throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`
`PATENT
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GARMIN INTERNATIONAL, INC. ET AL.
`
`Petitioner
`
`VC
`
`Patent of CUOZZO SPEED TECHNOLOGIES LLC
`
`Patent Owner
`
`Case:
`
`lPR2012—O0O0l
`
`Patent No.:
`
`6,778,074
`
`Filed:
`
`Issued:
`
`March 18, 2002
`
`August 17,2004
`
`Inventors:
`
`Giuseppe A. Cuozzo
`
`Title:
`
`Speed Limit Indicator and Method for Displaying Speed and
`the Relevant Speed Limit
`
`Docket No.:
`
`CUO000 1 -RE
`
`DECLARATION OF GIUSEPPE A. CUOZZO PURSUANT TO 37 C.F.R. §
`1.131
`
`Mail Stop "PA TENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`
`e
`
`P.O. Box 1450
`
`Alexandria, VA 22313-145
`
`

`
`Dear Sirs:
`
`I, Giuseppe A. Cuozzo, declare as follows:
`
`1.
`
`I am over the age of 18 and a resident of New Jersey. If called upon to do
`
`so, I could and would testify to the following facts.
`
`I live at 1 19 Park Street, Montclair, New Jersey 07042.
`
`I invented the subject matter disclosed and claimed in United States Patent
`
`No. 6,778,074 (hereinafter the ‘"074 patent”).
`
`My attorney, Anthony Campbell, prepared and filed the patent application
`
`that led to the issuance of the ‘O74 patent.
`
`I reviewed and approved the
`
`application before it was filed on March 18, 2002.
`
`I understand that the Patent Office is reviewing claims 10, 14, and 17 of the
`
`‘O74 patent
`
`in light of several other patents including U.S. Patent No.
`
`6,633,8l I (“Aumayer”) and U.S. Patent No. 6,515,596 (“Awada”).
`
`I also understand that Aumayer has a filing date of October 19, 2000, and
`
`Awada has a filing date of March 8, 2001. While these dates are before the
`
`date on which my patent application was filed, these dates are after the date
`
`on which I conceived of my invention that is described in the ‘074 patent.
`
`I have been asked to collect and review my records in order to show when I
`
`invented the subject matter of the ’074 patent and the events between my
`
`conception of the inventions disclosed in the ‘074 patent and the March 18,
`
`Cuozzo DECLARATION
`
`2
`
`

`
`2002 filing of the patent application that issued as the ‘074 patent. The
`
`following information details my recollection of my activities and related
`
`documents showing that I conceived my invention before October 19, 2000,
`
`and diligently pursued obtaining patent protection for my invention until my
`
`patent application was filed.
`
`8.
`
`I developed the initial
`
`idea for my invention while driving a 2000
`
`Volkswagen GTI (“VW”) that I purchased in July 1999. Exhibit A is a
`
`copy of my sales receipt.
`
`In November 1999, I was driving my VW in New
`
`York on an unfamiliar road.
`
`I did not see any speed limit signs indicating
`
`the speed limit, however, I was pulled over and ticketed by a police officer
`
`for speeding. Exhibit B is a copy of my driving record showing a speeding
`
`citation dated November 28, 1999 (Z32 V refers to New York).
`
`9. While the officer was writing me a ticket, I came up with the idea of using
`
`GPS technology combined with instrumentation for displaying a speed limit
`
`and its relation to vehicle speed in a manner that would alert a driver as to
`
`whether he or she was speeding without requiring the driver to refer to
`
`roadside speed limit signs. At the time I conceived of the idea, I was
`
`working as an auto technician, so I was familiar with vehicle systems and
`
`instrumentation, as well as GPS technology, and I knew my idea was
`
`something usefiil that was not available.
`
`Cuozzo DECLARATION
`
`3
`
`

`
`10. In May 2000, I was involved in a car accident in which my VW GTI was
`
`totaled. Exhibit C is a copy of a Carfax showing the title change in June
`
`2000.
`
`(The odometer record suggests the car was purchased from the
`
`insurance company and rebuilt or retitled by someone else.). (Exhibit C).
`
`11. In the Late Summer/ Early Fall of 2000, I went to an Invention Submission
`
`Corporation (“ISC”) office in Bloomfield, New Jersey.
`
`ISC gave me
`
`information about
`
`its services, how much it would cost to file a patent
`
`application, and provided me with several documents to complete, including
`
`a Statement of Confidentiality and Non-Use, Affirmative Disclosure
`
`Statement, and Disclosures Prior to Entering Into a Contract for Invention
`
`Promotion Services. My first visit to ISC’s office was in late September or
`
`early October, and certainly before October 19, because I carefully
`
`considered the cost and scope of ISC’s services,
`
`including the cost of
`
`patenting my invention, before I returned. On October 25, 2000, I returned
`
`completed copies of these documents. (Exhibit D).
`
`12. On October 30, 2000, I delivered to ISC a finalized “Disclosure to ISC and
`
`Record of Invention” (the “Disclosure”).
`
`(Exhibit E).
`
`In the Disclosure, I
`
`described my invention in detail.
`
`I explained in the Disclosure how speed
`
`limit
`
`information would be stored on a CD—ROM with street
`
`location
`
`information (along with “school zone and any other speed limits") and the
`
`Cuozzo DECLARATION
`
`4
`
`

