IN THE UNITED STATES PATENT AND TRADEMARK OFFICE

Transcription

1 IN THE UNITED STATES PATENT AND TRADEMARK OFFICE In re Patent of: Backman et al. U.S. Pat. No.: 5,902,347 Attorney Docket No.: IP1 Issue Date: May 11, 1999 Appl. Serial No.: 08/835,037 Filing Date: Mar. 27, 1997 Title: HAND-HELD GPS-MAPPING DEVICE Mail Stop Patent Board Patent Trial and Appeal Board U.S. Patent and Trademark Office P.O. Box 1450 Alexandria, VA PETITION FOR INTER PARTES REVIEW OF UNITED STATES PATENT NO. 5,902,347 PURSUANT TO 35 U.S.C , 37 C.F.R. 42

2 TABLE OF CONTENTS I. INTRODUCTION... 1 II. MANDATORY NOTICES UNDER 37 C.F.R A. Real Parties-In-Interest Under 37 C.F.R. 42.8(b)(1)... 2 B. Related Matters Under 37 C.F.R. 42.8(b)(2)... 2 C. Lead And Back-Up Counsel Under 37 C.F.R. 42.8(b)(3)... 2 D. Service Information... 2 III. PAYMENT OF FEES 37 C.F.R IV. REQUIREMENTS FOR IPR UNDER 37 C.F.R A. Grounds for Standing Under 37 C.F.R (a)... 3 B. Challenge Under 37 C.F.R (b) and Relief Requested... 3 V. SUMMARY OF THE 347 PATENT... 4 A. Brief Description... 4 B. Summary of the Original Prosecution... 6 VI. Claim Construction under 37 C.F.R (b)(3)... 7 VII. THERE IS A REASONABLE LIKELIHOOD THAT AT LEAST ONE CLAIM OF THE 347 PATENT IS UNPATENTABLE... 8 A. Ground 1 [Obviousness under 103 over DeLorme in view of Fedra] sets forth a reasonable likelihood to prevail on at least one of Claims 5, 8, and B. Ground 2 [Obvious under 103 over DeLorme in view of Fedra and Beckwith] sets forth a reasonable likelihood to prevail on at least one of Claims 6 and C. Ground 3 [Obvious over 103 over DeLorme in view of Fedra, Muller, TIFF, and JPEG] sets forth a reasonable likelihood to prevail on Claim D. Ground 4 [Obvious under 103 over Israni in view of Fedra] sets forth a reasonable likelihood to prevail on at least one of Claims 5, 8, and E. Ground 5 [Obvious under 103 over Israni in view of Fedra and Beckwith] sets forth a reasonable likelihood to prevail on at least one of Claims 6 and i

3 VIII. F. Ground 6 [Obvious under 103 over Israni in view of Fedra, Muller, TIFF, and JPEG] sets forth a reasonable likelihood to prevail on Claim [GROUND 1 CLAIM CHART] Obviousness of Claims 5, 8 & 10 under 103 by DeLorme in view of Fedra IX. [GROUND 2 CLAIM CHART] Obviousness of Claims 6 & 7 under 103 by DeLorme in view of Fedra and Beckwith X. [GROUND 3 CLAIM CHART] Obviousness of Claim 9 under 103 by DeLorme in view of Fedra, Muller, TIFF and JPEG XI. [GROUND 4 CLAIM CHART] Obviousness of Claims 5, 8 & 10 under 103 by Israni in view of Fedra XII. [GROUND 5 CLAIM CHART] Obviousness of Claims 6 & 7 under 103 by Israni in view of Fedra and Beckwith XIII. [GROUND 6 CLAIM CHART] Obviousness of Claim 9 under 103 by Israni in view of Fedra, Muller, TIFF and JPEG XIV. CONCLUSION ii

4 EXHIBITS APPLE1001 U.S. Pat. No. 5,902,347 to Backman et al. ( the 347 patent ) APPLE1002 Prosecution History of the 347 patent (Serial No. 08/835,037) APPLE1003 APPLE1004 APPLE1005 APPLE1006 APPLE1007 APPLE1008 APPLE1009 Declaration of Dr. Michael S. Braasch U.S. Pat. No. 5,848,373 to DeLorme et al. ( DeLorme ) Hybrid Geographical Information Systems by Fedra et al., EARSeL Advances in Remote Sensing Vol. 1. No. 3 VII, 1992 ( Fedra ) U.S. Pat. No. 5,140,532 to Beckwith, Jr. et al. ( Beckwith ) U.S. Pat. No. 5,968,109 to Israni et al. ( Israni ) U.S. Pat. No. 5,839,080 to Muller et al. ( Muller ) TIFF Revision 6.0, June 3, 1992 ( TIFF ) APPLE1010 JPEG File Interchange Format Version 1.02, September 1, 1992 ( JPEG ) APPLE1011 APPLE1012 U.S. Pat. No. 5,030,117 to DeLorme et al. Exhibit A to Patent Owner s Disclosure of Asserted Claims and Infringement Contentions for U.S. Pat. No. 5,902,347, served by Patent Owner in Am. Navigational Sys., Inc. v. Apple Inc., case no. 8:2014cv01130 (M.D. Fl., complaint filed May 12, 2014) iii

5 I. INTRODUCTION Google Inc., Apple Inc., Samsung Electronics America, Inc., and Samsung Electronics Co., Ltd. ( Petitioners ) petition for Inter Partes Review ( IPR ) under 35 U.S.C and 37 C.F.R. 42 of claims 5-10 of U.S. Patent 5,902,347 ( the 347 patent ). The 347 patent discloses a purported improvement to personal navigation systems exist[ing] as hand-held devices which report position in terns [sic] of latitude, longitude, and altitude, but which require[d] large amounts of data storage. Ex at 1: According to the 347 patent, that improvement was to [process] the image by dividing it into more useful square arrays, or tiles to allow the device to display portions of a map image without having to load the entire (decompressed) [map] image in memory. Id. at 4:17-19, 3: But the claimed device was not new. To the contrary, the 347 patent was granted without full consideration to the wide body of applicable prior art. For example, U.S. Pat. No. 5,848,373 to DeLorme et al. (Ex. 1004) discloses the exact limitations that the inventors indicated as [t]he proposed solution to [the] problem found in prior art devices namely, a plurality of tile data which tiles, taken together, represent a map image. Ex at 4: Much like the 347 patent, DeLorme discloses dividing a map of an area into grid quadrangles of a constant scale grid system representing a specified geographical area. Ex at 13:13-17; Ex. 1003, DeLorme is not alone, as Israni (Ex. 1007) and other references cited herein likewise disclose this same functionality. In sum, if the Office had been aware of DeLorme or other references cited herein, 1

