Unified Patents Inc. v. Shipping & Transit, LLC, IPR2017-00361, Paper 1 (Dec. 1, 2016) (Petition)

IPR2017-00361
U.S. Patent No. 6,415,207

Filed on behalf of Unified Patents Inc.
By:
P. Andrew Riley
Finnegan, Henderson,
Farabow, Garrett & Dunner, L.L.P.
901 New York Avenue, NW
Washington, DC 200014413
Telephone: 202-408-4266
Facsimile: 202-408-4400
Jonathan Stroud
Unified Patents Inc.
1875 Connecticut Ave. NW, Floor 10
Washington, D.C., 20009
Telephone: 202-805-8931
Email: Shipping-Transit-207IPR@finnegan.com
UNITED STATES PATENT AND TRADEMARK OFFICE
BEFORE THE PATENT TRIAL AND APPEAL BOARD
UNIFIED PATENTS INC.,

Petitioner
v.
SHIPPING & TRANSIT, LLC,
Patent Owner
Case IPR2017-00361
U.S. Patent No. 6,415,207 B1
SYSTEM AND METHOD FOR AUTOMATICALLY
PROVIDING VEHICLE STATUS INFORMATION
PETITION FOR INTER PARTES REVIEW
IPR2017-00361
TABLE OF CONTENTS
I.
Introduction.................................................................................................................... 1
II.
Mandatory Notices Under 37 C.F.R. 42.8 ........................................................... 1

A.
Real Parties-in-Interest .................................................................................... 1
B.
Related Matters ................................................................................................. 2
C.
Lead and Backup Counsel Information .....................................................14
III.
Fee Payment ................................................................................................................15
IV.
Statement of Precise Relief Requested for Each Claim Challenged ...............15
V.
VI.
A.
Claims for Which Review is Requested ....................................................15
B.
Statutory Grounds of Challenge ..................................................................15
The 207 Patent ...........................................................................................................16

A.
Overview of the Disclosure ..........................................................................16
B.
Prosecution History ........................................................................................19
C.
Level of Ordinary Skill in the Art ...............................................................20
D.
Challenged Claims..........................................................................................20
Claim Construction ....................................................................................................22
VII. Statement of Relief Requested: 37 C.F.R. 42.104(b) (Grounds 1-2) ...........26

A.
Ground 1: Peterson renders obvious challenged claims 1-15...............26

1.
Overview of Peterson ........................................................................26
1.
Peterson renders obvious claim 1 ...................................................28
2.
Peterson renders claim 2 obvious ...................................................32
3.
Peterson renders claim 9 obvious ..................................................32
IPR2017-00361
4.
B.
C.
Peterson renders claims 3-8, 10-15 obvious .................................34
Ground 2: Smith in view of Janky renders obvious challenged

claims 1-15 .......................................................................................................36
1.
Overview of Smith ..............................................................................36
2.
Overview of Janky ..............................................................................37
3.
Smith and Janky render obvious the subject matter of

claim 1 ...................................................................................................39
4.

claim 2 ...................................................................................................49
5.
Smith renders obvious the subject matter of claim 3 ...................50
6.

claim 9 ..................................................................................................51
7.

claims 4-8, 10-15 ...............................................................................52
Ground 3: Trask in view of Janky renders obvious challenged

claims 1-15 .......................................................................................................55
1.
Overview of Trask ..............................................................................55
2.
Trask and Janky render obvious the subject matter of

claim 1 ...................................................................................................57
3.

claim 2 ...................................................................................................64
4.
Trask renders obvious the subject matter of claim 3 ...................64
5.

claim 9 ..................................................................................................66
1.

claims 4-8, 10-15 ...............................................................................67
ii
IPR2017-00361
VIII. Conclusion ...................................................................................................................69
iii
IPR2017-00361
I.
Introduction
Unified Patents Inc. (Unified or Petitioner) requests inter partes review
of claims 1-15 of U.S. Patent No. 6,415,207 (the 207 patent) (EX1001), now
purportedly assigned to Shipping & Transit, LLC (Shipping or Patent Owner),
in accordance with 35 U.S.C. 311-319 and 37 C.F.R. 42.100 et seq. The 207
patent broadly claims systems and methods for monitoring and reporting the status
of vehicles. It describes using an interface to communicate with a system manager
configured to store status and related information associated with a vehicle in a
database. The system manager is also configured to retrieve status information and
to transmit this information to a remote communications device.
Systems and methods for monitoring, storing, and reporting vehicle status
information, however, were known before the earliest-claimed priority date of the
207 patent. This petition establishes that the challenged claims are unpatentable.
II.
Mandatory Notices Under 37 C.F.R. 42.8

A.
Real Parties-in-Interest
Pursuant to 37 C.F.R. 42.8(b)(1), Petitioner certifies that Unified is the real

party-in-interest, and further certifies that (1) that no other party exercised control
over Unifieds participation in this proceeding or the filing of this petition and (2)
that no other party will exercise any control over the conduct of any ensuing trial.
IPR2017-00361
In this regard, Unified has submitted voluntary discovery.
See EX1008,
Petitioners Voluntary Interrogatory Responses.

B.
Related Matters
The 207 patent is involved in a related proceeding, IPR2016-01465 (July

25, 2016). In addition, upon information and belief, the 207 patent has been
asserted in at least the following proceedings:
Name
Number
GlobalTranz Enterprises Incorporated v. 2-16-cv-
District Filed
AZD
04025
Shipping and Transit LLC
IntegraCore, LLC v. Shipping and Transit, 2-16-cv-
21, 2016
UTD
01065
LLC
Z-Firm, LLC v. Shipping and Transit, LLC 2-16-cv-
Shipping and Transit, LLC v. Fulmer 9-16-cv-
WAWD September
15, 2016
FLSD
81526
Logistics
Shipping and Transit, LLC v. Dispatch 2-16-cv-
Shipping & Transit, LLC v. DISH Network 2-16-cv06527
Corporation et al
August
30,
2016
CACD
06525
Technologies, Inc.
October 17,
2016
01462
et al
November
August
30,
2016
CACD
August
2016
30,
IPR2017-00361
Shipping & Transit, LLC v. Lighthouse.io 2-16-cv06531
Inc. et al
Shipping and Transit, LLC v. Comcast 2-16-cv-
Shipping and Transit, LLC v. Woodland 2-16-cvInternational Transport Company Inc. et al