`
`GPS would be wired to the speedometer to change a colored display and
`
`show speeds in different colors depending on the speed limit at the vehicle’s
`
`present location.
`
`In response to the question, “How did you develop this
`
`idea?” I responded that I was “driving one day.”
`
`13. The following is my handwritten explanation of my invention that appears in
`
`Exhibit E:
`
`c,'f§i.s_.1 tiggkh
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`
`
`
`N1-Lmajtgfiaff ‘in:
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`‘.}‘fi*_'<:et_‘_--.« ;:;-g'“ 5
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`L»
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`.4 at
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`7‘
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`
`The above handwritten explanation states:
`
`The on—board navigation system uses GPS (Global Positioning
`System) satellites and BMW technology to help show—and—tell—the
`way to your destination. This GPS navigation system runs on a
`CD Rom that has all the information and street names.
`I think if
`
`you can put the speed limit with the street and all you have to do
`is wire the speedometer to the GPS and buys this new CD—Rorn
`with the information of both street name and speed limit. This
`also will have school zone and any other speed limits at or law or
`a street were a speed limit changes.
`
`14. Also on October 30, 2000, I completed the ISC “Basic Information Package
`
`Agreement” (the “Agreement”) requesting a preliminary patentability search
`
`and opinion from a patent law firm referred by ISC.
`
`(Exhibit F).
`
`I noted
`
`my occupation as an auto technician on the Agreement. At the time, I could
`
`Cuozzo DECLARATION
`
`5
`
`

`
`not afford the $875 for the patentability search and opinion, so I entered into
`
`a “Retail
`
`Installment Contract
`
`and Security Agreement”
`
`(“Security
`
`Agreement”)
`
`that
`
`is also attached to Exhibit F. Under the Security
`
`Agreement, I was required to make three payments of $211.81 each.
`
`I paid
`
`the balance in three payments on October 30, 2000 ($250), December 7,
`
`2000 ($212), and January 5, 200! ($425). Exhibit G includes receipts each
`
`of these payments.
`
`15.0n December 8, 2000, I received a letter (Exhibit H) from Ivar Kaardal
`
`informing me that Mr. Kaardal’s law firm, Kaardal & Associates, PC (the
`
`“Kaardal Firm”), had been engaged by [SC to perform a preliminary
`
`patentability search and report based upon the Disclosure (Exhibit E).
`
`16. I received a preliminary report in January 2001 that identified several patents
`
`as potential prior art.
`
`I analyzed these patents and, on March 2, 2001, I sent
`
`my analysis to Monica Bealles, ISC Patent Services Coordinator, to forward
`
`to Mr. Kaardal, which she did on March 7, 2001. Exhibit I is a copy of my
`
`analysis, which I faxed to Ms. Bealles along with a copy of her forward to
`
`Mr. Kaardal.
`
`17. On March 10, 2001, I received the Kaardal F irm’s Preliminary Patentability
`
`Search Report recommending “that it is our professional opinion that utility
`
`CUOZZO DECLARATION
`
`6
`
`

`
`patent protection could potentially be obtainable for your
`
`invention.”
`
`(Exhibit J).
`
`18. With the good news from Kaardal Firm that my invention was potentially
`
`patentable,
`
`I discussed the patent application process with ISC. The ISC
`
`Submission Agreement (“Submission Agreement”) I entered into (Exhibit
`
`K) had an optional “Patent Services Addendum” under which ISC would
`
`refer me to patent counsel
`
`to prepare a patent application. The patent
`
`referral services, however, would not begin until
`
`I paid a minimum of
`
`$3,500 to ISC. The total cost was $9,945.00.
`
`19. The cost of the ISC Submission Agreement and patent services presented a
`
`significant
`
`financial obstacle to me, as I had insufficient
`
`income and
`
`financing through ISC was not an option. My only option was to use money
`
`that was in a trust account set up by my parents when I was a child.
`
`Gathering that money from the trust account and convincing my parents that
`
`I needed to do that took a few months. On August 8, 2001, after obtaining
`
`the needed funds from my trust account, I delivered a Cashier’s Check to
`
`ISC for $9,545.00 and paid the balance of $400 in two cash payments of
`
`$220 and $180. Exhibit L includes copies of the receipts for my payments
`
`to ISC.
`
`Cuozzo DECLARATION
`
`7
`
`

