`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________________
`
`FedEx Corp.,
`Petitioner
`v.
`
`Intellectual Ventures II LLC,
`Patent Owner
`_________________________
`
`U.S. Patent No. 6,633,900
`_________________________
`
`
`PETITION FOR INTER PARTES REVIEW
`OF U.S. PATENT NO. 6,633,900
`
`
`
`
`
`Exhibit 2003 Page 1
`
`IV Exhibit 2003
`FedEx v. IV
`Case IPR2017-00741
`
`

`

`U.S. Patent No. 6,633,900
`
`TABLE OF CONTENTS
`
`TABLE OF CONTENTS .......................................................................................... ii
`
`LIST OF EXHIBITS ................................................................................................ iv
`
`TABLE OF AUTHORITIES ..................................................................................... v
`
`I.
`
`II.
`
`Introduction ...................................................................................................... 1
`
`Statement of Precise Relief Requested for Each Claim Challenged ............... 3
`
`A.
`
`B.
`
`Claims for Which Review Is Requested ............................................... 3
`
`Statutory Grounds.................................................................................. 3
`
`III.
`
`’900 Patent Overview ...................................................................................... 4
`
`A.
`
`B.
`
`Summary ............................................................................................... 4
`
`Prosecution History ............................................................................... 8
`
`IV. The Level of Ordinary Skill in the Art ............................................................ 9
`
`V.
`
`Claim Construction ........................................................................................10
`
`VI. Ground 1: Jones and Kaman Render Obvious Claim 1 Under 35
`U.S.C. § 103 ...................................................................................................11
`
`A. Overview of Jones ...............................................................................11
`
`B. Overview of Kaman ............................................................................13
`
`C.
`
`D.
`
`Rationale to Combine Jones and Kaman ............................................15
`
`Jones and Kaman Collectively Teach Every Element of Claim 1 ......17
`
`VII. The Ground Presented in this Petition Is Not Redundant of the Ground
`Presented in IPR2017-00741 .........................................................................43
`
`VIII. Mandatory Notices Under 37 C.F.R. § 42.8 ..................................................44
`
`A.
`
`B.
`
`Real Party-in-Interest ..........................................................................44
`
`Related Matters ....................................................................................45
`
`–ii–
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`Exhibit 2003 Page 2
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`

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`U.S. Patent No. 6,633,900
`
`C.
`
`D.
`
`Lead and Backup Counsel ...................................................................45
`
`Service Information .............................................................................46
`
`IX. Grounds for Standing .....................................................................................46
`
`X.
`
`Fee Payments .................................................................................................47
`
`XI. Conclusion .....................................................................................................47
`
`
`
`
`
`–iii–
`
`Exhibit 2003 Page 3
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`

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`U.S. Patent No. 6,633,900
`
`LIST OF EXHIBITS
`
`Exhibit 1101.
`
`U.S. Patent No. 6,633,900 to (“the ’900 patent”)
`
`Exhibit 1102.
`
`U.S. Patent No. 6,748,318 to Jones (“Jones”)
`
`Exhibit 1103.
`
`U.S. Patent No. 5,715,905 to Kaman (“Kaman”)
`
`Exhibit 1104.
`
`Declaration of Tal Lavian, Ph.D.
`
`Exhibit 1105.
`
`Prosecution History of U.S. Application No. 09/509,100
`
`Exhibit 1106.
`
`Exhibit A to Plaintiff Intellectual Venture II LLC’s
`
`Infringement Contentions, Intellectual Ventures II LLC v.
`
`FedEx Corp., 2:16-cv-00980 (E.D. Tex., Jan. 17, 2017)
`
`Exhibit 1107.
`
`Complaint for Patent Infringement, Intellectual Ventures II LLC
`
`v. FedEx Corp., 2:16-cv-00980 (E.D. Tex., Aug. 31, 2016)
`
`Exhibit 1108.
`
`U.S. Patent No. 5,920,846 to Storch (“Storch”)
`
`Exhibit 1109.
`
`U.S. Patent No. 4,922,516 to Butler (“Butler”)
`
`Exhibit 1110.
`
`U.S. Patent No. 5,623,260 to Jones
`
`
`
`
`
`–iv–
`
`Exhibit 2003 Page 4
`
`

