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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`
`FORD MOTOR COMPANY,
`Petitioner
`
`v.
`
`Patent of CUOZZO SPEED TECHNOLOGIES LLC,
`Patent Owner.
`
`____________
`
`Case IPR: 2014-01393
`
`Patent 6,778,074
`
`____________
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`PETITIONER’S REPLY BRIEF
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`i
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`TABLE OF CONTENTS
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`I. INTRODUCTION ............................................................................................. 1
`II. CLAIM CONSTRUCTION ............................................................................. 1
`III. NAGOSHI ANTICIPATES CLAIMS 1, 9, 10, AND 19 .............................. 3
`A. NAGOSHI DISCLOSES A COLORED DISPLAY THAT IS ADJUSTED
`
`“INDEPENDENTLY OF” THE SPEEDOMETER. ..................................................... 3
`B. NAGOSHI DISCLOSES THAT “SAID DISPLAY CONTROLLER FURTHER COMPRISES
` A TONE GENERATOR,” AS REQUIRED BY CLAIMS 9 AND 19. ........................... 5
`C. NAGOSHI DISCLOSES A “GLOBAL POSITIONING SYSTEM RECEIVER,” AS
` REQUIRED BY CLAIM 10. .................................................................................. 6
`IV. NAGOSHI IN VIEW OF VAUGHN RENDERS CLAIMS 2, 11-13, AND
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`20 OBVIOUS .................................................................................................... 8
`A. NAGOSHI IN VIEW OF VAUGHN DISCLOSES “SAID COLORED DISPLAY IS A
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`LIQUID CRYSTAL DISPLAY,” AS REQUIRED BY CLAIMS 2 AND 12. .................. 8
`B. NAGOSHI IN VIEW OF VAUGHN DISCLOSES “SAID GLOBAL POSITIONING
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`SYSTEM RECEIVER FURTHER COMPRISES A DATABASE OF LOCATIONS AND
`
`THEIR CORRESPONDING SPEED LIMITS,” AS REQUIRED BY CLAIM 11. ............ 9
`C. NAGOSHI IN VIEW OF VAUGHN DISCLOSES THE “INDEPENDENTLY”
` LIMITATION OF CLAIM 13. ............................................................................. 11
`D. NAGOSHI IN VIEW OF VAUGHN RENDERS CLAIM 20 OBVIOUS. ..................... 11
`V. CLAIMS 3-6, 14-17, AND 18 ARE OBVIOUS BASED ON INSTITUTED
` GROUNDS 3, 4, AND 5. ................................................................................. 12
`VI. CLAIM 1 IS OBVIOUS OVER TEGETHOFF, VAUGHN, EVANS, AND
` WENDT. ......................................................................................................... 12
`VII. CONCLUSION ............................................................................................. 15
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`ii
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`APPENDIX OF EXHIBITS
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`
`
`Statement of Relevance
`Patent at issue
`
`
`
`Filed
`☒
`
`Invalidating prior art to the challenged
`claims
`English translation of invalidating prior
`art to the challenged claims
`Affidavit of Michael O’Keeffe attesting
`to the accuracy of the translation of the
`prior art Nagoshi reference from Japanese
`to English
`Patent Office’s brief in support of
`unpatentability of claims 10, 14, and 17
`Invalidating prior art to the challenged
`claims
`
`Patent Owner’s purported distinctions
`over prior art
`
`Invalidating prior art to the challenged
`claims
`Invalidating prior art to the challenged
`claims
`
`English translation of invalidating prior
`art to the challenged claims
`
`Affidavit of Joyce Chen attesting to the
`accuracy of the translation of the prior art
`Tegethoff reference from German to
`English
`Invalidating prior art to the challenged
`claims
`iii
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`
`
`☒
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`☒
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`☒
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`☒
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`☒
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`☒
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`☒
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`☒
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`☒
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`☒
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`☒
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`Description
`Exhibit
`1001 U.S.P.N. 6,778,074
`to Cuozzo
`JP H05-067294 to
`Nagoshi (Japanese)
`JP H05-067294 to
`Nagoshi (English)
`1004 Affidavit of
`Michael O’Keeffe
`
`1002
`
`1003
`
`1007
`
`1005
`
`1006
`
`Federal Circuit
`Brief
`Canadian Patent
`Application No.