6 the 347 patent never would have issued. Petitioners therefore request the Board to institute inter partes review of claims 5-10 on the grounds set forth below. II. MANDATORY NOTICES UNDER 37 C.F.R 42.8 A. Real Parties-In-Interest Under 37 C.F.R. 42.8(b)(1) Google Inc., Apple Inc., Samsung Electronics America, Inc., and Samsung Electronics Co., Ltd. are the real parties-in-interest. B. Related Matters Under 37 C.F.R. 42.8(b)(2) The Patent Owner is a non-practicing entity that filed complaints in the Middle District of Florida alleging infringement of the 347 patent in lawsuits on May 12, 2014 against Apple Inc. and Samsung Electronics America, Inc./Samsung Electronics Co., Ltd. (Case Nos. 8:2014cv01130 and 8:2014cv01131, now transferred to N.D. Cal.). Petitioners also submitted on this same day another IPR petition for the 347 patent based on different, nonredundant grounds. C. Lead And Back-Up Counsel Under 37 C.F.R. 42.8(b)(3) Petitioners provide the following designation of counsel. LEAD COUNSEL Michael T. Hawkins, Reg. No. 57, RBC Plaza, 60 South Sixth Street Minneapolis, MN Tel: / Fax BACK-UP COUNSEL Patrick J. Bisenius, Reg. No. 63,893 Tel: Kim H. Leung, Reg. No. 64,399 Tel: D. Service Information Please address all correspondence and service to the address listed above. Petitioners consent to electronic service by at IPR IP1@fr.com (referencing 2

7 No IP1 and cc ing and III. PAYMENT OF FEES 37 C.F.R Petitioners authorize the Patent and Trademark Office to charge Deposit Account No for the petition fee set in 37 C.F.R (a) and for any other required fees. IV. REQUIREMENTS FOR IPR UNDER 37 C.F.R A. Grounds for Standing Under 37 C.F.R (a) Petitioners certify that the 347 patent is available for IPR and that Petitioners are not barred or estopped from requesting IPR. B. Challenge Under 37 C.F.R (b) and Relief Requested Petitioners request IPR of claims 5-10 of the 347 patent on the grounds listed in the table below. In support, this Petition includes claim charts for each of these grounds and a supporting evidentiary declaration of Dr. Michael S. Braasch (Ex. 1003). Ground Claims Basis for Rejection Ground 1 5, 8 & 10 Obvious under 103 over U.S. Pat. No. 5,848,373 to DeLorme et al. ( DeLorme ) in view of Hybrid Geographical Information Systems by Fedra et al. ( Fedra ) Ground 2 6 & 7 Obvious under 103 over DeLorme in view of Fedra and U.S. Pat. No. 5,140,532 to Beckwith, Jr. et al. ( Beckwith ) Ground 3 9 Obvious under 103 over DeLorme in view of Fedra, U.S. Pat. No. 5,839,080 to Muller et al. ( Muller ), TIFF Revision 6.0 ( TIFF ), and JPEG File Interchange Format Version 1.02 ( JPEG ) 3

8 Ground 4 5, 8 & 10 Obvious under 103 over U.S. Pat. No. 5,968,109 to Israni et al. ( Israni ) in view of Fedra Ground 5 6 & 7 Ground 6 9 Obvious under 103 over Israni in view of Fedra and Beckwith Obvious under 103 over Israni in view of Fedra, Muller, TIFF, and JPEG DeLorme, Israni, and Muller qualify as prior art under at least 35 U.S.C. 102(e), having effective filing dates prior to November 19, 1996, the date of the provisional application to which the 347 patent claims priority. Fedra, Beckwith, TIFF, and JPEG are prior art under at least 35 U.S.C. 102(b), having publication dates before November 19, 1995, a year before the provisional was filed. None of these references were considered by the Examiner during prosecution. V. SUMMARY OF THE 347 PATENT A. Brief Description The 347 patent is directed to a portable device for viewing map images of an area around a user s geographic location. Ex at 1:8-10, 2: The specification of the 347 patent contends that in prior art systems a Mbyte compressed image is decompressed into virtual memory to its original size at which point it can be accessed and that [s]ince the total memory available in the handheld device will generally be far less than the uncompressed image requires, a more novel data compression retrieval, and storage scheme is required. Id. at 1: The supposed novel data compression retrieval, and 4

9 storage scheme proposed by the 347 patent was to [process] the image by dividing it into more useful square arrays, or tiles to present portions of a map image to a user without having to load the entire (decompressed) [map] image in memory. Id. at 4:17-19, 3: As described below, this supposed improvement was far from novel, as there were several earlier publications that taught this functionality of dividing map images into smaller segments for loading and presentation. The 347 patent further explains that the major steps required to post process the data begin with georeferencing the original image followed by tiling. Id. at 4: But this functionality of associating map image data with a geographic location and dividing the map image data into smaller segments for loading was likewise known before November Ex at 22-23, 25, 31-32, 70-72, Independent claim 5 is written nominally as a device claim, but recites generic features common to geolocation devices of the time in combination with elements describing mere data of image data including a plurality of tile data which tiles, taken together, represent a map image and method steps couched as software routines of a computer program adapted to control the computer. Independent claim 5 recites generic elements such as a case, a digital computer mounted in the case, a location receiver unit, an image storage unit, a computer program, and a display unit. Additionally, the elements defining the data structure of the image data recite generic elements such as pointers and header data that were commonly known in the areas of geographic image data and image data storage in general. Ex at 24, 33-39, The dependent claims recite sim- 5

10 ilarly predictable options that were also well known in the art at the time of filing. Indeed, numerous geographic display platforms implemented in the mid-1990s offered identical functionality of displaying map images that are divided into a series of smaller tiles. Id. at 22-23, 25, 31-32, 70-72, B. Summary of the Original Prosecution The 347 patent, filed on March 27, 1997, issued from a patent application that claimed the benefit of priority of a provisional application filed November 19, Independent claim 5 was allowed in October 1998 after a brief examination involving no office actions, no discussion on the record of the challenged claims, and prior art references that provided an incomplete picture of the state of the art prior to November See Ex Other than a response to a restriction requirement and a minor clerical amendment to claim 6, the challenged claims were never addressed by either the applicant or the examiner. Id. at Election and Amendment dated September 24, 1998 (pp of PDF). Additionally, the examiner s reasons for allowance address only claim 1 and its viewport and overlook the claim set challenged here. Id. at Notice of Allowability dated October 1, 1998, p. 3 (p. 81 of PDF) ( the prior art of record does not teach or make obvious a portable map display device associated with a location receiver unit, an image storage unit, an optical viewport, an image display unit and a computer program for displaying the user's location on the map image ) (emphasis added). As described in more detail below, other prior art publications which were never before the Examiner taught all elements of claim 5, which 6