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`U.S. Patent No. 6,633,900
`
`TABLE OF AUTHORITIES
`
`CASES
`Cuozzo Speed Techs, LLC v. Lee,
`136 S. Ct. 2131 (2016) .......................................................................................10
`
`Microsoft v. Proxyconn, Inc.,
`789 F.3d 1292 (Fed. Cir. 2015) ..........................................................................11
`
`In re GPAC Inc.,
`57 F.3d 1573 (Fed. Cir. 1995) ............................................................................10
`
`STATUTES
`
`35 U.S.C. § 102 ....................................................................................................3, 43
`
`35 U.S.C. § 103 ................................................................................................ passim
`
`35 U.S.C. § 311 ....................................................................................................3, 46
`
`35 U.S.C. § 315 ........................................................................................................47
`
`RULES/REGULATIONS
`
`37 C.F.R. § 42.100(b) ..............................................................................................10
`
`37 C.F.R. § 42.104(b)(3) ................................................................................... 11, 46
`
`Office Patent Trial Practice Guide,
`77 Fed. Reg. 48756 (Aug. 14, 2012) ..................................................................11
`
`–v–
`
`Exhibit 2003 Page 5
`
`

`

`U.S. Patent No. 6,633,900
`
`I.
`
`
`Introduction
`
`FedEx Corp. requests inter partes review of claim 1 of U.S. Patent No.
`
`6,633,900 (“the ’900 patent”) (Ex. 1101.) The Board should institute review and
`
`cancel claim 1 in view of the obviousness ground presented in this petition.
`
`The ’900 patent discloses and claims a method for distributing work order
`
`assignment data to a field crew. (Ex. 1101 at 2:20-24, 15:7-27.) The method of
`
`claim 1 includes eight different steps (A-H), but each one was well known long
`
`before the ’900 patent. (Ex. 1104 ¶¶ 6-7.) Steps A-B and E-H recite well-known
`
`tasks performed in prior art dispatching process: (A) updating a database with a
`
`new work assignment; (B) notifying a field crew of the assignment; (E) presenting
`
`a list of assignments; (F, G) retrieving and displaying detailed data regarding an
`
`assignment; (H) updating
`
`the detailed data based on field crew
`
`input.
`
`(Ex. 1104 ¶ 7; Ex. 1101 at 15:11-27.) The ’900 patent admits that these type of
`
`dispatching steps were performed in prior art systems. (Ex. 1104 ¶ 8; Ex. 1101 at
`
`1:18-51.) The remaining steps, C and D, add login functionality that merely
`
`verifies field crew identity and notifies the field crew of a successful login. (Ex.
`
`1101 at 15:11-27; Ex. 1104 ¶ 9.) Steps C and D are untethered to the remaining
`
`claim elements and recite only basic functions of system access that were well
`
`known long before the ’900 patent. (Ex. 1104 ¶ 9.)
`
`–1–
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`Exhibit 2003 Page 6
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`

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`U.S. Patent No. 6,633,900
`
`The ’900 patent, however, purports to have improved the prior art
`
`dispatching systems—which allegedly used voice, fax, or proprietary technology
`
`for communication—by using TCP/IP. (Ex. 1101 at 1:52-2:38.) Of course, the
`
`’900 patent inventors did not invent TCP/IP, (Ex. 1104 ¶ 10; Ex. 1101 at 4:52-55),
`
`and applying these ubiquitous protocols to existing systems is not patent worthy.
`
`Worse yet, claim 1 does not even mention a network, nor is it limited to TCP/IP.
`
`(Ex. 1104 ¶ 11.) Instead, it is silent regarding any communication protocol, and the
`
`only components it recites are an “enterprise computing system,” a “mobile field
`
`unit,” and a “database.” (Id.; Ex. 1101 at 15:7-11.) Moreover, the TCP/IP protocol
`
`disclosed in the ’900 patent is simply one embodiment of the broader concept of a
`
`“non-proprietary technolog[y]” that the ’900 patent contrasts with preexisting
`
`“proprietary technology. (Ex. 1101 at 1:66-2:14-27.)
`
`This petition presents a single obviousness ground based on two references
`
`from the delivery and transportation industry, Jones and Kaman. As Jones and
`
`Kaman demonstrate, drivers and/or delivery personnel operating delivery vehicles
`
`used a mobile unit to exchange information with an enterprise-side dispatching
`
`system to perform each step of claim 1. (Ex. 1104 ¶¶ 12-13.) Because the
`
`combination of Jones and Kaman renders obvious claim 1, Petitioner requests that
`
`the Board institute review and cancel claim 1. (Ex. 1104 ¶¶ 6-13, 51, 125-126.)
`
`–2–
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`Exhibit 2003 Page 7
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`

