.S.C. 102(b) (pre-AIA). Oshizawa

of the 285 Patent. Oshizawa describes [a]n on-board automobile navigation

system . . . us[ing] destination data downloaded from a remote transmission

the process of entering a desired destination for the user.).

The 285 Patent is broadly directed to the field of navigational or positional

information systems. 285 Patent (EX1001), at 1:9-13. Oshizawa similarly

(EX1004), at 1:5-6. As such, Oshizawa is in the same field of endeavor and is

including a communications center housing a human operator and computer

system, a communication device (such as a mobile telephone), and an on-board

vehicle navigation system is depicted below:

mobile phone having

mobile phone. Id.

1. A system for remotely entering location information into a positional

To the extent it is deemed limiting, Oshizawa discloses the preamble.

Oshizawa teaches a system for remotely entering a desired destination (i.e.,

location information) into an on-board vehicle navigation device (i.e.,