and
Transit,
LLC
v.
CACD
CACD
Shipping and Transit, LLC v. Ship it Smarter 9-16-cv-
CACD
FLSD
Shipping
and
Transit,
LLC
v.
Serra 9-16-cv-
International, Inc.
81516
Shipping and Transit LLC v. Adorpix LLC
1-16-cv-
FLSD
FLSD
Shipping and Transit, LLC v. St. George 9-16-cv-
August
30,
August
30,
August
29,
August
29,
2016
NYSD
August
25,
2016
PTAB
01465
Patents Inc.
30,
2016
06694
Petition for Inter Partes Review by Unified IPR2016-
August
2016
81515
Industries
30,
2016
81527
Shipping and Transit, LLC v. Roll-On 9-16-cv-
August
2016
06535
Enterprises, Inc.
30,
2016
06534
Hall 2-16-cv-
August
2016
06533
Corporation
Shipping
CACD
July
25,
2016
FLSD
July
22,
IPR2017-00361
Trucking & Warehouse, Inc.
81317
Shipping and Transit, LLC v. CD Universe
9-16-cv-
2016
FLSD
July 6, 2016
FLSD
July 6, 2016
FLSD
July 5, 2016
CACD
July 1, 2016
CACD
July 1, 2016
CACD
July 1, 2016
CACD
July 1, 2016
FLSD
June
81208
Shipping and Transit, LLC v. Wireless Links, 9-16-cv81210
Inc.
Shipping and Transit, LLC v. Fairprice 9-16-cv81195
Tobacco, Inc.
Shipping and Transit LLC v. GeoMetrix 2-16-cvUSA Inc.
04861
Shipping and Transit LLC v. SFG, LLC et al
2-16-cv04864
Shipping and Transit LLC v. Efuego Corp., 2-16-cv04868
et al
Shipping and Transit LLC v. Greyhound 2-16-cv04869
Lines, Inc et al
Shipping and Transit, LLC v. Auctane LLC 9-16-cv81119
d/b/a ShipStation
Shipping and Transit, LLC v. Eastern 9-16-cv81060
Shipping Worldwide, Inc.
27,
2016
FLSD
June
2016
23,
IPR2017-00361
Shipping and Transit, LLC v. iGlobal, LLC
9-16-cv-
FLSD
81061
Shipping and Transit, LLC v. AceRoute 9-16-cv-
Shipping and Transit, LLC v. Spice Jungle, 9-16-cv-
FLSD
Shipping and Transit, LLC v. Monkey 9-16-cvSports, Inc.
81038
Shipping and Transit, LLC v. 1A Auto, Inc.
9-16-cv-
FLSD
FLSD
Shipping and Transit, LLC v. Thrifty Drug 9-16-cv-
FLSD
Shipping and Transit, LLC v. Discount 9-16-cv-
Shipping and Transit, LLC v. Leatherology, 9-16-cv-
and
Transit,
v. 9-16-cv-
LLC
June
21,
June
21,
June
21,
2016
FLSD
June
21,
2016
FLSD
June
13,
2016
FLSD
80978
Inc.
Shipping
FLSD
80973
Electronics, Inc.
21,
2016
81041
Stores, Inc.
June
2016
81040
Inc.
22,
2016
81039
Shipping and Transit, LLC v. LD Products, 9-16-cv-
June
2016
81037
LLC
23,
2016
81053
Field Services d/b/a AceRoute Software
June
June
13,
2016
FLSD
June
13,
IPR2017-00361
80980
LensDiscounters.com
Mason Companies, Inc. v. Shipping and 3-16-cv-
Oden Industries, Inc. v. Shipping and 5-16-cv-
June
13,
2016
CACD
June 9, 2016
FLSD
June 8, 2016
FLSD
June 8, 2016
FLSD
June 8, 2016
FLSD
June 8, 2016
FLSD
June 8, 2016
CACD
June 6, 2016
CACD
June 6, 2016
01216
Transit, LLC
and
WIWD
00411
Transit, LLC
Shipping
2016
Transit,
LLC
v.
PINC 9-16-cv80939
Solutions
Shipping and Transit, LLC v. iCONTROL 9-16-cvInc.
80936
Shipping and Transit, LLC v. Tonzof, Inc.
9-16-cv80938
Shipping and Transit, LLC v. Toolbarn.com, 9-16-cvInc.
80940
Shipping and Transit, LLC v. SunFrog, LLC
9-16-cv80941
Shipping
and
Transit
LLC
v.
Baby 2-16-cv03947
Supermall, LLC et al
Shipping and Transit LLC v. Laneaxis, Inc. 2-16-cv03953
et al
IPR2017-00361
Shipping and Transit, LLC v. Eyefreight Inc. 2-16-cv-
June 6, 2016
CACD
June 6, 2016
CACD
June 6, 2016
CACD
June 6, 2016
CACD
June 3, 2016
CACD
June 3, 2016
FLSD
June 3, 2016
FLSD
June 3, 2016
FLSD
June 3, 2016
FLSD
June 2, 2016
03962
et al
Shipping
and
Transit
v. 2-16-cv-
LLC
03977
Healthwarehouse.com, Inc. et al
Shipping
and
Transit
v. 2-16-cv-
LLC
03981
FragranceNet.com, Inc. et al
Shipping
CACD
and
Transit
LLC
v.
Hawk 2-16-cv03982
Applications Corp. et al
Shipping and Transit, LLC v. Targus Group 2-16-cv03912
International, Inc. et al
Shipping and Transit, LLC v. Tanner Goods 2-16-cv03916
et al
Shipping and Transit, LLC v. Holabird 9-16-cv80910
Sports, LLC
Shipping and Transit, LLC v. Need Supply 9-16-cv80911
Company, LLC
Shipping and Transit, LLC v. Metrogistics, 9-16-cv80912
LLC
Shipping and Transit, LLC v. Stickers 9-16-cv-
IPR2017-00361
80893
Galore, Inc. d/b/a Acherryontop.com
Shipping and Transit, LLC v. Online Stores, 9-16-cv-
FLSD
June 2, 2016
FLSD
June 1, 2016
CACD
June 1, 2016
CACD
June 1, 2016
CACD
June 1, 2016
CACD
June 1, 2016
CACD
June 1, 2016
FLSD
May
80894
LLC
Shipping and Transit, LLC v. Blue Ridge Net 9-16-cvPublishing, Inc. d/b/a WeatherShack.com
80891
Shipping and Transit, LLC v. Invitation 2-16-cv03831
Consultants, Inc.
Shipping and Transit, LLC v. Loginext 2-16-cv03834
Solutions Inc.
Shipping and Transit, LLC v. Neptune 2-16-cv03836
Cigars, Inc.
Shipping and Transit, LLC v. Nonin 2-16-cv03839
Medical, Inc.
Shipping and Transit, LLC v. Sally Beauty 2-16-cv03841
Holdings, Inc.
Shipping and Transit, LLC v. Skyline Vapor 9-16-cv80857
Lounge, LLC
Shipping and Transit, LLC v. Jacksam 9-16-cv80859
Corporation d/b/a Blackoutx.com
31,
2016
FLSD
May
2016
31,
IPR2017-00361
Triple7Vaping.Com, LLC et al v. Shipping 9-16-cv-
FLSD
80855
and Transit, LLC
Shipping and Transit, LLC v. Crunchyroll, 9-16-cvInc.
80858
Shipping and Transit, LLC v. WOV, LLC
9-16-cv-
FLSD
Shipping and Transit, LLC v. Incuboom, Inc. 9-16-cv-
FLSD
Shipping and Transit, LLC v. Vera Bradley, 0-16-cv-
FLSD
Shipping and Transit, LLC v. Diakon 1-16-cv-
FLSD
Shipping & Transit, LLC v. Conn's, Inc. 9-16-cv-
FLSD
Shipping & Transit, LLC v. TigerGPS.com, 1-16-cv-
NJD
Shipping and Transit, LLC v. Arlington 9-16-cv-
31,
May
20,
May
20,
May
18,
2016
FLSD
May
17,
2016
NJD
02792
LLC
May
2016
80774
d/b/a Conns.com
31,
2016
02908
Logistics, Inc.
May
2016
61076
Inc.
31,
2016
80796
d/b/a BaxterBoo.com
May
2016
80861
Productions, LLC
31,
2016
80860
Shipping and Transit, LLC v. Rooster Teeth 9-16-cv-
May
May
17,
2016
FLSD
May 9, 2016
IPR2017-00361
Contact Lens Service, Inc. d/b/a AC 80724
Lens.com
Shipping
and
Transit,
v. 2-16-cv-
LLC
DiscountRamps.com, LLC
03026
Shipping and Transit, LLC v. Moftware, Inc.
2-16-cv-
CACD
May 3, 2016
CACD
May 3, 2016
CACD
May 2, 2016
FLSD
April
03029
Shipping and Transit, LLC v. Financial 2-16-cvGraphic Services, Inc.
03003
Shipping and Transit, LLC v. Notifii, LLC
9-16-cv80584
Shipping and Transit, LLC v. NFI Industries, 9-16-cvInc. a/k/a NFI Interactive Logistics, LLC
and
Automotive
Transit,
Logistics,
FLSD
LLC
LLC
v.McNutt 9-16-cv-
April
15,
2016
FLSD
80586
Inc. d/b/a GoCurb.com

Shipping
2016
80585
Shipping and Transit, LLC v. Ride Charge, 9-16-cv-
15,
April
15,
2016
FLSD
d/b/a 80587
April
15,
2016
McNuttTransport.com
Shipping and Transit, LLC v. State Logistics 9-16-cv80588
Services, Inc.
10
FLSD
April
2016
15,
IPR2017-00361
Shipping and Transit, LLC v. Makeup Geek, 9-16-cv-
FLSD
80515
LLC
Shipping and Transit, LLC v. Chapel 9-16-cv-
Shipping and Transit, LLC v. Tyson's Mens 2-16-cv-
FLSD
Shipping and Transit, LLC v. Coastermatic 2-16-cv-
CACD
Shipping and Transit, LLC v. Apollo Future 2-16-cvTechnology, Inc. et al
02178
Shipping and Transit, LLC v. Adorama, Inc.
2-16-cv-
CACD
CACD
FTL Apparel, LLC v. Shipping & Transit 3-16-cv-
CACD
Humble Abode, Inc. v. Shipping & Transit 3-16-cv-
CACD
Shipping and Transit, LLC v. Global 0-16-cv-
11
31,
March
30,
March
29,
March
28,
2016
CAND
March
23,
2016
CAND
01353
LLC
March
2016
01453
LLC
31,
2016
02101
Supply Warehouse, Inc.
March
2016
02149
Shipping and Transit, LLC v. The Beauty 2-16-cv-
4,
2016
02226
Inc.
April
2016
02223
Wear Inc.
5,
2016
80512
Headware LLC et al
April
March
19,
2016
FLSD
March
3,
IPR2017-00361
60417
Experience Specialists, Inc.

Shipping
and
Transit,
LLC
v.
CSA 9-16-cv-
Shipping and Transit, LLC v. Whenever 9-16-cv-
Transit,
LLC
v.
E&L 9-16-cv-
FLSD
Shipping and Transit, LLC v. The Signal 9-16-cv-
FLSD
Shipping and Transit, LLC v. Amain.com, 9-16-cv-
FLSD
Shipping and Transit, LLC v. Lifetime 9-16-cv-
FLSD
Academy Ltd. d/b/a Academy Sports + 4-16-cv-
February 24,
February 22,
February 22,
2016
FLSD
80249
Brands, Inc.
3,
2016
80248
Inc.
March
2016
80247
Group, LLC
3,
2016
80261
Corporation d/b/a Cameta Camera
March
2016
80314
Communications, LLC
and
FLSD
80313
Transportation, Inc.
Shipping
2016
February 22,
2016
TXSD
Outdoors v. Shipping and Transit, LLC f/k/a 00410
February 16,
2016
ArrivalStar SA
2-16-cv-
Del Sol, LC v. Shipping & Transit, LLC
UTD
00118
Shipping and Transit, LLC v. Pharmapacks, 9-16-cv-
12
February 11,
2016
FLSD
February
5,
IPR2017-00361
LLC
80189
Name
Number
Shipping and Transit, LLC v. CJ Pony Parts, 9-16-cv-
2016
District Filed
FLSD
80191
Inc.
Shipping and Transit, LLC v. What She Buys 9-16-cv-
FLSD
Jackthreads, Inc. v. Shipping and Transit, 1-16-cvLLC
00741
Tatcha, LLC v. Shipping and Transit, LLC
3-16-cv-
FLSD
5,
February
5,
2016
NYSD
February
1,
2016
CAND
00539
Shipping and Transit, LLC v. Noonday 9-16-cv-
February
2016
80190
d/b/a tinyprints.com
5,
2016
80192
Shipping and Transit, LLC v. Shutterfly, Inc. 9-16-cv-
February
February
1,
2016
FLSD
Collection, Inc. a/k/a Noonday Holdings, 80098
January
20,
2016
LLC
Shipping and Transit, LLC v. Arhaus, LLC
0-16-cv-
FLSD
60110
Shipping and Transit, LLC v. Hats.com, LLC 9-16-cv80091
d/b/a Hats.com
13
January
19,
2016
FLSD
January
2016
19,
IPR2017-00361
Shipping and Transit, LLC v. Langston, Co.
0-16-cv-
FLSD
60111
Shipping and Transit, LLC v. Langston Co.
0-16-cv-
FLSD
January
19,
2016
TXED
June 2, 2004
NYSD
January
00127
Systems, Inc. et al
Arrival Star, Inc. v. Descartes Systems 1-04-cv00182
Group, Inc. et al
Arrival Star, Inc. v. Flytecomm Corporatio, 1-02-cv02543
et al
C.
19,
2016
60114
Arrival Star, Inc. v. Cheetah Software 5-04-cv-
January
9,
2004
GAND
September
16, 2002
Lead and Backup Counsel Information
The signature block of this petition designates lead counsel, backup counsel,
and service information. Petitioner designates P. Andrew Riley (Reg. No. 66,290)
as lead counsel. He can be reached at Finnegan, Henderson, Farabow, Garrett &
Dunner, LLP, 901 New York Avenue, NW, Washington, DC 20001-4413 (phone:
202-408-4000; fax: 202-408-4400). Unified also designates as backup counsel
Jonathan Stroud (Reg. No. 72,518). Petitioner consents to e-mail service at
Shipping-Transit-207-IPR@finnegan.com.
14
IPR2017-00361
III.
Fee Payment
The required fees are submitted under 37 C.F.R. 42.103(a) and 42.15(a).
If any additional fees are due during this proceeding, the Office may charge such
fees to Deposit Account No. 50-6990.
IV.
Statement of Precise Relief Requested for Each Claim Challenged