`2,186,709 to
`McKenna
`Corrected
`Amendment from
`Prosecution of
`’074 Patent
`1008 U.S.P.N. 5,485,161
`to Vaughn
`1009 DE 197 55470 A1
`to Tegethoff
`(German)
`1010 DE 197 55470 A1
`to Tegethoff
`(English)
`1011 Affidavit of Joyce
`Chen
`
`1012 U.S.P.N. 3,980,041
`to Evans
`
`
`

`

`Description
`Exhibit
`1013 U.S.P.N. 2,711,153
`to Wendt
`
`Statement of Relevance
`Invalidating prior art to the challenged
`claims
`
`
`
`Filed
`☒
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`
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`
`iv
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`I.
`
`INTRODUCTION
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`Patent Owner raises strained arguments not supported by the teachings of the
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`prior art references themselves in an attempt to avoid the instituted grounds of
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`unpatentability. The teachings of the prior art refute Patent Owner’s arguments.
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`Patent Owner also re-argues the claim construction of the term “integrally
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`attached,” a term that the Board has already consistently construed three times
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`previously. Patent Owner fails to disclose that the U.S. Court of Appeals for the
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`Federal Circuit has already rejected Patent Owner’s overbroad construction and
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`affirmed the Board’s prior construction. Claims 1-6 and 9-20 should be cancelled,
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`for all of the reasons set forth herein, in the Petition, and in the Board’s Institution
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`Decision.
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`II. CLAIM CONSTRUCTION
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`Patent Owner contends that the term “integrally attached,” which is required
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`by claims 1 and 10, as well as claim 20 (via incorporation by reference) of the ‘074
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`Patent, should be construed as “joined or combined to work as a unit.” PO
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`Response, Paper 12, at 5. The Board, however, has already previously given
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`careful consideration of the construction of this term on no less than three separate
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`occasions and has consistently construed this term in the same manner as proposed
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`by Ford in its Petition: “integrally attached” requires “discrete parts physically
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`joined together as a unit without each part losing its own separate identity.” See
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`-1-
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`Corr. Petition (Paper 4), at 11 (citing IPR2012-00001, Paper 59 (Final Decision) at
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`9; Paper 15 (Inst. Dec.) at 8; and IPR2013-00373, Paper 12 (Inst. Dec.) at 12).
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`Patent Owner does not raise any new arguments that have not previously been
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`considered and improperly proposes to read the requirement of the speedometer
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`being “attached” to the colored display out of the claims. Patent Owner proposes
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`essentially the same construction that has been rejected by the Board in the past.
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`Compare PO Response, Paper 12, at 5 (“joined or combined to work as a unit.”)
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`with Paper IPR2012-00001, Paper 59, at 9 (“joined or combined to work as a
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`complete unit”) (emphasis added).
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`Additionally, Patent Owner fails to mention that the U.S. Court of Appeals
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`for the Federal Circuit has already conclusively affirmed the Board’s construction
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`of this claim term from the ‘074 Patent in its decision affirming the Board’s final
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`decision in the first IPR relating to this patent, IPR2012-00001. See In re Cuozzo
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`Speed Techs., LLC, 778 F.3d 1271, 1283 (Fed. Cir. Feb. 4, 2015). In that ruling,
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`the Federal Circuit rejected Patent Owner’s construction and expressly affirmed
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`the Board’s construction of “integrally attached” as requiring “discrete parts
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`physically joined together as a unit without each part losing its own separate
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`identity.” Id. Patent Owner and the Board are now bound by stare decisis to adopt
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`this construction. See Key Pharm. v. Hercon Labs. Corp., 161 F.3d 709, 716 (Fed.