`
`20. At first, my understanding was that the Kaardal Firm that had done the
`
`patentability search would prepare my patent application. But for reasons I
`
`have come to learn were due to the Kaardal Firm disorganizing and ceasing
`
`to do business,
`
`I was referred to another patent
`
`lawyer named David
`
`Lingbeck. His initial October 4, 2001 letter to me is attached as Exhibit N.
`
`In his letter, Mr. Lingbeck told me that my patent application would be
`
`ready for me to review within four months of his receipt of my invention file
`
`from ISC.
`
`I did not hear anything from either ISC or Mr. Lingbeck for a
`
`while, so I repeatedly called ISC to find out
`
`the status of my patent
`
`application.
`
`21. On October 31, 2001, I reviewed a press release prepared by ISC under the
`
`Submission Agreement.
`
`(Exhibit M). The press release recounts my
`
`conception of the invention and quotes me saying, “I was driving in a place I
`
`didn’t know, and I couldn’t see any speed limit signs. There’s nothing
`
`worse than getting a ticket just because you didn’t know the speed limit, so I
`
`developed SPEED CONTROL.”
`
`22. Then, on March 3, 2002, I received a letter from another patent attorney,
`
`Anthony Campbell, informing me that ISC had referred my invention file to
`0
`
`him and that he would be my attorney and had already prepared a patent
`
`Cuozzo DECLARATION
`
`8
`
`

`
`application for my invention based on my invention file from ISC. (Exhibit
`
`0).
`
`23. Mr. Campbell filed my patent application on March 18, 2002, with a check
`
`from my mother, Rosa Cuozzo, to cover the $370 filing fee.
`
`(Exhibit P).
`
`This patent application ultimately issued as the ‘074 patent.
`
`24. All of these events took place in the United States of America.
`
`25. I hereby declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to
`
`be true; and fiirther that these statements were made with the knowledge that
`
`willful false statements and the like so made are punishable by fine or
`
`imprisonment, or both, under 18 U.S.C. § 1001, and that such willful false
`
`statements may jeopardize the validity of the application or any patent
`
`issuing thereon.
`
`Date: March 10, 2013
`
`I
`
`/’l L
`fig ( "/ H/1;!/.»?"
`.
`_ 5
`/
`Cuozzo
`/Giuseppe
`
`CUOZZO DECLARATION
`
`9
`
`

`
`Exhibit A
`
`DECLARATION OF GIUSEPPE A. CUOZZO PURSUANT TO 37 C.F.R. §
`1.131
`
`(3 PAGES INCLUDING THIS COVER PAGE)
`
`
`

`
`

`
`\ ROUTES3&46
`
`GENSINGER MCTORS, INC.
`
`
`
`VALLEY ROAD
`
`A
`
`(973) 778-8500
`CLIFTON, NEW JERSEY 07013
`
`SINCE 1950
`ADDRESS: In 2x;V xiv
`
`
`
`
`SOLD TO:
`
`YEART ~5;vEgR K”
`
`EHICLE
`USTOMER NUMBER
`
`LIEN PAY-OFF
`
`USED CAR TRAED
`‘ CONTRACTS IN TRANSIT
`
`
`
`
`
`QMPLETE QDV $H@P
`E9
`ELQNG TERM LEA$ENG7
`T SATURDAY SERVICE
`N5 PICKUP OF SEFTVIIEE T
`8:00 AM TO 4:30 PM L VEHICLES AFTER 6:30 PM
`“CW3
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`
`
`
`MoN.—EnI.——€z:00 TO 5 PM Us:-:0 vEH.]%L MODE‘-
`
`N0 APPOINTMENT REQ.
`M MONDAY THHU FRIDAY
`’
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`no.
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`4 TQ OUR EARLY MORNING QFQ {LATE EVENENG SERVICE CUSTOMERS ussn on
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`
`STOCK I!
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`COLOR
`
`IMILEAGE
`COURTESY CARS
`
`
`
`.
`
`NJ. STATE ENSP. CENTER
`

`
`-
`
`

`
`(973) 778-8500
`
`W2
`
`SlNCE1950
`
`
`
`
`
`SE
`
`M
`
`Inc
`
`342 VALLEY ROAD, CLIFTON, N.J. o7o13
`
`Dear MR. cuozzo
`
`Thank you on behalf of Bensinger Motors Inc. for your purchase of
`your 00 RQBBIT GT1
`
`Qt your first servicing, please bring in your service
`folder to our Service counter. You will be greeted by one of
`our factory trained advisors who will see to all of your
`service needs. Our Service Departlent hours are Monday
`through Friday,
`from 7:#5 RM to #:3@ PM, with Service pickup
`until 5:30 PM Monday through Saturday.
`we work on a first cone first
`serve basis so no service appointlents are required.
`
`is
`Our well stocked colputerized Parts Departlent
`staffed with efficient personnel with extensive experience in the
`Volkswagen parts systen. Dur Parts Store is open Monday through
`Friday until 6 PM and Saturday from 7:#5 RM to 4:36 PM.
`
`He have a colplete Body Shop and our staff has Iany
`years of experience in repairs of Volkswagen and other make cars.
`we are available Monday through Friday, frol 7:é5 AM to #:3@ PM,
`repair estimates.
`
`to write
`
`We are a third generation falily owned and operated dealership
`having sold our first Volkswagen in 1959.
`If you have a problel,
`or just a question, please call us. Our Sales, Service, and Parts
`personnel will be glad to help you.
`He not only want you to
`be happy with your RQBBIT GT1
`but glad that you purchased it
`from Bensinger Motors.
`
`Very truly yours,
`
`6% F.
`
`ensinger Motor ,
`
`Inc.
`
`

