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`
`DEFENDANTS’ INVALIDITY CONTENTIONS
`APPENDIX C01
`
`Intellectual Ventures II LLC, v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG (E.D. TX)
`
`
`
`Exhibit 2104 Page 1
`
`IV Exhibit 2104
`FedEx v. IV
`Case IPR2017-02039
`
`

`

`
`
`
`
`
`
`INVALIDITY CHART FOR U.S. PATENT NO. 7,199,715
`
`AND
`
`UNITED STATES PATENT NO. 7,312,752 TO SMITH ET AL. (“SMITH”)
`
`As shown below, Smith anticipates U.S. Patent No. 7,199,715 (“’715 patent”) claims 1, 4, 5, 7, 9, 11, 14, 15, 17, 19, 22, 23, and 25.
`Additionally or alternatively, Smith renders obvious the ’715 patent, either alone or in combination with one or more of the following:
`- U.S. Patent No. 8,321,302 (“Bauer”) (Appendix C02)
`- U.S. Patent No. 6,909,356 (“Brown”) (Appendix C03)
`- U.S. Patent No. 5,682,142 (“Loosmore”) (Appendix C10)
`- U.S. Patent App. Pub. No. 2001/0051905 (“Lucas”) (Appendix C11)
`The above reference combinations are exemplary only and are not intended to be limiting. For example, Smith also renders obvious
`the ’715 patent in combination with one or more of the other prior art provided in the claim charts in Appendices C01-C26 and/or the
`prior art provided in Appendix F.
`’715 Patent Claims
`1. A method of tracking
`tags at several successive
`points of a business
`process, said method
`comprising:
`
`Disclosure by Smith and/or Other Prior Art
`Smith discloses a method of tracking tags at several successive points of a business process. For
`example, Smith discloses a position tracking system for tracking objects in various facilities and
`environments using tags. See, e.g., Smith, 2:11-13; 4:25-30; 6:49-59; 7:16-17; 8:20-37; and 12:13-
`30.
`
`(2:11-13) An accurate position location and tracking system suitable for a wide range of
`facilities in variable environments is disclosed.
`(4:25-30) In the example embodiment, object 170 may be any object or asset for which
`tracking is desired. An object 170 may also be referred to herein as a mobile device or a tag.
`A tag may be a device that is attached to the object for which tracking is desired, example
`embodiments of which are detailed below.
`three-dimensional space, makes
`(6:49-59) An object 170, within
`the mappable
`measurements from one or more beacon emitters 130, or other sources, such as noise source
`150 or jammer 140. Upon some triggering event, i.e. motion, sensor input, timer expiration,
`Intellectual Ventures II LLC v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG
`Defendants' Invalidity Contentions, Appendix C01
`
`2
`
`Exhibit 2104 Page 2
`
`

`

`
`
`
`
`’715 Patent Claims
`
`Disclosure by Smith and/or Other Prior Art
`direction from a controlling device (such as a positioning engine 110), or a condition being
`met in accordance with one or more parameters (which may be pre-defined, or updated and
`transmitted to the object 170), the object 170 may transmit the measurement information
`across a network. The object 170 may also transmit information about the triggering event
`across a network.
`(7:16-18) RF data from each device is measured and transmitted to positioning engine 110
`(also referred to as a Location Positioning Engine (LPE)).
`(8:20-37) In this example, the APs transmit beacons periodically, for example, every 100
`ms. The network monitors regularly (e.g. once a minute) listen for these beacons, measure
`the signal strength from them, and transmit this information (AP ID and signal strength) to
`the Location Positioning Engine. The LPE builds a model of the RF environment using a
`Radial Basis Function, although other neural network algorithms may be employed. In this
`example, some tags are configured to transmit location data when they stop moving. Other
`tags are configured to transmit location data on regular intervals (e.g. once per day). This
`configuration can be changed by a user on a remote machine. A configuration may be
`applied to multiple tags. When the battery on a tag falls below a predefined threshold the
`tag wakes up and transmits an alert message to a user. The tags also transmit alert messages
`when detached from assets. These aspects, along with many others, are detailed further
`below.
`(12:13-30) Various applications may interface with a location positioning engine such as
`position engine 110. Applications may communicate via any one of the numerous networks
`described above or may have alternate connections with the positioning engine. Various
`applications may produce queries and receive responses regarding the location of one or
`more assets to be tracked within the system. In addition, a positioning engine may be
`programmed to generate certain alarms based on predefined rule sets. For example, when
`an asset of a certain class travels outside a predefined area, an alarm may be generated to
`notify one or more applications (including an application for notifying an end user) that the
`alarm condition has been triggered. Various applications may also have such rules built-in
`for performing tracking, information gathering, location determination, and other activities
`in a separate application. In an alternate embodiment the positioning engine may be
`Intellectual Ventures II LLC v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG
`Defendants' Invalidity Contentions, Appendix C01
`
`
`
`3
`
`Exhibit 2104 Page 3
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`