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`Cir. 1998) (“[W]e recognize the national stare decisis effect that this court's
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`decisions on claim construction have.”); see also Kinetic Concepts, Inc. v. Smith &
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`Nephew, Inc., 688 F.3d 1342, 1363 (Fed. Cir. 2012) (“[W]e have already construed
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`the claims to include this limitation and that legal conclusion was binding on the
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`district court and is binding on this panel.”).
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`For all the reasons already previously set forth by the Board in its prior
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`rulings and by Ford in its Petition, as well as because the Federal Circuit has now
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`construed this term, the Board should maintain its claim construction of “integrally
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`attached.”1
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`III. NAGOSHI ANTICIPATES CLAIMS 1, 9, 10, AND 19
`A. Nagoshi Discloses A Colored Display That
`“Independently Of” The Speedometer.
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`Is Adjusted
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`Patent Owner half-heartedly argues that Nagoshi does not show that its
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`colored display is adjusted “independently of” its speedometer, as required by
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`claim 1. PO Resp. at 9-11. Patent Owner may be correct that Nagoshi does not
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`itself expressly use the term “independently,” but the law does not require such and
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`1 Of course, Patent Owner’s proposed construction, which is broader than that adopted by
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`the Board, does not provide Patent Owner with any additional patentability arguments.
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`See In re Cuozzo, 778 F.3d at 1283 (“Cuozzo contends that the correct construction of
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`‘integrally attached’ should be broader—‘joined or combined to work as a complete
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`unit.’”).
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`-3-
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`it is clear that Nagoshi’s colored green and red LEDs on the perimeter of the
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`speedometer dial operate independently of the speedometer itself.
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`First, as the vehicle speeds up, the pointer needle on the speedometer moves
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`along the speedometer markings to indicate the increasing speed. Patent Owner
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`appears to take issue with the fact that Fig. 4 and Fig. 5 both depict a current speed
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`of approximately 38 km/h and do not show that the speed “changes.” Patent
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`Owner’s argument is, frankly, absurd. A person of ordinary skill in the art, and
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`indeed, any layperson who has ever operated an automobile, knows that the needle
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`on a speedometer moves as speed changes. Even if that were not the case, Nagoshi
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`expressly teaches that in conventional systems, “[t]he running velocity . . . is
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`displayed on speedometer 17.” Ex.1003, at 2 [¶0003]. And speedometer 17 in Fig.
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`6, which otherwise resembles the speedometer shown in Figs. 4-5, shows a
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`different displayed speed of 110 km/h. Id. at Fig. 6.
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`Second, Nagoshi teaches that as the vehicle travels to a road with a different
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`speed limit, the current speed limit is output and sent to the display apparatus,
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`which displays the speed limit. Id. at 2 [¶¶0013-15]. Then, when describing Fig.
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`4, Nagoshi teaches that “the driver is informed of the speed limit of the road
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`currently being driven by the display green LEDs of the velocities below the speed
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`limit on the outer side of the speedometer, and the velocities above the speed limit
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`in red.” Id. at 2 [¶0016]. Thus, the lighting of the colored LCDs changes
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`-4-
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`corresponding to changes in the speed limit and not corresponding to changes in
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`the vehicle’s current speed, which is indicated separately by movement of the
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`speedometer’s needle. That is all that is required for the colored display to be
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`adjusted “independently of” the speedometer.
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` The ‘074 Patent’s written
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`description does not ever use the term “independently” or assign it any special
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`meaning. Instead, the ‘074 patent merely refers to the colored display being
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`adjusted with changes in speed limit. ‘074 Patent at 5:34-39, Fig. 2. Nagoshi
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`provides the same teaching when it refers to its LEDs being lit to indicate the speed
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`limit.
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`Finally, Patent Owner attempts to distinguish Fig. 5 by suggesting that it
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`shows “vehicle restriction information, other than the speed limit information.”
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`PO Resp. at 10. But, as paragraph [0017] of Nagoshi and Fig. 5 itself make clear,
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`Fig. 5 merely shows information about whether right and left turns are prohibited
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`(e.g., for one-way streets) in addition to the speed limit information indicated by
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`the illumination of the red and green LEDs.