A.
Claims for Which Review is Requested
Petitioner requests review under 35 U.S.C. 311 of claims 1-15 of the 207
patent and cancellation of those claims as unpatentable.
B.
Statutory Grounds of Challenge
This Petition presents the following grounds:

Grounds
Claims 1-15 are unpatentable as obvious under pre-AIA 35
Ground 1
U.S.C. 103(a) by Peterson

Ground 2
U.S.C. 103(a) by Smith in view of Janky

Ground 3
U.S.C. 103(a) by Trask in view of Janky
The 207 patent claims priority to U.S. Patent Application Number

09/516,476, which was filed on March 1, 2000, and to U.S. Provisional
15
IPR2017-00361
Application Number 60/122,482, filed on March 1, 1999. The 207 patent does not
claim priority to any earlier date.
V.
The 207 Patent

A.
Overview of the Disclosure
The 207 patent describes methods and systems for maintaining vehicle
status information and of automatically and efficiently providing this information
to users after communication is established with the users. EX1001 at 1:15-20.
According to the 207 patent, prior art systems existed for providing this
information. See id. at 1:22-46. These systems, however, required the user to
identify the vehicle they are interested in so that the computer could retrieve that
information. Id. at 1:36-46. The 207 patent alleges [h]aving to provide either the
operator or the computer with information identifying which vehicle is of interest
is timing [sic] consuming and burdensome. Id. at 1:47-49. To improve on this
prior art, the 207 patent automatically and efficiently provid[es] users with this
information. Id. at 1:53-56.
The system and method disclosed in the 207 patent includes three primary
components: a database, a communication interface, and a system manager. Id. at
1:66-2:1. Figure 1, below, illustrates the relationship among these primary
components.
16
IPR2017-00361
EX1001 at Fig. 1.
Base station 15 stores vehicle status information in database 72. Id. at 5:5-8.
According to the 207 patent, U.S. Patent Application No. 09/395,501, entitled
Base Station Apparatus and Method for Monitoring Travel of a Mobile Vehicle,
fully describes base station 15. Id. at 3:2-7.
Base station also includes interface 67 (and if necessary, interface 69) for
communicating with one or more vehicles and a user interface 21. Id. at 4:66-5:4.
As shown in figure 1, vehicle 17 and base station 15 can communicate via interface
67 and vehicle interface 32 over a cellular network 35 or a similar communications
network. Id. at 3:49-61, Fig. 1. According to the 207 patent, vehicle 17 can send
status updates to the base station as outlined in U.S. Patent Application No.
17
IPR2017-00361
09/395,497, entitled Apparatus and Method for Monitoring Travel of a Mobile
Vehicle. Id. at 3:62-4:6.
Base station 15 likewise communicates with user interface 21 using network
24, which can be the publicly switched telephone network (PSTN), or a similar
communications network. Id. at 2:60-63. To determine the identity of the user, base
station 15 uses caller I.D. information. Id. at 3:16-36. Again, the 207 patent relies
upon a prior publication for the details of how to utilize caller I.D. Specifically, the
207 patent incorporates U.S. Patent Number 4,924,496, entitled Automatic
Incoming Telephone Call Originating Number and Party Display System. Id. at
3:28-33.
Base station 15 also includes a system manager 44 that controls the
operation of the base station 15. The system manager 44 can be implemented in
software, hardware, or a combination thereof. Id. at 4:13-18; see also id. at Fig. 2.
According to the 207 patent, the system and method disclosed allows a user
to communicate with base station 15 over network 24 to obtain the status of
vehicle 17. Id. at 6:16-67. Once a user request is received, the system manager 44
obtains the caller I.D. information for the user and matches the user with vehicle
17. Id. at 6:44-64. After matching the use to a particular vehicle, the system
manager 44 then retrieves the most recent status information for the vehicle and
transmits that information to the user. Id. at 6:59-67.
18
IPR2017-00361
B.
Prosecution History
The 207 patent issued from U.S. Pat. Appl. 09/516,476, which was filed on
March 1, 2000, and claims priority to March 1, 1999. EX1001 at 1:7-11. Of
relevance, in a July 10, 2001 Office Action, the examiner rejected pending claims
1, 2, 4, 5, 7-10, and 12-14 under 35 U.S.C. 103(a) as being unpatentable over
Jones in view of Shah (U.S. Patent 5,758,313), and pending claims 3, 6, and 11
under 35 U.S.C. 103 (a) as being unpatentable over Jones in view of Shah, and
further in view of Murakami (U.S. Patent 5,590,178). File History, Office Action
at 38 (07/10/2001) (EX1010).
In response to the July 10, 2001 Office Action, the applicant argued that
Shah does not disclose or suggest the element of using caller identification
automatically transmitted to the vehicle monitoring system to search for and locate
vehicle status information pertaining to a vehicle of interest to the user. File
History, Office Action Response at 4 (10/09/2001) (EX1011).
On November 11, 2001, the examiner then allowed the claims, stating that
neither the Shah or Jones references individually disclose said system manager
further configured to automatically search for and locate a set of said status
information based on said caller identification information, said system manager
further configured to retrieve said set of status information and to transmit said
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retrieved set of status information to said remote communication device. File
History, Notice of Allowance at 1-4 (11/19/2001) (EX1012).
At the time the application for the 207 patent was filed, however, systems
for collecting, tracking, and disseminating vehicle location and status information
were well known in the art. EX1002 46. Contrary to the Examiners statement
on allowance, the prior art grounds asserted in this petition show that the claims of
the 207 patent are unpatentable.
Systems that provided a requester with
information about a vehicle without the requester inputting any information into
the system were known in the art. EX1002 47. The Examiner did not consider
any of the references asserted here during prosecution.
C.
Level of Ordinary Skill in the Art
A person of ordinary skill in the art (POSA) for the 207 patent would have a
Masters Degree in electrical engineering, computer science, or a related subject
and at least two years of experience working with vehicle information systems, or
an undergraduate degree in one of those fields with four years of relevant work
experience. See EX1002 at 31.
D.
Challenged Claims
The 207 patent contains fifteen claims, of which claims 1, 5, and 10 are
independent. Petitioner requests cancellation of claims 1-15.
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Independent claim 1 illustrates the subject matter of the challenged claims as
a system comprising a database, communication interface, and system manager:
[claim 1a] 1. A system for monitoring and reporting
status of vehicles, comprising:
[1b] a database storing status information associated with
a vehicle, said status information indicative of a
current proximity of said identified vehicle;
[1c]
communication
communicate
interface
with
configured
communication
to
devices
remotely located from said system; and

[1d] a system manager configured to receive a message
transmitted from said vehicle and to update said
status information based on said message, said
system manager further configured to analyze
caller identification information automatically
transmitted to said communication interface when
a remote communication device establishes
communication
with
said
communication
interface, said system manager further configured

to automatically search for and locate a set of said
status
information
based
on
said
caller
identification information, said system manager

further configured to retrieve said set of status
information and to transmit said retrieved set of
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status information to said remote communication
device.
EX1001 at 7:62-8:17 (claim 1). Independent system claim 5 is substantially similar
to claim 1, but invokes Sec. 112, 6 language, as discussed below as part of claim
construction. EX1002 at 34. Independent method claim 10 recites the same
substantive limitations as claim 1 but is rewritten from the perspective of a method
performed by a computer. See EX1002 at 35.
The remaining dependent claims add various limitations examined in the
analysis below.
VI.
Claim Construction
A claim in an unexpired patent subject to inter partes review shall be given
its broadest reasonable construction in light of the specification of the patent in