11 were never substantively addressed by the Examiner or the Applicant. VI. Claim Construction under 37 C.F.R (b)(3) Claims are to be given their broadest reasonable construction in light of the specification. 37 C.F.R (b); In re Cuozzo Speed Technologies, LLC, F.3d, 2015 WL , *6-*7 (Fed. Cir. 2015). The broadest reasonable constructions below should be understood as not waiving any arguments concerning indefiniteness or claim scope that may be raised in any litigation, which requires different construction standards. The preamble (claim 5) under the broadest reasonable interpretation standard, the preamble is not limiting. Ex at 18. The preamble provides a recitation of intended use for the device, and is not necessary to give life, meaning, and vitality to the claim. Catalina Mktg. Int l, Inc. v. Coolsavings.com, Inc., 289 F.3d 801, 808 (Fed. Cir. 2002). mounted (claim 5) physically located in or housed in. Ex at 19. This interpretation is consistent with the broadest reasonable interpretation of these terms and the specification of the 347 patent. See Ex at 2:45-47, FIG. 2; Ex at 19. header data describing the size... of each tile (claim 5) data in a file header indicating the size of a geographic area associated with a tile. Ex at 20. The specification of the 347 patent uses the term size to refer the geographic size of a particular geographic area. Ex at 4: This interpretation is therefore consistent with the broadest reasonable interpretation of the claim terms and with the specification of the 347 patent. See Ex at 4:45-52; Ex at 20. 7

12 pointer (claims 5 and 10) information identifying the location of data. Ex at 20. This interpretation is consistent with the specification of the 347 patent and with the ordinary use of the term. Ex at 3:53-59, FIGS. 5, 6, 10; Ex at 20. VII. THERE IS A REASONABLE LIKELIHOOD THAT AT LEAST ONE CLAIM OF THE 347 PATENT IS UNPATENTABLE As detailed below, each of claims 5-10 of the 347 patent are rendered obvious by at least two combinations of references (Grounds 1-6). Each of the Grounds independently shows a reasonable likelihood that one or more claims of the 347 patent are unpatentable. The Grounds are not cumulative or redundant. Instead, they rely upon different combinations of references that individually assert unique benefits to the user and, additionally, they address the dependent claims in different ways. See Ex at For example, DeLorme, on which Grounds 1-3 are based, describes a new computer aided map location system (CAMLS) that uses a digital computer electronic map to display the user location, route, speed, and direction of travel with greater or lesser background context and detail of selected routes and landmarks or other geographical landmarks to allow the user to correlate the displayed location on the electronic map with a location on a printed map. Ex at 1:47-50, 6:14-20, 9: The system of DeLorme provides for correlation and coordination of spatially related data between digital electronic media such as transitory computer displays [and] printed maps. Id. at 1:9-13; 11:54-66 (describing [g]reater levels of detail on the digital map with increased memory ). DeLorme provides a more detailed teaching on the prior art trend toward the portability of the naviga- 8

13 tion device and the user convenience/experience. Id. at 1:9-13, 1:47-50, 6:14-20, 9: By contrast, Israni, on which Grounds 4-6 are based, describes a system for providing geographic data on a physical storage medium for use in a computer-based navigation system. Ex at 1: Israni is not redundant with DeLorme in that Israni focuses more on an improved method and system for storage of geographic data on physical storage media that facilitates and enhances use and access of the data by various navigation application functions in navigation systems that use the data. Id. at 2: Thus, both DeLorme and Israni explicitly disclose all (or nearly all) elements of claim 5 as described below, yet Israni provides a more detailed teaching on the prior art knowledge of improvements in storage of geographic data in physical storage media while DeLorme provides a more detailed teaching on the state of the prior art for a grid system for user correlation of location data and other specified data including by reference to a common geographical coordinate system such as the standard latitude/longitude location coordination system. Ex at 2:46-48; Ex at 1: These two references differ in the way in which they address the claim elements in material ways, including different approaches to addressing the dependent claims, as detailed below. A. Ground 1 [Obviousness under 103 over DeLorme in view of Fedra] sets forth a reasonable likelihood to prevail on at least one of Claims 5, 8, and 10 Referring to Ground 1 (charted below), the teachings of DeLorme in view of Fedra provide all elements of independent claim 5 and dependent claims 8 and 10. In particular, DeLorme describes a new computer aided map location system (CAMLS) using a coacting 9

14 personal digital assistant (PDA) or other digital or electronic computer (EC). Ex at 1: DeLorme discloses that a digital computer electronic map, is presented on a transitory computer display. Id. at 9: The digital computer electronic map displays intelligent map location information including the location of the user using a novel grid system of uniquely named grid quadrangles. Id. at 9:44-55, 9:26-29, 10: Regarding the actual structures recited in claim 5 (elements 5(a), 5(b), 5(c), and 5(d) in the charts below), DeLorme s FIG. 3 (reproduced at right) shows a user operating a PDA 15 having a case, microprocessor or CPU 217, a GPS receiver for displaying location, internal memory 219 for storing mapping data, and a graphics display 18 displaying one of several grid quadrangles and showing the location of the user 12 in that grid quadrangle. Id. at 19:41-46, 26:9-11, 2:16-21, 37:65-38:2, 19:66-20:2, 9: DeLorme further discloses the claimed tile data which tiles, taken together, represent a map image in the form of a generalized display of grid quadrangles of a constant scale grid system representing a specified geographical area. Ex at 9:49-51, 1: This is the feature that the inventors of the 347 patent characterized as their proposed solution to [the supposed] problem presented by prior art systems. Ex at 4: The grid quadrangles are created by dividing the country into constant scale regional grids and can be subdivided to create more detailed quadrangles for different zoom levels. Ex. 10

15 1004 at 8:48-49, 61:45-48; FIG. 12; Ex at 22-23, DeLorme even indicates that the terms tile and grid quadrangle are equivalent. Ex at 1:63-65 ( geographical objects are displayed on one or more generalized grid quadrangles or tiles of the grid system ); 8: Further, DeLorme, when considered in view of Fedra, provides each of the nonstructural elements (data elements/computer program) recited elements 5(d)(i)-(iii) and 5(f) of claim 5. For example, FIG. 8 of DeLorme (reproduced at right) shows a general representation of the standard CAMLS data structure. Id. at 28: DeLorme discloses that the header portion of all standard CAMLS data structures... consist[s] of [the] ID and Location Data components. Ex at 30:21-27 (emphasis added); Ex at DeLorme discloses that [t]he grid quadrangles themselves can be viewed as data items or loc/objects ordered and presented in the data structure of FIG. 8. Ex at 29:13-16 (emphasis added). DeLorme discloses that the data structure of FIG. 8 includes lat/long, the latitude and longitude coordinate location of the locatable object according to the traditional latitude/longitude geographical coordinate system, and thus provides header data describing the... geographical location of each tile. Ex at 28: As covered in greater detail in the claim chart in section VIII, infra, the CAMLS data structure likewise provides header data describing the size... of each tile in the form of 11

