`
`Case IPR2017-00741
`
`U.S. Patent No. 6,633,900
`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________
`
`
`FEDEX CORP.
`Petitioner
`
`
`v.
`
`
`INTELLECTUAL VENTURES II LLC
`Patent Owner
`
`__________________
`
`
`Case IPR2017-00741
`
`
`U.S. Patent No. 6,633,900
`TITLE: MOBILE CREW MANAGEMENT SYSTEM FOR DISTRIBUTING
`WORK ORDER ASSIGNMENTS TO MOBILE FIELD CREW UNITS
`Issue Date: October 14, 2003
`
`__________________
`
`
`
`DECLARATION OF JACOB SHARONY, Ph.D., MBA
`
`
`
`
`
`
`
`
`
`Exhibit 2010 Page 1
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`IV Exhibit 2010
`FedEx v. IV
`Case IPR2017-00741
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`

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`Case IPR2017-00741
`U.S. Patent No. 6,633,900
`
`
`TABLE OF CONTENTS
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`
`
`Page
`
`
`I.
`
`II.
`
`INTRODUCTION .......................................................................................... 4
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`BASES FOR OPINIONS ............................................................................... 4
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`III. MATERIALS REVIEWED ........................................................................... 5
`
`IV. EDUCATION AND EXPERIENCE .............................................................. 5
`
`V.
`
`LEGAL STANDARDS .................................................................................. 8
`
`VI. LEVEL OF ORDINARY SKILL IN THE ART .......................................... 11
`
`VII. OVERVIEW OF THE ’900 PATENT ......................................................... 12
`
`VIII. OVERVIEW OF THE INSTITUTED GROUND ........................................ 14
`
`A. Overview Of Storch ........................................................................... 14
`
`B. Overview Of Butler ............................................................................ 15
`
`IX. SUMMARY OF OPINIONS ........................................................................ 17
`
`X. OPINIONS ABOUT “MOBILE FIELD UNIT” .......................................... 18
`
`A.
`
`B.
`
`Claim 1 Requires A “Mobile Field Unit,” Which Is An
`Essential Part Of The Invention Of The ’900 Patent. ......................... 18
`
`The Broadest Reasonable Interpretation Of “Mobile Field Unit”
`In Claim 1 Of The ’900 Patent Is “Computing Device That
`Communicates Over A Wireless Network.” ...................................... 20
`
`C. Neither Storch Nor Butler Has A Computing Device That
`Communicates Over A Wireless Network. ........................................ 40
`
`D. A Person Of Ordinary Skill In The Art Would Not Have
`Considered Storch’s And Butler’s Devices To Be “Mobile”
`Because They Cannot Communicate Unless Tethered To A
`Landline. ............................................................................................. 47
`
`
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`Exhibit 2010 Page 2
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`Case IPR2017-00741
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`U.S. Patent No. 6,633,900
`XI. A PERSON OF ORDINARY SKILL IN THE ART WOULD NOT
`HAVE COMBINED STORCH AND BUTLER AS IN THE
`PETITION. ................................................................................................... 51
`
`
`
`XII. APPENDIX A: THE CHALLENGED CLAIM OF THE ’900
`PATENT ....................................................................................................... 56
`
`
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`Exhibit 2010 Page 3
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`Case IPR2017-00741
`U.S. Patent No. 6,633,900
`I.
`INTRODUCTION
`
`
`
`
`
`
`I, Jacob Sharony, a resident of Dix Hills, New York, over 18 years of age,
`
`hereby declare as follows:
`
`1.
`
`I have personal knowledge of all of the matters about which I testify
`
`in this declaration.
`
`2.
`
`Desmarais LLP retained me on behalf of Intellectual Ventures II LLC
`
`(“Intellectual Ventures”) to provide my technical opinions and testimony about
`
`claim 1 of U.S. Patent Number 6,633,900 to Khalessi et al. (“the ’900 patent”). I
`
`refer to that claim as the “challenged claim.” The full text of the challenged claim
`
`appears in Appendix A to my declaration.