which it appears. 37 C.F.R. 42.100(b); Cuozzo Speed Techs., LLC v. Lee, 136
S.Ct. 2131, *2145 (U.S. 2016).
Claims 5 and 8 of the 207 patent include means for limitations that
include the phrase means for and describe functional characteristics of the
claims. Means-plus function terms are construed to cover the corresponding
structure, material, or acts described in the specification and equivalents thereof.
Pre-AIA 35 U.S.C 112, 6. To determine whether a limitation falls under 35
U.S.C. 112, 6, the essential inquiry is not merely the presence or absence of
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the word means but whether the words of the claim are understood by persons of
ordinary skill in the art to have a sufficiently definite meaning as the name for
structure. Williamson v. Citrix Online, LLC 792 F.3d 1339, 1348 (Fed. Cir. 2015).
A POSA reading the limitations from claims 5 and 8 of the 207 patent listed
below, would not have understood them to have a sufficiently definite meaning as
the name for structure. The terms, therefore, may be construed under 35 U.S.C.
112, 6. EX1002 at 58. The remaining claim terms in the 207 patent consist of
general terms of art that do not require special construction beyond their plain and
ordinary meaning. EX1002 at 59.
Construing a means-plus function claim term is a two-step process. The
court must first identify the claimed function .... Then, the court must determine
what structure, if any, disclosed in the specification corresponds to the claimed
function. Williamson, 792 F.3d at 1351. The 207 patent discloses that the system
manager can be implemented in software, hardware or a combination of both. See
EX1001 at 4:11-20; 5:45-50.
Unified proposes the following constructions under the BRI standard:
1. means for maintaining status information associated with a vehicle,
Claimed function: maintaining status information associated with a vehicle.
Structure: The 207 patent specification provides the following structure to
for performing this function: Base station 15 [shown in Fig. 1 is] configured to
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store information the status of at least one vehicle 17. In figure 2, the base station
is a general-purpose computer having a database 72. See EX1001 at 2:55-56 and
4:11-5:16.
2. means for communicating with a remote communication device,

including means for receiving caller identification information automatically
transmitted to said communicating means,
Claimed function: communicating with a remote communication device,
including receiving caller identification information automatically transmitted to
said communicating means.
Structure: The specification provides the following structure to for
performing this claimed function: regarding figure 1, the base station 15 includes
an interface 69 for communicating with a remote communication device. The
base station 15 is designed to utilize the caller I.D. information automatically
transmitted to the interface 69. See EX1001 at 3:23-36 and 4:66-5:4.
3. means for utilizing said caller identification information to automatically

search for and locate a set of said status information;
Claimed function: utilizing said caller identification information to
automatically search for and locate a set of said status information.
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Structure: The specification provides the following structure to for
performing this claimed function: [T]he base station 15 [shown in Fig. 1] is
preferably aware of which users are associated with which vehicles 17.
Accordingly after identifying the user ..., the base station 15 is configured to
automatically retrieve status information. Regarding figure 2, the base station is a
general-purpose computer and a database. See EX1001 at 3:36-48 and 5:5-44.
4. means for automatically retrieving and transmitting said set of said status
information,
Claimed function: automatically retrieving and transmitting said set of said
status information.
Structure: The specification provides the following structure for performing
the claimed function: regarding figure 2, system manager 44 [included in base
station 15], is configured to retrieve the status information from the identified entry
or entries and to transmit this information to the user. The system manager can
be implemented in software, hardware or a combination of both. See EX1001 at
4:11-20, 5:45-50, Fig. 2.
5. means for receiving a status message transmitted from said vehicle

Claimed function: receiving a status message transmitted from said vehicle.
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this function: regarding figure 1, the base station 15 includes an interface 67 for
receiving a status message from a vehicle 17. See EX1001 at 4:66-5:4.
6. means for updating said status information based on said status message
Claimed function: updating said status information based on said status
message.
this function: The base station 15 is configured to receive the status message and
to update the status information stored in the base station 15 in response to the
status message. The base station 15 stores the status information in database 72.
See EX1001 at 4:6-11, 5:5-6.
VII. Statement of Relief Requested: 37 C.F.R. 42.104(b) (Grounds 1-2)
A.
Ground 1: Peterson renders obvious challenged claims 1-15
As discussed below, Peterson renders obvious challenged claims 1-15 of the

207 patent.
1.
Overview of Peterson
U.S. Patent No. 5,845,227 to T. Peterson (Peterson) was filed on February

9, 1996, and issued on December 1, 1998. EX1006. Peterson is a continuation-inpart of allowed U.S. patent application Ser. No. 08/436,892, filed May 8, 1995,
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now U.S. Pat. No. 5,523,950 which is a continuation of 08/032,830, filed Mar. 10,
1993, abandoned, which is a continuation of 07/649,599, filed Feb. 1, 1991,
abandoned. EX1006. Peterson, therefore, has an effective filing date before March
1, 1999, and is prior art under pre-AIA 35 U.S.C. 102(b).
Peterson discloses a method and apparatus for supplying traffic information
to users and more particularly to such a method and apparatus for assisting the
users in selecting shortest elapsed time routes between various origin and
destination combinations. In addition, the invention proves useful for vehicle
tracking and management. EX1006 at 1:13-18. The Peterson system includes a
central computer for tracking user location and user information. Id. at 3:66-4:23.
The central computer communicates with user vehicles that are equipped with
global positioning systems (GPS). Id. at 4:9-16; 4:62-67. The central computer can
recognize a users caller ID or internet connection and perform a number of
functions to help them. Id. at 3:46-50; 4:3-8. For example, [t]he computer will
monitor the users progress and upon request will be available to identify the users
current location and to provide further directions and the arrival time. Id. at 4:1316. The Peterson system can be used to manage and track a fleet of vehicles, such
as ambulances, fire trucks, and cargo trucks. Id. at 5:40-53.
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1.
Peterson renders obvious claim 1

a.
Peterson discloses A system for monitoring and

reporting status of vehicles [claim 1a]
Peterson discloses a system for monitoring and reporting status of

vehicles as recited in claim 1. EX1002 at 85-86. Peterson discloses a system
for vehicle tracking and management. EX1006 at 1:13-18; EX1002 at 86.
According to Peterson, users equipped with Global Positioning Systems (GPS),
the location of the vehicle will be determined by the computer through
communication with the GPS device in the vehicle. EX1006 at 4:9-12. Peterson
discloses that users can call and request their location from the central computer,
among other services. Id. at 3:65-4:16.4. In addition, the system disclosed in
Peterson can be used to track and manage a fleet of vehicles. Id. at 5:10-14, 5:4053.
b.
Peterson discloses a database storing status

information associated with a vehicle, said status
information indicative of a current proximity of said
identified vehicle [claim 1b]
Peterson discloses a database storing status information associated with a

vehicle, said status information indicative of a current proximity of said identified
vehicle as recited in claim 1. EX1002 at 87-89. Peterson discloses a central
computer for storing user information, routes, and for tracking current user
locations. EX1006 at 3:65-4:23; see also id. at 3:46-50; 4:3-8. To do this, the
28
IPR2017-00361
computer receives GPS location information from the various vehicles it tracks. Id.
at 4:8-16; 4:62-67. The central computer also will automatically keep track of the
users current location by assuming that the user is on the shortest time route and
that he is travelling at the speed of traffic predicted for him based on his own
individual driving profile. Id. at 3:66-4:3, 4:62-5:9. In addition, the computer
will monitor the users progress and upon request will be available to identify the
user's current location and to provide further directions and the arrival time. It is
further the objective to constantly recalculate the user's route and to call the user
back if conditions change and additional time can be saved. Id. at 4:13-18; see
also id. at 3:46-4:23.
To the extent the Patent Owner argues Peterson does not specifically use the
word database, it would have been obvious to one of skill in the art to use a
database with Petersons central computer. EX1002 at 89. A person of ordinary
skill in the art at the time the 207 patent application was filed would have been
familiar with using general purpose computers and databases. EX1002 at 89. For
example, both Smith and Janky disclose using a database as part of their systems,
but do not provide details regarding the database because one of skill in the art
would understand how to use one in conjunction with the disclosed systems.
EX1003 at 5:20-32, 11:8-11; EX1004 at 8:27-35; EX1002 at 89.
29
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c.
Peterson discloses a communication interface

configured to communicate with communication
devices remotely located from said system [claim 1c]
Peterson discloses a communication interface configured to communicate

with communication devices remotely located from said system as recited in
claim 1. EX1002 at 90-91. The Peterson central computer communicates with
user vehicles that are equipped with global positioning systems (GPS). EX1006 at
4:8-16; 4:62-67. This communication can occur over a cellular telephone network.
Id. at Abstract, 2:51-67, 4:40-43, 4:64-67, Fig. 5. The Peterson invention
preferably contemplates means such as mobile devices i.e., radio, fax, pager, data
terminal, satellite connection or cellular telephone for providing communication
between the central computer 12 and each user vehicle such as that indicated at 14.
Accordingly, the central computer 12 is preferably coupled with a mobile
telephone broadcasting station 16 while each vehicle user 14 is provided with a
cellular telephone, represented by the antenna 18, for maintaining communication
with the central computer 12 by means of the mobile telephone station 16. In
addition, it is contemplated that the vehicle 14 may be equipped with a GPS unit
which continuously looks to satellites and its own algorithms to determine the
latitude and longitude of the vehicle 14. Id. at 8:36-49.
d.
Peterson discloses a system manager configured to

receive a message transmitted from said vehicle and
to update said status information based on said
30
IPR2017-00361
message, said system manager further configured to
analyze caller identification information
automatically transmitted to said communication
interface when a remote communication device
establishes communication with said communication
interface, said system manager further configured to
automatically search for and locate a set of said status
information based on said caller identification
information, said system manager further configured
to retrieve said set of status information and to
transmit said retrieved set of status information to
said remote communication device [claim 1d]
Peterson discloses a system manager configured to receive a message
transmitted from said vehicle and to update said status information based on said
message, said system manager further configured to analyze caller identification
information automatically transmitted to said communication interface when a
remote
communication
device
establishes
communication
with
said
communication interface, said system manager further configured to automatically