16 the grid name, which refers to the unique grid quadrangle name. Ex at 28:62-29:4; Ex at DeLorme describes providing unique grid quadrangles at various different grid scales with each grid scale including grid quadrangles of constant size. See Ex at 13:58-59, 8:40-9:10, 11:44-12:24, 11:44-46, 12:37-38, 14:23-25, 25:30-32, 61:66-62:6; Ex at 35. The grid name for each grid quadrangle (included in the CAMLS data structure) identifies the grid scale for a given grid quadrangle. Ex at 8:55-56, 31: Because the grid name indicates the grid scale, and each grid scale is associated with a consistent grid size, the grid name of each CAMLS data structure indicates the size for the corresponding grid quadrangle. Ex at 35; Ex at 31: Also, U.S. Pat. No. 5,030,117, incorporated by reference in DeLorme, gives a detailed description of how grid scale is indicated by the grid quadrangle name thereby indicating the size of the grid (i.e., the consistent grid size associated with grid quadrangles of each grid scale). Ex at 12:17-33; Ex at 35. To the extent that the GRIDNAME field is not considered to indicate the size of a grid quadrangle, this claim element ( header data describing the size and geographical location of each tile ) was commonly implemented in similar prior art systems. Ex at 36. For example, Fedra describes the Geographical Resource Analysis Support System for use with computer based tools to capture, manipulate, process and display spatial or georeferenced data. Ex at Fedra s system stores map image data as Grid cell files where [e]ach grid has an absolute spatial reference in terms of its position and size. 12

17 Id. at 90. Fedra discloses that each grid cell file or tile includes a description regarding size and position of the tile in its header file. Id. at 92. Fedra further discloses that the cell header for each tile/grid cell includes geographic boundaries, resolution, format containing bytes-per-cell information and compress indicator. Id. at 90. Here, the geographic boundaries information included in the header defines both the location and size of a given grid cell. Ex at 36. DeLorme further discloses pointers to the location, in the storage unit, of the data for each tile in the form of the links shown in FIG. 8 (above), which constitute the substance, the information or function of interest to the user for any CAMLS data structure. Ex at 29: DeLorme discloses that [t]he grid quadrangles themselves can be viewed as data items and that the substantive information for each data item is available elsewhere in other data records identified by links or pointers. Such pointers are the digital addresses of the related records containing the significant information. Id. at 29:13-15, 29: Both DeLorme and Fedra disclose the claimed compressed tile data and the decompressing routine. DeLorme describes [d]ata compression in order to save memory or to speed up communications such as facsimile transmissions, and the CAMLS data is later decompressed whenever the compressed CAMLS data structure is retrieved from memory. Ex at 31: Additionally, Fedra discloses that [t]he physical structure of a cell file can take one of three formats: uncompressed, compressed or reclassed. Ex at 90 (emphasis added); 93. Fedra s compressed cell file data would be decom- 13

18 pressed when the resulting cell-raster based information [is] displayed on the graphic monitor. Ex at 93; Ex at 45. Lastly, DeLorme provides the same routines/results as the claimed computer program. Ex at DeLorme teaches an associating routine in the context of using the GPS location information for displaying the location, direction of travel, route, speed, and other travel data of a CAMLS user on a generalized grid quadrangle for correlation of user location. Ex at 5: Also, the decompressing routine performed by DeLorme s system (described above) performs the same function as that recited in claim 5. Lastly, regarding the locating routine, DeLorme further teaches that [b]ased upon GPS data, the PDA responds by identifying the unique gridname or address US-NE-41-C3 for the grid quadrangle of a map where the user 12 is located. Id. at 19:49-51; 13:3-5 ( the user location may be pinpointed on a generalized grid ); 19:66-20:2. Multiple reasons would have prompted a person of ordinary skill in the art (POSITA) to combine the above-described features (suggested by Fedra) with the teachings of De- Lorme. First, a POSITA would have been prompted to modify the CAMLS data structure disclosed by DeLorme to implement header data describing the size and geographical location of each tile (as expressly suggested by Fedra) to allow for integration of the geographic information system (GIS) taught by DeLorme with one or more numerical simulation models [or] expert systems for use by planners and decision makers concerned with problem domains that include a spatial dimension such as urban or regional planning, environmental 14

19 management, transportation planning, etc, as suggested by Fedra. Ex at 89; Ex at 37. Fedra discloses that combining geographic information system data such as that taught by DeLorme with dedicated information and decision support systems holds promise for a very powerful class of integrated tools. Ex at 89. Second, a POSITA would have understood that applying the teachings of Fedra (cited above) to DeLorme would allow the tiled geographic image data disclosed by De- Lorme to be compatible with multiple systems as well as easy importation, digitization, conversion, editing, and analysis of the geographic data of DeLorme as suggested by Fedra. Ex at 90 ( exported to some other system, for instance a modeling or decision support system or an expert system. ); Ex at 38. Using the header structure disclosed by Fedra would allow the grid quadrangle data of DeLorme to be compatible with the nearly 200 different computer programs implementing a broad range of functionality that utilize the geographic data described by Fedra. Ex at 90. Third, a POSITA would have been prompted to modify DeLorme s system to include the grid cell file header information (as suggested by Fedra) because doing so would be merely the use of a known technique (e.g., including relevant information about a data file in the data file header) to improve similar devices (e.g., systems for storing and displaying geographic image data as a series of grid cell/quadrangle files) in the same way. Ex at 39. Indeed, when a patent simply arranges old elements with each performing the same function it had been known to perform and yields no more than one would expect from such 15