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`U.S. Patent No. 6,633,900
`
`II.
`
`
`Statement of Precise Relief Requested for Each Claim Challenged
`
` Claims for Which Review Is Requested A.
`Petitioner respectfully requests review under 35 U.S.C. § 311 of claim 1 of
`
`the ’900 patent and cancellation of this claim as unpatentable.
`
`Statutory Grounds
`
`B.
`
`Claim 1 of the ’900 patent is unpatentable and should be cancelled in view
`
`of the following grounds and prior art references.
`
`Prior Art References
`
`Ref. 1:
`
`Jones, U.S. Patent No. 6,748,318 (Ex. 1102); filed May 6, 1997;
`
`prior art under 35 U.S.C. § 102(e).
`
`Ref. 2: Kaman, U.S. Patent No. 5,715,905 (Ex. 1103); filed February 5,
`
`1997, issued February 10, 1998; prior art under 35 U.S.C. §§ 102(a),
`
`Ground of Unpatentability
`
`(e).
`
`
`
`Ground
`
`1
`
`Jones and Kaman render obvious claim 1 under 35 U.S.C. § 103
`
`–3–
`
`Exhibit 2003 Page 8
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`

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`U.S. Patent No. 6,633,900
`
`III.
`
`
`
`’900 Patent Overview
`A.
`
`The ’900 patent describes a system and method for assigning and
`
`Summary
`
`communicating work orders to field crew personnel. (Ex. 1101 at 2:20-24; Ex.
`
`1104 ¶ 37.) The disclosed systems and methods may be used by businesses such as
`
`“utility companies,” which “deploy numerous employees over a wide geographic
`
`area to service a dispersed infrastructure or client base.” (Ex. 1101 at 1:18-23.)
`
`The disclosed system and method use both an enterprise computing system
`
`and at least one mobile field unit. (Id. at 2:24-25; Ex. 1104 ¶ 38.) The enterprise
`
`computing system is a dispatch system, assigning and communicating work order
`
`assignments
`
`to field crew personnel “with minimum dispatcher/operator
`
`interference.” (Ex. 1101 at 3:38-49.) The field crews use the mobile field unit—a
`
`computing device such as a portable computer, a personal digital assistant (PDA),
`
`or similar device—to receive the work order assignments, gather information about
`
`the work order, and update the enterprise computing system regarding the status of
`
`the work order. (Id. at 3:42-46, 4:13-16, 4:41-44.)
`
`To communicate data between the field crews and the enterprise computing
`
`system, the ’900 patent describes using standard networking components and
`
`techniques that were widely available and well-known. (Ex. 1104 ¶ 39.) In
`
`particular, the ’900 patent discloses using a wireless communication network that
`
`–4–
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`Exhibit 2003 Page 9
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`

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`U.S. Patent No. 6,633,900
`
`supports terminal control protocol/internet protocol (TCP/IP). (Ex. 1101 at 2:24-
`
`27, 3:55-4:4, 4:23-30.) As shown in Fig. 1 (below), the enterprise computing
`
`system 50 of the ’900 patent includes one or more servers 56, 60, 62, 64 or
`
`workstations 66 connected over a LAN 68 to a database 58 and a TCP/IP gateway
`
`70. (Id. at 3:55-4:4.) The mobile field unit 72 includes a wireless radio modem 74
`
`and communicates with the enterprise computing system 50 over the wireless
`
`communication network 54.
`
`
`
`The ’900 patent discloses using this system to perform a method for
`
`distributing work order assignments to field crews as shown in Fig. 5 (below). (Id.
`
`at 8:66-9:19; Ex. 1104 ¶ 40.) The method includes updating a database on the
`
`enterprise computing system to indicate an assignment has been assigned to a field
`
`–5–
`
`Exhibit 2003 Page 10
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`

