Sisvel v. Unified Patents Inc., IPR2017-00565, Paper 1 (Jan. 23, 2017) (Petition)

IPR2017-00565
U.S. Patent 6,754,580

DOCKET NO. 10111-0004
Filed on behalf of Unified Patents Inc.
By:
Kevin B. Laurence, Reg. No. 38,219

Matthew C. Phillips, Reg. No. 43,403
Renaissance IP Law Group LLP
1940 Duke Street, Suite 200
Alexandria, VA 22134
Tel: (703) 448-8787
Email: kevin.laurence@renaissanceiplaw.com
Email: matthew.phillips@renaissanceiplaw.com
Jonathan Stroud, Reg. No. 72,518
Unified Patents Inc.
1875 Connecticut Ave. NW, Floor 10
Washington, D.C. 20009
Tel: (202) 805-8931
Email: jonathan@unifiedpatents.com
UNITED STATES PATENT AND TRADEMARK OFFICE
_______________________________________________
BEFORE THE PATENT TRIAL AND APPEAL BOARD
_______________________________________________
Unified Patents Inc.
Petitioner
v.
Societ Italiana Per Lo Sviluppo dellElettronica S.p.A.
Patent Owner
IPR2017-00565
Patent 6,754,580
PETITION FOR INTER PARTES REVIEW OF
U.S. PATENT NO. 6,754,580
CHALLENGING CLAIMS 113
UNDER 35 U.S.C. 312 AND 37 C.F.R. 42.104
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U.S. Patent 6,754,580
Table of Contents
I.
INTRODUCTION .............................................................................................................. 1
A.
Real Party-in-Interest ........................................................................... 1
B.
Related Matters .................................................................................... 1
C.
Counsel ................................................................................................. 1
D.
Service Information, Email, Hand Delivery, and Postal ...................... 1
II.
CERTIFICATION OF GROUNDS FOR STANDING ......................................... 2
III.
OVERVIEW OF CHALLENGE AND RELIEF REQUESTED ........................ 2

A.
B.
Prior Art Patents and Printed Publications ........................................... 2

1.
Gazis........................................................................................... 3
2.
Oates .......................................................................................... 3
3.
Anagnostopoulos ........................................................................ 3
4.
Mertens....................................................................................... 3
Grounds for Challenge ......................................................................... 3
IV.
TECHNOLOGY BACKGROUND .............................................................................. 4
V.
OVERVIEW OF 580 PATENT ................................................................................... 4
VI.
A.
Summary of the Alleged Invention ...................................................... 4
B.
Level of Ordinary Skill in the Art ........................................................ 7
C.
Prosecution History .............................................................................. 7
CLAIM INTERPRETATION ......................................................................................... 8

A.
Preamble ............................................................................................. 10
1.
exhibit ............................................................................................. 11
2.
a plurality of vehicles that exhibit means for identification ........... 12

i
3.
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U.S. Patent 6,754,580
a plurality of vehicles that exhibit . . . means for road
information ....................................................................................... 13
4.
a plurality of vehicles that exhibit . . . means for transmission

of information between the vehicle and a traffic information
center ................................................................................................ 14
B.
road network ................................................................................... 16
C.
traffic information center ................................................................ 17
D.
the road network is so arranged as to be entered into the

system as a data network .................................................................. 18
E.
each vehicle that is intended to make use of the road network

is logged in for travelling on the road network ................................ 19
F.
the system exhibits an exact image of the actual traffic

situation and guides the traffic dynamically, for control of the
traffic situation centrally................................................................... 21
VII. SPECIFIC GROUNDS FOR PETITION ................................................................ 22

A.
B.
Ground 1: Claims 18 and 1011 would have been obvious in

view of Gazis, Oates and Anagnostopoulos ....................................... 22
1.
Overview of Gazis ................................................................... 22
2.
Overview of Oates ................................................................... 24
3.
Overview of Anagnostopoulos ................................................. 26
4.
Overview of combination of Gazis, Oates, and

Anagnostopoulos ...................................................................... 28
5.
Rationales
to
combine
Gazis,
Oates,
and
Anagnostopoulos ...................................................................... 31
6.
Detailed identification of claimed subject matter in

Gazis, Oates, and Anagnostopoulos ......................................... 34
Ground 2: Claims 9, 12, and 13 would have been obvious in

view of Gazis, Oates, Anagnostopoulos, and Mertens ....................... 63
ii
1.
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U.S. Patent 6,754,580
Overview of Mertens ............................................................... 63
2.
Rationales to combine Mertens with the other references ....... 65
3.
Detailed identification of claimed subject matter in the

references ................................................................................. 66
VIII. CONCLUSION ................................................................................................................. 70
iii
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Table of Authorities
Cases
Cuozzo Speed Techs. LLC v. Lee, 136 S. Ct. 2131 (2016)........................................ 9
In re ICON Health & Fitness, Inc., 496 F.3d 1374, 1379 (Fed. Cir. 2007).............. 9
In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir. 1994) ................................................. 9
In re Translogic Tech., Inc., 504 F.3d 1249, 1257 (Fed. Cir. 2007)......................... 9
Williamson v. Citrix Online, LLC 792 F.3d 1339 (Fed. Cir. 2015) (en banc in
relevant part) ....................................................................................................... 11
York Prod., Inc. v. Central Tractor Farm & Family Center, 99 F.3d 1568 (Fed.
Cir. 1996) ............................................................................................................ 11
Statutes
35 U.S.C. 102(b) .................................................................................................... 2
35 U.S.C. 103 ......................................................................................................... 3
35 U.S.C. 112, 6 .......................................................................................... 11, 15
35 U.S.C. 112(f) ................................................................................................... 11
35 U.S.C. 112, 2 ..................................................................................................... 8
Rules
37 C.F.R. 42.100(b) ............................................................................................... 9
37 C.F.R. 42.104(a)................................................................................................ 2
37 C.F.R. 42.8(b)(1) ............................................................................................... 1
iv
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37 C.F.R. 42.22(a)(1) ............................................................................................. 2
37 C.F.R. 42.104(b)(1)(2) .................................................................................... 2
77 Fed. Reg. 48,756, 48,764 (Aug. 14, 2012)......................................................... 10
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U.S. Patent 6,754,580
Initial Exhibit List
Exhibit
Document
EX1001
U.S. Pat. 6,754,580 (filed Sept. 21, 2000; published Jun. 22,
2004) (580 Patent)
EX1002
Declaration of Scott Andrews (Andrews Decl.)
EX1003
Prosecution File History Documents of the 580 Patent (580

File History)
EX1004
U.S. Pat. 5,610,821 (filed Nov. 18, 1994; published Mar. 11,
1997) (Gazis)
EX1005
UK Patent Application 2,288,892 (filed Apr. 29, 1994; published

Nov. 1, 1995) (Oates)
EX1006
WO 1993/05492 A1 (filed Aug. 28, 1991; published Mar. 18,

1993) (Anagnostopoulos)
EX1007
U.S. Pat. 5,767,505 (filed Jan. 27, 1995; priority date of Jan. 28,
1994) (Mertens)
EX1008
Unified Patents Inc.s Voluntary Interrogatories
EX1009
Merriam-Webster,
available
at
https://www.merriamwebster.com/dictionary/exhibit (last visited Jan. 19, 2017)
(Merriam-Webster)
EX1010
U.S. Pat. 5,031,104 to Ikeda (filed Nov. 18, 1994; published

Mar. 11, 1997) (Ikeda)
EX1011
U.S. Pat. 5,721,678 to Widl (filed Mar 10, 1994; published Feb.
24, 1998) (Widl)
EX1012
Magellan Nav 1000 (available at https://timeandnavigation.si.

edu/multimedia-asset/magellan-nav-1000-gps-receiver-1988
(last visited Jan. 19, 2017). (Magellan Nav 1000)
EX1013
U.S. Pat. 3,906,166 to Cooper (filed Oct. 17, 1973; published

Sep. 16, 1975) (Cooper)
vi
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U.S. Patent 6,754,580
EX1014
Ylin Zhao, Vehicle Location and Navigation Systems, Artech

House, 1997 (Zhao)
EX1015
Intentionally omitted
EX1016
Honda, The Car Navigation System, Gyro Research: The

Worlds
First
Automotive
Navigation
System,
http://world.honda.com/history/challenge/1981navigationsystem/
index.html (last visited Jan. 9, 2017) (Honda)
EX1017
Raymond A. Cass, Building Navigable Databases for the Real

World, IEEE, 1992 (Cass)
EX1018
Richard J. Weiland, Standards for Navigable Databases: A

Progress Report, IEEE, No. 912752, 1991 (Weiland)
EX1019
Hidekazu Oshizawa and Clay Collier, Description and

Performance of Navmate, An In-Vehicle Route Guidance System,
IEEE, 782787, May 23, 1990 (Oshizawa)
EX1020
Stanley K. Honey and Walter B. Zavolis, A Novel Approach to

Automotive Navigation and Map Display, IEEE, 1987 (Honey)
EX1021
James H. Rillings and James W. Lewis, TravTek, IEEE, No.

912819, 1991 (Rillings)
EX1022
ISO, ISO 14819-12003, http://www.iso.org/iso/catalogue_detail.

htm?csnumber=36922&utm_source=ISO&utm_medium=
RSS&utm_campaign=Catalogue (last visited Jan. 9, 2017) (ISO)
EX1023
TaeJin Kim, et al., Development of Personal Traffic Information

on Demand Service (PTIODS), 4th Its World Congress in Berlin,
October 2124, 1997 (Kim)
EX1024
Morie Yamaguchi et al., Trial Application of the Interactive

CDRG in UTMS, 4th Its World Congress in Berlin, October 21
24, 1997 (Yamaguchi)
EX1025
U.S. Patent 5,982,298 to Lapenbusch (filed Nov. 14, 1996;

published Nov. 9, 1999) (Lapenbusch)
vii
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I.
INTRODUCTION
A.
Real Party-in-Interest
Pursuant to 37 C.F.R. 42.8(b)(1), Unified Patents Inc. (Unified or

Petitioner) certifies that Unified is the real party-in-interest and further certifies
that no other party exercised control or could exercise control over Unifieds
participation in this proceeding, the filing of this petition, or the conduct of any
ensuing trial. In this regard, Unified has submitted voluntary discovery. See
EX1008 (Petitioners Voluntary Interrogatory Responses).
B.
Related Matters
U.S. Pat. No. 6,754,580 (580 Patent (EX1001)) is owned by Societa

Italiana Per Lo Sviluppo Dellelettronica S.p.A. (Sisvel or Patent Owner). The
Petitioner knows of no related proceedings involving the 580 Patent. The 580
Patent has not been the subject of any known litigation.
C.
Counsel
Kevin B. Laurence (Reg. No. 38,219) will act as lead counsel. Jonathan
Stroud (Reg. No. 72,518) and Matthew C. Phillips (Reg. No. 43,403) will act as
backup counsel.
D.
Service Information, Email, Hand Delivery, and Postal
Unified consents to electronic service via email at the following addresses:

kevin.laurence@renaissanceiplaw.com; matthew.phillips@renaissanceiplaw.com;
and jonathan@unifiedpatents.com. Petitioner can be reached at Renaissance IP
1
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U.S. Patent 6,754,580
Law Group LLP, 1940 Duke Street, Suite 200, Alexandria, Virginia 22314 and
(703) 448-8787 and Unified Patents Inc., 1875 Connecticut Ave. NW, Floor 10,
Washington, D.C. 20009 and (650) 9990899.
II.
CERTIFICATION OF GROUNDS FOR STANDING

Petitioner certifies pursuant to 37 C.F.R. 42.104(a) that the patent for
which review is sought is available for inter partes review and that Petitioner is not
barred or estopped from requesting an inter partes review challenging the patent
claims on the grounds identified in this Petition.
III.
OVERVIEW OF CHALLENGE AND RELIEF REQUESTED

Pursuant to 37 C.F.R. 42.22(a)(1) and 42.104(b)(1)(2), Petitioner
challenges claims 113 of the 580 Patent.