`

`
`
`
`
`’715 Patent Claims
`
`attempting to read each
`tag at each successive
`point;
`
`Disclosure by Smith and/or Other Prior Art
`programmable to perform these tasks as well.
`Smith discloses positioning engine 110, and associated applications, track emitted signals at certain
`stages of an object’s progression through the facilities’ process. See, e.g., Smith 1:27-30; 4:25-30;
`7:13-23; 8:20-37; 11:15-45; and Figure 4.
`(1:27-30) Security applications may include locating missing equipment, or preventing the
`loss of equipment.
`(4:25-30) In the example embodiment, object 170 may be any object or asset for which
`tracking is desired. An object 170 may also be referred to herein as a mobile device or a tag.
`A tag may be a device that is attached to the object for which tracking is desired, example
`embodiments of which are detailed below.
`(7:13-23) To determine the location of devices 170 in any given facility, the radio
`frequency (RF) environment in the facility may be measured. During this calibration
`procedure, one or more network monitors are placed at known locations in the facility. RF
`data from each device is measured and transmitted to positioning engine 110 (also referred
`to as a Location Positioning Engine (LPE)). A network monitor is also referred to as a
`conditioner, sensor, calibrator, or calibration device. The RF data is recorded along with the
`actual location of the network monitor to produce an RF data map of the environment. Such
`a data map is one example of a mapped space.
`(8:20-37) In this example, the APs transmit beacons periodically, for example, every 100
`ms. The network monitors regularly (e.g. once a minute) listen for these beacons, measure
`the signal strength from them, and transmit this information (AP ID and signal strength) to
`the Location Positioning Engine. The LPE builds a model of the RF environment using a
`Radial Basis Function, although other neural network algorithms may be employed. In this
`example, some tags are configured to transmit location data when they stop moving. Other
`tags are configured to transmit location data on regular intervals (e.g. once per day). This
`configuration can be changed by a user on a remote machine. A configuration may be
`applied to multiple tags. When the battery on a tag falls below a predefined threshold the
`tag wakes up and transmits an alert message to a user. The tags also transmit alert messages
`when detached from assets. These aspects, along with many others, are detailed further
`Intellectual Ventures II LLC v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG
`Defendants' Invalidity Contentions, Appendix C01
`
`
`
`4
`
`Exhibit 2104 Page 4
`
`