`
`Exhibit of B of the
`
`DECLARATION OF GIUSEPPE A. CUOZZO PURSUANT TO 37 C.F.R. §
`1.131
`
`Is Protective Order Material
`
`Please See Revised Exhibit 3000 for Exhibit B
`
`
`
`

`
`

`
`Exhibit C
`
`DECLARATION OF GIUSEPPE A. CUOZZO PURSUANT TO 37 C.F.R. §
`1.131
`
`(9 PAGES INCLUDING THIS COVER PAGE)
`
`
`

`
`

`
`CARFAX Vehicle History Report on WVWDE21JOYW084092
`
`http://WWW.ca1‘fax.com/organizer/generateRepo1’t.cfx
`
`
`
`For Personal Use Only
`
` 1
`
`‘
`
`NO accident / damage reported to CARFAX
`
`Potential odometer rollback indicated
`
`4 Previous owners
`
`12 Service records available
`
`Personal vehicle
`
`$570 Below retail book value
`
`&
`WM
`
` i
`
`fl
`
`
`
`'\7eHrt:'ie ‘il"lfOT|"fidEiU'l‘l‘.
`2000 VOLKSWAGEN G11 GLX
`VIN: W\/\NDE21JOYW084092
`HATCHBACK 2 DR
`2.8L V6 FI 12v
`: FRONT WHEEL DRIVE
`Standard Equipment l Safetx_09£i.ons
`
`My
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`i
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`This CARFAX Vehicle History Report is based only on information supplied to CARFAX and available as of 11/14/12 at 10:18:03 PM
`(EST). Other information about this vehicle, including problems, may not have been reported to CARFAX. Use this report as one important
`tool, along with a vehicle inspection and test drive, to make a better decision about your next used car.
`
`
`
`Price Calculatorm
`.5 Adjust the value of this 2000 Volkswagen GTI GLX based on the information available in this report
`
`1) Retail Book Value
`prrrrrrrrrrrrrrrrrr
`
`_
`Enter retail book value here
`
`1 2) CARFAX Price Adjustment”
`
`-$57o
`
`\
`
`Below retail book value
`
`.1
`3%
`
`1 3) Adjusted Retail Value
`
`the retail book value
`
`
`