search for and locate a set of said status information based on said caller
identification information, said system manager further configured to retrieve said
set of status information and to transmit said retrieved set of status information to
said remote communication device as recited in claim 1. EX1002 at 92-93.
Peterson discloses a system that includes a central computer for tracking user
location and user information. EX1006 at 3:66-4:23. User vehicles equipped with
global positioning systems (GPS) continuously update the central computer via a
31
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communications network. Id. at 4:8-16; 4:62-67. The central computer can
recognize a users caller ID or internet connection and perform a number of
functions to help them. Id. at 3:46-50; 4:3-8. For example, [t]he computer will
monitor the users progress and upon request will be available to identify the users
current location and to provide further directions and the arrival time. Id. at 4:1316. Further, [w]hen the user calls in and enters his caller ID, the computer will say
Traffic Assist calculates your current position as . . . Id. at 4:3-5.
2.
Peterson renders claim 2 obvious
Peterson discloses wherein said caller identification information is a

telephone number associated with said remote communication device as recited in
claim 2. EX1002 at 94-95. The Peterson system includes a central computer that
can recognize a users caller ID or internet connection, which transmits the users
web address (identity), and perform a number of functions to help them.
EX1006 at 3:46-50; 4:3-8. For example, [t]he computer will monitor the users
progress and upon request will be available to identify the users current location
and to provide further directions and the arrival time. Id. at 4:13-16; see also id. at
3:45-49.
3.
Peterson renders claim 9 obvious
Peterson discloses wherein said status information indicates a proximity of

said vehicle from a particular location as recited in claim 9. EX1002 at 96-98.
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The central computer in Peterson stores user information, routes, and tracks
current user locations. EX1006 at 3:66-4:23; see also id. at 3:46-50; 4:3-8. To track
vehicle locations, the computer receives GPS location information from the
vehicles. Id. at 4:8-16; 4:62-67. In addition, the central computer will
automatically keep track of the users current location by assuming that the user is
on the shortest time route and that he is travelling at the speed of traffic predicted
for him based on his own individual driving profile. Id. at 3:66-4:3, 4:62-5:9. The
computer also will monitor the users progress and upon request will be available
to identify the users current location and to provide further directions and the
arrival time. It is further the objective to constantly recalculate the users route and
to call the user back if conditions change and additional time can be saved. Id. at
4:13-18; see also id. at 3:46-4:23.
The system is able to track the vehicle and provide information on the
location of the vehicle. For example: The users current change in position,
latitude and longitude, can be used as a probe. In addition, the current position in
conjunction with the route can be used by the dispatcher. Id. at 9:38-41. This
requires the central computer to determine a vehicles current location, determine
the vehicles proximity to its destination, and examine the travel times on the
planned route. EX1002 at 98.
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[5d] means for utilizing said caller
identification information to
automatically search for and locate a
set of said status information;
[5e] means for automatically retrieving
and transmitting said set of said status
information.
6. The system of claim 5, wherein said
caller identification information is a
telephone number.
caller identification information is an email address.
8. The system of claim 5, further
comprising: means for receiving a
status message transmitted from said
vehicle; and means for updating said
status information based on said status
message.
[10a] 10. A method for monitoring and
reporting status of vehicles, comprising
the steps of:
[10b] maintaining status information
associated with a vehicle, said status
information indicative of a current
proximity of said vehicle;
[10c] communicating with a remote
communication device;
[10d] receiving caller identification
information automatically transmitted
in said communicating step;
[10e] utilizing said caller identification
information to automatically search for
and locate a set of said status
information;
[10f] automatically retrieving said set
of status information based on said
searching for and locating step; and
[10g] transmitting said retrieved set of
See claim 1d; EX1002 at 99.
See claim 2; EX1002 at 99.
See claim 1a; EX1002 at 99.
See claims 1b, 9; EX1002 at 99.
See claim 1c; EX1002 at 99.

See claims 1d, 2, 3; EX1002 at 99.
See claims 1d, 4; EX1002 at 99.
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status information to said remote
communication device.
11. The method of claim 10, wherein
said caller identification information is
a telephone number.
an e-mail address.
13. The method of claim 10, further
comprising the steps of:
receiving a status message transmitted
from said vehicle;
and updating said status information
based on said status message.
comprising the step of indicating a
proximity of said vehicle from a
particular location via said status
information.
said utilizing, retrieving, and
transmitting steps are performed in
response to said receiving step.
B.
Ground 2: Smith in view of Janky renders obvious challenged

claims 1-15
As discussed below, Smith in view of Janky renders obvious challenged

claims 1-15 of the 207 patent.
1.
Overview of Smith
U.S. Patent No. 6,430,496 to Smith et al. (Smith) claims priority to U.S.
Appl. No. 08/549,380 filed October 27, 1995, and has an effective filing date
36
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before March 1, 1999. EX1003. Smith, therefore, is prior art under pre-AIA 35
U.S.C. 102(b).
Smith describes a system for controlling vehicles to provide transportation
services, such as taxis, ambulances, or other vehicles. Id. at Abstract, 1:12-13. In
addition, a variety of methods for obtaining and updating vehicle activity
information are disclosed, as are various applications for the system. Id. at
Abstract. Smith discloses a fully automated dispatch and monitoring system, which
includes database server 10, AVL system 18, communications processes 24,
dispatching processes 26, and vehicle monitoring processes 28. Id. at 5:20-32. In
the system disclosed in Smith, a customer can request a vehicle from the dispatch
system using any of a variety of methods, including telephone, data terminal, or
other method. Id. at 3:12-16. The Smith system, which continuously monitors the
vehicles in the fleet, matches the requested location with the appropriate vehicle,
and communicates with the customer and the vehicle to match the two. Id. at 3:4247, 4:49-5:7, 7:25-32, 7:61-67, 8:17-43, 21:45-50.
2.
Overview of Janky
U.S. Patent No. 5,794,174 to Janky et al. (Janky) was filed on March 15,
1996 and claims priority to U.S. Appl. No. 08/544,556, filed October 18, 1995.
EX1004. Janky, therefore, is prior art to the 207 patent under pre-AIA 35
U.S.C. 102(b).
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IPR2017-00361
Janky describes a system that automatically provides a vehicle location in
response to a telephone request. EX1004 at 5:35-60. In one embodiment, the
system disclosed in Janky communicates a visual representation of the vehicles
position to the requestors TV or other display device. Id. at Abstract, 6:2-20, Fig. 2.
Alternatively, the system can provide nonvisual vehicle location information, such
as longitude, latitude, and elevation. Id. at 7:1-8.
Janky also discloses a system where users can request the location of a
particular vehicle using a telephone. EX1004 at 5:36-50; see also id. at 5:12-32.
After receiving this request, the Janky system initiates a prompt to vehicle 10 to
transmit the vehicles position information to the service provider. EX1004 at
5:36-50. The vehicle then sends this position information and the Janky system
automatically sends the location information to the user. EX1004 at 5:61-66. The
system can send a visual representation of the vehicles location or a numeric
display of the vehicles latitude, longitude, and altitude. EX1004 at 5:61-66, 7:18. According to Janky, each telephone is uniquely addressable. Hence, each user
of the present invention is uniquely identifiable. EX1004 at 6:31-38, 8:20-25.
Thus, the Janky system only provides to a caller, the information for the particular
vehicle associated that callers phone number. Id.
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3.

claim 1
a.
Smith discloses A system for monitoring and

Smith discloses a system for monitoring and reporting status of vehicles as

recited in claim 1. EX1002 at 107-109. Smith discloses a fully automated system
to monitor and dispatch vehicles. EX1003 at 5:20-32, Fig. 1; EX1002 at 108.
According to Smith, many prior Automatic Vehicle Locator (AVL) systems existed
which automatically track (typically via satellite navigation) the locations of
managed vehicles, so that this information can be reported to a dispatcher in
textual or graphic form to assist the dispatcher determining the locations of
vehicles. EX1003 at 1:48-56; EX1002 at 108.
Janky also discloses a system that can monitor the position of a vehicle, and
provide the location of the vehicle to a requester. EX1002 at 109. For example:
Position information indicative of the location of the item is generated by the
position determining system. When desired, the position information is transmitted
from the item to a receiver. The position information is then transmitted from the
receiver to the telephone company. In response to the users request, the acquired
position information is then transmitted from the telephone company to the user's
television. EX1004 at 2:14-21; EX1002 at 109.
39
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b.
Smith discloses a database storing status information

associated with a vehicle, said status information
indicative of a current proximity of said identified
vehicle [claim 1b]
Smith discloses a database storing status information associated with a

vehicle as recited in claim 1. EX1002 at 110-112. The system in Smith
includes a database server 10 for storing records indicating requested vehicle
services and associated information. EX1003 at 4:49-5:7; EX1002 at 111.
Server 10 communicates with AVL system 18, which maintains location and status
information for each vehicle. EX1003 at 7:61-67; EX1002 at 111. In fact, Smith
discloses that a single database server contains both the information on current
vehicle positions and status, and information on future appointments for vehicle
use. EX1003 at 11:8-11; EX1002 at 111.
Janky also discloses a database for storing vehicle status information
indicative of the position of the vehicle (i.e. proximity). EX1002 at 112. For
example: In the present embodiment, telephone company 20 contains a map
information GIS database 86. Map information coordinate matching component 88
matches the contents of map information GIS database with the position
information received at AVL comm link 90. In so doing, map information
corresponding to the region in which the monitored item is currently located is sent
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to the customer. More specifically, the map information is selected such that the
icon representing the monitored item is approximately centered with respect to the
displayed map information. EX1004 at 8:27-35.
c.
Smith discloses a communication interface

Smith discloses a communication interface configured to communicate with

communication devices remotely located from said system as recited in claim 1.
EX1002 at 113-116. As shown in figure 1 below, the system disclosed in Smith
includes numerous communications interfaces. EX1001 at Fig. 1; EX1002 at
114.
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EX1001 (Smith) at Fig. 1