`
`3.
`
`I am being compensated for my work in this proceeding and receiving
`
`reimbursement for expenses incurred in the course of my work. My compensation
`
`is not contingent in any way on either the opinions I have reached or the outcome
`
`of this case.
`
`II. BASES FOR OPINIONS
`4.
`I have reviewed and considered the documents and other materials
`
`listed below in Section III in light of my specialized knowledge provided by my
`
`education, training, research, and experience, as summarized in Section IV and
`
`described in detail in my CV, which is attached hereto as Appendix B. My
`
`analysis of those materials, combined with the specialized knowledge that I have
`
`
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`Exhibit 2010 Page 4
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`U.S. Patent No. 6,633,900
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`obtained over the course of my education and career, form the bases for my
`
`opinions in this declaration.
`
`III. MATERIALS REVIEWED
`5.
`I have reviewed and analyzed the parties’ papers and exhibits in this
`
`proceeding, including the ’900 patent (Ex. 1001) and its file history (Ex. 1005); the
`
`Petition and the exhibits cited by the Petitioner in this proceeding, including U.S.
`
`Patent No. 5,920,846 to Storch et al. (Ex. 1002, “Storch”); U.S. Patent No.
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`4,922,516 to Butler et al. (Ex. 1003, “Butler”), and the Declaration of Tal Lavian
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`(Ex. 1004); IV’s preliminary response and the exhibits cited therein; the Board’s
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`institution decision; and the deposition transcript of Dr. Lavian. (Ex. 2011.) I
`
`have also reviewed and analyzed the exhibits cited in this declaration.
`
`IV. EDUCATION AND EXPERIENCE
`6.
`I have 25 years of experience working in mobile and wireless
`
`technology, which has resulted in over 50 issued patents and numerous
`
`publications in scientific journals and conferences. I have also served on various
`
`government expert panels, including for the National Science Foundation and
`
`National Institutes of Health.
`
`7.
`
`Since 2010, I have been an Adjunct Professor in Electrical
`
`Engineering at Columbia University, teaching graduate level courses on advanced
`
`wireless technologies including in the areas of wireless sensing technology,
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`
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`Exhibit 2010 Page 5
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`mmWave communications, and applications for 5G wireless networks and
`
`systems.
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`8.
`
`I received a Bachelor’s Degree (1979) and Master’s Degree (1984) in
`
`Electrical Engineering from Tel Aviv University. I have M.Phil. (1991) and Ph.D.
`
`(1993) Degrees in Electrical Engineering from Columbia University. I also have
`
`an MBA Degree (1989) from Tel Aviv University.
`
`9.
`
`I have been
`
`involved with mobile and wireless networking
`
`technologies since the mid-1990s working as a researcher, developer and educator
`
`on wide and local area networks infrastructure and mobile devices. Over these two
`
`decades I have witnessed the change from voice-centric to data-centric networks,
`
`and have worked on enterprise mobility products and solutions as early as the late
`
`1990s.
`
`10. After obtaining my Ph.D., I led the advanced mobile networking
`
`group at BAE Systems, developing tactical mesh-based wireless network systems
`
`for the Department of Defense. I also conducted research and development in
`
`advanced mobile and wireless networks. My work resulted in several issued
`
`patents including patents such as U.S. Patent No. 5,652,751 titled “Architecture for
`
`mobile radio networks with dynamically changing topology using virtual subnets,”
`
`and U.S. Patent No. 5,742,593 titled “On-line distributed TDMA/FDMA/CDMA
`
`link assignment in mobile radio networks with flexible directivity.”