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`U.S. Patent No. 6,633,900
`
`crew, after which the field crew is notified. (Ex. 1101 at 8:66-9:19, steps 300, 302.)
`
`In response to the field crew inputting login data, the method verifies the field crew
`
`identity and notifies the field crew of a successful login. (Id., steps 304-308). The
`
`method also presents a list of assignments to the field crew and retrieves detailed
`
`assignment data in response to input by the field crew. (Id., steps 308-312.)
`
`Finally, in response to the field crew identifying that an action was taken with
`
`regard to the assignment, the database is updated. (Id., step 314.)
`
`–6–
`
`Exhibit 2003 Page 11
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`

`

`U.S. Patent No. 6,633,900
`
`
`
`Claim 1 of the ’900 patent is the only independent claim and recites a
`
`method for distributing work order assignment data to the field crew. (Ex. 1101 at
`
`15:7-27.) While the ’900 patent describes embodiments where the enterprise
`
`computing system and mobile field unit communicate using a computer network
`
`and TCP/IP, claim 1 is not so limited. (Ex. 1104 ¶ 41.) In fact, claim 1 does not at
`
`–7–
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`Exhibit 2003 Page 12
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`

`

`all limit the communications medium through which the claimed steps are
`
`performed. (Id.) Claim 1 recites:
`
`U.S. Patent No. 6,633,900
`
`1. A method for distributing work order assignment data to a
`field crew using a system having an enterprise computing system
`and at least one mobile field unit, comprising the following steps:
`(A) updating a database on the enterprise computing system to
`indicate an assignment has been assigned to the field crew;
`(B) notifying the field crew of the assignment;
`(C) in response to the input of field crew login data, verifying
`field crew identity;
`(D) notifying the field crew of successful login;
`(E) retrieving and presenting a list of assignments to the field
`
`crew;
`
`(F) in response to field crew input selecting an assignment
`from the list of assignments, retrieving detailed assignment data for
`the selected assignment;
`(G) displaying the detailed assignment data to the field crew;
`
`and
`
`(H) in response to field crew input identifying an action was
`taken with regard
`to the assignment, updating the detailed
`assignment data.
`
`(Ex. 1101 at 15:7-27.)
`
`Prosecution History
`
`B.
`
`The ’900 patent was filed on April 26, 2000 as U.S. Patent Application No.
`
`09/509,100. (Ex. 1101, cover.) This application was a national stage entry from
`
`–8–
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`Exhibit 2003 Page 13
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`

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`U.S. Patent No. 6,633,900
`
`PCT Application No. PCT/US99/00497 filed on January 8, 1999. (Id.) The PCT
`
`application claimed priority to U.S. Provisional Application No. 60/070,858 filed
`
`on January 9, 1998. (Ex. 1105 at 96.) The ’900 patent, however, does not claim
`
`priority back to the U.S. provisional application. (Ex. 1101 at 1:8-9.) Nonetheless,
`
`for purposes of this proceeding only, and without waiving the ability to challenge
`
`the priority date of the ’900 patent before this Office or in another forum,
`
`Petitioner has assumed that the priority date of the ’900 patent is the January 9,
`
`1998 provisional filing date.
`
`The ’900 patent issued after a short prosecution. During the international
`
`phase of the PCT application, the written search report identified only five prior art
`
`references, none of which were sufficiently related (either individually or in
`
`combination) to form a prior art rejection of the claims. (Ex. 1105 at 99, 107.)
`
`Upon entry into the U.S., the same examiner who issued the written search report
`
`handled the U.S. prosecution. (See id. at 104, 193 (listing same examiner).) There,
`
`the Applicant was only issued a restriction requirement, (id. at 193-201 (restriction
`
`requirement)), and the case was allowed after election, (id. at 210-14 (notice of
`
`allowability in response to election)).
`
` The Level of Ordinary Skill in the Art IV.
`
`
`Factors defining the level of ordinary skill in the art include: (1) the types of
`
`problems encountered in the art; (2) the prior art solutions to those problems;
`
`–9–
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`Exhibit 2003 Page 14
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`U.S. Patent No. 6,633,900
`
`(3) the rapidity with which innovations are made; (4) the sophistication of
`
`technology; and (5) the educational level of active workers in the field. In re GPAC
`
`Inc., 57 F.3d 1573, 1579 (Fed. Cir. 1995).
`
`Based on these factors, a person of ordinary skill at the time of the alleged
`
`invention of the ’900 patent would have held at least a Bachelor’s Degree in
`
`Electrical Engineering, Computer Engineering, Computer Science or
`
`the
`
`equivalent. (Ex. 1104 ¶¶ 42-43.) One skilled in the art would also have had two or
`
`more years of industry experience in the field of computer networking generally,
`
`and wireless networking or mobile communications specifically, or the academic
`
`equivalent thereof. (Ex. 1104 ¶¶ 44-49 (citing Ex. 1101 at 3:55-4:34, 4:47-5:10,
`
`Figs. 1, 2).) Such a person would have been familiar with the components,
`
`methods, and protocols used at the time of the alleged invention of the ’900 patent
`
`to communicate between a mobile field unit and an enterprise computing system.
`
`(Id.)
`
` Claim Construction V.
`
`
`A claim in an unexpired patent “shall be given its broadest reasonable
`
`construction in light of the specification of the patent in which it appears.”
`
`37 C.F.R. § 42.100(b). Under this standard, claim terms are given their ordinary
`
`and customary meaning as would be understood by one of ordinary skill in the art
`
`in the context of the specification. Cuozzo Speed Techs, LLC v. Lee, 136 S. Ct.
`
`–10–
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`Exhibit 2003 Page 15
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`