`
`Start by entering the‘
`retail lnoyoklraltse from a 0
`pricing guide website.
`_
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`"
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`V
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`
`
`This vehicle is worth
`less than average,
`based on information
`in this report. *
`_
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`T
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`price when makirlg
`your decision.
`‘
`
`5.;
`
`E:
`5,:
`
`£3
`
`Ownership History
`The number of owners is estimated
`Year purchased
`Type of owner
`Estimated length of ownership
`Owned in the following states/provinces
`Estimated miles driven per year
`Last reported odometer reading
`
`Owners 1-2
`
`Owner 3
`
`Owner4
`
`1999
`Personal
`2 yrs. 10 mo.
`See Details
`—--
`—--
`
`2002
`Personal
`4 yrs. 6 mo.
`Massachusetts
`—--
`—--
`
`2007
`Personal
`5 yrs. 5 mo.
`Massachusetts
`—--
`—--
`
`K
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`_ ,, :
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`Title History
`CARFAX guarantees the information in this section
`
`—,
`
`1 M ,, ,
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`_
`Owners 1-2
`
`1
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`l
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`Owner 3
`
`i
`
`;
`
`Owner 4
`
`1of8
`
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`CARFAX Vehicle History Report on WVWDE21JOYW084092
`
`http://www.ca1‘fax.com/o1'ganizer/gene1‘ateRepo1't.cfx
`
`.
`.
`.
`'
`Salvage | Junk | Rebuilt | Fire | Flood | Hall | Lemon
`
`Not Actual Mileage I Exceeds Mechanical Limits
`
`Guaranteed
`1 No Problem
`
`Guaranteed
`No Problem
`
`
`
`E
`
`Guaranteed
`No Problem
`
`Guaranteed
`No Problem
`
`1‘
`
`E
`
`Guaranteed
`No Problem
`
`Guaranteed
`No Problem
`
`15
`
`0.0‘
`
`
`
`
` GUARANTEED — None of these major title problems were reported by a state Department of Motor Vehicles
`an [ii
`
`(DM\/). If you find that any of these title problems were reported by a DMV and not included in this report,
`CARFAX will buy this vehicle back. Register | View Terms | View Certificate
`
`Additional History
`
`Owners 1-2
`
`Owner 3
`
`Owner 4
`
`liIll
`
`
`
`No Issues
`. Reported
`No Issues
`
`Reported
`
`. No Issues
`Reported
`No New Issues
`Indicated
`
`Not all accidents / issues are reported to CARFAX
`
`3; Total Loss
`‘F No total loss reported to CARFAX.
`
`Structural Damage
`No structural damage reported to CARFAX.
`
`’
`
`Airbag Deployment
`No airbag deployment reported to CARFAX.
`Odometer Check
`Potential odometer rollback indicated.
`
`,.
`
`
`
`
`
`No Issues
`Reported
`
`No Issues
`Reported
`
`No Issues
`Reported
`Potential
`Rollback
`
`
`
`_; No Issues
`Reported
`No Issues
`Reported
`
`No Issues
`Reported
`No New Issues
`Indicated
`
`ff Accidentl Damage
`No accidents or damage reported to CARFAX.
`Manufacturer Recall
`Check with an authorized Volkswagen dealer for any open recalls.
`Basic Warranty
`O_n estimated to have expired. Interested in an extended ;
`warrany?
`:
`
`‘V
`
`
`No Issues
`Reported
`Ask Your
`Dealer
`
`g
`
`
`No Issues
`Reported
`Ask Your
`Dealer
`
`
`No Issues
`Reported
`Ask Your
`Dealer
`
`Warranty
`Expired
`
`f
`
`Warranty
`Expired
`
`;
`
`Warranty
`Expired
`
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`CARFAX Vehicle History Report on WVWDE21JOYW084092
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`
`12000 VOLKSWAGEN GTl GLX
`
`Body Style: Hatchback 2 DR
`
`Engine Type: 2.8L V6 Fl 12V
`Standard Equipment: Power Windows, Power Steering, Air Conditioning,
`AM/ FM Cassette, Power Brakes, Power sun / moon roof, Tilt Wheel, 6-digit
`Odometer
`llflflflfifllill Free CARFAX Report
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`
`Body Style: Hatchback 2 DR
`Engine Type: 1.8L L4 PFI DOHC
`Free CARFAX Report
`
`BMW of Bayside
`516-304-3722
`
`Distance: 25.55 mi
`Wew Dealer inventory
`Contact Dealer
`
`Preferred Auto Sales
`Distance: 9.58 mi
`View Details & Photos
`
`Lexus Of Queens
`Distance: 15.34 mi
`Contact Dealer
`
`1
`
`1
`
`
`
`Service Facility
`
`'3,
`
`,1
`3.-
`
`2?
`
`J
`if»
`
`if
`
`:1";v:;-:-.:.::~:-:v::’>_:,‘:.:
`
`19
`
`New J ersey
`Motor Vehicle Dept.
`Bloomfield, NJ
`
`'|'itle issued or updated
`First owner reported
`Registered as
`personal vehicle
`
`; 08/24/1999
`
`2,896
`
`Service Facility
`
`Recommended maintenance performed
`
`10/14/1999
`
`9,401
`
`Service Facility
`
`Computer reprogrammed
`
`f 11/30/1999
`
`15,468
`
`Service Facility
`
`Engine/powertrain computer/module checked
`Cruise control checked
`
`01/25/2000
`
`Three County
`Volkswagen
`Lyndhurst, NJ
`201-933-8383
`
`threecounty\/vv. com
`
`f 02/01/2000
`
`20,122
`
`Service Facility
`
`Airbag system checked
`Coolant temperature sensor replaced
`Cruise control switch replaced
`Steering/suspension checked
`
`Window regu|ator(s) replaced
`Window(s) checked
`Anti-theft/key less system checked
`Body electrical wiring repaired
`Airbag system checked
`Engine/powertrain computer/module replaced
`
`Recommended maintenance performed
`Anti-theft/keyless system checked
`
`
`
`9
`
`
`
`:1
`
`7/
`
`§_:
`
`?«
`
`1>
`
`1
`1‘;1
`5,1
`L
`
`‘
`3?
`
`
`
`1‘
`
`Est. length
`owned:
`
`
`
`0
`0
`0
`0
`0
`0
`—g[g|3[;3[g :e:1:1.edH1s1;i, 1
`
`
` Comments:
`
`wne
`i
`1999
`Purchased:
`Pre-delivery inspection completed
`
`, 07/23/1999
`Persona,
`Type:Where:
`Battery/charging system checked
`New Jersey, New
`Fluids checked
`York
`g
`8/5/99 -
`2 08/05/1999
`10/19/01
`‘
`
`3of8
`
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`
`