20 an arrangement, the combination is obvious. KSR Int l Co. v. Teleflex Inc., 550 U.S. 398, 417 (2007). Here, both DeLorme and Fedra disclose Geographical Information Systems (GIS) for storing and presenting geographic location information to users. See Ex at 1:47-50, 9:49-51, 10:31-34; Ex at 89. Additionally, both DeLorme and Fedra disclose the common GIS method of tiling, which is dividing geographical information for an area into smaller tiles (i.e., grid quadrangles or grid cells) for storage, retrieval, and presentation. Ex at 9:49-51, 1:55-57, 8:48-49, 61:45-48; Ex at 90, 92. Thus, the combination of DeLorme (which describes a data structure for storing tiled geographic image data and includes headers) and Fedra (which also describes a data structure for storing tiled geographic image data and includes headers, but with additional information to include in the header) is merely combining prior art elements according to known methods to yield predictable results. For at least these reasons and the additional explanations described in the chart below and the Declaration of Dr. Braasch, there is a reasonable likelihood that claims 5, 8, and 10 of the 347 patent are rendered obvious by DeLorme in view of Fedra. Ex at 22-51; XIII, infra (providing additional disclosure for claims 8 and 10). Moreover, to the extent the Patent Owner argues that any element of claims 5, 8, and 10 is not expressly disclosed by the combination of DeLorme in view of Fedra, such element would be rendered obvious in view of the disclosures of the DeLorme and Fedra references and in light of the knowledge of a POSITA. See Id. at

21 B. Ground 2 [Obvious under 103 over DeLorme in view of Fedra and Beckwith] sets forth a reasonable likelihood to prevail on at least one of Claims 6 and 7 As described in section VII.A., supra, DeLorme in view of Fedra discloses every element of claim 5. Additionally, in Ground 2 (charted below), DeLorme in view of Fedra and Beckwith teaches all elements of, and thus renders obvious, claims 6 and 7. Regarding claims 6 and 7, DeLorme discloses many routine data building and display processes, as well as obvious buffering techniques for speeding up computer operations, involve searching or retrieving and interrelating many data records associated with the immediate and adjacent grid quadrangles. Ex at 31:37-42 (emphasis added). Here, the buffering techniques refers to pre-loading and decompressing the compressed data for adjacent grid quadrangles. Ex at 54. This retrieval of adjacent grid quadrangle information is performed in accordance with procedures for sequencing or scripting map display/output concerning a group of grids. Ex at 34: DeLorme further describes GPS information indicating the moving location of a CAMLS equipped user traveling in a car and loading grid information for a grid quadrangle when the user travel[s] into an adjacent grid. Id. at 35:15-24; 35: DeLorme also teaches loading the current named grid quadrangle, with adjacent grids in the case of multiple grid display. Id. at 36:44-46 (emphasis added); 54:9-12. Here again, this disclosure of loading of grid quadrangle information for adjacent grids where the adjacent grid quadrangle data is compressed would include decompressing the data for the adjacent grid quadrangle. Ex at

22 DeLorme further discloses identifying which adjacent grids to buffer based on a predicted travel route of the user. Ex at 60. For example, DeLorme discloses using GPS information to determine speed [and] travel direction of a user. Ex at 56: The CAMLS system can also predict an optimum route from the user location to proposed destination and provide multigrid displays for tracking or mapping routes. Ex at 23:15-20, 50: The grid quadrangles are displayed sequentially using a sequencing or scripting map display/output concerning a group of grids along the route. Id. at 34: A POSITA would understand that each subsequent adjacent grid quadrangle along the predicted route would be buffered using buffering techniques for speeding up computer operations, [including buffering of] adjacent grid quadrangles as disclosed by DeLorme. Ex at 31:37-42; Ex at 60. To the extent that the elements of claims 6 or 7 are not expressly disclosed by De- Lorme in view of Fedra, Beckwith provides further evidence that the peripheral routine and projection routine of claims 6 and 7 were conventionally used in similar prior art systems. Ex at 55-59, 61. Beckwith is directed toward a digital system for the display of elevation and cultural terrain data so as to provide a dynamic visual map of the terrain. Ex at 1:12-16 (emphasis added). The geographic data of Beckwith is divided into 12.5 km square areas. Id. at 5:46-60, 6:44-50, 7: The system of Beckwith track[s] the movement of the aircraft causing the scene to change. New 12.5 km data blocks required to update the square are then written over old 12.5 km blocks which are no longer in 18

23 the square. Ex at 9:1-16 (emphasis added). Beckwith further discloses that [u]pon receiving position commands from the navigation computer 100, the memory management control 25 will determine which 12.5 km blocks of data are required to fill out the intermediate memory 20 Then, as the aircraft moves, based on the heading and position data received from the navigation computer 100, the memory management control 25 will determine which new blocks of data will be required from the tape... to ensure a valid display. Ex at 10:10-16 (emphasis added); see also 10:67-11:6 ( The scene memory guarantees the availability of sufficient scene data for all potential aircraft headings. ), 11:62-68, FIGs Beckwith also discloses that the geographic data is stored in a compressed format. Id. at Abstract, 2:29-36, 2:48-50, 6:1-4. A POSITA would recognize that loading new adjacent 12.5 km blocks from the memory 20 based on the heading and position data received from the navigation computer where the data is compressed would include decompressing the data for the new 12.5 km blocks. Ex at 56, 61. There are a number of reasons that would have prompted a POSITA to modify the system of DeLorme as modified by Fedra (described in the analysis of claim 5) to further implement the teachings of Beckwith. First, a POSITA would have been prompted to modify the system of DeLorme to include Beckwith s routine for pre-loading geographic image data tiles (the 12.5 km blocks in Beckwith, and the grid quadrangles in DeLorme) based on the heading and position data to allow for quicker loading as the map display device 19

24 moves to ensure a valid display as suggested by Beckwith. Ex at 10:3-19; Ex at 57. Second, a POSITA would have recognized that applying the teachings of Beckwith to DeLorme would allow compressed tiled geographic data to be reconstruct[ed] to a noncompressed form prior to the time that the tiled geographic data is needed for display since the new tiles (i.e., blocks or grid quadrangles) are identified based on the heading and position data prior to display of the new tiles. Ex at 10:10-19; Ex at 58. Third, a POSITA would have been prompted to modify the system of DeLorme and Fedra to include the tile decompression routines as suggested by Beckwith because doing so would be merely the use of a known technique (e.g., pre-loading and decompressing of data for future display based on a predicted future state) to improve similar devices (e.g., systems for storing and displaying geographic image data as a series of square areas / grid quadrangles) in the same way. KSR, 550 U.S. at 417. Here, DeLorme, Fedra, and Beckwith all disclose systems for storing and presenting geographic location information to users and storing the geographic information as tiled image data. Ex at 1:47-50, 9:49-51, 10:31-34, 9:49-51, 1:55-57, 8:48-49, 61:45-48; Ex at 89-92; Ex at 5:46-60, 6:44-50, 7: Thus, the combination of DeLorme (which describes a system for buffering and displaying geographic image data) and Beckwith (which discloses predicting which geographic tiles to pre-load and decompress based on the heading and position data ) is merely combining prior art elements according to known methods to yield predictable re- 20