`

`U.S. Patent No. 6,633,900
`
`2131, 2142 (2016). “The PTO should also consult the patent’s prosecution history
`
`in [IPR] proceedings.” Microsoft v. Proxyconn, Inc., 789 F.3d 1292, 1298 (Fed.
`
`Cir. 2015).
`
`In this proceeding, Petitioner submits that the claim terms of the ’900 patent
`
`should be given their broadest reasonable interpretation as understood by one of
`
`ordinary skill in the art and consistent with the disclosure. 37 C.F.R.
`
`§ 42.104(b)(3); Office Patent Trial Practice Guide, 77 Fed. Reg. 48756, 48764
`
`(Aug. 14, 2012). (Ex. 1104 ¶ 50.)
`
` Ground 1: Jones and Kaman Render Obvious Claim 1 Under 35
`VI.
`U.S.C. § 103
` Overview of Jones
`A.
`Jones discloses an advanced notification system and method for notifying
`
`users in advance of an impending vehicle arrival. (Ex. 1102 at 1:43-49;
`
`Ex. 1104 ¶¶ 51-52.) This allows users to predict arrival times, avoid unnecessary
`
`waiting, and plan accordingly. (Ex. 1102 at 1:56-65.) Jones states that its
`
`disclosure is useful for arriving buses, trains, delivery vehicles, vessels, and even
`
`individuals. (Id. at 1:43-49.) In the context of package delivery systems, customers
`
`are alerted of an impending delivery based on the location of the delivery vehicle.
`
`(Id., Abstract.)
`
`As shown in Fig. 2 (below), Jones describes a system including a vehicle
`
`control unit (VCU) on each vehicle and a base station control unit (BSCU) that
`
`–11–
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`Exhibit 2003 Page 16
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`

`

`U.S. Patent No. 6,633,900
`
`communicates with the VCUs. (Id. at 10:52-59; Ex. 1104 ¶ 53.) The BSCU (14)
`
`coordinates communication between the VCUs (12) and customer devices (36),
`
`(36x). (Ex. 1102 at 10:52-63.)
`
`
`
`The VCU displays stop information to the driver in the field using a display
`
`module (33). (Id. at 19:53-57; Ex. 1104 ¶ 54.) For example, as shown in Figure 41
`
`(below), the VCU may display a route list of upcoming stops for the driver to make
`
`throughout the day. (Ex. 1102 at 9:41-64, Figs. 40-43.) The BSCU can update the
`
`route list both prior to a driver starting his or her route when packages are added
`
`and mid-route if new requests to pick up packages are added. (Id. at 18:5-22.)
`
`Thus, the route list can be updated throughout the day and updates can be sent to
`
`the VCU. (Id. at 21:66-22:9; Ex. 1104 ¶ 54.)
`
`–12–
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`Exhibit 2003 Page 17
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`

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`U.S. Patent No. 6,633,900
`
`
`
` Overview of Kaman
`B.
`Kaman discloses a vehicle access controller for “monitoring mobile
`
`vehicles[,] . . . collecting operational information of mobile vehicles[,] and
`
`securing such vehicles against unauthorized use.” (Ex. 1103 at 1:7-10; Ex. 1104
`
`¶ 55.) Kaman describes use of its system in small and large organizations,
`
`including those in which “one operator is assigned to a vehicle,” or where “many
`
`operators may use a given vehicle within a given time period without any one
`
`operator being assigned to any given vehicle.” (Ex. 1103 at 1:37-45.) As shown in
`
`Fig. 1 (below), the controller of Kaman includes a mobile vehicle data collection
`
`unit (10) including “a transceiver 20 for transmitting vehicular information from
`
`–13–
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`Exhibit 2003 Page 18
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`