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`
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`Exhibit 2010 Page 6
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`11. From 1997-2005, I held various positions at Symbol Technologies
`
`(acquired by Motorola Solutions). While working at Motorola/Symbol I gained
`
`substantial experience
`
`in application-specific mobile device, and wireless
`
`networking and architecture solutions in several vertical applications, e.g.,
`
`transportation and logistics, healthcare, warehousing, retail, education, among
`
`others. As Senior Director, Research and Development, I initiated and led several
`
`research and development programs in wireless LAN technologies including
`
`mobile device management and security. As Senior Director, Technology Strategy
`
`and Development, I was responsible for the research and development of new
`
`mobile applications for delivering multimedia-rich content to mobile devices
`
`connected over heterogeneous networks. That work resulted in several U.S.
`
`patents, including U.S. Patent No. 7,778,649 titled “System and method for asset
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`location in wireless networks” and U.S. Patent No. 6,925,094 titled “System and
`
`method for wireless network channel management.”
`
`12.
`
`In 2004, I founded Mobius Consulting, a consulting firm providing
`
`professional services in mobile wireless strategy, technologies, systems, and
`
`applications, including enterprise mobility, wireless communication networks,
`
`mobile embedded devices, device management, and mobile applications and
`
`services. In this capacity, I have worked with many companies in the mobile and
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`wireless ecosystem including service providers and operators, equipment vendors,
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`
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`and semiconductor companies. Since founding Mobius Consulting, I have worked
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`with many enterprises interested in deploying mobile and wireless solutions in
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`order to become more productive, efficient, and cost effective. These solutions
`
`spanned numerous industry sectors and involved various mobile and wireless
`
`technologies including 3G/4G Cellular, Wi-Fi, Bluetooth, ZigBee, and RFID.
`
`13.
`
`In addition to the summary I have provided here, I describe my
`
`education and experience in greater detail in my CV, attached as Appendix B.
`
`14. For further technical background, I have also attached as Appendix C
`
`a presentation that I gave in 2009 that summarizes technologies for enterprise
`
`mobility and empowering the mobile workforce.
`
`V. LEGAL STANDARDS
`15.
`Intellectual Ventures’ attorneys have informed me that Petitioner in
`
`this proceeding is asserting that the challenged claim is unpatentable because of
`
`obviousness. Intellectual Ventures’ attorneys have explained to me the legal
`
`standards that apply to Petitioner’s obviousness challenge. My understanding of
`
`those standards is described below. I am not an attorney, and I do not have formal
`
`training in the law regarding patents. I have used my understanding of the
`
`following legal principles set forth in this section in reaching my opinions.
`
`16.
`
`I understand that a claim is unpatentable as obvious if the differences
`
`between the claim and the prior art are such that the subject matter as a whole
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`
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`Exhibit 2010 Page 8
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`would have been obvious at the time the invention was made to a person having
`
`ordinary skill in the art to which the subject matter pertains at the time of the
`
`invention.
`
`17.
`
`I understand that obviousness is a question of law based on underlying
`
`factual issues. Those factual issues are (1) the scope and content of the prior art;
`
`(2) differences between the prior art and the claimed invention as a whole; (3) the
`
`level of ordinary skill in the art at the time the invention was made; and (4)
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`objective indicia of non-obviousness.
`
`18.
`
`I understand that an obviousness case based on modifying or
`
`combining one or more prior art references requires the petitioner to show that a
`
`person of ordinary skill in the art would have had a reason to modify or combine
`
`those prior art references to achieve the claimed invention.
`
`19.
`
`I understand that example reasons to combine or modify prior art
`
`references that may support a conclusion of obviousness include combining prior
`
`art elements according to known methods to yield predictable results, simple
`
`substitution of one known element for another to obtain predictable results; use of
`
`a known technique to improve similar techniques; combining elements in a way
`
`that would be “obvious to try” where there exists a finite number of identified,
`
`predictable solutions and a reasonable expectation of success; design incentives or
`
`market forces that would prompt variations of known work if those variations were
`
`
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`predictable to a person of ordinary skill in the art; a teaching, suggestion, or
`
`motivation in the prior art to combine or modify prior art references to arrive at the
`
`claimed subject matter; and optimization of a recognized result-effective variable
`
`by a person of ordinary skill in the art if that optimization would be routine.