Smith discloses, for example, database server 10 may be at a geographically
central location whereas AVL systems and computing systems running processes
24, 26 and 28 may be remotely located and communicating with database server
over a wide-area or Internet network through the above-described communications
facilities. EX1003 at 7:7-16; EX1002 at 115. In addition, Smith teaches that
[t]he processing circuitry is in continuous automatic communication with the
vehicles, forwarding instructions to vehicles and obtaining vehicle activity
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information relating to each vehicle. EX1003 at 2:57-60. The communications in
the Smith system can use ground-based radio communication, satellite-based
radio communication, or both. In particular, satellite-based vehicle tracking
circuitry may be used to track the locations of the vehicles, and the vehicle
locations forwarded via satellite or radio to the processing circuitry for using in
vehicle monitoring. EX1003 at 3:1-6.
Janky also discloses a communication interface for communicating with
remotely located devices. EX1002 at 117. For example: As shown in FIG. 1,
communication device 14 is communicatively coupled to a receiver 16 via
communication link 18. Likewise, receiver 16 is coupled to a service provider 20
via communication link 22. EX1004 at 4:10-13; see also Fig. 1.
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d.
Smith discloses a system manager configured to

Smith discloses a system manager configured to receive a message

remote
communication
device
establishes
communication
with
said

The system disclosed in Smith is designed to combine the collection of
information on current vehicle status and future appointments to provide
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IPR2017-00361
continual, automated system status management, to determine and predict future
needs for transportation services and compare the future needs to expected
availability of transportation services. EX1003 at 3:42-47. Smith discloses that a
single database server can store both the information on current vehicle positions
and status, and information on future appointments for vehicle use. EX1003 at
11:9-12.
The system in Smith can display the status of vehicles and their locations
for a human dispatcher 16, or may produce reports of vehicle activity and vehicle
availability. EX1003 at 21:45-50. Smith discloses that a customer can use a
variety of methods to request a vehicle, including using the telephone, the internet,
radio, remote data entry terminals, and the like. EX1003 at 4:49-5:7. The Smith
system also automatically creates an invoice at the conclusion of a requested trip
with such information as the customer identification, pickup and drop off locations,
the route taken, and the like. EX1003 at 7:45-54, 21:9-40. The Smith system can
then automatically send this invoice to the customer electronically. Id.
Smith discloses an automated system where the user can request a vehicle
using any number of methods, including telephone, internet, and the like. EX1003
at 4:49-5:7; EX1002 at 121. For example, Smith discloses that [r]equests for
vehicle service may be entered by call takers at the location of the database server,
or may be entered remotely via telephone, either at a data terminal at a customer
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IPR2017-00361
site or via touch-tone telephone or at an ATM-like facility using a customer
identification card. EX1003 at 3:12-16; see also id. at 4:61-5:7. The Smith system
assigns customers unique identifiers that the Smith system associates with the
vehicle requested. EX1003 at 8:62-67.
The 207 patent uses known caller ID systems and known computer
processing techniques in place of the person receiving calls in the system in Smith.
EX1002 at 122. A person of ordinary skill in the art would find the teachings
from Smith, coupled with that persons knowledge of known processing techniques
and known caller ID systems, disclose this limitation from the 207 patent.
EX1002 at 122.
The Patent Owner may argue that Smith does not disclose this limitation
because Smith discloses having a person take vehicle requests over the phone from
customers. That argument should fail for two reasons. First, Smith discloses an
automated system where the user can request a vehicle using any number of
methods, including telephone, internet, and the like. EX1003 at 4:49-5:7.
Second, under guiding Federal Circuit precedent it does not matter that
Smith discloses manual input of a callers request. For example, in Muniauction,
Inc. v. Thomson Corporation, the Federal Circuit found it obvious where the
claims adapt[ed] existing electronic processes into the claimed invention. 532
F.3d 1318, 1327 (Fed. Cir. 2008). In that case, the Court found the claims, which
46
IPR2017-00361
were filed in 1998, merely incorporated modern internet and web browser
technology that was commonplace at the time. Id.
In Leapfrog Enters., Inc. v. FisherPrice, Inc., the Federal Circuit reached a
similar conclusion. 485 F.3d 1157 (Fed. Cir. 2007). The Court upheld the district
courts obviousness decision because [a]pplying modern electronics to older
mechanical devices has been commonplace in recent years. Id. at 1161. In that
case, the patent claim covered a device that used a processor and related
electronics whereas the prior art used an electric motor and mechanical
structures to create a device that makes letter sounds in a childs toy. Id.
Like the patents at issue in Leapfrog and Muniauction, the 207 patent
merely uses known caller ID systems and known computer processing techniques
in place of the person receiving calls in the system in Smith. For at least this
reason, a person of ordinary skill in the art would still find the teachings from
Smith, coupled with that persons knowledge of known processing techniques and
known caller ID systems, disclose this limitation from the 207 patent. EX1002 at
122.
But even to the extent Smith does not disclose every element of said system
manager further configured to analyze caller identification information
automatically transmitted to said communication interface when a remote
communication device establishes communication with said communication
47
IPR2017-00361
interface, said system manager further configured to automatically search for and
locate a set of said status information based on said caller identification
information, said system manager further configured to retrieve said set of status
information and to transmit said retrieved set of status information to said remote
communication device, when combined with Janky (EX1004), it does. EX1002 at
123.
Janky discloses a system where a user can request the location of a particular
vehicle using a telephone. EX1004 at 5:36-50; see also 5:12-32. In response, the
system in Janky initiates a prompt to vehicle 10 to transmit the vehicles position
information to the service provider. EX1004 at 5:36-50. After receiving the
position information from the vehicle, the Janky system automatically sends the
location information to the user. EX1004 at 5:61-66. The system can send a visual
representation of the vehicles location or a numeric display of the vehicles
latitude, longitude, and altitude. EX1004 at 5:61-66, 7:1-8.
Janky also discloses that each telephone is uniquely addressable. Hence,
each user of the present invention is uniquely identifiable. EX1004 at 6:31-38,
8:20-25. The Janky system, therefore, only provides to a caller the information for
the particular vehicle associated that callers phone number. Id. It would be
obvious to one of skill in the art at the time of the 207 patent application filing that
such telephone identification would be automatic. EX1002 at 124. For example,
48
IPR2017-00361
U.S. Patent No. 3,812,296 described such automatic caller identification at least as
early as 1972. EX1002 at 124.
A person of ordinary skill in the art would have been motivated to combine
Janky with Smith for a number of reasons. Both patents address overlapping
subject matternamely, updated vehicle location information. See, e.g., EX1003
at 3:42-47, 21:45-50; EX1004 at 5:36-66; EX1002 at 102. In addition, both Janky
and Smith seek to build additional functionality on top of existing automatic
vehicle location systems (AVL). See, e.g., EX1003 at 5:8-19, Fig. 1; EX1004 at
4:10-43, Fig. 1; EX1002 at 102. Moreover, adding the functionality from Janky
of automatically providing vehicle location information in response to a call to the
system in Smith would have been obvious to try to a POSA. EX1002 at 103. A
POSA would have expected predictable results if they added the known Janky
functionality to the Smith system as a way to improve the Smith system. EX1002 at
104.
4.

claim 2
Smith discloses wherein said caller identification information is a telephone

number associated with said remote communication device as recited in claim 2.
EX1002 at 125-126. Smith discloses that Requests for vehicle service may be
entered by call takers at the location of the database server, or may be entered
49
IPR2017-00361
remotely via telephone, either at a data terminal at a customer site or via touch-tone
telephone or at an ATM-like facility using a customer identification card. EX1003
at 3:12-16; see also 4:61-5:7. Customers using the Smith system are assigned
unique identifiers that the Smith system associates with the vehicle requested.
EX1003 at 8:62-67; EX1002 at 126.
To the extent Smith does not disclose claim 2, Smith combined with Janky
does. EX1002 at 127. According to Janky, each telephone is uniquely
addressable. Hence, each user of the present invention is uniquely identifiable.
EX1004 at 6:31-38, 8:20-25. Thus, the Janky system only provides to a caller, the
information for the particular vehicle associated that callers phone number. Id.;
EX1002 at 127. It would be obvious to one of skill in the art at the time of the
207 patent application filing that such telephone identification would be
automatic. EX1002 at 101-105, 127.
5.
Smith renders obvious the subject matter of claim 3
Smith discloses wherein said caller identification information is included

within a message transmitted over the internet and received by said communication
interface, and wherein said caller identification information is a source address
automatically inserted into said message by said remote communication device,
said source address identifying an address of said remote communication device
as recited in claim 3. EX1002 at 128-129. For example, Smith discloses that
50
IPR2017-00361
customers can request vehicles using remote data terminals or the Internet.
EX1003 at 3:12-16, 4:61-5:7. The Smith system creates a dispatch record using
information received from the customer, including a code for the customer.
EX1003 at 8:62-67; EX1002 at 129.
Janky discloses that each telephone is uniquely addressable. Hence, each
user of the present invention is uniquely identifiable. EX1004 at 6:31-38, 8:20-25.
vehicle associated that callers phone number. Id.; EX1002 at 130. It would be
such telephone identification would be automatic. EX1002 at 130.
6.

claim 9
Smith in view of Janky discloses wherein said status information indicates a

proximity of said vehicle from a particular location as recited in claim 9. EX1002
at 131-134. Smith discloses that [t]he vehicle monitoring may evaluate the
vehicles movements and position to determine if it has arrived at or is en route to
an appointed location. EX1003 at 3:1-11. More specifically, Smith discloses that
the monitoring process might simply compare the position of the vehicle to the
position of the pickup and destination site, to determine whether the vehicle is at
one of these sites. EX1003 at 22:1-17.
51
IPR2017-00361
Now turning to FIG. 2, the various data
files used by automated dispatch
processes 24, 26 and 28 to perform
automated dispatching of vehicles 20
can be elaborated. The dispatch file 30
is the primary file used by the
automated dispatch processes to store
information regarding a job and the
status of a vehicle assigned to a job and
to interact with other processes in the
dispatching system. EX1003 at 7:2532.
The automatic vehicle locator system
18 retains internal tables indicating the
status of each of the vehicles that it
tracks, so that it may for example
display the status of vehicles and their
locations for a human dispatcher 16, or
may produce reports of vehicle activity
and vehicle availability. EX1003 at
21:45-50.
[5a] 5. A system for monitoring and
reporting status of vehicles,
comprising:
[5b] means for maintaining status
information associated with a vehicle,
said status information indicative of a
current proximity of said identified
vehicle;
[5c] means for communicating with a
remote communication device, said
means for communicating including a
means for receiving caller
identification information
automatically transmitted to said
communicating means;
[5d] means for utilizing said caller
See claim 1b; EX1002 at 135.