`

`the data collection unit 10 to a central data collection unit computer 38.” (Id. at
`
`U.S. Patent No. 6,633,900
`
`2:45-51.)
`
`
`
`To ensure only authorized operators are using a particular vehicle, the data
`
`collection unit employs an access control device to obtain credential information
`
`from the operator. (Id. at 6:66-7:10; Ex. 1104 ¶ 56.) The access control device is
`
`“any device structured for determining indicia of identity of a prospective vehicle
`
`user (e.g., a keyboard, a magnetic card reader, a key card reader, a fingerprint
`
`scanner, or a retinal scanner).” (Ex. 1103 at 6:66-7:10.) Kaman further states that
`
`“[w]here the access control device 28 is a keypad or card reader, the indicia of
`
`identity may be an access code.” (Id.) The indicia of identity of a prospective user
`
`is either transmitted to a central station or is processed locally to be compared with
`
`previously stored indicia of identity of authorized users. (Id. at 2:17-22, 7:24-31.)
`
`–14–
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`Exhibit 2003 Page 19
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`

`

`U.S. Patent No. 6,633,900
`
` Rationale to Combine Jones and Kaman
`C.
`A skilled artisan would have been motivated to combine Jones and Kaman
`
`for the purposes of controlling access to Jones’s delivery vehicles and systems.
`
`(Ex. 1104 ¶¶ 57-65.) Jones teaches a system with VCUs on each vehicle, where the
`
`system can be deployed in a delivery service organization. (Ex. 1102 at 2:33-45.)
`
`Kaman teaches a vehicle access controller for preventing unauthorized use of a
`
`vehicle in small and large organizations. (Ex. 1103 at 1:7-10, 37-45; Ex. 1104
`
`¶ 58.) It would have been obvious to one skilled in the art to combine the vehicle
`
`system of Jones with the vehicle access controller of Kaman for the purposes of
`
`validating an authorized user before granting access to a vehicle or VCU. (Ex.
`
`1104 ¶ 58.)
`
`Jones discloses that the drivers may be part of a commercial delivery
`
`company. (Ex. 1102 at 2:33-45.) One skilled in the art would have been motivated
`
`to determine the identity of a driver and verify his or her credentials before
`
`allowing the driver to access the VCU and communicate with the BSCU. (Ex. 1104
`
`¶ 59.) Kaman provides a vehicle access controller that verifies the identity of a
`
`driver by using indicia of identity and an access control device. (Ex. 1103 at 7:1-
`
`10.) Combining the access control device of Kaman with the vehicle or VCU of
`
`Jones would yield predictable results by preventing unauthorized access to the
`
`vehicle and the BSCU. (Ex. 1104 ¶ 60.)
`
`–15–
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`Exhibit 2003 Page 20
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`

`

`U.S. Patent No. 6,633,900
`
`The motivation to combine would furthermore be apparent to one skilled in
`
`the art as an organization with one or more delivery vehicles would want to limit
`
`access to those vehicles and associated VCUs to only authorized users. (Id. ¶¶ 61-
`
`63.) Limiting access to the vehicles would provide the organization with increased
`
`security and control over the system. (Id. ¶ 61.) Security would be increased
`
`because the organization could use the combination to ensure that only authorized
`
`employees are allowed to access the system or vehicles. (Id. ¶ 62.) This would
`
`reduce the risk that vehicles or system components would be stolen or tampered
`
`with. (Id.) Control would also be increased because the organization would be able
`
`to determine which employee accessed which vehicle or VCU. (Id. ¶ 63.)
`
`One skilled in the art would further have been motivated to add Kaman’s
`
`security features to Jones because Jones recognizes the importance of system
`
`security in related contexts. (Id. ¶ 64.) For example, Jones discloses that a
`
`customer can establish notification preferences using software resident on his or
`
`her personal computer or via an internet website. (Ex. 1102 at 36:16-26.) When a
`
`notification is requested, the “computer address” of the user is registered so that
`
`only one computer may be used to receive notifications. (Id. at 36:29-37; see also
`
`Fig. 30 (stating “Notice - You May ONLY Subscribe From The Computer Address
`
`You Are Using Now!”).) Jones states that “this allows the advance notification
`
`system to have a level of security.” (Id.) Indeed, the file history of Jones indicates
`
`–16–
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`Exhibit 2003 Page 21
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`