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`Patent Owner cannot credibly contend that Nagoshi’s LEDs do not adjust to
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`indicate the current speed limit independently of the speedometer’s own
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`adjustments to indicate changes in current speed.
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`B. Nagoshi Discloses That “Said Display Controller Further Comprises
`A Tone Generator,” As Required By Claims 9 and 19.
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`Next, Patent Owner contends
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`that Nagoshi
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`teaches “an alternative
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`-5-
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`embodiment in which the display 13 is replaced by a warning buzzer,” and that this
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`prevents Nagoshi from teaching that “said display controller further comprises a
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`tone generator.” PO Resp. at 12. Nagoshi, however, never teaches that its display
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`13 is “replaced by” the warning buzzer. Nagoshi merely teaches that instead of its
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`display displaying the speed limit on the speedometer when the speed exceeds the
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`speed limit, the driver can be informed by the sound of a buzzer. Nagoshi never
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`teaches an embodiment in which its display is removed and replaced by only a
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`buzzer. Indeed, this would be contrary to Nagoshi’s teaching that the conventional
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`system in the prior art (as shown in Fig. 6 and described at [¶¶0003-0006])
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`included only a warning buzzer and no separate speed limit display. At best,
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`Nagoshi teaches that the display may not be actively displaying the speed limit
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`when the buzzer is sounded—not that the display is somehow entirely removed.
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`Nagoshi, therefore, discloses a system that includes both a display controller and a
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`tone generator, even if the display may not actively indicate the speed limit at the
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`same time the warning buzzer is activated.
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`C. Nagoshi Discloses A “Global Positioning System Receiver,” As
`Required By Claim 10.
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`Nagoshi teaches that instead of using inputs from the geomagnetic sensor 8,
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`wheel velocity sensor 9, and map data in CD-ROM 10 to compute the current
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`position of the vehicle, the “vehicle location computation means [which is
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`described as means 3 elsewhere] may be configured by employing GPS.” Ex.
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`-6-
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`1003 at 5 [¶0019]; at 4 [¶0010]. Patent Owner incredibly suggests there is some
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`potential shred of ambiguity as to whether GPS means “Global Positioning
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`System” in this context, but offers no alternative interpretation of the term “GPS”
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`as used in this context. The conclusion that GPS refers to Global Positioning
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`System is inescapable. Patent Owner also faults Nagoshi for not expressly saying
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`GPS “receiver,” but there is no way the vehicle could use GPS to compute its
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`present location without using a GPS receiver to receive signals from the GPS
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`satellites. Finally, Patent Owner argues that Nagoshi could be referring to simply
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`using GPS to “calibrate” its vehicle location computation means. But Nagoshi
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`expressly states that “the vehicle location computation means of claim 1 was
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`configured from the geomagnetic sensor 8, the wheel velocity sensor 9 and the
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`CDROM 10, but it is not limited to this in the present invention, and said vehicle
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`location computation means may be configured by employing GPS”—Nagoshi is
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`consistently using the term “configured” to refer to the components that are used to
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`determine the present position of the vehicle. In the first embodiment, the
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`vehicle’s position is dead-reckoned using map data and various sensors for
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`detecting movement and direction. See id. at [¶0010] (describing how navigation
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`system 11 computes current location from values output from sensors 8 and 9 and
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`map data from CDROM 10). Thus, in this alternative embodiment, when Nagoshi
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`teaches that the vehicle location computation means is “not limited to” using just
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`the sensors 8 and 9 and CDROM 10, Nagoshi is teaching that GPS can be used in
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`determining the vehicle’s location. There is nothing in Nagoshi to support Patent
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`Owner’s argument that the term “configured” is being used to mean “calibrated.”
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`Patent Owner raises no other arguments with respect to claims 1, 9, 10, and
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`19. Therefore, claims 1, 9, 10, and 19 are anticipated by Nagoshi.