`
`20.
`
`I understand that there are also reasons that would prevent a person of
`
`ordinary skill in the art from modifying or combining prior art references.
`
`Examples of prior art references that a person of ordinary skill in the art would not
`
`combine or modify to achieve the claimed invention include prior art references
`
`that teach away from one another; prior art references that teach away from the
`
`claimed invention; prior art references whose combination or modification would
`
`change the principle of operation of either prior art reference; and prior art
`
`references whose combination or modification would render them inoperable or
`
`unsuitable for their intended purpose.
`
`21.
`
`I understand that in determining whether a person of ordinary skill in
`
`the art would combine or modify prior art references, the entire contents of each
`
`prior art reference must be considered, including parts of those references that
`
`would suggest against the proposed combination or modification.
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`
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`VI. LEVEL OF ORDINARY SKILL IN THE ART
`22.
`I have been informed by Intellectual Ventures’ attorneys that
`
`
`
`obviousness is considered from the perspective of a person of ordinary skill in the
`
`art at the time of the invention.
`
`23.
`
`I understand that several factors are considered in determining the
`
`level of ordinary skill in the art, including the educational level of active workers
`
`in the field, the types of problems encountered in the art, the nature of prior art
`
`solutions to those problems, prior art patents and publications, the activities of
`
`others, the sophistication of the technology involved, and the rapidity of
`
`innovations in the field.
`
`24.
`
`I have been informed by Intellectual Ventures’ attorneys that the ’900
`
`patent has an effective filing date of January 9, 1998. Accordingly, my analysis in
`
`this case is based on the perspective of a person of ordinary skill in the art as of
`
`that date. I understand that Petitioner may dispute the effective filing date of
`
`the ’900 patent and argue that it is January 9, 1999. However, my analysis herein
`
`would not change if the effective filing date of the ’900 patent is considered to be
`
`January 9, 1999.
`
`25.
`
`I understand that Petitioner has asserted that a person of ordinary skill
`
`at the time of the invention of the ’900 patent would have held at least a Bachelor’s
`
`Degree in Electrical Engineering, Computer Engineering, Computer Science, or
`
`
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`the equivalent, and two or more years of industry experience in the field of
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`computer networking generally,
`
`and wireless networking or mobile
`
`communications specifically, or the academic equivalent thereof. Petitioner has
`
`asserted that such a person would have been familiar with the components,
`
`methods, and protocols used at the time of the invention to communicate between a
`
`mobile field unit and an enterprise computing system.
`
`26.
`
`I do not make any assertions regarding whether Petitioner’s asserted
`
`level of skill in the art is correct. Rather, solely for purposes of this declaration, I
`
`have adopted Petitioner’s proposed level of skill in the art.
`
`27.
`
`I had sufficient education and experience to qualify as a person of
`
`ordinary skill in the art as of January 9, 1998 and as of January 9, 1999.
`
`VII. OVERVIEW OF THE ’900 PATENT
`28. The ’900 patent is titled “Mobile Crew Management System for
`
`Distributing Work Order Assignments to Mobile Field Crew Units.”
`
`29. The ’900 patent generally relates to “management information
`
`systems and more particularly to automated systems and methods for work order
`
`assignment and field communication.” (Ex. 1001, at 1:12-15.)
`
`30. The ’900 patent seeks to improve problems faced by businesses that
`
`“deploy numerous employees over a wide geographic area to service a dispersed
`
`infrastructure or client base” particularly as it relates to the “cumbersome task of
`
`
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`Exhibit 2010 Page 12
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`communicating work assignments and related data to personnel that are dispersed
`
`in the field.” (Ex. 1001, at 1:18-23.)