53
IPR2017-00361
identification information to
automatically search for and locate a
set of said status information;
[5e] means for automatically retrieving
and transmitting said set of said status
information.
caller identification information is a
telephone number.
message.
the steps of:
information;
See claims 1b, 9; EX1002 at 135.

54
IPR2017-00361
a telephone number.
an e-mail address.
from said vehicle;
information.
C.
Ground 3: Trask in view of Janky renders obvious challenged

claims 1-15
As discussed below, Trask in view of Janky renders obvious challenged

claims 1-15 of the 207 patent.
1.
Overview of Trask
U.S. Patent No. 5,945,919 to M. Trask (Trask) claims priority to U.S.

Appl. No. 08/652,688 filed May 30, 1996, and has an effective filing date before
March 1, 1999. EX1005. Trask, therefore, is prior art under pre-AIA 35
U.S.C. 102(b).
55
IPR2017-00361
Trask relates to vehicle tracking and dispatch systems. EX1005 at 1:5-6.
According to Trask, taxis, ambulance, fire, maintenance, security, law
enforcement and the like could use such a system. Id. at 1:13-15. The dispatcher
free vehicle allocation (DSVA) system disclosed in Trask swiftly and
automatically recommends which of a plurality of vehicles can respond most
quickly to an event. Id. at 2:22-25. In the Trask system, the position of each of
the vehicles is communicated to the DFVA computer system. Id. at 2:27-28. Next,
the Trask system tracks the present position of each of the vehicles. Id. at 2:2930. As illustrated in Figure 3 shown below, a customer 300 can contact the central
base 308 using telephone 302. Id. at 5:19-39.
56
IPR2017-00361
EX1005 at Fig. 3.
Central base 308 can communicate with vehicles 304a to 304d using
communications links 306a to 306d. Id.
2.

claim 1
a.
Trask discloses A system for monitoring and

Trask discloses a system for monitoring and reporting status of vehicles as

recited in claim 1. EX1002 at 142-143. Trask discloses a dispatcher free
vehicle allocation (DFVA) system that includes a central base that communicates
with vehicles that contain a position determining system. EX1005 at Abstract.
The Trask system then track[s] the present location of each vehicle. Id. After
receiving a user request, the Trask system can then determine the most
appropriate vehicle of the plurality of vehicles, to respond to the customer's
dispatch request. Id.
Janky also discloses a system that can monitor the position of a vehicle, and
provide the location of the vehicle to a requester. EX1002 at 144. For example:
Position information indicative of the location of the item is generated by the
position determining system. When desired, the position information is transmitted
from the item to a receiver. The position information is then transmitted from the
receiver to the telephone company. In response to the users request, the acquired
57
IPR2017-00361
position information is then transmitted from the telephone company to the users
television. EX1004 at 2:15-21; EX1002 at 144.
b.
Trask discloses a database storing status information

associated with a vehicle, said status information
indicative of a current proximity of said identified
vehicle [claim 1b]
Trask discloses a database storing status information associated with a

vehicle as recited in claim 1. EX1002 at 145-147. The Trask system includes
an address/data bus 112 for communicating information, a central processor unit
102 coupled to bus 112 for processing information and instructions. EX1005 at
4:20-33, Fig. 1; EX1002 at 146. The system in Trask also includes a data storage
unit and volatile and non-volatile memory, coupled to a processor. EX1005 at
4:20-33, Fig. 1; EX1002 at 147. As shown in Figure 4, each vehicle is equipped
with a global positioning systems (GPS) and communications equipment for
communicating with the Trask system. EX1005 at 5:54-65, Fig. 4; see also id. at
7:44-50. Using this and other equipment, the Trask system tracks the present
position of each of the vehicles. EX1005 at 2:22-30; EX1002 at 147.
Janky also discloses a database for storing vehicle status information
indicative of the position of the vehicle (i.e. proximity). EX1002 at 148. For
example: In the present embodiment, telephone company 20 contains a map
58
IPR2017-00361
information GIS database 86. Map information coordinate matching component 88
matches the contents of map information GIS database with the position
information received at AVL comm link 90. In so doing, map information
corresponding to the region in which the monitored item is currently located is sent
to the customer. More specifically, the map information is selected such that the
icon representing the monitored item is approximately centered with respect to the
displayed map information. EX1004 at 8:27-35; EX1002 at 148.
c.
Trask discloses a communication interface

Trask discloses a communication interface configured to communicate with

communication devices remotely located from said system as recited in claim 1.
EX1002 at 149-151. As shown in Figure 3, above, the Trask system
communicates with customers 300 as well as with vehicles 3041 to 304d. EX1005
at 4:45-49, 5:19-30, Fig. 3; see also id. at 4:28-33, Fig. 1 (discussing
communicating with other systems, including computer systems, wireless local
area networks (LAN)/wide area networks (WAN), or conventional land line
telephone systems). More specifically, the Trask system can send and receive
communications from vehicle 304a using communications link 306a, which could
be a wide area network (WAN) or a similar communications link. EX1005 at 5:666:32.
59
IPR2017-00361
Janky also discloses a communication interface for communicating with
remotely located devices. EX1002 at 152. For example: As shown in FIG. 1,
communication device 14 is communicatively coupled to a receiver 16 via
communication link 18. Likewise, receiver 16 is coupled to a service provider 20
via communication link 22. EX1004 at 4:10-13; see also Figure 1; EX1002 at
152.
d.
Trask discloses a system manager configured to

Trask discloses a system manager configured to receive a message

remote
communication
device
establishes
communication
with
said
60
IPR2017-00361
The system in Trask can track, monitor, allocate, and dispatch each of a plurality
of mobile service providers, e.g. vehicles. EX1005 at 4:3-18. As discussed above
regarding claim 1c, the Trask system includes a central base that can communicate
with vehicles equipped with GPS systems. See supra Sec. VII.B.2.c. In addition,
the system in Trask uses an automatic number identification/automatic location
identification (ANI/ALI) system to determine the geographic location of a caller.
EX1005 at 7:6-10, Fig. 6.
Once the system in Trask matches a user request with a particular vehicle,
for example, a taxi, the system can send customer data to the vehicle driver. This
data can include the callers phone number, address, location, and any other
special information. EX1005 at 8:29-41, Fig. 7. Next, in step 706, the driver
verbally confirms directions, pickup time, or other special information. EX1005 at
8:29-41, Fig. 7. In order to confirm directions as part of this communication, the
driver must provide the vehicles current location to the caller. EX1002 at 155.
The Patent Owner may argue that Trask does not disclose claim 1d because
Trask discloses having a vehicle driver provide the vehicles location over the
61
IPR2017-00361
phone to the customer. For the same reasons discussed above in section VII.A.3.d,
this argument should fail. Replacing the call placed by the driver with known
computer processing and communication techniques would have been obvious to a
person of ordinary skill in the art. EX1002 at 156. Thus, Trask teaches this claim
limitation. EX1002 at 137-40, 156.
But even to the extent Trask does not disclose every element of said system
manager further configured to analyze caller identification information
automatically transmitted to said communication interface when a remote
communication device establishes communication with said communication
interface, said system manager further configured to automatically search for and
locate a set of said status information based on said caller identification
information, said system manager further configured to retrieve said set of status
information and to transmit said retrieved set of status information to said remote
communication device, when combined with Janky (EX1004), it does. EX1002 at
157.
Janky discloses a system where a user can request the location of a particular
vehicle using a telephone. EX1004 at 5:36-50; see also 5:12-32. In response, the
system in Janky initiates a prompt to vehicle 10 to transmit the vehicles position
information to the service provider. EX1004 at 5:36-50. After receiving the
position information from the vehicle, the Janky system automatically sends the
62
IPR2017-00361
location information to the user. EX1004 at 5:61-66. The system can send a visual
representation of the vehicles location or a numeric display of the vehicles
latitude, longitude, and altitude. EX1004 at 5:61-66, 7:1-8. According to Janky,
each telephone is uniquely addressable. Hence, each user of the present invention
is uniquely identifiable. EX1004 at 6:31-38, 8:20-25; EX1002 158. The Janky
system, therefore, only provides to a caller the information for the particular
vehicle associated that callers phone number. Id. It would be obvious to one of
skill in the art at the time of the 207 patent application filing that such telephone
identification would be automatic. EX1002 at 158.
A person of ordinary skill in the art would have been motivated to combine
Janky with Trask for a number of reasons. Both patents address overlapping
subject matternamely, updated vehicle location information for use with taxi and
similar dispatching systems. See, e.g., EX1005 at 1:13-15; EX1004 at 5:36-66;
EX1002 at 138. Moreover, the systems in both Janky and Trask add additional
functionality to existing automatic vehicle location systems. See, e.g., EX1005 at
2:14-18; EX1004 at 4:10-43, Fig. 1; EX1002 at 139. In addition, it would have
been obvious to a POSA to add the functionality of automatically providing
vehicle location information in response to a call as disclosed in Janky, to the
system in Trask. EX1002 at 139. Adding the known Janky functionality to the
63
IPR2017-00361
Trask system would have yielded predictable results and was a way for a POSA to
improve the Trask system. EX1002 at 140.
3.