A.
Prior Art Patents and Printed Publications
The 580 Patent issued from an application that claimed priority to

PCT/SE00/01836, which was filed on September 21, 2000, and to SE9903409,
which was filed on September 21, 1999. Because the 580 Patent was filed prior to
enactment of the America Invents Act (AIA), the pre-AIA statutory framework
applies. The following references, each of which qualifies as prior art to the 580
Patent under 35 U.S.C. 102(b), are pertinent to the grounds of unpatentability
explained below.
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U.S. Patent 6,754,580
1.
Gazis
U.S. Patent 5,610,821 (Gazis (EX1004)), granted March 11, 1997. Gazis
is admitted prior art mentioned in the background of the 580 Patent. Gazis
teaches that routing can be performed holistically from a central station.
As
explained below, Gazis discloses almost all of the features claimed in the 580
Patent.
2.
Oates
UK Patent Application 2,288,892 (Oates (EX1005)), published January

11, 1995. Oates teaches the reporting of vehicle information for fleet management.
3.
Anagnostopoulos
Intl Patent Appl. Publ. WO 93/05492 (Anagnostopoulos (EX1006)),

published March 18, 1993 discloses methods for automatic vehicle routing.
4.
Mertens
U.S. Patent 5,767,505 (Mertens (EX1007)) granted June 16, 1998.

Mertens teaches payment system using GPS.
B.
Grounds for Challenge
This Petition, supported by the declaration of Scott Andrews, requests

cancellation of challenged claim 113 as unpatentable under 35 U.S.C. 103.
Specifically, claims 18 and 1011 should be cancelled as obvious over Gazis in
view of Oates and Anagnostopoulos (Ground 1), while claims 9, 12 and 13 should
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U.S. Patent 6,754,580
be cancelled as obvious over Gazis in view of Oates and Anagnostopoulos and
further in view of Mertens (Ground 2).
IV.
TECHNOLOGY BACKGROUND
Mr. Andrews, in his declaration, explains the technology discussed in this
Petition in detail, specifically delving into the concepts of centrally controlling

traffic, identifying a vehicle, logging a vehicle in to a data network, and
communicating between a vehicle and a traffic information center. See Andrews
Declaration (EX1002) at 1533.
V.
OVERVIEW OF 580 PATENT

A.
Summary of the Alleged Invention
The system as claimed in the 580 Patent enables a traffic information center
to centrally control traffic on a road network. 580 Patent (EX1001) at Abstract.
Each vehicle is required to have an identification that is used to log the vehicle in
to a data network to track the speed of the vehicle and its location on a road
network. Id.; see also id. at 8:1617. The prior art is criticized for not requiring
identification of a vehicle based on its type and size such as whether the vehicle is
a passenger car or a heavy goods vehicle because such information can be used
when determining the best route. Id. at 2:630; see also id. at 8:1724.
The specification provides limited guidance as to what logging in should
require. See VI-E infra (logged in); 580 Patent at 5:1867. Instead, the 580
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Patent provides one example and two figures that show logging in of the vehicle
and the validation of the logging in. See 580 Patent at FIGS. 1, 2 (reproduced
below); see also id. at 4:1617.
Id. at figure 1.
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Id. at figure 2.
The 580 Patent admits, as part of its background, that systems for centrally
controlling traffic were not new at the time of filing. See Id. at 1:1568. Rather,
the drafters of the 580 Patent tried to distinguish it from previous systems by
requiring identification of the vehicle when logging in to a data network.
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B.
Level of Ordinary Skill in the Art
A person having ordinary skill in the art (PHOSITA) at the time of alleged
effective filing date of the 580 Patent1 would be familiar with vehicle guidance
and traffic management and have at least the equivalent of a B.S. degree in
computer science, electrical engineering, network engineering, city planning, or a
related subject, with at least two years of experience in the field of traffic
management or evaluation and a working knowledge of domestic or global
positioning systems. Andrews Decl. at 47. A higher level of education may make
up for less experience. Id.
C.
Prosecution History
On March 12, 2002, Benny Ask et al. filed Application No. 10/088,065,
titled Systems for Guiding Vehicles. See EX1003 (580 File History) at 8. The
original application included one independent claim and eight dependent claims.
The Petitioner does not concede that the 580 Patent is entitled to the priority
dates to which it refers. The references relied upon here qualify as prior art even
if the earliest claimed priority date is assumed arguendo to be deserved, and the
definition of a PHOSITA is the same regardless of whether the actual filing date
or earliest claimed priority date is accorded to the 580 Patent.
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U.S. Patent 6,754,580
Id. at 4143. The application was filed with a preliminary amendment to change
the recited claim dependency. Id. at 6671.
On January 27, 2003, a non-final office action issued rejecting claims 19 as
being indefinite under 35 U.S.C. 112, 2 for grammatical errors, lack of
antecedent basis, and use of unacceptable grammar and claim terminology,
including thanks to, are known, such as, etc., and for example. Id. at
7583. No other rejections were made. On January 20, 2004, a response was filed
with amendments to the specification and claims and additional claims were added.
Id. at 140176. The examiner characterized the prior art of record, in the Notice of
Allowability mailed on February 13, 2004, as failing to disclose a system that
"exhibits an exact image of the actual traffic situation and guides the traffic
dynamically for control of the traffic situation centrally." Id. at 177182. Prior art
references are discussed in the section of the 580 Patent titled Description of
Related Art such as Gazis. 580 Patent (EX1001) at 1:142:30.
However,
because the claims were never rejected based on any prior art reference, there is no
discussion of prior art in the record. The 580 Patent issued on June 22, 2004, after
payment of the issue fee on May 18, 2004. EX1003 (580 File History) at 183.
VI.
CLAIM INTERPRETATION
Claim terms of an unexpired patent in an inter partes review are given the
broadest reasonable construction in light of the specification. 37 C.F.R.
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42.100(b); Cuozzo Speed Techs. LLC v. Lee, 136 S. Ct. 2131, 214546 (2016).
Any claim term that lacks a definition in the specification is therefore given a
broad interpretation. In re ICON Health & Fitness, Inc., 496 F.3d 1374, 1379
(Fed. Cir. 2007). Using the broadest reasonable interpretation, claim terms are
given their ordinary and customary meaning as they would be understood by a
PHOSITA in the context of the disclosure. In re Translogic Tech., Inc., 504 F.3d
1249, 1257 (Fed. Cir. 2007). Any special definition for a claim term must be set
forth in the specification with reasonable clarity, deliberateness, and precision.
In re Paulsen, 30 F.3d 1475, 1480 (Fed. Cir. 1994).
The following proposes interpretations under the broadest-reasonableinterpretation standard and offers support for those interpretations. Any claim term
not specifically discussed below should be given its broadest reasonable
interpretation in light of the specification, as commonly understood by a
PHOSITA.
The 580 Patent has 13 claims, only one of which, claim 1, is independent.
An image of claim 1 from the 580 Patent is below:
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U.S. Patent 6,754,580
A.
Preamble
The subject matter of the preamble is within the scope of the prior art
because each element is specifically admitted to be in the prior art in the
Description of Related Art, such as the discussion of Gazis.
10
580 Patent
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U.S. Patent 6,754,580
(EX1001) at 1:3552. The preamble recites a plurality of vehicles that exhibit
three means for limitations, which are each discussed in turn.
Whether a limitation should be construed under 35 U.S.C. 112, 6 as a
means-plus-function limitation is not merely the presence or absence of 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) (en banc in relevant part).
While the term means usually raises a
presumption that a means-plus-function limitation is recited, id., the use of the term
means without recitation of a function does not create that presumption, York
Prod., Inc. v. Central Tractor Farm & Family Center, 99 F.3d 1568, 1574 (Fed.
Cir. 1996) (Without a means sufficiently connected to a recited function, the
presumption in use of the word means does not operate.); see also MPEP 2181
(The claim limitation is presumed to invoke 35 U.S.C. 112(f) or pre-AIA 35
U.S.C. 112, 6 when it explicitly uses the term means or step and includes
functional language. (emphasis added)).
1.
exhibit
The preamble of claim 1 recites a plurality of vehicles that exhibit. 580

Patent (EX1001) at 10:47. The word exhibit, which is not defined, is used
consistently in the preamble, body of the claim, and the specification.
11
For
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example, in the specification it is stated that systems are disclosed that exhibit the
indicated characteristics. 580 Patent at 1:37. In each context, exhibit simply
means have. Andrews Decl. (EX1002) at 58.
2.
a plurality of vehicles that exhibit means for

identification
The preamble of claim 1 recites a plurality of vehicles that exhibit means

for identification.
580 Patent (EX1001) at 10:47.
identification involves the function of identifying.
The phrase means for

The phrase means for,
coupled with a recitation of a function, raises a presumption that it is a means-plusfunction limitation. The claim does not recite sufficient structure for performing
the recited function so as to overcome the presumption raised by the recitation of
means for.
The corresponding structure in the specification
disclosed as performing this claimed function is expressly
disclosed. The specification uses reference number 3 in
figure 7 to refer to a means 3 for identification. 580
Patent at 6:6263. The specification discloses an ID that identifies a vehicle. For
example, the SUMMARY OF THE INVENTION refers to communication with
a vehicle via an ID and states that [t]his ID is also used for communication
between items of vehicle equipment and between vehicles and road side
equipment.
Id. at 2:67, 3:1012.
To wit, [i]dentification is important and

12
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includes inter alia IP address or a similar network identity. Id. at 3:16-17.
Additional examples are provided in the first table in the patent, which refers to a
Vehicle ID with information about: registration, number, country code, vehicle
type, engine, etc., environmental equipment, size (height, length, etc.). Id. at
4:4348.
Thus, a plurality of vehicles that exhibit means for identification
should be interpreted as including a means-plus-function limitation in which the

recited function of identifying a vehicle, takes its ordinary meaning, and the
corresponding structure for performing that function involves each vehicle in the
plurality of vehicles having an in-vehicle device that identifies the vehicle with any
data such as the exemplary vehicle IDs listed above.
Andrews Declaration
(EX1002) at 59.
3.
a plurality of vehicles that exhibit . . . means for road

information
The preamble of claim 1 recites a plurality of vehicles that exhibit . . .