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`IV. NAGOSHI IN VIEW OF VAUGHN RENDERS CLAIMS 2, 11-13, AND
`20 OBVIOUS
`A. Nagoshi in view of Vaughn Discloses “Said Colored Display Is A
`Liquid Crystal Display,” As Required By Claims 2 And 12.
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`Patent Owner argues that it would not have been obvious to combine
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`Nagoshi and Vaughn for claim 2 and claim 12’s requirement that the colored
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`display for indicating the speed limit comprise a liquid crystal display (LCD).
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`Patent Owner makes a series of unsupported arguments about how LEDs and
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`LCDs may have certain respective benefits and drawbacks. Importantly, Patent
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`Owner makes these arguments in the abstract without referencing the context of
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`the claimed invention: displaying speed and the current speed limit to the driver.
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`Vaughn itself expressly teaches a system for displaying speed and speed limit to
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`the driver, and Vaughn expressly teaches that it is possible to interchangeably
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`utilize various display technologies, such as LEDs, LCDs, or cathode ray tube
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`displays for its display in a system that uses current GPS position and map data to
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`determine and display the speed limit for the vehicle’s current location. Ex. 1008
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`at 9:10-23. Whether LCDs or LEDs have interchangeability in other types of
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`contexts is irrelevant. And the only evidence in the record establishes that for the
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`claimed purpose of displaying speed and current speed limit, either LCDs or LEDs
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`were both known alternatives. From this express teaching in Vaughn, a person of
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`ordinary skill in the art would have known that an LCD could be used in place of
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`LEDs for the purposes of indicating speed and the current speed limit. Finally,
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`Patent Owner has not shown that Vaughn or Nagoshi teaches away from the
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`proposed combination because neither reference criticizes, discredits, or
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`discourages the claimed combination, i.e., use of an LCD. See In re Fulton, 391
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`F.3d 1195, 1201 (Fed. Cir. 2004) (“The prior art’s mere disclosure of more than
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`one alternative does not constitute a teaching away from any of these alternatives
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`because such disclosure does not criticize, discredit, or otherwise discourage the
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`solution claimed . . . .”). Nagoshi, in view of Vaughn, therefore, renders claims 2
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`and 12 obvious.
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`B. Nagoshi In View Of Vaughn Discloses “Said Global Positioning
`System Receiver Further Comprises A Database Of Locations And
`Their Corresponding Speed Limits,” As Required By Claim 11.
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`Patent Owner contends
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`that Nagoshi and Vaughn are “inherently
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`incompatible” because Nagoshi “provides a speed warning whereas Vaughn
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`ensures that vehicle can never exceed the speed limit.” PO Resp. at 17.
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`Presumably, Patent Owner is suggesting that Nagoshi’s visual indication of the
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`-9-
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`current speed limit (e.g., by lighting colored LEDs around the perimeter of the
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`speedometer) would not be useful with Vaughn’s system for preventing speed from
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`exceeding the speed limit. Vaughn’s own teachings, however, refute Patent
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`Owner’s argument. Vaughn expressly teaches that its system does display the
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`current speed limit to the driver. Ex. 1008 at 9:10-11 (“The location of the vehicle,
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`its current speed, and maximum posted speed can be displayed on the electronic
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`map.”); 9:20-23 (“The display 12 is connected to the GPS computer 47 and to the
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`engine computer 15. Accordingly, the location, current speed of the vehicle and the
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`maximum posted speed is displayed on the electronic map.”). Thus, Vaughn
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`demonstrates that, even in a system designed to control the speed of the vehicle,
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`the driver may want to be visually informed of the speed limit. The driver also, of
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`course, would benefit from being provided with some warning that the vehicle is
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`automatically decreasing vehicle speed, as suggested by Vaughn’s “Alarm System
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`20” in Fig. 1. Finally, Patent Owner is incorrect when it argues that “Vaughn
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`ensures that a vehicle can never exceed the speed limit.” PO Resp. at 17. Vaughn
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`teaches that it uses some predetermined threshold above the speed limit before its
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`system takes action to decrease speed. See, e.g., Ex. 1008 at Abstract (“to decrease
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`the vehicle speed if the vehicle speed exceeds the maximum posted speed plus
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`some predetermined value.”); 8:58-64 (“The memory unit also keeps some
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`predetermined speed value which is added to the maximum posted speed before
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`the comparison with the vehicle speed is made. If the vehicle speed exceeds the
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`maximum posted speed plus the predetermined speed value, the GPS computer
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`connected to an odometer 26 transmits the signal to the odometer to decrease the
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`vehicle speed.”). Thus, Patent Owner is incorrect when it argues that Vaughn
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`prevents the vehicle from ever exceeding the speed limit. Therefore, even in
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`Vaughn’s system, a driver would benefit from being informed when the current
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`speed exceeds the speed limit prior to speed control being activated. Nagoshi and
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`Vaughn are strongly complementary and are in no way “incompatible.”