25 sults. Ex at 59. For at least these reasons and the additional explanations described in the chart below and the accompanying declaration by Dr. Braasch, there is a reasonable likelihood that claims 6 and 7 of the 347 patent are rendered obvious by DeLorme in view of Fedra and Beckwith. Ex at Moreover, to the extent the Patent Owner argues that any element of claims 6 and 7 is not expressly disclosed by the combination of DeLorme in view of Fedra and Beckwith, such element would be rendered obvious in view of the disclosures of DeLorme, Fedra, and Beckwith and in light of the knowledge of a POSITA. Id. at C. Ground 3 [Obvious over 103 over DeLorme in view of Fedra, Muller, TIFF, and JPEG] sets forth a reasonable likelihood to prevail on Claim 9 As described in section VII.A., supra, DeLorme in view of Fedra discloses every element of claim 5, including header data describing the size and geographical location of each tile. Additionally, in Ground 3 (charted below), DeLorme in view of Fedra, Muller, TIFF, and JPEG teaches all elements of, and thus renders obvious, claim 9. Fedra discloses that the cell header for each tile/grid cell includes geographic boundaries, resolution, format containing bytes-per-cell information and compress indicator. Id. at 90. The geographic boundaries information included in Fedra s cell header contains information about the location, size, and aspect ratio of a given grid cell. Ex at 63. Fedra also discloses that the grid cells are numbered. Ex at 90. Additionally, DeLorme displays the location of the user position, velocity, route, etc. on a map display and therefore includes the required geographic interpolation parameters to calcu- 21

26 late position. Ex at 10:17-34; Ex at 63. To the extent that DeLorme and Fedra do not expressly disclose a header that contains information about the number of pixels or the aspect ratio (as recited in claim 9), such information was traditionally included in a header for image data, and in fact standard specifications for image data formats show that inclusion of such information in a header was an ordinary and predictable design choice long before Ex at 62, For example, TIFF describes dividing an image into roughly square tiles where the data structure for each tile stores pixel dimension (i.e., size) values for tile width in pixels and tile length (height) in pixels. Ex at The tile width and tile length values provide information about the aspect ratio and because TileWidth and TileLength are expressed as pixel values, the [t]ile size defined by TileWidth and TileLength is the number of pixels in a tile. Id.; Ex at 64. TIFF makes clear that these values are stored in a header. Ex at 64. Additionally, TIFF indicates that the disclosed file structure is compatibl[e] with compression schemes such as JPEG. Ex at The JPEG specification ( JPEG ) shows the traditional implementation of storing such information in an image file header. Ex at 5 (describing the frame header as including: Horizontal pixel density... Vertical pixel density... pixel count ). Also, to the extent that DeLorme and Fedra do not disclose a header that contains information about the number of tiles (as listed in claim 9), such information was traditionally included in a header for image data, and the prior art shows that inclusion of such in- 22

27 formation in a header was nothing more than an ordinary and predictable design choice long before Ex at 65. For example, Muller discloses a terrain awareness system that breaks geographic data into a plurality of subsquares also referred to as map files or cells. Ex at 4:59, 7:7-11, 7:60-8:8. Muller further discloses a data index associated with each individual terrain data file and header information indicating the [n]umber of index s. Ex at columns The number of index s indicates the number of tiles or subsquares in Muller. Ex at 65. The evidence here shows that it was ordinary and predictable by the mid-1990s to provide a header that contains information about the list of items recited in claim 9. Ex at Indeed, a POSITA would have recognized that it was common to include such information in a header, which would have been readily implemented as a traditional design choice (as evidenced by the publications above) leading to predictable and beneficial results. Id. Here, a POSITA would have been prompted to modify the combination of DeLorme and Fedra (as described in the analysis of claim 5) to further include the suggestions of TIFF, JPEG, and Muller for multiple reasons. First, a POSITA would have been prompted to modify the CAMLS data structure disclosed by DeLorme to include some or all of the header data suggested by TIFF to allow high-resolution images [to] be accessed more efficiently and to improve compression. Ex at 66; Ex at 67. Second, a POSITA would have recognized TIFF and JPEG as standard specifica- 23

28 tions for commonly known and widely used image file formats and that use of any or all of the teachings of TIFF and JPEG would have led to predictable and beneficial results. Ex at 68. Here, the application of TIFF and JPEG to DeLorme would be predictable because a skilled artisan would have sought a standard reference. Intel Corporation v. Fuzzysharp Technologies, Inc. IPR Paper 23 at 25. Third, a POSITA would have been prompted to modify DeLorme s system to include the header information disclosed by TIFF, JPEG, and Muller because doing so would be merely the use of a known technique (e.g., including relevant information about an image data file in the data file header) to improve similar devices (e.g., systems for storing and displaying image data) in the same way. KSR, 550 U.S. at 417. Here, DeLorme discloses tilizing geographic image data by dividing the data into grid quadrangles. Ex at 9:49-51, 1:55-57, 8:48-49, 61: Similarly, Muller discloses dividing geographic data into a plurality of subsquares also referred to as map files or cells while TIFF discloses dividing an image into roughly square tiles. Ex at 4:59, 7:7-11, 7:60-8:8; Ex at 66. A POSITA would have also been motivated to use JPEG in combination with TIFF because the image file structure of TIFF is compatibl[e] with compression schemes such as JPEG. Ex at Thus, the combination of DeLorme (which describes a data structure for storing tiled geographic image data) with Fedra, TIFF, and Muller (which disclose additional information to include in a header of a tiled geographic image data file) and JPEG (which is referenced by TIFF) is merely combining prior art elements according to 24

29 known methods to yield predictable results. Ex at 69. For at least these reasons and the additional explanations described in the chart below and the accompanying declaration by Dr. Braasch, there is a reasonable likelihood that claim 9 of the 347 patent is rendered obvious by DeLorme in view of Fedra, TIFF, JPEG, and Muller. Ex at D. Ground 4 [Obvious under 103 over Israni in view of Fedra] sets forth a reasonable likelihood to prevail on at least one of Claims 5, 8, and 10 Referring to Ground 4 (charted below), the teachings of Israni in view of Fedra provide all elements of independent claim 5 and dependent claims 8 and 10. In particular, Israni discloses a system for providing geographic data on a physical storage medium for use in a computer-based navigation system. Ex at 1: Israni s system includes a map display function 30 so that [t]he navigation application program may provide the user with a graphical display (e.g. a map ) of his specific location in the geographic area. Id. at 9:38-52, 41:64-67, 1:62-64; see also 5:1-10, 10: Israni also describes the traditional option in which such a navigation system can be a single unit to be carried by persons. Id. at 2:1-4. The evidence here shows that such a single unit navigation system would have a case, and Israni s FIG. 1 also illustrates the various components of Israni s navigation system mounted in a case. Ex at 75. Regarding the claimed digital computer, the navigation system 10 of Israni is a combination of hardware and software components includ[ing] a processor 12, a drive 14 connected to the processor, and a memory storage device 16. Ex at 4: Also, Israni provides a location receiver 25