means for road information. Id. at 10:4647. The claim identifies the claimed
function of a vehicle exhibiting road information.
The claim does not recite
sufficient structure for performing the recited function so as to overcome the

presumption raised by the recitation of means for.
13
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The corresponding structure in the specification
disclosed as performing this claimed function is
disclosed.
Figure 7 shows a means 4 for road
information, as described at column 6, line 63. The

specification discloses that the vehicles exhibit road information. For example, the
SUMMARY OF THE INVENTION states that information about the proposed
route for each vehicle . . . is transmitted from the traffic information center to the
vehicle in question and in that way achieves dynamic guiding of the traffic. Id. at
2:5559.
Additional information about use of a model of a road network at
information centers and communicating that model to a vehicles computer is

described in the Description of Related Art. Andrews Decl. (EX1002) at 60
61. Thus, a plurality of vehicles that exhibit . . . means for road information
should be interpreted as including a means-plus-function limitation in which the
recited function of a vehicle exhibiting road information, takes its ordinary
meaning, and the corresponding structure for performing that function involves an
in-vehicle device that has road information.
4.
a plurality of vehicles that exhibit . . . means for

transmission of information between the vehicle and a
traffic information center
The preamble to claim 1 recites a plurality of vehicles that exhibit . . .

means for transmission of information between the vehicle and a traffic
14
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information center. 580 Patent (EX1001) at 10:4649. This limitation identifies
the function of: transmission of information between the vehicle and a traffic
information center. While the limitation makes it clear that the vehicles exhibit
the means and not the traffic information center, it does not specify whether the
transmission of information is bidirectional or unidirectional or, if the latter, the
direction of the transmission, but the body of the claim recites that information is
sent from the vehicles to the traffic information center, id. at 10:5859, and vice
versa, id. at 11:13. The recitation of a vehicle and a traffic information
center in the function merely specify the endpoints of the information
transmission, not structure for performing that information transmission. Thus the
vehicle and traffic information center do not remove the limitation from the
ambit of 35 U.S.C. 112, 6.
The corresponding structure in the specification performing this claimed
function is expressly disclosed. Specifically, figures 1 and 2 illustrate a Mobile
Communications Unit as part of or associated with the vehicle. Id. at FIGS. 12.
Overall, a plurality of vehicles that exhibit . . . means for transmission of
information between the vehicle and a traffic information center in claim 1 should
be interpreted as including a means-plus-function limitation in which the recited
function is clearly stated and takes its ordinary meaning, and the corresponding
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structure for performing that function involves a mobile communication unit in the
vehicle. Andrews Decl. (EX1002) at 62.
B.
road network
The preamble of claim 1 recites a road network and the body of claim 1
refers three times to the road network. In the Field of the Invention, the
system is introduced as being useful in densely populated areas containing a road
network. 580 Patent (EX1001) at 1:79. The 580 Patent does not define the
phrase road network, but provides an example of a road network as shown below
in figure 7 at 1.
Id. at figure 7.
16
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The road network 1 in figure 7 is clearly a representation of interconnected
roads. Thus road network should be interpreted to mean interconnected roads.
Andrews Decl. (EX1002) at 6364.
The proposed interpretation of road
network is consistent with the specification and the ordinary use of the term road
network.
C.
traffic information center
Claim 1 recites a traffic information center in its preamble and the traffic
information center is recited several times in the body of claim 1.
The
SUMMARY OF THE INVENTION describes how the information pertinent to

providing directions or guidance for a motor vehicle can be transferred to,
processed at, and sent from a traffic information center. 580 Patent (EX1001) at
1:42.
Figure 7, reproduced above, depicts a central traffic information center 6 and
a plurality of peripherally located traffic information centers 6AD. Because claim
1 does not limit the scope of the recited traffic information center to a hub such
as the central traffic information center 6, its scope includes both a central traffic
information center and any peripheral traffic center, such as traffic information
centers 6A-D. On this basis, traffic information center is at least broad enough
to encompass any node to which information pertinent to providing directions or
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guidance for a motor vehicle can be transferred to, processed at, and sent from.
Andrews Decl. (EX1002) at 6567.
D.
the road network is so arranged as to be entered into the system

as a data network
Claim 1 states that the road network is so arranged as to be entered into the
system as a data network.
The 580 Patent does not define the term data
network.
Under the heading of The Invention, the 580 Patent states, The invention
is characterized by the idea that: The road network is regarded as a data network,
into which you log in when you drive out on the road. 580 Patent (EX1001) at
8:1115. Claim 1 was amended during prosecution and originally recited that the
road network is so arranged as to be entered into the system in such a way that it is
regarded as a data network. Prosecution History (Ex. 1003) at 172 (Amendment
of June 4, 2003 at 33). The amendment removed the concept from the claim that
the road network is regarded as a data network.
The term road network is discussed above and means interconnected
roads.
The patents Description of Related Art, prior art references are
summarized including Gazis, which has a traffic information center that stores a
model of the road network. 580 Patent at 1:4142. Gazis describes a stored
model on a computer of a road network that specifies the geometry of road
segments and traffic characteristics of the road segments. Gazis (EX1004) at 1:12
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15 and 6466. As best understood, the 580 Patent seems to carry forward this
concept to the invention. Andrews Decl. (EX1002) at 6870. In this way, data
representing a model of the road network is entered into and stored in the data
network, which includes the traffic information center and the claimed system.
Id. Thus, the limitation means that data representing a model of the road network
is stored in the data network, which may be a computer network.
E.
each vehicle that is intended to make use of the road network is

logged in for travelling on the road network
Claim 1 recites that each vehicle that is intended to make use of the road
network is logged in for travelling on the road network. 580 Patent (EX1001) at
10:5253. The language of this logged in phrase requires that what logs in are
certain vehicle[s], not the users, such as the drivers, of the vehicles. In the
Description of Related Art, the 580 Patent criticizes the prior art as not
requiring an indication of information about the vehicle such as vehicle type, size
and environmental data, etc. because without such information heavy goods
vehicles are guided in the same way as passenger cars. Id. at 2:79.
The recited logged in phrase does not specify what the vehicle is logged
into, but the most likely option is for the vehicle to be logged into the data
network, which is referred to, as best understood, as the system. Andrews Decl.
(EX1002) at 71-76. The 580 Patent also criticizes the prior art for not requiring
that the vehicles must be logged into the system, making them known and at all
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times identified with an indication of their position. 580 Patent at 2:1517
(emphasis added). This supports each vehicle being logged into the system. To
wit, the patent refers to a data network, which you log in to, when the patent
characterizes The Invention. Id. at 8:1115. The system requires registration of
a vehicle once, and the system then tracks future demands based on a unique
vehicle identification. Andrews Decl. at 74.
The system is only able to control vehicles that are logged in to the data
network so this limitation only relates to vehicles that are logged into the data
network. Id. at 75. This view is supported by the scope of the vehicles that are
described in the preamble, which limits the system to use with vehicles that meet
the limitations recited in the three means clauses. Id. The limitation of the system
to vehicles that meet the requirements of the means clauses makes it clear that
recitation of each vehicle relates to just a subset of possible vehicles.
In
particular, the subset of possible vehicles includes those vehicles capable of

logging in to the data network, which requires that the vehicles have an
identification and the ability to communicate with a traffic information center
about data such as road information. Id. Overall, the phrase each vehicle that is
intended to make use of the road network is logged in for travelling on the road
network should be interpreted to mean that all vehicles capable of logging in to
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the data network and that will make use of the road network have been logged in to
the data network.
F.
the system exhibits an exact image of the actual traffic situation

and guides the traffic dynamically, for control of the traffic
situation centrally
The final element in claim 1 recites that the system exhibits an exact image
of the actual traffic situation and guides the traffic dynamically, for control of the
traffic situation centrally. The specification indicates that all vehicle movements
are known. Id. at 2:5963, 7:2327, 9:4647. Of course, awareness of all vehicle
movements is limited to vehicles that are logged in to the data network. Andrews
Decl. (EX1002) at 8082. Awareness of all vehicle movements yields an exact
assessment of the actual traffic situation, which enables centralized traffic
planning. Id. This phrase should thus be interpreted to mean that the system has
data from vehicles such that the system has an exact assessment of the actual
traffic situation for the vehicles that are logged into the data network, and that
assessment is used for centralized traffic control. Id. Because the system has an
exact assessment of the actual traffic situation, guidance is provided to each
vehicle based on the centralized traffic control and the guidance may include
displayed guidance with displayed images of maps. Id.
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VII.
SPECIFIC GROUNDS FOR PETITION

A.
Ground 1: Claims 18 and 1011 would have been obvious in

view of Gazis, Oates and Anagnostopoulos
1.
Overview of Gazis
Gazis is one of many prior-art references that teach centralized routing. In

the Gazis system, a driver inputs a destination into the in-vehicle unit 6, which
determines the current starting position by interfacing with a GPS receiver. Gazis
(EX1004) at 4:3742. That data is transmitted to a traffic management center
(TMC) 2, as a superior alternative to decentralized, autonomous routing performed
in each vehicle. The TMC 2 has route planning algorithms so that an optimal or
near optimal shortest time route can be selected. Id. at 3:4143. Because the
TMC has awareness of the routes selected by other travelers and congestion
information not known to all drivers, the TMC can perform optimal and stable
route planning holistically. Id. at 4:4445, 1:1618, 4:37.
Gaziss figure 1 illustrates the TMC 2, the in-vehicle units 6, and their
interconnection via the cellular network 4:
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Id. at figure 1.
[E]ach vehicle computer is assigned an IP address. Id. at 3:1519. The IP
address is an identification and enables a vehicle to log into a data network once
the computer of in-vehicle unit 6 receives power from the vehicles electrical
system. Andrews Decl. (EX1002) at 86. Further, Gazis implicitly requires a
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vehicle to be logged in to the data network because the TMC maintains a list of all
active participants in the system. For example, Gazis provides that
[w]hen the TMC detects a significant change in a road
segment's traffic parameters, it searches its list of travel
plans to see if any en route vehicles would be affected. If
the new travel plans result in significantly better
performance based on the driver's criteria, the new plan
and an explanation for the change will be sent over the
wireless means to the vehicle's mobile computer.
Gazis (EX1004) at 5:1719.
Gazis can only search its list of travel plans of the vehicles in the system if the
vehicles have registered their information and identity with the systems by logging
in to the system. Andrews Decl. at 87.
2.
Overview of Oates
Oates discloses a truck fleet management system in which each truck is

equipped with a capture device 5, sensors 610, and a receiver/transmitter 11, as
shown in figure 1 (reproduced below).
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Oates (EX1005) at figure 1.

Data is collected by the data capture device 5 and transmitted to a data
analyser 20 at a remote site via a communications link (11, 60, 21). Oates
(EX1005) at Abstract. The data capture device may continuously monitor various
parameters relating to a vehicle. Id. at 17:1115. The data is communicated to the
data analyser 20 substantially continuously, and/or at discrete time intervals,
which may be periodic. Id. at 2:1520. The data for a particular vehicle can be
analyzed, as shown below in figure 23, which implicitly requires that the vehicles
being analyzed are registered or logged into a system. Andrews Decl. (EX1002) at
9091.
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Oates (EX1005) at figure 23.