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`C. Nagoshi In View Of Vaughn Discloses The “Independently”
`Limitation Of Claim 13.
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`Patent Owner repeats the same argument with respect to this limitation as
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`from Claim 1. PO Resp. at 18. Petitioner, therefore, incorporates by reference its
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`argument above with respect to the “independently of said speedometer” limitation
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`of Claim 1. See Sec. III.A, supra. Claim 13, therefore, is obvious.
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`D. Nagoshi In View Of Vaughn Renders Claim 20 Obvious.
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`Patent Owner raises no independent arguments in response to the instituted
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`ground that Nagoshi in view of Vaughn renders Claim 20 obvious, nor does Patent
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`Owner incorporate by reference any other arguments. Claim 20, therefore, is
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`obvious.
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`V. CLAIMS 3-6, 14-17, AND 18 ARE OBVIOUS BASED ON INSTITUTED
`GROUNDS 3, 4, AND 5.
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`Patent Owner relies solely on arguments with respect to Nagoshi in Ground
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`1 (anticipation by Nagoshi) for Grounds 3, 4, and 5. Petitioner, therefore,
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`incorporates by reference its arguments above with respect to Ground 1. See Sec.
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`III, supra. Claims 3-6 and 14-18, therefore, are obvious.
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`VI. CLAIM 1 IS OBVIOUS OVER TEGETHOFF, VAUGHN, EVANS, AND
`WENDT.
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`First, Patent Owner argues that Tegethoff lacks the claimed “display
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`controller” that “adjusts said colored display independently of said speedometer to
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`continuously update the delineation of which speed readings are in violation of the
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`speed limit at a vehicle’s present location.” PO Resp. at 19-20. Tegethoff,
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`however, expressly teaches “an image generating computer 33” (Ex. 1010 at p. 4,
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`col. 2; p.5, col. 1; p. 6, col. 1; Fig. 1) that “can be embodied such that the
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`representation on the screen, such as of pointers, markings, and scales, can be
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`programmed completely freely.” Ex. 1010 at p. 5, col. 1-2; see also Corr. Petition
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`(Paper 4) at 22 (discussing “image generating computer 33”) & 16-17 (discussing
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`Tegethoff’s teaching or a red tick mark on the speedometer dial). Further,
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`Tegethoff teaches that its screen 37 can be a colored LCD. Id. at p.5, col. 1. As
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`shown in Fig. 2 and described on pages 6 and 7 of Tegethoff, a red tick mark is
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`displayed to indicate the speed limit on the speedometer. Thus, because the speed
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`limit is independent of the current speed, the display of the red tick mark for the
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`speed limit is independent of the displayed movement of the pointer on the
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`speedometer indicating current speed. Tegethoff, therefore, discloses the claimed
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`“display controller.”