`
`CARFAX Vehicle History Repolt on WVWDE21JOYW084092
`
`http://www.carfax.com/organizer/generateReport,cfi<
`
`} 03/10/2000
`
`Three County
`Volkswagen
`Ly ndhurst, NJ
`201-933-8383
`
`threecountyvw.com
`
`Window(s) checked
`Front window regulator(s) replaced
`
`03/1 3/2000
`
`21,095
`
`Service Facility
`
`Vehicle serviced
`
`
`
`05/31/2000
`
`23,205
`
`Service Facility
`
`03/29/2000
`
`6,328
`
`New Jersey
`Motor Vehicle Dept.
`Marlton, NJ
`'l'ltle #8020001810409
`
`Emission system checked
`Throttle valve/housing replaced
`Engine/powertrain computer/module replaced
`Cruise control checked
`Rear ashtray replaced
`
`‘title issued or updated
`POTENTIAL ODOMETER ROLLBACK
`
`There are signs of potential odometer rollback here, so
`/verify the mileage with the seller.
`I know I would.
`
`
`
`
`we
`New Jersey
`Motor Vehicle Dept.
`Brooklyn, NY
`"title #EB20002160417
`
`New York
`
`New York City Area
`Inspection Station
`
`; 08/03/2000
`
`11/21/2000
`
`3 12/12/2000
`
`7,679
`
`Inspection Co.
`New York
`
`01/17/2001
`
`3 09/12/2001
`
`32,525
`
`New York
`
`Motor Vehicle Dept.
`Rosedale, NY
`New York
`New York City Area
`inspection Station
`
`09/28/2001
`
`Inspection Co.
`New York
`
`Title issued or updated
`
`Exempt from emission inspection
`Passed safety inspection
`
`View what was inspected
`
`Vehicle inspected
`Anti~theft device present
`at the time of inspection
`
`Title issued or updated
`
`Exempt from emission inspection
`Passed safety inspection
`
`View what was inspected
`
`Vehicle inspected
`Anti-theft device present
`t the ti
`f '
`cti
`
`
`
`Source:
`New York
`Title issued or updated
`Motor Vehicle De t
`New owner reported
`P ‘
`Loan or lien reported
`Listed as a dealer vehicle
`Sold at auction
`
`Bronx’ NY
`37,035 Auto Auction
`Eastern Region
`37,070 Dealer inventory
`Lynn, MA
`
`37,077 Massachusetts
`Motor Vehicle Dept.
`Winthrop, MA
`
`Vehicle offered for sale
`
`Vehicle purchase reported
`
`
`1 Date:
`Mileage:
`10/19/2001
`‘
`
`
`
`;
`06/20/2002
`
`08/20/2002
`
`10/28/2002
`
`
`
`
`
`
`
`owner 2
`Purchased:
`2001
`Type:
`Personal
`Where:
`New York,
`Massachusetts
`10/19/01 -
`5/20/02
`
`
`
`- Est. length
`0Wn€d!
`we
`
`4of8
`
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`
`

`
`CARFAX Vehicle History Report on WVWDE21JOYW084092
`
`http://www.carfax.com/o1‘ganizer/gene1'ateRepo11.cfx
`
`11/01/2002
`
`11/06/2002
`
`Massachusetts
`Motor Vehicle Dept.
`Medford, MA
`
`37,120
`
`Inspection Co.
`Massachusetts
`
`Registration updated when owner moved
`the vehicle to a new location
`
`Vehicle inspected
`Anti-theft device present
`at the time of inspection
`
`11/13/2002
`
`37,241
`
`Passed safety or emissions inspection
`
`Massachusetts
`Inspection Station
`View what was inspected
`Somerville, MA
`
`Source:
`Comments:
`Mileage:
`Piirchased:
`Type:
`Where:
`Est. length
`owned:
`
`2002
`Personal
`Massachusetts
`11/15/02 -
`6/8/07
`
`11/15/2002
`
`Massachusetts
`Motor Vehicle Dept.
`Title #AY147760
`
`11/13/2003
`
`44,052
`
`Service Facility
`
`Title or registration issued
`New owner reported
`Loan or lien reported
`Vehicle serviced
`
`,
`f
`
`
`
`
`
`5
`
`2 12/05/2003
`
`45, 296
`
`12/02/2004
`
`12/02/2004
`
`01/31/2005
`
`56, 350
`
`03/29/2005
`
`57,632
`
`Massachusetts
`Inspection Station
`Cambridge, MA
`Massachusetts
`Motor Vehicle Dept.
`Winthrop, MA
`Title #AY147760
`
`Massachusetts
`Motor Vehicle Dept.
`Brookline, MA
`‘l‘itle #AY147760
`
`Massachusetts
`Inspection Station
`Boston, MA
`
`Massachusetts
`I nspection Station
`Boston, MA
`
`12/02/2005
`
`61,915
`
`Inspection Co.
`Massachusetts
`
`j 02/02/2006
`
`63,081
`
`11/28/2006
`
`L 11/28/2006
`
`Massachusetts
`Inspection Station
`Revere, MA
`Massachusetts
`Motor Vehicle Dept.
`Brookline, MA
`‘Ftle #AY147760
`
`Massachusetts
`Motor Vehicle Dept.
`Medford, MA
`‘|’itle #AY147760
`
`Passed safety or emissions inspection
`
`View what was Inspected
`
`Registration issued or renewed
`Registration updated when owner moved
`the vehicle to a new location
`Vehicle color noted as White
`
`Registration issued or renewed
`Vehicle color noted as White
`
`Failed safety inspection
`Passed emissions inspection
`
`View what was inspected
`
`Passed safety inspection
`Passed emissions inspection
`
`\fiew what was inspected
`
`Inspection performed
`
`Passed safety inspection
`
`View what was inspected
`
`Registration issued or renewed
`Registration updated when owner moved
`the vehicle to a new location
`Vehicle color noted as White
`
`Registration issued or renewed
`Vehicle color noted as White
`
`5-1,
`E,
`
`I
`M21511/Iiéf 4 I
`07
`P
`h
`d:
`Tggceése
`figmonal
`Where:
`Massachusetts
`Est. length
`6/8/O7-
`Ownedi
`Present
`‘
`
`
`06/16/2007
`
`>l3ate:Wm I Mii;a§;‘§I‘“”i‘sogrE;;
`06/08/2007
`68,987 Massachusetts
`1‘/"V‘?“:,’]Ve“l"\’/I’: Dept‘
`'" '°P'
`69,128 Massachusetts
`Inspection Station
`Boston, MA
`
`” 2 giconiiiiénisé 5 I
`.
`Vehicle purchase reported
`
`Failed safety inspection
`Failed emissions inspection
`
`View what was inspected
`
`
`
`5of8
`
`11/14/2012 10:20 PM
`
`