3. Overview of Anagnostopoulos
Anagnostopoulos provides a rich, lengthy disclosure of a comprehensive vehicle
routing and navigation system and teaches almost all of the features of the
purported invention claimed in the 580 Patent. See Andrews Decl. (EX1002) at
9294. Vehicles in the Anagnostopoulos system are equipped with a system as
illustrated in, for example, figure 1:
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Anagnostopoulos (EX1006) at figure 1.

The vehicles memory unit 5 stores data representing the topography of the
road network in encoded form. Id. at 18:3031. Using that data, the processing
unit 1 provides navigation and routing services to guide the driver to a desired
destination. Id. at 1416. The selected route [is presented] on a part of the road
map. Id. at 15:6-7. A dot represents the vehicles real position on a display.
Id. at 43:2930.
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One feature of Anagnostopoulos is that Traffic Police can re-route traffic.
Id. at 17:118. Specifically, the traffic police maintain a central station or set of
sub-stations that transmit messages to one or more vehicles for guidance of the
drivers, such as course modification recommendations. Id. at 27:2938. Each
vehicle has a receiver 7 to receive messages. To address specific vehicles, each
vehicle has a unique travelling code at any given time, id. at 9697, as well as
license plate number to which messages can be directed, id. at 9798. The former
is dynamic while the latter is static. Anagnostopoulos also refers to a vehicle
identification code. Id. at 34:46. Re-routing by the traffic police may be done to
avoid traffic congestion. Id. at 102:14. The traffic police may direct other
vehicles to the right, others to the left and allow other [sic] to remain on course,
according to their instructions. Id. at 102:2224. Additionally, Anagnostopoulos
discloses that a vehicles identification, such as a license plate number that is
registered, may be used to identify the size or type of vehicles, such as whether
each vehicle is a passenger vehicle, truck, tractor, or ambulance. Id. at 34:46;
74:45; and 97:2598:2.
4. Overview of combination of Gazis, Oates, and Anagnostopoulos
The table below summarizes the components of Gazis, Oates, and
Anagnostopoulos most directly corresponding to elements in the claims of the 580
Patent. Other corresponding components are identified in the claim charts below.
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580 Patent Claim
Element
Gazis
Oates
Anagnostopoulos
vehicle
vehicle
fleet of trucks
vehicle
road network
road network
road network
road network
data analyser
traffic police
central station
vehicle has an IP
address
an
identification;
vehicle engine
number;
registration
number
vehicle
identification
code, travelling
code, license
plate number
means for road

information
a model of a road
network
GPS apparatus road network

plus map
means for
transmission of
information
between the vehicle
and a traffic
information center
communication
between in-vehicle
computer and a
network
transmission
from a vehicle
to a data
analyser
tracks and updates

active participants
each vehicle is every vehicle is

tracked
known by type
desired destination
destination
desired
destination
optimal route
route
information
course
recommendation
traffic information traffic management

center
center
means for
identification or
vehicle identity
logging in
intended
destination
proposed route
control of the
traffic situation
centrally
centrally planned;
routing system assigns
traffic routes to
maintain optimal
traffic stability
29
transmission of
information to
vehicles from
central
information
stations
traffic police
transmit traffic
routes
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The combination appears exactly like figure 1 of Gazis, which is provided
below again for convenience.
Id. at figure 1.
Each reference involves vehicles that are logged in to a data network to
provide information about the vehicles. The only difference to the functions of the
elements in figure 1 of Gazis in light of the combination of Gazis with Oates and
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Anagnostopoulos is that after the combination, each in-vehicle unit 6 permits entry
of more detailed identification information about a vehicle, as taught by Oates and
Anagnostopoulos, such that the vehicle is logged in to the data network to permit
the traffic management center (TMC) 2 to centrally control the traffic using this
more detailed identification information. As explained below, a PHOSITA would
have found it obvious to modify Gaziss system for centralized, holistic routing at
TMCs by incorporating Oatess transmission of more detailed identification data
and other information from a vehicle with the identification data in
Anagnostopoulos that may include information about the type of vehicle such as
whether a vehicle is a passenger vehicle, truck, tractor, or ambulance.
5. Rationales to combine Gazis, Oates, and Anagnostopoulos
Gazis states that a TMC is provided with route planning algorithms so that
an optimal or near optimal shortest time route can be selected for a vehicle. Gazis
(EX1004) at 4:3742.
Additionally, Gazis states that a TMC may also be
equipped with algorithms to optimize routes based on other criteria, possibly

selected by the driver, such as cheapest route (shortest time constrained to
minimize cost), or least acceleration/deceleration (to minimize pollution and/or
fuel consumption). Id. at 3:4550. A PHOSITA would have been motivated to
modify Gazis to improve its options for a system to optimize routes for factors
other than just the shortest time, such as minimizing pollution and/or fuel
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consumption. Optimizing routes for these factors requires centralized control of
the traffic as taught by Gazis, in combination with a correct understanding about
the vehicles using the road network obtained by the vehicles identification and
being logged in to a data network. Andrews Decl. (EX1002) at 95.
Gazis discloses that each vehicle has an identification because each vehicle
has an IP address.
Id. at 3:1519.
However, to achieve objectives such as
minimizing pollution or fuel consumption, more detailed identifying information is

needed than the IP address used by Gazis. To wit, Oates discloses transmission of
a vehicles identification such as a vehicle engine number and a registration
number.
Oates (EX1005) at 18:3319:5.
The information associated with a
vehicles identification in Oates is sufficient for a vehicle to be guided based on its

pollution potential or fuel consumption via a centralized control because the
identification in Oates implicitly indicates that the network receives relevant data
to recognize a type of vehicle. And Anagnostopoulos explicitly discloses that the
identification may include the size or type of vehicle such as whether the vehicle is
a truck or an ambulance. Anagnostopoulos (EX1006) at 34:46. Recognition that
a vehicle is a truck may prompt the vehicle to be guided to an area that can tolerate
some pollution, while awareness that a vehicle is an ambulance would prompt the
shortest route to be emphasized. Andrews Decl. at 88, 91, and 96.
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Oates discloses continuously monitoring various parameters and conditions
relating to a vehicle and then providing the related data to a data analyser on a
continuous basis and/or at discrete time intervals. Oates (EX1005) at 11:3412:12
and 17:1115. Because analysis of a vehicles performance requires ability to
track a particular vehicle, Oates implicitly requires the vehicles to be logged in or
registered. In addition to indicating the size or type of a vehicle, a vehicle in
Anagnostopoulos may receive instructions, course modification recommendations,
warnings, and personal calls based on identification such as a license plate number.
Anagnostopoulos (EX1006) at 97:3898:2.
The unique identifications in
Anagnostopoulos require vehicles to be registered to, or logged into, a data

network. Andrews Decl. at 97.
Based on the motivations provided by Gazis, a PHOSITA would have found
it obvious to modify the system of Gazis to use the transmittal of information, as
taught by Oates, to plan routes based on the more-detailed vehicle identification, as
taught in Oates and Anagnostopoulos, at least to minimize pollution or fuel
consumption. This information can be even more finely deployed with the type of
identification utilized in Anagnostopoulos. Andrews Decl. at 98.
The detailed identifying information used in Oates and Anagnostopoulos
also implicitly requires the vehicles to be registered or logged in to the data
network, like Gazis.
To be sure, the 580 Patent discusses Gazis, and then
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incorrectly criticizes prior art systems such as Gazis for not requiring the vehicles
to be logged in to a data network and making them known and at all times
identified with an indication of their position. 580 Patent (EX1001) at 1:3852
and 2:1518. This unrebutted criticism overlooks vehicles implicitly logging in to
a data network in Gazis. Andrews Decl. at 99 & 132133.
6. Detailed identification of claimed subject matter in Gazis, Oates,
and Anagnostopoulos
Each claim limitation is correlated with citations to the prior art references.
Summaries are provided when multiple sections of a prior art reference are quoted.
Claim
Limitations
Citations to Gazis (EX1004), Oates (EX1005), and