`
`31. As the ’900 patent explains, older approaches for distributing work
`
`assignments to field personnel included telephone or fax, both of which suffer from
`
`limitations on the amount of information that could be conveyed. (Ex. 1001, at
`
`1:52-65.)
`
`32. The ’900 patent solves that problem and others by providing “two
`
`way data communication between field personnel and a central office…whereby
`
`tasks can be assigned and automatically communicated…with little or no
`
`dispatcher intervention,” allowing field personnel to access “on-line the most up-
`
`to-date data related to the work order,” as well as allowing field personnel to
`
`“update system records to reflect physical changes resulting from their work as
`
`well as…to reflect changed work order status.” (Ex. 1001, at 2:5-15.)
`
`33. As one example, the ’900 patent provides a system comprising “an
`
`enterprise computing system, a mobile field unit, and wireless communication
`
`network which supports terminal control protocol/internet protocol (TCP/IP).”
`
`(Ex. 1001, at 2:24-27.) The enterprise computing system comprises application
`
`programs for assigning and managing work orders, local area network for
`
`connecting servers, and a gateway to a wireless network, and the mobile field unit
`
`
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`Exhibit 2010 Page 13
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`comprises a computing device and modem for communication over the wireless
`
`network to the enterprise computing system. (Ex. 1001, at 2:27-32.)
`
`VIII. OVERVIEW OF THE INSTITUTED GROUND
`34.
`I understand that the Board instituted trial on whether Claim 1 is
`
`obvious over Storch and Butler. I discuss Storch and Butler below.
`
`A. Overview Of Storch
`
`35. Storch, titled “Method and System for Processing A Service Request
`
`Relating To Installation, Maintenance, Or Repair Of Telecommunications Services
`
`Provided To A Customer Premises” issued on July 6, 1999 from an application
`
`filed on February 27, 1996. (Ex. 1002.) When issued, it was assigned to
`
`Southwestern Bell Telephone Company. (Id.)
`
`36. Storch is directed to systems and methods “for processing a service
`
`request for installation, maintenance or repair of a local loop maintained by a
`
`telecommunications company and providing locally switched service to a customer
`
`premise.” (Ex. 1002, at Abstract.)
`
`37. Storch describes the limitations of prior art telecommunication
`
`systems and methods for installing amplifiers to maintain loop loss within a
`
`desired range at the central office that often require significant space and elaborate
`
`cooling mechanisms and processing those service requests. Some of those
`
`
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`Exhibit 2010 Page 14
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`limitations included the extended time to process a service order using the prior art
`
`design processes. (Ex. 1002, at 2:36-40, 2:60-65, 3:14-44.)
`
`38. Storch attempts to address those limitations by providing improved
`
`line conditioning termination equipment at the customer premises and addressing
`
`how to handle service requests relating to installing, maintaining, or repairing the
`
`improved equipment. (Ex. 1002, at 5:11-15, 5:32-38.)
`
`39.
`
`In Storch, technicians carry “technician access units” (referred to as
`
`“TAUs”), by which
`
`they may request
`
`jobs from
`
`the Work and Force
`
`Administration/Dispatch Out (“WFA/DO”) dispatching system accessed through
`
`the technician access system (referred to as “TAS”). (Ex. 1002, at 26:27-37,
`
`27:19-25, 36:64-37:5, 71:28-36, 72:24-32.)
`
`B. Overview Of Butler
`
`40. Butler, titled “Telephone Technician’s Terminals With Auto-Selection
`
`of Dial Pulse On DTMF Signaling,” issued on May 1, 1990 from an application
`
`filed on June 2, 1989. (Ex. 1003.) Butler is assigned to Communications
`
`Technology Corporation. (Id.)
`
`41. Butler is generally directed to telephone equipment for technicians to
`
`communicate with a central maintenance office. (Ex. 1003, at 1:15-20.)
`
`42.