`
`CARFAX Vehicle History Report on WVWDE21JOYWO84092
`
`http://www.ca1*fax.coIn/o1‘ganize1‘/gene1'ateRepo1't.cfx
`
`06/29/2007
`
`08/11/2007
`
`70,487
`
`‘ 03/19/2008
`
`73, 731
`
`‘ 04/01/2008
`
`04/01 /2008
`
`,1 05/09/2003
`
`74,000
`
`Massachusetts
`Motor Vehicle Dept.
`Winthrop, MA
`Title #BE630445
`
`Massachusetts
`Inspection Station
`Boston, MA
`
`Boston Volkswagen
`Allston, MA
`617-783-1300
`bostonwv. com
`
`Massachusetts
`Motor Vehicle Dept.
`Winthrop, MA
`Title #BE630445
`
`Massachusetts
`
`Motor Vehicle Dept.
`Maiden, MA
`Title #BE630445
`
`Boston Volkswagen
`Allston, MA
`617-783-1300
`bostonvw.com
`
`'|'itJe issued or updated
`New owner reported
`Vehicle color noted as Gray
`
`Passed safety inspection
`Passed emissions inspection
`
`View what was inspected
`
`Brake light switch replaced
`
`Registration issued or renewed
`Registration updated when owner moved
`the vehicle to a new location
`Vehicle color noted as Gray
`
`Registration issued or renewed
`Vehicle color noted as Gray
`
`Hazard light switch replaced
`
`Print this CARFAX Report and take it to your pre-purchase inspection
`es“ .-gm.
`"-'z:»rA7:¢{'V?"u~«mz=2»z2»Zé*/.‘¢4&V3Li.1‘A’sz/?/u:;:n:‘E-‘a-ne7u$,w7;\&@cxzmsr»:=r».awa;Ezm§:2fi;rrri/$~.mya:.Qiav‘2,~¢«’*{m"»fi1:s3E:5:E»Tz“=*~
`
`',
`
`Tell us what you know about this vehicle
`
`l
`
`Have Questions? Please visit our Help Center at www.carfax.com.
`
`View Full Glossary 2i
`
`CARFAX Price Adjustment”
`Accidents, service records, number of owners and many other history factors can affect a vehicle's value. The CARFAX Price
`Adjustment is a tool that analyzes millions of used car transactions to measure how the combination of all the information reported to
`CARFAX affects the value of a particular vehicle. The vehicle's retail book value plus the CARFAX Price Adjustment will give you a
`more accurate measure of the vehicle's value. Use this tool, along with a vehicle inspection and test drive, to make a better decision
`about your next used car.
`
`Failed Emissions Inspection
`The emissions check performed during a vehicle inspection indicated the vehicle was emitting more than allowable emissions
`standards and/or had missing or modified parts. Repeated failed emissions records can indicate engine problems and CARFAX
`recommends you have the vehicle inspected.
`
`First Owner
`
`
`
`When the first owner(s) obtains a title from a Department of Motor Vehicles as proof of ownership.
`
`inspections
`Many states or counties require annual or biennial emissions and/or safety inspections. Odometer readings are collected at the time of
`the inspection.
`
`New Owner Reported
`When a vehicle is sold to a new owner, the ‘title must be transferred to the new owner(s) at a Department of Motor Vehicles.
`
`Odometer Rollback
`
`if a more recent odometer reading is less than an older reading, then the odometer may have been tampered with and ''rolled back."
`CARFAX analyzes the mileage history and the sources of this information to indicate a potential odometer rollback.
`
`Ownership History
`CARFAX defines an owner as an individual or business that possesses and uses a vehicle. Not all title transactions represent changes
`in ownership. To provide estimated number of owners, CARFAX proprietary technology analyzes all the events in a vehicle history.
`Estimated ownership is available for vehicles manufactured after 1994 and titled solely in the US including Puerto Rico. Dealers
`
`it,.
`
`6of8
`
`11/14/201210:20 PM
`
`