Anagnostopoulos (EX1006), (with emphases added in bold)
[1.0] System for

Gazis discloses:
controlling
The present invention relates to vehicle route planning
vehicle
systems, and in particular, to a system for maintaining
movements, in
optimal vehicle traffic flow.
areas containing a
Gazis at 1:68.
road network,
Anagnostopoulos discloses:
The invention refers to a method of routing (that is
setting-up the vehicles course towards a
predetermined destination), navigation (that is
estimating and verifying the vehicles position, on the
road network at any instant and guiding the driver on
the course and manoeuvres [sic] he has to follow.
Anagnostopoulos at Abstract.
See Andrews Decl. at 101104.
[1.1] and a
plurality of
Gazis discloses:
The communication protocols can follow the TCP/IP
34
vehicles that
exhibit means for
identification,
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[transport communication protocol/internet protocol]
suite of open protocols used in the Internet wide area data
network communication scheme. In this way, each TMC
[traffic management center] is assigned an internet
protocol (IP) address, and likewise each vehicle
computer is assigned an IP address.
Gazis at 3:1519.
Gazis discloses:
an optimal route planning system comprising: one or
more fixed computers connected via a wide area network
. . . [and] . . . communication means allowing fixed and
wireless communication between the fixed computers
and mobile in-vehicle computer units.
Id. at 1:622:2.
Because Gazis discloses that each vehicle is assigned an IP
address and that the vehicles have computers that
communicate with traffic information centers, this limitation is
met by Gazis. See Andrews Decl. at 105106.
Oates discloses:
[t]he input device, eg. [sic] a hand held terminal and/or
modem, and/or PC or computer memory storage device,
may be used to program the data capture device unit with
various
vehicle
specifications,
for
example
manufacturers engine and or chassis number;
registration number; owner; supplier/dealer details;
road fund tax licence category; recommended oil type,
eg. synthetic /mineral; recommended tyre size; purchase
price paid for vehicle.
Oates at 18:3319:5.
Oates discloses:
[t]he hand held terminal may be used to perform the
following data input or data monitoring operations: enter
an identification.
Id. at 20:1416.
Because Oates discloses that an identification such as a vehicle
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registration number may be entered in an input device in a
vehicle, this limitation is met by Oates. See Andrews Decl. at
107108.
This limitation is also met by Anagnostopoulos, which
discloses that a central station may transmit instructions,
course modification recommendations, warnings, and personal
calls to a vehicle based on the vehicles identification.
Anagnostopoulos at 27:2933. Further, Anagnostopoulos
makes specific reference to an identification code, which is
used to identify the size or type of vehicles such as whether
the vehicles are trucks, ambulances, etc. Id. at 34:46; see
also id. at 73:3874:6. Anagnostopoulos also utilizes license
plate numbers to direct messages to specific vehicles. Id. at
97:3898:2. See Andrews Decl. at 109110.
Information and guidance of the drivers by the traffic
regulation agency e.g. by the traffic police or the police,
in the following ways:
* Through a central station of the agency from which
messages are transmitted containing instructions, course
modification recommendations, warnings and personal
calls. These messages are accompanied by positions
codes or vehicles identification, so that they are
decoded and taken into consideration by vehicles of a
particular position or identification.
Anagnostopoulos at 27:2535.
vehicles, the size or type or identification of which, is
determined by the identification code (e.g. trucks,
ambulances etc.
Id. at 34:46.
following data is available to the microcomputer:
the type of vehicle, that has been supplied with the
present supporting method (passenger vehicle, truck,
tractor, weight, dimensions, number of wheels etc.)
Id. at 73:3874:6.
The method has a personal character as it concerns
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every time a particular vehicle and a particular driver,
e.g. by the service and the driving method of specific
vehicles type or each vehicle separately when inputting
the vehicles type in the memory unit or by the ability to
identify special characteristics of the driver etc.
Id. at 39:38.
Other preconditions that enable message reception are:
. . . Vehicles with license plate number registered in
the memory unit. Thus, only the particular vehicles
may receive the message.
Id. at 97:2598:2.
[1.2] means for
road information
and
Gazis discloses:
computers storing a model of a road network specifying
the geometry of road segments and traffic characteristics
of the road segments . . . communication between the
fixed computers and mobile in-vehicle computer units.
Gazis at 1:632:2.
Gazis also discloses road information obtained from user
vehicles: for example:
[a]s each road segment is transited by the vehicle, the onboard computer records the time it took to transit the road
segment, and transmits this information over the wireless
communication means to the TMC, which uses this
information to update its model of the road segment for
future travel planning. In this way, each vehicle acts as a
probe to measure the real-time dynamic transit
information of the road network. The probe data is also
used to update the location of the vehicle and its expected
future progress through the road network.
Id. at 5:110.
Gazis discloses communication of various road information
from user vehicles to the traffic management center:
It is, therefore, the function of the in-vehicle units to
provide the TMCs with trip planning, location and route
guidance information. This information is in the form of
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destinations and travel preferences, actual link travel
times and intersection delay queues; and also mayday
requests.
Id. at 3:64 to 4:2.
Because Gazis discloses computers with a stored model of a
road network that communicate with mobile in-vehicle
computer units, Gazis discloses means for road information.
Oates discloses a GPS apparatus, which allows the vehicle
position to be tracked on an on-screen map. Oates at 20:33
21:4. A PHOSITA would recognize that that a map is a
graphical representation of road information. See Andrews
Decl. at 114115.
This limitation is also met by Anagnostopoulos, which
discloses a data processing system on-board a vehicle that
stores data representing a road network. Anagnostopoulos at
1:2934, 53:58. Routes are presented on a road map that is
displayed. Id. at 15:59, 43:1232. See Andrews Decl. at
116117.
The road network of an area is registered in the
memory unit, in such a way as that the real needs of the
driver are served.
The invention refers to a method of . . . navigation (that
is estimating and verifying the vehicles position, on the
road network and guiding the driver on the course and
manoeuvres he has to follow) . . . using a limited number
of devices . . . and which devices are connected with and
controlled by a data processing system which is
installed on-board the vehicle in such a way that the
processing system, upon receipt of the devices indiations
[sic], based on pre-programmed criteria as well as on
data stored in its memory unit, to . . . . identify the road
network and the prevailing conditions in every spot
(traffic signs, locations and building on both sides,
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topography etc.
Id. at 1:636.
Services for the vehicles routing on the road network
. . . . Provides, from the start, the information about the
selected route, such as its duration, its presentation on a
part of the road map, its overall length, the number of
required turns, the number of traffic lights included, etc.
Id. at 15:59.
Driver Interface (Display) . . . . It refers to a display
presenting data in the following forms:
* Characters, texts, etc.
* Symbols
* Figures, letters
. . . . During this function, a small cycle and a dot with
cruciform ends (Fig. 3) appears on the display. Those two
spots appear in a square frame. In this figure the dot
represents the vehicles real position, whilst the cycle
represents the imaginary position concluded by the road
network topography data and the regulations for safe
driving.
Id. at 43:1232.
[1.3] means for
transmission of
information
between the
vehicle and a
traffic
information
center,
characterized in
that
The 580 Patent admits that a traffic information center (TMC)

was known because it states prior art discloses that . . . .
traffic is controlled optimally via traffic information centers.
580 Patent at 2:15. See Andrews Decl. at 118120.
Gazis discloses:
one or more fixed computers connected via a wide area
network . . . [and] . . . communication means allowing
fixed and wireless communication between the fixed
computers and mobile in-vehicle computer units.
Gazis at 1:632:2.
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Id. at figure 1.
The network 4 also provides means for TMC
communication with a plurality of in-vehicle
communication and processing units 6 located in
vehicles participating in the system via a wireless data
network service provider. The wired and wireless
network communication service providers are connected
(bridged) together as is the practice today. The network
includes a plurality of base stations 8 located in strategic
geographic locations as is common in the existing
cellular mobile phone system to ensure broad,
uninterrupted coverage of a particular region.
Id. at 2:5060.
Oates discloses vehicle fleet monitoring with transmission of
information between the vehicle and a data analyser, which
is the same or similar to a traffic information center. Id. at
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11:3412:12; 17:1115. See Andrews Decl. at 121122.
Oates discloses, with reference to figure 1:
The vehicle mounted equipment includes a transmitter
and/or receiver 11 for communicating with the data
analyser 20 at a site remote from the vehicle via the
communications link.
The communications link
preferably but not necessarily comprises a satellite
communications link between the vehicle and a ground
station 21 eg. a conventional cellular telephone network,
the ground station being connectable to the data analyser
20. The communications link may comprise a local radio
network or a cell phone network. The data analyser is
preferably a personal computer, and may be connected to
the ground station over a conventional telephone
network.
Oates at 11:3412:12.
Id. at figure 1.
Anagnostopoulos discloses the transmission of information to
vehicles from central information and control centers,
which are the same or similar to a traffic information center.
Anagnostopoulos at 33:2230. The vehicles are equipped with
receivers and portable transmitters. Id. at 33:2234. See
Andrews Decl. at 123124.
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[T]he method provides general information to the drivers
on subjects concerning the surrounding area, as well as
intercommunication of the vehicles through messages
received by each vehicle's receiver which are
transmitted by: central information and control
centers, . . . transmitters installed on board other
vehicles.
List of Method Embodiment Devices[.] Those devices
are (Fig. 1): . . . Receiver (7) installed on board the
vehicle. . . Moreover, the method provides for the
installation of a subsystem of transmitters (8) of limited
range and number.
Id. at 42:38 to 43:1.
Id. at figure 1.
Gazis, Oates, and Anagnostopoulos thus meet this limitation.
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[1.4] the road
network is so
arranged as to be
entered into the
system as a data
network,
[1.5] each vehicle
that is intended to
make use of the
road network is
logged in for
travelling on the
road network,
See limitation [1.2] supra. See Andrews Decl. at 125130.
See limitation [1.1] supra.

Gazis discloses that the TMC generates travel plans for each
requesting vehicle, and that it maintains a list of such travel
plans so that if traffic conditions change the TMC can send
updated travel plans to the affected vehicles.
When the TMC detects a significant change in a road
segment's traffic parameters, it searches its list of travel
plans to see if any en route vehicles would be affected,
and if so; it computes new travel plans for those vehicles.
If the new travel plans result in significantly better
performance based on the driver's criteria, the new plan
and an explanation for the change will be sent over the
wireless means to the vehicles mobile computer.
Gazis at 5:1724 (emphasis added)
While Gazis does not explicitly refer to logging in when
generating travel plans, a PHOSITA would recognize logging
in occurs for the system to create and later search its list of
travel plans to see if any en route vehicles would be affected
by changes in traffic conditions. Andrews Decl. at 128
130. Further, a vehicle implicitly logs in to a data network
whenever a vehicle with a computer having an IP address
requests a route by communicating with a TMC. Gazis
(EX1004) at 3:1519; see also id. at 1:62-2:2. Andrews Decl.
at 131133.
Figure 1 of Oates, which is shown above with respect to
limitation [1.3], depicts a data capture device 5 in a truck and
its communication with a data analyser 20 to continuously
monitor vehicle performance functions such as speed. Id. at
11:3412:12.
Oates discloses:
43
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U.S. Patent 6,754,580
the data capture device may continuously monitor
various parameters or conditions relating to the
vehicle or its load, via inputs from the input devices such
as the hand held terminal, the radio or telecom modem,
or the sensor inputs.
Oates at 17:1115.
Figure 23 of Oates, which is provided below, depicts use of
data obtained from vehicles.
Id. at figure 23.

Oates discloses:
Referring to figure 23 . . . the data management and
storage program may allow for an analysis of driver
hours, an analysis of driver performance, and an analysis
of vehicle performance.
Oates at 32:2528.
In Oates, vehicles are logged in to a data network because
Oates teaches that each vehicle has an identification, a GPS
device, and the ability to transmit information between a
vehicle and a traffic information center.
Vehicles are
implicitly required to be logged in to enable a particular
44
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U.S. Patent 6,754,580
vehicles performance to be tracked and analyzed. Oates thus
teaches that each vehicle that will make use of a road network
is logged in for travelling on the road network. Andrews Decl.
at 134137.
The unique identification associated with vehicles in
Anagnostopoulos implicitly requires that such vehicles are
registered or logged into a system. Andrews Decl. at 138
139. For example, by identifying the size or type of vehicles
such as whether the vehicles are trucks, ambulances, etc. a
PHOSITA would recognize that a message may then be
received that is specifically for that size or type of vehicle. Id.
at 34:46. The same is true for enabling message reception to
vehicles with license plate numbers registered in the memory
unit such that only the particular vehicles may receive the
message. Id. at 97:3898:2. Andrews Decl. at 138139.
Anagnostopoulos thus discloses that each vehicle that is
intended to make use of the road network is logged in for
travelling on the road network.
[1.6] the each
[sic] vehicle is
identified with an
identity at the
time of logging
in, in conjunction
with which the
identity is either
dynamic or static,
See limitations [1.1] and [1.5] supra.