claim 2
Trask discloses wherein said caller identification information is a telephone

number associated with said remote communication device as recited in claim 2.
EX1002
at
159-160.
Trask
discloses
using
an
automatic
number
identification/automatic location identification (ANI/ALI) system to determine

the geographic location of a caller. EX1005 at 7:6-10, Fig. 6.
To the extent Smith does not disclose claim 2, Janky does. EX1002 at 161.
According to Janky, each telephone is uniquely addressable. Hence, each user of
the present invention is uniquely identifiable. EX1004 at 6:31-38, 8:20-25. Thus,
the Janky system only provides to a caller, the information for the particular
vehicle associated that callers phone number. Id.; EX1002 at 162. It would be
4.
Trask renders obvious the subject matter of claim 3
Smith discloses wherein said caller identification information is included

within a message transmitted over the internet and received by said communication
interface, and wherein said caller identification information is a source address
64
IPR2017-00361
automatically inserted into said message by said remote communication device,
said source address identifying an address of said remote communication device
as recited in claim 3. Trask discloses a number of known communications links
that could be used by the parts of the system to communicate with one another. See
EX1005 at 5:66-6:32. For example, it discloses Metricomm Wide Area Network
(WAN), a trunked radio system, rf communication links, a Subscription Mobile
Radio (SMR) system, and a Cellular Digital Packet Data (CDPD) protocol. Id. For
the CDPD link, Trask system then bursts packet data, using, for example, TCP/IP
protocol, to deliver the data to corn device 404. Id. To send customer data,
including the callers phone number, address, location, and any other special in
formation, to a vehicle, the Trask system could use this TCP/IP protocol. EX1005
at 8:29-41; EX1002 at 164.
Janky discloses that each telephone is uniquely addressable. Hence, each
user of the present invention is uniquely identifiable. EX1004 at 6:31-38, 8:20-25.
vehicle associated that callers phone number. Id; EX1002 at 165. It would be
65
IPR2017-00361
5.

claim 9
Trask in view of Janky disclose wherein said status information indicates a

proximity of said vehicle from a particular location as recited in claim 9. EX1002
at 166-169. Trask discloses determining the proximate location for a vehicle
twice. First, to determine the vehicle that is closest to a callers location. EX1005
at 8:1-4. Second, the Trask system monitors the any dispatch vehicle to determine
its proximity to its destination to calculate its estimate arrival time. EX1005 at
8:58-61. A POSA would understand that both of these proximate calculations
could be sent to a vehicle and/or a customer. EX1002 at 167.
Janky likewise discloses determining whether the vehicle is moving.
EX1004 at 4:1-9. As discussed above for claim 1d, Janky discloses a system that
automatically provide vehicle location information in response to a users call. A
POSA would have found it obvious to transmit the proximity information disclosed
in Trask at the same time it sent the vehicles current location. EX1002 at 169.
For example, in the taxi example used in Trask, a POSA would have been
motivated to provide the proximity information of Trask at the same time they
provided the vehicles present location as disclosed in Janky. EX1002 at 169.
66
IPR2017-00361
telephone number.
message.
the steps of:
information;
a telephone number.
an e-mail address.
See claims 1b; EX1002 at 170.

68
IPR2017-00361
from said vehicle;
information.
VIII. Conclusion
For these reasons, challenged claims 1-15 are unpatentable and Petitioner
respectfully requests that the Board grant this Petition and institute trial.
69
IPR2017-00361
Date: December 1, 2016
Respectfully submitted,
By: /P. Andrew Riley/
P. Andrew Riley
Reg. No. 66,290
Finnegan, Henderson, Farabow,
Garrett & Dunner, LLP
Washington, DC 20001-4413
Telephone: 202-408-4266
Facsimile: 202-408-4400
E-mail: Shipping-Transit-207IPR@finnegan.com
Jonathan Stroud
Reg. No. 72,518
Unified Patents Inc.
1875 Connecticut Ave. NW, Floor 10
Telephone: 202-805-8931
Facsimile: 650-887-0349
E-mail: jonathan@unifiedpatents.com
70
IPR2017-00361
CERTIFICATE OF COMPLIANCE
The undersigned hereby certifies that the foregoing Petition for Inter Partes
Review of U.S. Patent No. 6,415,207 contains less than 14,000 words, excluding
those portions identified in 37 C.F.R. 42.24(a), as measured by the wordprocessing system used to prepare this paper.
By: /P. Andrew Riley/

P. Andrew Riley
Reg. No. 66,290
Washington, DC 20001-4413
Telephone: 202-408-4266
Facsimile: 202-408-4400
E-mail: Shipping-Transit-207IPR@finnegan.com
71
IPR2017-00361
CERTIFICATE OF SERVICE
Pursuant to 37 C.F.R. 42.6(e) and 42.105(b), the undersigned certifies
that the foregoing Petition for Inter Partes Review and the associated Exhibits
1001 through 1013 were served on December 1, 2016, by FedEx at the following
address of record for the subject patent.
Henry Artoush Ohanian
Law Offices of Artoush Ohanian
400 West 15th Street
Suite 1450
Austin, Texas 78701
(512)791-7963
Dated: December 1, 2016
Respectfully submitted,
By: /Lauren K. Young/
Lauren K. Young
Legal Assistant
72

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Unified Patents Inc. v. Shipping &amp; Transit, LLC, IPR2017-00361, Paper 1 (Dec. 1, 2016) (Petition)

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IPR2017-00361

U.S. Patent No. 6,415,207

UNITED STATES PATENT AND TRADEMARK OFFICE

BEFORE THE PATENT TRIAL AND APPEAL BOARD

UNIFIED PATENTS INC.,

Mandatory Notices Under 37 C.F.R. 42.8 ........................................................... 1

Real Parties-in-Interest .................................................................................... 1

Related Matters ................................................................................................. 2

Lead and Backup Counsel Information .....................................................14

Fee Payment ................................................................................................................15

Statement of Precise Relief Requested for Each Claim Challenged ...............15

Claims for Which Review is Requested ....................................................15

Statutory Grounds of Challenge ..................................................................15

The 207 Patent ...........................................................................................................16

Overview of the Disclosure ..........................................................................16

Prosecution History ........................................................................................19

Level of Ordinary Skill in the Art ...............................................................20

Claim Construction ....................................................................................................22

VII. Statement of Relief Requested: 37 C.F.R. 42.104(b) (Grounds 1-2) ...........26

Ground 1: Peterson renders obvious challenged claims 1-15...............26

Overview of Peterson ........................................................................26

Peterson renders obvious claim 1 ...................................................28

Peterson renders claim 2 obvious ...................................................32

Peterson renders claim 9 obvious ..................................................32

Peterson renders claims 3-8, 10-15 obvious .................................34

Ground 2: Smith in view of Janky renders obvious challenged

Overview of Smith ..............................................................................36

Overview of Janky ..............................................................................37

Smith and Janky render obvious the subject matter of

Smith and Janky render obvious the subject matter of

Smith renders obvious the subject matter of claim 3 ...................50

Smith and Janky render obvious the subject matter of

Smith and Janky render obvious the subject matter of

Ground 3: Trask in view of Janky renders obvious challenged

Overview of Trask ..............................................................................55

Trask and Janky render obvious the subject matter of

Smith and Janky render obvious the subject matter of

Trask renders obvious the subject matter of claim 3 ...................64

Trask and Janky render obvious the subject matter of

Trask and Janky render obvious the subject matter of

Mandatory Notices Under 37 C.F.R. 42.8

Pursuant to 37 C.F.R. 42.8(b)(1), Petitioner certifies that Unified is the real

Petitioners Voluntary Interrogatory Responses.

The 207 patent is involved in a related proceeding, IPR2016-01465 (July

GlobalTranz Enterprises Incorporated v. 2-16-cv-

Shipping and Transit LLC

IntegraCore, LLC v. Shipping and Transit, 2-16-cv-

Z-Firm, LLC v. Shipping and Transit, LLC 2-16-cv-

Shipping and Transit, LLC v. Fulmer 9-16-cv-

Shipping and Transit, LLC v. Dispatch 2-16-cv-

Shipping & Transit, LLC v. DISH Network 2-16-cv06527

Shipping and Transit, LLC v. Comcast 2-16-cv-

Shipping and Transit, LLC v. Woodland 2-16-cvInternational Transport Company Inc. et al

Shipping and Transit, LLC v. Ship it Smarter 9-16-cv-

Shipping and Transit LLC v. Adorpix LLC

Shipping and Transit, LLC v. St. George 9-16-cv-

Shipping and Transit, LLC v. CD Universe

Shipping and Transit, LLC v. Fairprice 9-16-cv81195

Shipping and Transit LLC v. GeoMetrix 2-16-cvUSA Inc.

Shipping and Transit LLC v. SFG, LLC et al

Shipping and Transit LLC v. Efuego Corp., 2-16-cv04868

Shipping and Transit LLC v. Greyhound 2-16-cv04869

Shipping and Transit, LLC v. Auctane LLC 9-16-cv81119

Shipping and Transit, LLC v. Eastern 9-16-cv81060

Unified Patents Inc. v. Shipping & Transit, LLC, IPR2017-00361, Paper 1 (Dec. 1, 2016) (Petition)

Unified Patents Inc. v. Shipping & Transit, LLC, IPR2017-00361, Paper 1 (Dec. 1, 2016) (Petition)