`
`CARFAX Vehicle History Report on WVWDE21JOYW084092
`
`http://www. ca1‘fax.com/o1‘ganizer/generateRepo1't.cfi(
`
`sometimes opt to take ownership of a vehicle and are required to in the following states: Maine, Massachusetts, New Jersey, Ohio,
`Oklahoma, Pennsylvania and South Dakota. Please consider this as you review a vehicle's estimated ownership history.
`Title Issued
`73 A state issues a title to provide a vehicle owner with proof of ownership. Each title has a unique number. Each title or registration
`record on a CARFAX report does not necessarily indicate a change in ownership, In Canada, a registration and bill of sale are used
`E;T as proof of ownership.
`
`if}
`
`
`
`fi @CarfaxFteports
`
`Follow Us: facebook.comICARFA)(
`CARFAX DEPENDS ON ITS SOURCES FOR THE ACCURACY AND RELIABILITY OF ITS INFORMATION. THEREFORE, NO
`RESPONSIBILITY IS ASSUMED BY CARFAX OR ITS AGENTS FOR ERRORS OR OMISSIONS IN THIS REPORT CARFAX FURTHER
`EXPRESSLY DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING ANY IMPLIED WARRAN'I1ES OF
`MERCHANTABILITY OR FITNESS FORA PARTICULAR PURPOSE. CARFAX®
`© 2012 CARFAX, Inc., an RL. Polk & Co. company. All rights reserved.
`Covered by United States Patents Nos. 7,113,853; 7,505,838 and 7,596,512.
`11/14/1210:18:03 PM (EST)
`
`CARFAX on Google+
`
`
`
`70f8
`
`11/14/2012 10:20 PM
`
`

`
`CARFAX Vehicle Histoty Report on WVWDE21JOYW084092
`
`http2//www.carfax.com/organizer/generateRep01t.cfk
`
`CARFAX has estimated the remaining original manufacturer warranty coverage based on information reported to us on this 2000
`VOLKSWAGEN GTI GLX (WVWDE21JOYW084092). Please confirm remaining factory warranty and extended warranty options with
`your dealer. Interested in an extended warranty?
`CARFAX used time only to calculate the remaining warranty coverage because mileage problems were found in this vehicle's history.
`
`VIN:
`
`WVWDE21JOYW084092
`
`
`
`Estimated start date of warranty:
`Last CARFAX reading reported on 05/09/2008:
`
`Today's Date:
`
`/l
`
`08/05/1999
`74,000 miles
`
`November 14, 2012
`
`Type of Coverage:
`
`Original Warranty:
`
`Estimated Remaining Coverage:
`
`Basic
`
`Drivetrain
`
`Emissions
`
`Corrosion
`
`Transferable
`
`24 months or 24,000 miles
`
`120 months or 100,000 miles
`
`96 months or 80,000 miles
`
`144 months or unlimited mileage
`
`For original owner or immediate family
`member, otherwise subsequent owner has
`5/50,000 powertrain
`
`Coverage expired
`
`Coverage expired
`
`Coverage expired
`
`Coverage expired
`
`Same
`
`Roadside Assistance
`
`No data reported to CARFAX
`
`Safety belt & inflatable restraint
`
`No data reported to CARFAX
`
`Specific Components
`Notes:
`
`96 months or 80,000 miles
`
`Coverage expired
`
`Emissions: Manufacturer covers emissions components under basic warranty.
`Emissions coverage may vary by state. Refer to owners manual for specific details.
`Transferable: For original owner or immediate family menber, othen/vise subsequent
`owner has 5/50,000 powertrain. Roadside Assistance: Administered by Cross Country.
`Notes: Adjustments 1/12,000.
`
`5*‘ CARFAX Warranty Check provides an estimate of this vehicle's remaining warranty coverage. it does not take into account
`some vehicle history events such as some title brands that may void the original manufacturer warranty or ownership transfers
`that may decrease warranty coverage. This warranty information is only valid for vehicles manufactured for the United States.
`Complete warranty coverage information is available for this vehicle at the VOLKSWAGEN web site.
`
`8of8
`
`11/14/2012 10:20 PM
`
`

`
`Exhibit D
`
`DECLARATION OF GIUSEPPE A. CUOZZO PURSUANT TO 37 C.F.R. §
`1.131
`
`(4 PAGES INCLUDING THIS COVER PAGE)
`
`
`

`
`

`
`CORPORATION
`
`INVENTION
`SUBMISSION
`
`Executive Headquarters:
`
`217 Ninth Street
`
`- Pittsburgh, PA 15222-3506 -
`
`(412) 288-1300
`
`STATEMENT OF CONFIDENTIALITY AND NON-USE
`
`
`Ztgzza
`fzfiusgfl
`NAME:
`ADDRESS: lj Maflé £7/IQ!
`CITY:
`iilognkd
`
`//M )0/« /3//V
`
`PHONE No.:(_ i7 3) (7/c§L2~ O00}
`STATE: AZIZ
`ZIP CODE: 0700 3
`
`You have approached lSC for the purpose of discussing your idea, invention, or product and exploring services which ISC
`may perform for you an your concept described or named as:
`
`
`
`ISO is in the business of preparing basic information packages for a great number of different product concepts, and its
`integrity depends on maintaining the confidentiality of each of the product concepts presented to it. ISC hereby agrees that the
`idea, invention, or product you are disclosing and which you believe to be your own original creation shall not be used, sold,
`assigned, or disclosed to any other person, organization, or corporation without your permission, and further, that none of the
`empl

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