As discussed with respect to Gazis, Oates, and
Anagnostopoulos regarding limitations [1.1] and [1.5], each of
their systems requires that each vehicle has an identification
and implicitly requires that the vehicle is identified with its
identification at the time of logging in. Because an identity
that is either dynamic or static covers all possible options, it is
not necessary to determine whether Gazis, Oates, and
Anagnostopoulos teach use of a dynamic or static identity to
find that this limitation is met.
Gazis, Oates, and
Anagnostopoulos thus teach meet this limitation. See Andrews
Decl. at 140141.
[1.7] information Gazis discloses:

relating to the
means in the fixed computers for computing an optimal
intended
route for each vehicle based upon data supplied by the
destination is sent
in-vehicle units.
in from each
Id. at 2:35.
vehicle to the
traffic
The TMC is provided with route planning algorithms so
45
information
center in
conjunction with
logging in or later
in the course of a
journey when
there is a new
desired
destination,
IPR2017-00565
U.S. Patent 6,754,580
that an optimal or near optimal shortest time route can be
selected for a vehicle based on the road database static
connectivity information and individual road segment
expected delay times. The TMC may also be equipped
with algorithms to optimize routes based on other
criteria, possibly selected by the driver, such as
cheapest route (shortest time constrained to minimize
cost), or least acceleration/deceleration (to minimize
pollution and/or fuel consumption.
Id. at 3:4150.
A GPS receiver 24 is provided for generating vehicle
position data, which, when combined with GPS
differential correction data of the local TMC, will yield
precise vehicle position. The GPS receiver 24 is linked
with the in-vehicle unit via PCMCIA slot 26, but any
other data interface would not depart from the scope of
the invention. It is, therefore, the function of the invehicle units to provide the TMCs with trip planning,
location and route guidance information.
This
information is in the form of destinations and travel
preferences, actual link travel times and intersection
delay queues; and also mayday requests.
Id. at 3:574:2.
The optimal and stable route planning system of the
present invention works as follows. Before proceeding
with a trip, the driver, using his mobile computer,
interacts with the TMC 2 over the wireless system to
identify a destination.
The starting location is
communicated to the TMC from the vehicle position
subsystem. Subsequently, the TMC computes a best
route based on the drivers criteria (e.g., shortest time)
and the TMCs awareness of the routes selected by other
travelers, and then sends to the in-vehicle computer a list
of road segments and their expected characteristics (e.g.,
time to transit) that the in-vehicle computer can use to
assist the driver in navigating.
Id. at 4:3748.
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Gazis thus discloses that its system may be used to select an
intended destination and that the information relating to the
intended destination is sent in from each vehicle to its traffic
information center in conjunction with logging in or later in
the course of a journey when there is a new desired
destination. See Andrews Decl. at 142143.
As discussed with respect to Oates and Anagnostopoulos
regarding limitations [1.1] and [1.5], each of their systems
implicitly requires that each vehicle is identified with its
identification at the time of logging in.
Oates discloses that information relating to the intended
destination is implicitly sent in from each vehicle when each
vehicle uses the GPS in conjunction with logging in or later in
the course of a journey when there is a new desired
destination. Oates at 11:3412:12, 12:2224, and 32:2528.
As shown above in figure 1 of Oates, information is
transmitted from a transmitter/receiver 11 via a satellite 60 to a
ground station 20 and then to a data analyser 20, which is the
same or similar to a traffic information center. See Andrews
Decl. at 144145.
By the term routing we signify the determination of a
vehicles course from a given origin towards a
predetermined destination. With a view of providing the
routing services, the method:
a. Takes into consideration the drivers requirements
concerning the desired routing mode, that is short,
economical, easy etc.). . . .
g. Automatically selects, from the start, or adjusts
certain selected route, taking into consideration the traffic
congestion in one or more sections of the road network.
h. Automatically selects a new route towards the
predefined destination if the vehicle deviates from its
course, either on purpose or due to erroneous
manoeuvring.
Anagnostopoulos at 15:2316:15; see also id. at 16:1837.
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U.S. Patent 6,754,580
This limitation is met by the combination of Gazis, Oates, and
Anagnostopoulos because Gazis and Oates teach all aspects of
the limitation and Anagnostopoulos discloses that its system
may be used to select an intended destination and
automatically select a new route towards the intended
destination if the vehicle deviates from its course.
[1.8] information
about position
and speed of the
each vehicle is
reported at
regular intervals
to the
aforementioned
traffic
information
center,
Gazis discloses, with reference to figure 3, which is provided

below:
The in-vehicle unit includes a wireless data modem 22
acting as an interface between the unit 20 and the wide
area network antenna 33. A GPS receiver 24 is provided
for generating vehicle position data, which, when
combined with GPS differential correction data of the
local TMC, will yield precise vehicle position. The GPS
receiver 24 is linked with the in-vehicle unit via
PCMCIA slot 26, but any other data interface would not
depart from the scope of the invention.
Gazis at 3:5661.
Id. at figure 3.
As each road segment is transited by the vehicle, the onboard computer records the time it took to transit the
road segment, and transmits this information over the
48
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U.S. Patent 6,754,580
wireless communication means to the TMC, which uses
this information to update its model of the road segment
for future travel planning. In this way, each vehicle acts
as a probe to measure the real-time dynamic transit
information of the road network. The probe data is also
used to update the location of the vehicle and its
expected future progress through the road network.
Id. at 5:110.
Gazis discloses that the position and speed of each vehicle is
reported to a TMC and it would be obvious to report this
information at regular intervals, particularly since Gazis
indicates that updates regarding transit time are reported to the
TMC to update its model of the road segment. Andrews Decl.
at 146. See Andrews Decl. at 148149.
Oates discloses the tracking of a vehicles speed and position
then periodically transmitting the information to a data
analyser. See Andrews Decl. at 150151.
Oates discloses:
the data monitoring apparatus is arranged to monitor data
relationing to one or a plurality of vehicles. Preferably
the data monitoring apparatus is capable of providing real
time monitoring of data by: . . . communications of
collected data between the data capture device and the
data
analyser
device
occurring
substantially
continuously, and/or at discrete time intervals.
Preferably said time intervals are periodic.
Oates at 2:420.
The data capture unit may be pre programmed to make
covert continuous broadcast of data relating to the
vehicle position, for tracking of the vehicle.
Id. at 20:14; see also id. at 17:1113.
The data capture device comprises . . . a speed sensor
input.
Id. at 13:618.
Anagnostopoulos discloses the tracking of a vehicles position.
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U.S. Patent 6,754,580
The position estimation and verification methods,
provided by the present method, are the following: . . . .
2) Verification of vehicles position by reception from
the vehicles receiver, of signal of a nearby transmitter by
means of a transmitter network installed on the road
network.
Anagnostopoulos at 21:112. It would be obvious to a
PHOSITA to calculate a vehicles speed when possessing
positional data and data regarding the length of points along
the road network. See Andrews Decl. at 152.
[1.9] whereby
overall control of
the traffic is
achieved on the
basis of the
information
reported to the
traffic
information
center,
Gazis discloses:
A system for providing a centrally planned, completely
general routing system that assigns traffic routes to
maintain optimal traffic system stability.
Id. at Abstract.
Gazis discloses:
The TMC's act as local data processing stations for
communicating both with vehicles in the area (via a
communication service provider), as well as with other
sources of traffic information and TMCs, to calculate
an optimal routing scheme.
Id. at 2:3440.
If the TMC has already assigned routes to vehicles on
one of the routes, the resulting marginal expected
congestion caused by these vehicles occupying the links
may cause the next routed vehicle to be assigned the
alternate route (as the best available route).
Id. at 6:6064.
This limitation is thus met at least by Gazis. See Andrews
Decl. at 153154.
Anagnostopoulos also discloses routing services to control
traffic:
By the term routing we signify the determination of a
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U.S. Patent 6,754,580
vehicles course from a given origin towards a
predetermined destination.
Another example of dynamic activation concerns the
service of regulating traffic. With this service, routing
services are activated and courses for arriving at a
destination in a dynamic interacting with other vehicles
courses, in order to avoid traffic congestion are selected.
In order to regulate the traffic, in some cases, the
activation of routing services are effected from a distance
(e.g. from the Traffic Police).
Id. at 17:815. See Andrews Decl. at 155156.
[1.10]
Gazis discloses:
information about
The system includes a plurality of fixed computers,
a proposed route
linked by a wide area network, which can communicate
for each vehicle is
seemlessly [sic] with all vehicles in a region via a
transmitted from
wireless communication system. The system is
the traffic
interactive, in that the fixed computers receive data such
information
as desired route, position and segment transit time
center to the each
data from individual in-vehicle computer units and
vehicle [sic] and
determine and communicate the system optimal route to
each such in-vehicle unit.
Gazis at Abstract.
When the TMC detects a significant change in a road
segments traffic parameters, it searches its list of travel
plans to see if any en route vehicles would be affected,
and if so, it computes new travel plans for those
vehicles. If the new travel plans result in significantly
better performance based on the drivers criteria, the new
plan and an explanation for the change will be sent
over the wireless means to the vehicles mobile
computer.
1) In order to avoid traffic congestion or to transmit
necessary warnings, the traffic police selects the area of
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U.S. Patent 6,754,580
required transmission as well as the vehicles that they
desire to receive it. Thereafter, they transmit the
relevant code numbers as specified hereinabove. In this
way, the traffic police provides the desired vehicles
with the new route to be followed.
2) The traffic police may direct other vehicles to the
right, others to the left and allow other to remain on
course, according to their instructions.
As soon as the course to be followed by the vehicle
from an origin to a destination point is estimated, the
method provides a driver navigation service towards
his/her destination. This service may be divided into the
following general subservices.
a. Guidance for manoeuvres [sic] and movements
required for the course along a route. . . .
d. Guidance and notification for avoiding traffic
congestion.
Id. at 150:1623; see also id. at 300:1322. See Andrews
Decl. at 159160.
Centralized control to dynamically guide vehicles is taught by
Gazis. Additionally, Anagnostopoulos discloses information
about a proposed route for each vehicle being transmitted from
a traffic information center such as the traffic police to each
vehicle to dynamically guide vehicles for centralized traffic
control.
[1.11] the system
exhibits an exact
image of the
actual traffic
situation and
Gazis discloses a system exhibiting an exact assessment of the

actual traffic situation for the vehicles that are logged into the
data network and that assessment is used to guide and control
the traffic via a TMC. For example, figures 6-7 in Gazis
illustrate data used by a TMC to route traffic on a grid of
streets by providing different options and offering varying
transit times based on traffic delays. See Andrews Decl. at
161166.
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U.S. Patent 6,754,580
Gazis at figure 6.
Gazis discloses:
FIGS. 6 and 7 show how the Djikstra algorithm works in
the presence of blocked streets. The X's in the grid
indicate streets that are closed. Like numerals indicate a
like iso-time perimeter, i.e., the same amount of time to
reach that destination from the origin O. As shown in
FIG. 6, various ones of the streets could also be slower or
faster, accumulating more or less time to transit. In the
invention, the queue delay at intersections will be
accumulated as well, considering the different delays for
left turns, right turns and no turns. . . .
If the TMC has already assigned routes to vehicles on
one of the routes, the resulting marginal expected
congestion caused by these vehicles occupying the links
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U.S. Patent 6,754,580
may cause the next routed vehicle to be assigned the
alternate route (as the best available route).
Gazis at 6:4564.
In addition to the TMCs accurate assessment of the actual
traffic situation for vehicles that are logged into the data
network, Gazis discloses transmitting information for
displaying images in vehicles regarding actual traffic
situations. Andrews Decl. at 162163. For example, Gazis
incorporates by reference patents describing computergenerated instructions for routes including Ikeda (EX1010).
Gazis at 5:2832. Ikeda teaches display [of] the road map. . .
together with the vehicle location and the recommended
route. Ikeda at Abstract. Figures 5C-5F of Ikeda, which are
provided below, are described as showing operation of an invehicle navigator to show modes with increasing levels of
detail. Ikeda at 10:3210:11:11.
Ikeda at figure 5C.
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U.S. Patent 6,754,580
Ikeda at figure 5D.
Ikeda at figure 5E.
Ikeda at figure 5F.