`
`In particular, Butler attempts to improve existing technician terminals
`
`by disclosing a “terminal that is capable of handling voice and/or data
`
`
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`Exhibit 2010 Page 15
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`communication with any of several centralized technician access systems.” (Ex.
`
`1003, at 1:62-66.) Butler’s craft technician terminal is capable of communicating
`
`data using dual tone multi-frequency and/or ASCII code to the technician access
`
`system. (Ex. 1003, at 2:6-11.) To communicate data, Butler’s craft technician
`
`terminal “is connected to the telephone line in conventional manner in
`
`communication with the telephone access network.” (Ex. 1003, at Abstract.)
`
`43.
`
`In Butler, like in Storch, technicians use craft technician terminals in
`
`order to request assignments from the network. More specifically, in Butler, a
`
`technician connects a craft technician terminal to a landline phone cable and dials
`
`the technician access network, then may request an assignment. (Ex. 1003, at
`
`1:64-2:5, 7:6-19, 8:49:66.) The connections that Butler’s craft technician terminal
`
`employs to connect to landline phones are shown in Figs. 2B and 6B of Butler.
`
`Specification of Butler
`“The terminal 40 is enclosed in a
`rectangular case 42 which is pocket-
`sized and adapted for hand-held
`operation. A pair of RJ-11 connector
`plugs 44 and 46 are provided in an
`end panel to provide interconnection.”
`(Ex. 1003, at 4:9-14.)
`
`Figure
`
`
`(Ex. 1003, at Fig. 2B (annotations added).)
`
`
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`Exhibit 2010 Page 16
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`Figure
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`
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`Case IPR2017-00741
`U.S. Patent No. 6,633,900
`Specification of Butler
`“The terminal 180 is enclosed in
`shock-mounting within a rectangular
`case 182 having a flat front face 184.
`External connection is made via a
`standard RJ-11C
`connector 186
`located in one side wall of the case
`182.” (Ex. 1003, at 9:63-66.)
`
`
`(Ex. 1003, at Fig. 6B (annotations added).)
`
`
`IX. SUMMARY OF OPINIONS
`44.
`It is my opinion that claim 1 of the ’900 patent is not obvious over
`
`Storch and Butler because Storch and Butler do not have a “mobile field unit.”
`
`The below table summarizes my opinions about the term “mobile field unit” in
`
`claim 1, and lists where those opinions are discussed in detail in my declaration.
`
`Section
`X.A
`
`X.B
`
`X.C
`
`X.D
`
`Opinions About “Mobile Field Unit”
`A “mobile field unit” is an essential part of the invention of the ’900
`patent.
`The broadest reasonable interpretation of “mobile field unit” as that
`term is used in claim 1 of the ’900 patent is “computing device that
`communicates over a wireless network.”
`Storch and Butler do not disclose or render obvious a computing device
`that communicates over a wireless network.
`Because Storch and Butler’s devices cannot communicate unless
`tethered to a fixed land line, Storch and Butler do not disclose or render
`obvious a “mobile field unit.”
`
`45.
`
`It is also my opinion that claim 1 of the ‘’900 patent is not obvious
`
`
`
`over Storch and Butler because a person of ordinary skill in the art would not have
`
`
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`Exhibit 2010 Page 17
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`combined Storch and Butler as Petitioner has proposed. Specifically, a person of
`
`ordinary skill in the art would not have combined Storch and Butler such that the
`
`combined system first sends a short job message to a technician as in Butler, then
`
`sends a detailed service order to the technician as in Storch. Petitioner’s proposed
`
`combination is needlessly inconvenient and time-consuming for the technician. I
`
`discuss that opinion in detail in Section XI.
`
`X. OPINIONS ABOUT “MOBILE FIELD UNIT”
`A. Claim 1 Requires A “Mobile Field Unit,” Which Is An Essential
`Part Of The Invention Of The ’900 Patent.
`
`46. Claim 1 requires at least one mobile field unit: “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 . . . .”