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`Next, Patent Owner repeats its argument that Vaughn’s system is
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`incompatible with speed limit warning devices, such as that of Tegethoff because
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`“the entire purpose of Vaughn’s system is to ensure that a vehicle can never exceed
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`the speed limit by automatically controlling the vehicle’s speed.” PO Resp. at 21-
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`22. However, as discussed above, this argument is misplaced. First, Vaughn itself
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`displays the current speed limit at the vehicle’s current location, demonstrating that
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`Vaughn is not incompatible with displaying speed limit warnings. Second,
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`Vaughn does not prevent the speed limit from being exceeded because it employs a
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`threshold above the speed limit before speed control begins. Finally, Vaughn
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`teaches an “alarm system,” which is consistent with the idea that the driver of a
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`vehicle containing the system of Vaughn would benefit from being provided a
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`visual indication regarding the speed limit being exceeded before speed control
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`was activated.
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`With regard to Tegethoff and Evans, Patent Owner argues that Evans’
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`colored plate 12 is “glued to the glass cover 24 of the speedometer” (citing Ex.
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`1012 at 2:67-3:3). But Evans does not use such language nor does it teach that the
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`adhesive is a permanent attachment. Instead, Evans teaches that “plate 12 can, if
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`desired, be removed from cover 24” to allow a different sized plate to be placed or
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`to allow the plate to be repositioned on the speedometer cover. Id. at 3:37-43; see
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`also id. at claim 1 (“said plate being releasable and repositionable”). Thus, Patent
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`Owner is incorrect to suggest that Evans’ plate is permanently attached to the
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`speedometer. Further, Patent Owner argues that it would not make sense to attach
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`Evans’ physical plate onto Tegethoff’s digital display, but offers no reason why. It
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`is not uncommon to combine physical elements with digital displays and there is
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`nothing counterintuitive about doing so here. As Petitioner explained, it would be
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`possible to either “graphically represent” Evans’ colored plate (such as under
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`Patent Owner’s construction of “integrally attached”) or use its physical colored
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`plate, rotatably mounted, as taught by its combination with Wendt (which satisfies
`
`the Board’s construction of “integrally attached”). With regard to Tegethoff,
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`Evans, and Wendt, the petition merely asserts that it would have also been obvious
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`to utilize a rotatable colored plate (as taught by Evans combined with Wendt)
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`driven by Tegethoff’s computer as an alternative to digitizing the rotatable colored
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`plate. In this manner, the “integrally attached” requirement of the claims is
`
`satisfied. And, Tegethoff, combined with Evans and Wendt, discloses the claimed
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`colored display that adjusts “independently of said speedometer to continuously
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`-14-
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`

`

`
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`update the delineation of which speed readings are in violation of the speed limit at
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`a vehicle’s present location.”
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`Claim 1, therefore, is obvious over Tegethoff, Vaughn, Evans, and Wendt.
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`VII. CONCLUSION
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`For the forgoing reasons, Petitioner respectfully requests that the Board
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`cancel claims 1-6 and 9-20.
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`
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`
`
`June 15, 2015
`
`Respectfully submitted,
`
`By: /s/ Eric A. Buresh
`Eric Buresh (Lead Counsel)
`Reg. No. 50,394
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, Kansas 66211
`P: 913-777-5600 / F: 913-777-5601
`eric.buresh@eriseip.com
`
`
`
`
`
`Jason R. Mudd (Backup Counsel)
`Reg. No. 57,700
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, Kansas 66211
`P: 913-777-5600 / F: 913-777-5601
`jason.mudd@eriseip.com
`
`
`-15-
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`

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`CERTIFICATE OF SERVICE
`
`
`
`The undersigned certifies that a copy of the foregoing PETITIONER’S
`
`REPLY BRIEF was sent via electronic mail on June 15, 2015, to the following:
`
`John R. Kasha
`Reg. No. 53,100
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(708) 867-1886
`john.kasha@kashalaw.com
`
`
`
`
`
`Date: June 15, 2015
`
`
`By:
`
`
`
`
`
`/s/ Eric A. Buresh
`Eric A. Buresh
`Reg. No. 50,394
`Jason R. Mudd
`Reg. No. 57,700
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`Telephone: (913) 777-5600
`Facsimile: (913) 777-5601
`
`Counsel
`Company
`
`for Petitioner Ford Motor
`
`
`
`
`
`