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`U.S. Patent No. 6,633,900
`
`that security is relevant to Jones because it includes cited prior art directed to
`
`vehicle systems with security. (See Ex. 1102 at 2 (citing U.S. Patent No. 5,223,844
`
`to Mansell et al., entitled “Vehicle tracking and security system”).)
`
`That Jones discloses the need for security in one context would suggest to
`
`one skilled in the art that security is important to its notification system. (Ex. 1104.
`
`¶ 65.) Moreover, one skilled in the art would have been prompted to consider other
`
`forms of security for the notification system to ensure only authorized users have
`
`access. This suggestion would have led one of ordinary skill to modify Jones and
`
`combine Jones with Kaman. (Id.) Doing so would have been nothing more than a
`
`combination of known elements based on the suggestion provided in the prior art.
`
`(Id.)
`
`D.
`
`
`Jones and Kaman Collectively Teach Every Element of Claim 1
`i.
`
`
`“A method for distributing work order assignment data to a
`field crew”
`Jones teaches a method for distributing work order assignment data to a field
`
`crew. (Ex. 1104 ¶¶ 66-70.) Jones discloses a system including a VCU and BSCU
`
`that communicate to coordinate a route stop list1 for a driver throughout the day.
`
`
`1 Jones also refers to this as the “route list,” “stop list,” or “delivery list.”
`
`See Ex. 1102 at 9:41-64 (“route list”), Figs. 41-43 (“stop list”), 33:39-61 (“delivery
`
`list” and “stop list”).)
`
`–17–
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`Exhibit 2003 Page 22
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`

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`U.S. Patent No. 6,633,900
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`(Ex. 1102 at Abstract.) The VCU displays the route stop list to the driver using a
`
`display, such as the one shown in Figure 41, reproduced below. (Id. at 9:41-64,
`
`Figs. 40-43.)
`
`
`
`Jones discloses that the BSCU updates and optimizes the route stop list as
`
`packages are added to the vehicle and as stops are added to a driver’s route. (Id. at
`
`33:39-55; 17:63-18:11; Ex. 1104 ¶ 67.) The BSCU updates the route stop list both
`
`prior to a driver starting his or her route when packages are added and mid-route if
`
`new requests to pick up packages are added. (Ex. 1102 at 18:5-22.) The BSCU also
`
`optimizes the route stop list by organizing it using both optimization software and
`
`–18–
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`Exhibit 2003 Page 23
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`

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`U.S. Patent No. 6,633,900
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`driver input. (Id. at 33:45-34:4.) The route stop list is therefore updated throughout
`
`the day and updates may be sent to the driver’s VCU. (Id. at 21:66-22:9.)
`
`One skilled in the art would consider a route stop list to be “work order
`
`assignment data” within the context of the ’900 patent. (Ex. 1104 ¶ 68.) For
`
`example, the ’900 patent broadly describes a “work order” as “any type of
`
`description of a particular task.” (Ex. 1101 at 3:38-39.) Each stop in Jones is a
`
`work order assignment that a driver must carry out (e.g., drive the vehicle to that
`
`location and pick up or deliver a package). (Ex. 1104 ¶ 68.) One skilled in the art
`
`also would consider adding stops to the route and/or optimizing a list of stops,
`
`either before the route begins or during the route, to be “distributing work order
`
`assignment data to a field crew.” (Id. ¶ 69.) Patent Owner agrees because it has
`
`alleged that FedEx uses a method for distributing work order assignment data to a
`
`field crew by providing “couriers” and “truck delivery drivers” with “information
`
`regarding its package deliveries.” (Ex. 1106 at 3; Ex. 1104 ¶ 70.) Thus, Patent
`
`Owner cannot reasonably contend that Jones’s distribution of stops in a route stop
`
`list does not disclose distributing work orders to a field crew.
`
`ii.
`
`
`“using a system having an enterprise computing system and
`at least one mobile field unit, comprising the following
`steps”
`Jones discloses using a system having an enterprise computing system and at
`
`least one mobile field unit. (Ex. 1104 ¶¶ 71-78.) Jones discloses delivery vehicles
`
`–19–
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`Exhibit 2003 Page 24
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`