`
`(Ex. 1001, at cl. 1.)
`
`47. The specification describes mobile field units as a key part of the
`
`invention of the ’900 patent:
`
`- “Briefly, the present invention provides a system for assigning
`work orders, communicating work orders to deployed field
`personnel, and communicating at the request of field personnel,
`up-to-date data related to an assigned work order. The system
`comprises an enterprise computing system, a mobile field unit, and
`wireless communication network which supports terminal control
`protocol/internet protocol (TCP/IP).” (Ex. 1001, at 2:20-27
`(emphasis added).)
`
`
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`Exhibit 2010 Page 18
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`Case IPR2017-00741
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`U.S. Patent No. 6,633,900
`- “Thus, as described above the present invention provides systems
`and methods for low-cost, timely, two-way communications
`between a central enterprise systems and geographically
`distributed field personnel. The system comprises an enterprise
`computing system, a wireless network, and a mobile field unit.”
`(Id. at 14:45-50 (emphasis added).)
`
`
`
`48. The steps of claim 1 involving communicating with the field crew
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`also require at least one mobile field unit. In the ’900 patent, field crews carry
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`mobile field units. (Ex. 1001, at 3:38-42, 8:66-9:2.) “Each field crew is assigned a
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`mobile field unit 52.” (Id. at 4:35.) For example, claim 1, step (B) is “notifying
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`the field crew of the assignment.” The specification explains that a mobile field
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`unit is used to notify the field crew of the assignment: “At step 302, the field crew
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`is notified of the assignment via mobile field unit 52.” (Ex. 1001, at 9:4-5.)
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`49. Finally, the use of a mobile field unit as opposed to voice or fax
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`systems is one of the key improvements that the ’900 patent makes to empower the
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`mobile work force. As the ’900 patent explains, in previous approaches,
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`“field personnel and centralized dispatching operations
`communicate by two-way voice systems such as wireless
`phone or radio. Such systems allow for communication
`of voice and in some cases, with the advent of fax
`machines, data. But by either voice or fax, the amount
`and type of information that can be easily communicated
`to field personnel is limited. Indeed, while all of the
`
`
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`Exhibit 2010 Page 19
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`

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`Case IPR2017-00741
`
`U.S. Patent No. 6,633,900
`relevant data necessary for completing a task may be
`located in a central office, very little of it can be
`communicated to field personnel. For this reason, field
`personnel carry with them information resources such as
`maps and data sheets. Unfortunately, these often quickly
`become outdated which can lead to a dangerous work
`environment for field personnel.” (Ex. 1001, at 1:52-65.)
`
`
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`50. The ’900 patent overcomes the disadvantages of those previous fax
`
`and voice systems by enabling field crews to access the information resources at
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`the enterprise computing system via the mobile field units that they carry: “In
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`addition, mobile field crews can access information resources at the central
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`operations level including work order and mapped vehicle location data and other
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`pertinent information.” (Id. at 14:57-60.)
`
`B.
`
`The Broadest Reasonable Interpretation Of “Mobile Field Unit”
`In Claim 1 Of The ’900 Patent Is “Computing Device That
`Communicates Over A Wireless Network.”
`
`51. The specification of the ’900 patent, in the summary of the invention,
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`defines a mobile field unit as follows: “A mobile field unit comprises a computing
`
`device and modem for communicating over the wireless network to the enterprise
`
`computing system.” (Ex. 1001, at 2:32-34.) Similarly, the abstract of the ’900
`
`patent states, “A mobile field unit comprises a computing device and modem for
`
`communicating over the wireless network to the enterprise computing system.”
`
`
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`Exhibit 2010 Page 20
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`

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`Case IPR2017-00741
`
`U.S. Patent No. 6,633,900
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`(Id. at Abstract.) That definition of “mobile field unit” indicates that a mobile field
`
`unit must be able to communicate wirelessly over a wireless network.