55
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U.S. Patent 6,754,580
Gazis thus discloses systems exhibiting exact assessments of
actual traffic situations for the vehicles logged into the data
network and that assessment is used to guide and control the
traffic via a traffic information center.
[1.12] guides
dynamically, for
control of the
traffic situation
centrally.
See limitation [1.10] supra. See Andrews Decl. at 167170.
[2.1] System in
Gazis discloses:
accordance with
The network includes a plurality of base stations 8
claim 1,
located in strategic geographic locations as is common
characterized in
in the existing cellular mobile phone system to ensure
that a number of
broad, uninterrupted coverage of a particular region.
traffic
Gazis at 2:5660. See Andrews Decl. at 172173.
information
centers are
arranged at a
Information and guidance of the drivers by the traffic
mutual distance
regulation agency e.g. by the traffic police or the police,
from one another,
in the following ways:
* Through a central station of the agency from which
messages are transmitted containing instructions, course
modification recommendations, warnings and personal
calls. . . .
* Through sub-stations of the agency, installed at
central points, that transmit messages when activated by
the central station.
Id. at 27:2539.
Drivers awareness and guidance . . . via substations of
the present service, located at key points, which
transmit messages upon activation by the central station.
Gazis and Anagnostopoulos thus meet this limitation.
[2.2] and that
See limitation [1.1] supra.

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U.S. Patent 6,754,580
unique addressing Gazis discloses:
is so arranged as
The TMCs [sic] are nodes on a wide area network (e.g.,
to take place from
ADVANTIS), with communication capability being
this network to
provided by, in a preferred embodiment, a fixed data
these centers in
network 4 (e.g., a cellular wireless network) by means of
order to permit
an RF network message switch 5. The network 4 also
roaming between
provides means for TMC communication with a plurality
the centers.
of in-vehicle communication and processing units 6
located in vehicles participating in the system via a
wireless data network service provider. The wired and
wireless network communication service providers are
connected (bridged) together as is the practice today.
The network includes a plurality of base stations 8
located in strategic geographic locations as is common
in the existing cellular mobile phone system to ensure
broad, uninterrupted coverage of a particular region.
Id. at 2:4656.
The communication protocols can follow the TCP/IP . . .
suite of open protocols used in the Internet wide area data
network communication scheme. In this way, each TMC
is assigned an internet protocol (IP) address, and
likewise each vehicle computer is assigned an IP
address.
For the traffic regulation in the large cities, dozens of
transmitters and receivers of low range (500 or 1000
meters) are installed in all central locations and major
crossroads. The traffic police, instead of transmitting
local messages for dozens or hundreds of cases, activates
those transmitters and receivers which undertake the
task to transmit themselves, instead of the central
station, the relevant local messages.
Anagnostopoulos at 124:822. See Andrews Decl. at 178
179.
Gazis and Anagnostopoulos thus meet this limitation.
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U.S. Patent 6,754,580
3. System in
See limitations [1.8] and [1.9] supra. See Andrews Decl. at
accordance with
181185.
claim 1,
characterized in
that information
about the present
position and
information about
the present speed
of the each
vehicle is
arranged to be
sent at regular
intervals from the
each vehicle to
the traffic
information
center.
4. System in
accordance with
claim 1, further
characterized in
that dynamic
updating of semistationary data, is
achieved by
means of an
updating
protocol.
See limitation [1.2] supra. Semi-stationary data includes maps

and address information. 580 Patent at 7:4648.
Gazis discloses:
Each TMC computer has a geographic territory for which
it is responsible. Each TMC operator updates the static
information
(e.g.,
road
geometry,
one-way
restrictions, etc.) in his TMC computer's database to
correspond to the actual road infrastructure. Changes to
the static part of the road database will be broadcast
to all the other TMCs over the wide area network.
Gazis at 5:3339.
Oates discloses use of the GPS to transmit information about a

vehicles position:
to allow the vehicle position to be tracked on an on
screen map, generated by the software.
Oates at 5:3339.
A PHOSITA would recognize that maps and address
information are necessarily updated by a protocol for use in
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U.S. Patent 6,754,580
conjunction with a GPS as in Oates because the system would
become useless without accurate and current information about
semi-stationary data such as maps and address information.
Anagnostopoulos discloses dynamic updating of semistationary data, such as map and address information, which is
achieved by means of an updating protocol. For example,
Anagnostopoulos discloses updates regarding locations of drug
stores and gas stations, which implicitly involves updates to
map and address information.
Automated stations transmit timely informations without
any or with minimum requirements in e.g. maintenance
personnel. These automated stations are placed at every
area which the system covers e.g. neighborhoods,
country towns etc. These automated stations transmit a
variety of information of interest to drivers and other
users as well, e.g. drug stores and gas stations which
are open all night, ferry-boats itinerary, beginning or
termination of traffic restrictions etc., which are
characterised by variation of time during short or long
periods of time.
Before the transmission of any group of information, as
for drug stores which stay open all night, a typical code
number precedes which characterises the type of
information that will follow. The code messages which
follow consist the information that interest the driver.
These information are provided periodically e.g. every 5
min. and are continuously updated.
Anagnostopoulos at 227:320; see also id. at 73:533 and
305:35306:3.
where the following are registered:
* General interest information concerning areas or
buildings on both sides of the road.
* Elements of the road network and surrounding areas,
which vary during one day, week, month or year.
59
Id. at 292:1823.
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U.S. Patent 6,754,580

5. System in
See claim 4 supra and Andrews Decl. at 194.
accordance with
claim 4 wherein
semi-stationary
data includes map
and address
information.
6. System in
accordance with
claim 1,
characterized in
that vehicle
information
relating to the
each vehicle,
transmitted in
conjunction with
the each vehicle
logging in.
See limitations [1.1], [1.3] and [1.7] supra.

Gazis discloses that routes are computed for vehicles based
upon data supplied by the in-vehicle units. Id. at 2:35.
Information about the location of a vehicle is transmitted via
its GPS receiver to the TMC. Id. at 3:574:2. The identity of
the vehicle is also transmitted through its use of an IP address.
Id. at 3:1519. Gazis thus discloses that information relating
to each vehicle, including at least the location and
identification of each vehicle, is transmitted to a TMC in
conjunction with logging in or later in the course of a journey
when there is a new desired destination. Gazis indicates that
such information may be transmitted via the mobile in-vehicle
computer units that communicate with the fixed computers at a
TMC. Id. at 1:632:2. See Andrews Decl. at 196197.
As discussed with respect to Oates and limitations [1.3] and
[1.5], analysis of a particular vehicles performance requires
ability to track a particular vehicle, which implicitly requires
vehicle information to be transmitted in conjunction with each
vehicle logging in. Andrews Decl. at 198199.
As discussed with respect to limitation [1.1], Anagnostopoulos
discloses use of size or type such as whether the vehicles are
trucks, ambulances, etc. and other specific details such as the
weight, dimensions, and the number of wheels, which is
analogous to the other vehicle information described in the
580 Patent such as model year, presence of a catalyser, details
of environmentally friendly fuel and combinations thereof.
Andrews Decl. at 200201. To the extent that the vehicle
information in Anagnostopoulos, is not transmitted in
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U.S. Patent 6,754,580
conjunction with each vehicle logging in, a PHOSITA would
find it obvious to use this vehicle information with the system
of Gazis as described with respect to limitations [1.1], [1.3]
and [1.7]. Id. A PHOSITA would be motivated to use the
type of vehicle information disclosed by Anagnostopoulos in
combination with the vehicle information and system of Gazis
and Oates. Id.
On this basis, the combination of Gazis, Oates, and
Anagnostopoulos meet this limitation.
7. System in
accordance with
claim 6,
characterized in
that the identity
for the each
vehicle is so
arranged as to be
used for guiding
the each vehicle
during the each
vehicles journey.
See limitations [1.1] and [2.2] supra.

Gazis and Anagnostopoulos disclose this limitation as they
disclose the use of identification of vehicles that are guided
based on the identification.
For example, Gazis discloses that each vehicle is assigned an
IP address, which enables TMCs to communicate with and
guide a particular vehicle. Id. at 3:1519 and 5166.
Additionally, Anagnostopoulos discloses:
The estimation and setting-up of the course to be
followed by the vehicle in order to arrive at the
destination, coming from an initial starting point, consists
the basic supporting function provided by the method.
...
Furthermore, following
microcomputer:
data
is
available
to
the
the type of vehicle, that has been supplied with the

present supporting method (passenger vehicle, truck,
tractor, weight, dimensions, number of wheels etc.)
Anagnostopoulos at 73:574:6.
It would be obvious to a PHOSITA to use the system and
identification in Gazis in combination with the more specific
identification of size or type of vehicle in Anagnostopoulos.
8. System in
accordance with
claim 7,
See limitations [1.1], [1.5], and [1.8] supra.

As
discussed
with
61
respect
to
Gazis,
Oates,
and
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U.S. Patent 6,754,580
characterized in
Anagnostopoulos regarding limitations [1.1] and [1.5], each of
that updating of
their systems explicitly or implicitly requires that each vehicle
the position of the has an identification. As discussed with respect to Gazis and
each vehicle to
Oates regarding limitation [1.8], a vehicle with identification
the central traffic data transmits information to a central information system via
information
a separate system in the vehicle. The separate system in the
center takes place vehicle contains the identification data and other data and
via a separate
position-determining equipment. For example the other
system in the
information may be vehicle information described with respect
each vehicle, said to claim 6. Gazis, Oates, and Anagnostopoulos thus meet this
separate system
limitation. See Andrews Decl. at 208214.
contains the
identification data
of the each
vehicle and other
information for
the system.
10. System in
accordance with
claim 6, wherein
vehicle
information
comprises type,
model year,
presence of a
catalyser, details
of
environmentally
friendly fuel and
combinations
thereof.
See claim 6 supra.
11. System in
accordance with
claim 1,
characterized in
that dynamic
updating of the
route can be
See limitation [1.7] and [1.10] supra.
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U.S. Patent 6,754,580
obtained from the
traffic
information
center, which will
give a new
suggestion for a
route, in the event
of one of a
changed traffic
situation, a traffic
accident and a
wish for a
reduced volume
of traffic.