30 unit and a display unit in that [t]he navigation system 10 may also include a positioning system 24 and display 27 for displaying map images. Id. at 4:64-5:5, 5:8-17; Ex at 76, Regarding the claimed image storage unit, Israni discloses that [t]he storage medium 22 includes geographic data, the geographic data including [a] group 50 of parcels of data for the cartographic function (i.e. map display) 30. Ex at 4:48-63, 8:41-44; see also 9:3-5, 9: Israni further discloses the claimed tile data which tiles, taken together, represent a map image in the form of geographic data that is organized into smaller groupings or parcels... each parcel represents geographic data encompassed with a geographic rectangular area (including square areas) of the physical region. Id. at 10: This is the feature that the inventors of the 347 patent characterized as their proposed solution to [the supposed] problem presented by prior art systems. Ex at 4:12-19; see also Ex at 71, Further, Israni, when considered in view of the teachings of Fedra, provides each of the non-structural elements (data elements/computer program) recited elements 5(d)(i)-(iii) and 5(f) of claim 5. For example, Israni discloses header data describing the... geographical location of each tile, as it describes that [d]ata in the header portion of each parcel, [is] used to describe the parcel and navigate within it. Ex at 23:62-64 (emphasis added). Additionally, Israni describes header pointers or keys that point to geographic position and information on the entity to which the position corresponds. Ex at 42:62-26

31 43:8 ( the positional data (e.g. latitude, longitude) for each layer are organized by either the longitudes or latitudes of the positions. For example, keys may be generated for each position, with a pointer to the position and a pointer to the entity to which the position corresponds. ) (emphasis added); see also 45: Israni discloses subsets of geographic data for each of the functions are cross-referenced (and may include pointers) to provide interoperability among the functions. Id. at 8:51-53 (emphasis added); see also 10:18-22, 42: To the extent that Israni does not expressly disclose header data describing the size and geographical location of each tile, this ordinary element was commonly implemented in similar prior art systems. Ex at 80. For example, as described above in section VII.A., Fedra describes a similar prior art system and suggests that the cell header should describe both the location and size of a given grid cell. Ex at 80. For reasons described above in section VII.A., a POSITA would have been prompted to modify Israni s system to include header data describing the size and geographical location of each tile (suggested by Fedra). Id. at 81-83; Ex at 89 (easier integration with other systems); 90 (improved exporting of geographic data to other systems); KSR, 550 U.S. at 417. Also, regarding the claimed compressed tile data and the decompressing routine, Israni discloses that parcels are maintained in their compressed form in memory 20 after they are read from disk 22, and entities within a parcel are decompressed as they are requested by the navigation application functions. Ex at 23:37-46 (emphasis add- 27

32 ed); see also 47:53-56, 15:16-17, 21: Israni also teaches the other associating and locating routines included in the claimed computer program. Ex at Israni describes that [t]he positioning system 24 outputs a signal used by the navigation application program to determine the location, direction, speed, etc., of the navigation system [for use in] map display, [and] vehicle positioning. Id. at 5:1-10 (emphasis added); see also 10:56-62, 20: Israni further discloses a route guidance application initially locates the map data corresponding to a vehicles current position. Once a starting position is known... all information about nearby map data can be found in indices internal to a parcel. Id. at 20:17-21 (emphasis added). For at least these reasons and the additional explanations described in the chart below and the accompanying declaration by Dr. Braasch, there is a reasonable likelihood that claims 5, 8, and 10 of the 347 patent are rendered obvious by Israni in view of Fedra. Ex at 70-95; XIII, infra (providing additional disclosure for claims 8 and 10). Moreover, to the extent the Patent Owner argues that any element of claims 5, 8, and 10 is not expressly disclosed by the combination of Israni in view of Fedra, such element would be rendered obvious in view of the disclosures of the Israni and Fedra references and in light of the knowledge of a POSITA. Id. at 95. E. Ground 5 [Obvious under 103 over Israni in view of Fedra and Beckwith] sets forth a reasonable likelihood to prevail on at least one of Claims 6 and 7 As described in section VII.D., supra, Israni in view of Fedra discloses every element of claim 5. Additionally, referring to Ground 5 (charted below), the teachings of Israni in 28

33 view of Fedra and Beckwith provide all elements of claims 6 and 7. For example, regarding the claimed peripheral routine and projection routine, Israni discloses that each of the data parcels contains an index of its neighboring parcels then panning and zooming can be done more efficiently by the map display function 30 without further looking up in a separate index file. Ex at 9:45-49 (emphasis added). Israni also discloses that [a] neighboring kd-tree within a parcel identifies the parcel and the parcel's adjacent parcels. Id. at 47:47-49 (emphasis added); see also 19: The evidence here shows that navigat[ing] between neighboring parcels involves decompressing adjacent neighboring parcels because, as Israni discloses, entities within a parcel are decompressed as they are requested by the navigation application functions. Ex at 23:37-46; Ex at 99. To the extent that any elements of claims 6 or 7 are not taught by Israni in view of Fedra, Beckwith provides further evidence that the peripheral routine and projection routine of claims 6 and 7 were conventionally used in similar prior art systems, as described above in section VII.B.. Ex at For reasons similar to those described in section VII.B., a POSITA would have been prompted to modify the combination of Israni and Fedra (described in the analysis of claim 5) to further include Beckwith s routine for preloading geographic data tiles based on the heading and position data so as to achieve the predictable benefits. Id. at ; Ex at 10:3-19; KSR, 550 U.S. at 417. For at least these reasons and the additional explanations described in the chart below and the accompanying declaration by Dr. Braasch, there is a reasonable likelihood that 29