`
`52. The specification of the ’900 patent also consistently defines the
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`invention of the ’900 patent to involve a wireless network, as shown below:
`
`- “Briefly, the present invention provides a system for assigning
`work orders, communicating work orders to deployed field
`personnel, and communicating at the request of field personnel,
`up-to-date data related to an assigned work order. The system
`comprises an enterprise computing system, a mobile field unit, and
`wireless communication network which supports terminal control
`protocol/internet protocol (TCP/IP).” (Ex. 1001, at 2:20-27.)
`- “The present invention provides a multi-crew management system.
`More particularly the management system is an automated system
`for the distribution of work orders and related materials to field
`personnel dispersed over a wide geographic area. A work order,
`which may be any type of description of a particular task, are
`assigned using a centralized enterprise computing system and are
`communicated over a wireless network to field personnel having
`mobile computing units.” (Id. at 3:34-42.)
`- “FIG. 1 graphically depicts a system in accordance with the
`invention. As shown, the inventive system comprises enterprise
`computing system 50, mobile field unit 52, and wireless
`communication network 54 operably connecting the two.” (Id. at
`3:50-54.)
`
`
`
`Exhibit 2010 Page 21
`
`

`

`Case IPR2017-00741
`
`U.S. Patent No. 6,633,900
`- “Thus, as described above the present invention provides systems
`and methods for low-cost, timely, two-way communications
`between a central enterprise systems and geographically
`distributed field personnel. The system comprises an enterprise
`computing system, a wireless network, and a mobile field unit.”
`(Id. at 14:45-48.)
`
`
`
`53. Consistent with the specification’s description of the invention as
`
`involving a wireless network, all of the figures of the ’900 patent that depict a
`
`mobile field unit (indicated by reference number 52) communicating with the
`
`enterprise computing system (indicated by reference number 50) depict those
`
`communications as occurring over a wireless network (indicated by reference
`
`number 54). Figs . 1, 2, 4, and 17 of the ’900 are reproduced below with
`
`annotations indicating the wireless network in each of those figures.
`
`///
`
`
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`Exhibit 2010 Page 22
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`Case IPR2017-00741
`U.S. Patent No. 6,633,900
`
`
`
`
`
`Enterptise
`
`Mobile Field
`
`.mmNSwNW
`
`Unit
`
`(Ex. 1001, at Fig. 1.)
`
`
`
`
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`Exhibit 2010 Page 23
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`Case IPR2017-00741
`U.S. Patent No. 6,633,900
`
`
`
`
`
`Mapping Plug-in
`
`and/or Applet
`
`(Ex. 1001, at Fig. 2.)
`
`
`
`
`
`
`
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`Exhibit 2010 Page 24
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`Case IPR2017-00741
`U.S. Patent No. 6,633,900
`
`
`
`
`
`Mappir; Plug-in
`
`and/or Apple1
`
`(Ex. 1001, at Fig. 4.)
`
`
`
`
`
`
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`Exhibit 2010 Page 25
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`Case IPR2017-00741
`U.S. Patent No. 6,633,900
`
`
`
`
`
`(Ex. 1001, at Fig. 17.)
`
`
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`54.
`
`I also note that the mobile field unit 52 in Figs. 1, 2, 4, and 17 is
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`connected by a lightning bolt to the wireless network 54. Lightning bolts are
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`
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`Exhibit 2010 Page 26
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`Case IPR2017-00741
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`U.S. Patent No. 6,633,900
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`commonly used in the electronic communications field to indicate wireless
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`communications. In fact, one of my own patents, U.S. Patent No. 7,668,201 (Ex.
`
`2012) uses lightning bolts to depict devices wirelessly communicating with a
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`wireless local area network (WLAN) access point.
`
`(Ex. 2012, at Fig. 1; 3:24-33.)
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`55. Returning to the ’900 patent, wireless network 54 is des