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`U.S. Patent No. 6,633,900
`
`with onboard VCUs (e.g., mobile field units), each communicating with the BSCU
`
`(e.g., an enterprise computing system). (Ex. 1102 at 10:52-64.) The VCUs
`
`communicate with the BSCU (id.), to perform the steps discussed in the analysis
`
`that follows.
`
`One skilled in the art would consider the VCU to be or include a “mobile
`
`field unit” within the context of the ’900 patent. (Ex. 1104 ¶¶ 72-73.) As shown in
`
`Fig. 11 (below) the VCU is “a compact unit with a generally rectangular housing
`
`that is mounted preferably on or in front of the dashboard of the vehicle 19 in view
`
`of and within reach of the vehicle driver.” (Ex. 1102 at 14:7-11.) The VCU
`
`includes a microprocessor controller 16, display (LCD) module 33, a mobile
`
`telephone transceiver 18, and user controls 21a for making inputs into the VCU.
`
`(Id. at 6:55-67, 10:66-11:22, 14:7-38.) The VCU displays information to the driver
`
`through the display module 33, and the driver can communicate with the BSCU via
`
`the user controls 21a. (Id. at 12:30-39, 13:47-55; Ex. 1104 ¶ 73.) Jones also
`
`discloses using wireless communication between the VCUs and the BSCU,
`
`including cellular networks. (Ex. 1102 at 11:4-12.)
`
`–20–
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`Exhibit 2003 Page 25
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`

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`U.S. Patent No. 6,633,900
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`
`
`In a similar manner, the ’900 patent describes the mobile field unit as a
`
`“portable computer, a personal digital assistant (PDA), or similar device.” (Ex.
`
`1101 at 4:13-16.) One skilled in the art would consider Jones’s VCU, a small
`
`computer with a microprocessor controller, display, mobile telephone transceiver,
`
`and user controls (Ex. 1102 at 6:55-67, 10:66-11:22), to be a “portable computer
`
`. . . or similar device.” (Ex. 1104 ¶ 74.) Patent Owner cannot reasonably contend
`
`that Jones’s VCU is not a “mobile field unit,” because Patent Owner has accused
`
`FedEx of using mobile units by relying on the PowerPad and MC9500 devices that
`
`Patent Owner alleges “FedEx has provided [to] its couriers . . . .” (Ex. 1106 at 4-5.)
`
`One skilled in the art also would have considered the BSCU to be an
`
`“enterprise computing system” within the context of the ’900 patent. (Ex. 1104
`
`¶¶ 75-77.) Jones’s BSCU “may be implemented using any conventional computer
`
`–21–
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`Exhibit 2003 Page 26
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`

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`U.S. Patent No. 6,633,900
`
`with suitable processing capabilities.” (Ex. 1102 at 14:41-50.) The BSCU
`
`communicates with the VCUs and customer computers over a network, including
`
`“a computer network operated by an Internet service provider.” (Id.) As shown in
`
`Fig. 10 (below), Jones discloses several different modules maintained by the
`
`BSCU, including a “Route List with Order of Delivery (RL),” “Vehicle Location
`
`Data Base (VLDB),” and “Mapping Software Data Base (MSDB).” (Id. at 15:37-
`
`67, 16:57-64.) The route stop list (RL) is created when addresses from package
`
`data are uploaded to the BSCU. (Id. at 25:57-67.) The sequence of addresses is
`
`optimized by the BSCU to create the route stop list. (Id. at 17:63-18:22, 33:39-60;
`
`Ex. 1104 ¶ 76.) Using this data in combination with the VLDB and MSDS, the
`
`BSCU tracks a vehicle’s progress along its route stop list. (Ex. 1102 at 19:58-
`
`20:10.) The BSCU uses this data to send customers notice of impending deliveries.
`
`(Id. at 15:6-10.)
`
`–22–
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`Exhibit 2003 Page 27
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`U.S. Patent No. 6,633,900
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`
`
`Jones disclosure of the BSCU is similar to the ’900 patent’s disclosure of an
`
`enterprise computing system that includes one or more servers or workstations
`
`connected in a computer network to field requests and provide data regarding work
`
`orders. (Ex. 1101 at 3:55-67.) Thus, one ski