34 claims 6 and 7 of the 347 patent are rendered obvious by Israni in view of Fedra and Beckwith. Ex at Moreover, to the extent the Patent Owner argues that any element of claims 6 and 7 is not expressly disclosed by the combination of Israni in view of Fedra and Beckwith, such element would be rendered obvious by the disclosures of Israni, Fedra, and Beckwith and in light of the knowledge of a POSITA. See Id. at F. Ground 6 [Obvious under 103 over Israni in view of Fedra, Muller, TIFF, and JPEG] sets forth a reasonable likelihood to prevail on Claim 9 As described in section VII.D., supra, Israni in view of Fedra discloses every element of claim 5, including header data describing the size and geographical location of each tile. Additionally, Israni in view of Fedra, Muller, TIFF, and JPEG teaches all elements of, and thus renders obvious, claim 9. As described above in section VII.C., Fedra s cell header contains information about the location, size, and aspect ratio of a given grid cell. Ex at 90; Ex at 110. To the extent that Israni and Fedra do not expressly disclose that the header contains information about other items in the list recited in claim 9 (the number of tiles, the number of pixels or the aspect ratio ), such information was traditionally included in a header for image data, and in fact standard specifications for image data formats show that inclusion of such information in a header was an ordinary and predictable design choice long before Ex at 109, For example, as described in section VII.C., such items were typically included in the header, as evidence by the TIFF, JPEG, and Muller references. Ex at ; Ex at 66-68; Ex at 5; Ex at 4:59, 7:7-30

35 11, 7:60-8:8, and cols Additionally, a POSITA would have recognized that it was common to identify and store information such as number of tiles, tile size, number of pixels, aspect ratio, and the required geographic interpolation parameters to calculate position for tiled geographic image data and that inclusion of such information in a header would have been an easily implemented design choice leading to predictable and beneficial results. Ex at For reasons similar to those described in section VII.C., a POSITA would have been prompted to modify Israni s data structure to provide a header that includes the traditional (above-cited) items to provide the predictable benefits as suggested by Fedra, TIFF, JPEG, and Muller. Ex at ; Ex at 66; KSR, 550 U.S. at 417. For at least these reasons and the additional explanations described in the chart below and the accompanying declaration by Dr. Braasch, there is a reasonable likelihood that claim 9 is rendered obvious by Israni in view of Fedra, TIFF, JPEG, and Muller. Ex at Moreover, to the extent the Patent Owner argues that any element of claim 9 is not expressly disclosed by the combination of Israni in view of Fedra, Muller, TIFF, and JPEG, such element would be rendered obvious in view of the disclosures of Israni, Fedra, Muller, TIFF, and JPEG and in light of the knowledge of a POSITA. Id. at VIII. [GROUND 1 CLAIM CHART] Obviousness of Claims 5, 8 & 10 under 103 by DeLorme in view of Fedra U.S. Pat. 5,902,347 5.p. A device for personal, portable DeLorme in view of Fedra Under the broadest reasonable interpretation, the preamble is not a limitation and merely provides a recitation of intended use. Howev- 31

36 mapping and navigation, by a user, and adapted to display a map image to the user and to display, to the user, the user's actual location, on the map image, comprising; a) a case b) a digital computer mounted in the case, er, to the extent that the preamble is considered limiting, each element of the preamble is disclosed by Delorme. In particular, De- Lorme discloses a device for personal, portable mapping and navigation, by a user. Ex at 27. DeLorme describes a new computer aided map location system (CAMLS) using a coacting personal digital assistant (PDA) or other digital or electronic computer (EC). Ex at 1:47-50; see also 3:35 ( a self contained electronic map and navigation device ). A personal digital assistant, portable personal computer, or other digital or electronic computer (PDA/PC/EC) provides a display or other computer output. Id. at 7: Also, the various computing devices described in DeLorme are adapted to display a map image to the user. Ex at 22, 27. For example, DeLorme discloses that a digital computer electronic map, is presented on a transitory computer display, is readily changeable, and intelligent. Ex at 9:49-51; see also 4:44-46 ( provide direct visual display of intelligent map location information on grid quadrangles of a PDA/PC/EC display. ). Additionally, the various computing devices of DeLorme are adapted to display, to the user, the user s actual location, on the map image. Ex at 27, 46. For example, DeLorme discloses displaying location of the user position, velocity, route, etc. along with additional visual cues such as major routes, street location, cities, or other geographical landmarks in the grid quadrangle. Ex at 10:34; 10: DeLorme further discloses the user location may be pinpointed on a generalized grid quadrangle displayed on the PDA/PC/EC. Id. at 13:3-5; see also 6:14-19 ( the user location, route, speed, and direction of travel... may also be displayed with greater or lesser background context and detail of selected routes and landmarks or other geographical landmarks. ) DeLorme discloses a case and a digital computer mounted in the case as recited in this claim. Ex at For example, DeLorme describes a new computer aided map location system (CAMLS) using a coacting personal digital assistant (PDA) or other digital or electronic computer (EC) such as a digital microprocessor based personal computer (PC). Ex at 1:47-51; see also 3:35 ( a self contained electronic map and navigation device ). FIG. 3A shows a detailed diagrammatic view of the CAMLS PDA/PC including a case housing a digital computer. Ex at 18: Ex at

37 c) a location receiver unit associated with the case and adapted to provide user location information to the computer, d) an image storage unit adapted to store image data and to provide the image data to the computer, FIG. 7 shows the components included in the digital computer mounted within the case of the CAMLS PDA, including the microprocessor or CPU 217. Ex at 26:9-11; Ex at 29. DeLorme discloses a location receiver unit associated with the case and adapted to provide user location information to the computer. Ex at 30. FIG. 14D of DeLorme shows the CAMLS PDA with GPS displaying the user s location on a map display. Ex at 63: DeLorme further teaches that [t]he CAMLS is also applicable for use with radio location systems, dead reckoning location systems, and hybrid location systems. For example, the GPS satellite system is used with a GPS receiver for displaying location, travel direction, speed, route, and other traveling data of the CAMLS user on the generalized grid quadrangles. Id. at 2:16-21; see also 25: FIG. 7 shows the real time position data receiver 201 contained within the CAMLS unit. DeLorme discloses an image storage unit adapted to store image data and to provide the image data to the computer. Ex at 31. For example, DeLorme discloses that [t]he PDA/PC/EC permits generalized display of grid quadrangles of a constant scale grid system representing a specified geographical area. Ex at 1: DeLorme describes that quadrangle map images are displayed with greater or lesser degrees of details such as background, overlays, or loc/object types. Id. at 23: The degree of detail can vary from simple points and lines to more complicated geographical and mapping images and including the grid quadrangles. Id. at 29:20-23 (emphasis added). Map image data is retrieved from a set of databases stored in PDA/PC/EC memory devices or accessible through wired and wireless data communications links. Id. at 1:61-63; see also 30:15-17 ( information is actually stored at specified addresses in internal memory or some accessible external databases ); 37:65-38:2. 33