B.
Ground 2: Claims 9, 12, and 13 would have been obvious in view

of Gazis, Oates, Anagnostopoulos, and Mertens
1.
Overview of Mertens
Mertens provides a GPS system for determining positional data and then
transmitting the relevant positional data via a data transmission system to a central
point to pay the toll. Mertens (EX1007) at Abstract.
Figure 1, which is copied below, shows a road 1 with two virtual collecting
points 23 and vehicles 57. Id. at 5:412.
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U.S. Patent 6,754,580
Id. at figure 1.
GPS tracks the movement of each vehicle. By continuously determining the
position of the vehicle and comparing the vehicles position with the positions of
the collecting points 2, 3, positional data is generated to calculate the amount due.
Id. at 5:1721. The charges are totaled and temporarily stored in an in-vehicle
memory. Id. at 2:22 and 2:39. Payment is made when the use of the toll roads
reaches a predetermined amount. Id. at 2:2028. The vehicle device then makes a
connection with the central point 11 via the mobile radio network 10 for payment.
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U.S. Patent 6,754,580
Id. at 5:3132. In addition to information about the predetermined user fees being
reached, data is also transmitted identifying the debit account to be charged. Id. at
5:4550. The central point 11 may also provide billings for the vehicle owner or
user and collect the billed amounts from the bank 12 of the user. Id. at 5:5154.
By transmitting data when a predetermined amount is reached, transmission
paths in the data transmission system are not continuously occupied by payment of
small sums. Id. at 2:2936. Control data is thus temporarily stored that identifies
the vehicle as well as data regarding the traveled route, date, time and the
respectively applied fee structure. Id. at 3:916.
2.
Rationales to combine Mertens with the other references
A PHOSITA would have been motivated to combine the teachings of Gazis,

Oates, Anagnostopoulos, and Mertens for several reasons.
Andrews Decl.
(EX1002), at 233234. Mertens indicates it is advantageous to transmit data

when a predetermined amount is reached to minimize the need for transmitting
data, which requires that control data is temporarily stored to identify the vehicle
as well as data regarding the traveled route, date, time and the respectively applied
fee structure. Id. at 3:916. Because this requisite data can be obtained by the
combined teachings of Gazis, Oates, and Anagnostopoulos, a PHOSITA would
seek to combine the teachings of these three references with Mertens. Mertens
also indicates that certain identifiers, such as the license plate and vehicle shape,
65
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U.S. Patent 6,754,580
may be recorded to verify that the recorded information correlates with the control
data. Mertens at 5:3244. Because such identifiers are used in Anagnostopoulos, a
PHOSITA would recognize the advantages of their combined teachings for
security purposes.
Additionally, fleet management in Oates would be enhanced by centralized
payment of toll fees as taught by Mertens.
Such centralized payment is an
advantage over systems that use a mobile card to pay fees in conjunction with a
GPS as disclosed in Widl, which requires a driver to find a station to purchase
additional credit when the card has a low amount of remaining credit.
3.
9. System in
accordance with
claim 6,
characterized in
that the identity
for the each
vehicle is
indicated in
conjunction with
logging in, and
the identity can
be used for
services in
conjunction with
the journey
and/or at the end
of the journey
and/or during
Detailed identification of claimed subject matter in the

references
See limitations [1.1], [1.5], and [1.8] supra.
Mertens discloses:
method and system for determining toll charges for
traffic routes and areas, toll charges are calculated
with the aid of a device installed in the vehicle on the
basis of positional and tariff data. The data are then
transmitted via a data transmission system to a central
point, with the possibility of verification of the
appropriate charge.
Id. at Abstract.
the position of the vehicle is continuously determined
with the aid of the device in the vehicle [and the GPS
system] and is compared with a predetermined position
unique to a collecting point, and that upon agreement
the respective position in the form of position data is
made the basis of the calculation of the user fees.
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IPR2017-00565
U.S. Patent 6,754,580
stops.
Id. at 3:916.
to make possible a control of the determination or
debiting, it is provided in accordance with another
development that control data are temporarily stored in
the memory which allow the control of the fee
calculation, in particular data which identify the
vehicle, the traveled route, date, time and the
respectively applied fee structure.
Id. at 2:3742.
Id. at figure 1.
FIG. 1 shows a road 1. . . Two virtual collecting points 2,
3 . . . A monitoring station 4 is associated with the
collecting station 3. . . Data can be transmitted between
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IPR2017-00565
U.S. Patent 6,754,580
the vehicles 5, 6, 7 and a central point 11 via a digital
mobile radio network 10.
Id. at 5:513.
charged user fees are added up in a memory inside the
vehicle, and that the transmission to the central point
takes place at a predetermined amount of the added-up
user fees. In this connection it is preferably provided
that by means of the transfer to the central point a
corresponding credit is stored in the memory, to
which the respectively calculated fees are debited.
Id. at 2:2228.
Once the user fees added up in the vehicle device have
reached a predetermined amount, the vehicle device
makes a connection with the central point 11 via the
mobile radio network. Besides the fact that the
predetermined user fees have been reached, data which
identify the debit account to be charged are transmitted
there. . . . If it is deemed to be advantageous, the central
point 11 can also provide billings for the vehicle owner
or user and, if desired, collect the billed amounts from
the bank 12 of the user.
Id. at 5:4554.
Id. at figure 4.
The central point represented in FIG. 4 consists of a
central computer 51 . . . the monitoring devices 4 and the
banks 12 (FIG. 1) are connected with the central
computer 51.
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U.S. Patent 6,754,580
Id. at 6:5157.
The limitations of claim 9 have been met because Mertens
discloses that the vehicles identity can be used for services
such as payment of a toll in conjunction with the journey,
and/or at the end of the journey and/or during stops. See
12. System in
accordance with
claim 1,
characterized in
that payment for
using a certain
road is so
arranged as to be
recorded and
invoiced from the
traffic
information
center.
See claim [9] supra.
13. System in
accordance with
claim 1,
characterized in
that the
equipment in the
vehicle includes a
unit for reading
cash cards, or
equipment where
payment has been
effected in
advance.
See claim [9] supra.
Mertens meets this limitation because payment for using a

certain road is recorded as payment for a toll and it is invoiced
from a central point like a traffic information center. Mertens
at 5:5154. See Andrews Decl. at 236237.
Mertens meets this limitation because equipment in the vehicle

provides for means of prepayment of the user fee. Mertens
at 3:5256. Additionally, it would be obvious to a PHOSITA
that payment may be effected in advance from the users bank
because a central point provides billings for the vehicle owner
or user and collects the billed amounts from the users bank.
See id. at 5:4554. See Andrews Decl. at 239240.
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U.S. Patent 6,754,580
VIII. CONCLUSION
Based on the foregoing, the challenged claims of the 580 Patent recite
unpatentable subject matter. The Petitioner requests institution of an inter partes
review to cancel these claims.
Respectfully submitted,
/Kevin Laurence/
Kevin Laurence
Registration No. 38,219
Jonathan Stroud
Matthew Phillips
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IPR2017-00565
U.S. Patent 6,754,580
WORD-COUNT CERTIFICATE OF COMPLIANCE
Pursuant to 37 C.F.R. 42.24(d), I hereby certify that this Petition complies
with the type-volume limitation of 37 C.F.R. 42.24(a)(1)(i) because it contains
13,883 words as determined by the Microsoft Office Word 2010 wordprocessing system used to prepare the petition, excluding the parts of the petition
exempted by 37 C.F.R. 42.24(a)(1).
/Kevin Laurence/
Kevin Laurence
IPR2017-00565
U.S. Patent 6,754,580
CERTIFICATE OF SERVICE
The undersigned certifies service pursuant to 37 C.F.R. 42.6(e) and
42.105(b) of the following materials:
Petition for Inter Partes Review of U.S. Patent No. 6,754,580 Under
35 U.S.C. 312 and 37 C.F.R. 42.104 including its exhibit list
Exhibits for Petition for Inter Partes Review of U.S. Patent No.
6,754,580 (EX10011014 and EX10161025)
Word Count Certificate of Compliance
Fee Authorization
Power of Attorney
on the Patent Owner by UPS, next day delivery at the correspondence
address of record for the subject patent as listed on PAIR:
Dvorak & Orum
53 West Jackson Boulevard
Chicago IL 60604-3606
312-922-6262 Phone
312-922-7747 Fax
With an additional copy to the correspondent for the most recent assignment
of the subject patent:
Howard Cohen
13 Avenue F. Clement
Mondorf-Les-Bains
5612 Luxembourg
Dated: January 23, 2017
/Kevin Laurence/
Kevin Laurence

Sisvel v. Unified Patents Inc., IPR2017-00565, Paper 1 (Jan. 23, 2017) (Petition)

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Sisvel v. Unified Patents Inc., IPR2017-00565, Paper 1 (Jan. 23, 2017) (Petition)

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IPR2017-00565

U.S. Patent 6,754,580

Kevin B. Laurence, Reg. No. 38,219

Real Party-in-Interest ........................................................................... 1

Related Matters .................................................................................... 1

Service Information, Email, Hand Delivery, and Postal ...................... 1

CERTIFICATION OF GROUNDS FOR STANDING ......................................... 2

OVERVIEW OF CHALLENGE AND RELIEF REQUESTED ........................ 2

Prior Art Patents and Printed Publications ........................................... 2

Grounds for Challenge ......................................................................... 3

TECHNOLOGY BACKGROUND .............................................................................. 4

OVERVIEW OF 580 PATENT ................................................................................... 4

Summary of the Alleged Invention ...................................................... 4

Level of Ordinary Skill in the Art ........................................................ 7

Prosecution History .............................................................................. 7

CLAIM INTERPRETATION ......................................................................................... 8

a plurality of vehicles that exhibit means for identification ........... 12

a plurality of vehicles that exhibit . . . means for transmission

road network ................................................................................... 16

traffic information center ................................................................ 17

the road network is so arranged as to be entered into the

each vehicle that is intended to make use of the road network

the system exhibits an exact image of the actual traffic

VII. SPECIFIC GROUNDS FOR PETITION ................................................................ 22

Ground 1: Claims 18 and 1011 would have been obvious in

Overview of Gazis ................................................................... 22

Overview of Oates ................................................................... 24

Overview of Anagnostopoulos ................................................. 26

Overview of combination of Gazis, Oates, and

Detailed identification of claimed subject matter in

Ground 2: Claims 9, 12, and 13 would have been obvious in

Rationales to combine Mertens with the other references ....... 65

Detailed identification of claimed subject matter in the

VIII. CONCLUSION ................................................................................................................. 70

Declaration of Scott Andrews (Andrews Decl.)

Prosecution File History Documents of the 580 Patent (580

UK Patent Application 2,288,892 (filed Apr. 29, 1994; published

WO 1993/05492 A1 (filed Aug. 28, 1991; published Mar. 18,

Unified Patents Inc.s Voluntary Interrogatories

U.S. Pat. 5,031,104 to Ikeda (filed Nov. 18, 1994; published

Magellan Nav 1000 (available at https://timeandnavigation.si.

U.S. Pat. 3,906,166 to Cooper (filed Oct. 17, 1973; published

Ylin Zhao, Vehicle Location and Navigation Systems, Artech

Honda, The Car Navigation System, Gyro Research: The

Raymond A. Cass, Building Navigable Databases for the Real

Richard J. Weiland, Standards for Navigable Databases: A

Hidekazu Oshizawa and Clay Collier, Description and

Stanley K. Honey and Walter B. Zavolis, A Novel Approach to

James H. Rillings and James W. Lewis, TravTek, IEEE, No.

ISO, ISO 14819-12003, http://www.iso.org/iso/catalogue_detail.

TaeJin Kim, et al., Development of Personal Traffic Information

Morie Yamaguchi et al., Trial Application of the Interactive

U.S. Patent 5,982,298 to Lapenbusch (filed Nov. 14, 1996;

Pursuant to 37 C.F.R. 42.8(b)(1), Unified Patents Inc. (Unified or

U.S. Pat. No. 6,754,580 (580 Patent (EX1001)) is owned by Societa

Service Information, Email, Hand Delivery, and Postal

Unified consents to electronic service via email at the following addresses:

CERTIFICATION OF GROUNDS FOR STANDING

OVERVIEW OF CHALLENGE AND RELIEF REQUESTED

challenges claims 113 of the 580 Patent.

Prior Art Patents and Printed Publications

The 580 Patent issued from an application that claimed priority to

UK Patent Application 2,288,892 (Oates (EX1005)), published January

Intl Patent Appl. Publ. WO 93/05492 (Anagnostopoulos (EX1006)),