`

`
`
`
`
`’715 Patent Claims
`
`Disclosure by Smith and/or Other Prior Art
`
`below.
`(11:15-45) FIG. 4 depicts example method 400 for creating a mapped space, such as for
`example system 100. This method may be applied to continuously (including periodically
`or intermittently) updating the mapped space. The process begins in block 410, where
`beacons are transmitted throughout the facility or area in which objects are to be tracked.
`Note that each beacon need not be receivable throughout the entire facility, but a facility
`may incorporate multiple beacons, one or more of which generally should be receivable at
`each location within the desired tracking area. Beacons may be transmitted as known
`signals, and may be any other noise source or jammer signal as well, as described above. In
`block 420, various devices throughout the facility, such as network monitors 120, measure
`the beacons or mobile devices to be tracked 170. The beacons may be measured at network
`monitors, static mobile stations, access points, beacon emitters, any device containing a
`combination of one or more of the above, etc. In block 430, measurements are transmitted
`to a positioning engine such as positioning engine 110. The transmission may be over a
`wireless link, through a wired connection, communicated through a power grid, any
`combination thereof, or any other type of communication link. In block 440, the mapped
`space is updated in response to the received measurements. The process may then repeat
`and may be repeated for as long as tracking is desired.
`(Figure 4)
`Smith discloses a positioning engine 110 that populates database 1710 with calibration points, past
`and present location estimates for objects, functions, parameters, time stamps and other such data
`collected from object 170 readings. See, e.g., Smith 7:11-23; 11:15-32; 20:5-15; 25:32-40; Figure
`4; and Figure 17.
`(7:11-23) To determine the location of devices 170 in any given facility, the radio
`frequency (RF) environment in the facility may be measured. During this calibration
`procedure, one or more network monitors are placed at known locations in the facility. RF
`data from each device is measured and transmitted to positioning engine 110 (also referred
`to as a Location Positioning Engine (LPE)). A network monitor is also referred to as a
`conditioner, sensor, calibrator, or calibration device. The RF data is recorded along with the
`actual location of the network monitor to produce an RF data map of the environment. Such
`Intellectual Ventures II LLC v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG
`Defendants' Invalidity Contentions, Appendix C01
`
`populating a database
`with information
`corresponding to the
`reading of each tag at
`each successive point and
`the time of each reading;
`
`
`
`5
`
`Exhibit 2104 Page 5
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`

`

`
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`
`
`’715 Patent Claims
`
`Disclosure by Smith and/or Other Prior Art
`a data map is one example of a mapped space.
`(11:15-32) FIG. 4 depicts example method 400 for creating a mapped space, such as for
`example system 100. This method may be applied to continuously (including periodically
`or intermittently) updating the mapped space. The process begins in block 410, where
`beacons are transmitted throughout the facility or area in which objects are to be tracked.
`Note that each beacon need not be receivable throughout the entire facility, but a facility
`may incorporate multiple beacons, one or more of which generally should be receivable at
`each location within the desired tracking area. Beacons may be transmitted as known
`signals, and may be any other noise source or jammer signal as well, as described above. In
`block 420, various devices throughout the facility, such as network monitors 120, measure
`the beacons or mobile devices to be tracked 170. The beacons may be measured at network
`monitors, static mobile stations, access points, beacon emitters, any device containing a
`combination of one or more of the above, etc.
`(20:5-15) In yet another alternative, a mobile device or tag may measure and generate
`positioning information periodically, storing those results for transmission at a later time.
`Those results may be stored in accordance, or along with, an associated time stamp. The
`results may also be stored with corresponding measurements of other environment
`parameters such as temperature, humidity, ambient RF noise, and the like. The sets of
`generated positioning information, along with any associated data, may be transmitted
`together after motion has been detected (or based upon an alternate triggering event).
`(25:32-42) FIG. 17 depicts an example embodiment of a positioning engine 110. Model
`1720 receives tag data as well as other data, examples of which are detailed above, and is
`used to determine a position for the particular tag in accordance with data stored in database
`1710. A database may include, but is not limited to, known locations of calibration points,
`both static and dynamic, past and present location estimates for one or more objects,
`functions, parameters, etc. for use in position location, and may include any media storage
`such as a hard disk, memory, removable media, floppy disks, CD-ROMS, etc.
`(Figure 4)
`(Figure 17)
`Intellectual Ventures II LLC v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG
`Defendants' Invalidity Contentions, Appendix C01
`
`
`
`6
`
`Exhibit 2104 Page 6
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`

`

`
`
`
`
`’715 Patent Claims
`modifying part of the
`information in the
`database as a function of
`other information in the
`database; and
`
`Disclosure by Smith and/or Other Prior Art
`Smith discloses modifying part of the information in the database as a function of other information
`in the database. In particular, Smith discloses collecting data from object 170 tags, analyzing the
`data with positioning engines 110, storing the data in database 1710, constructing a modeled
`mapped space from the information stored in database 1710, and modifying the stored model
`parameters. See, e.g., Smith 20:5-15; 25:32-40; 25:54-67; 27:25-36; 27:60-67; 28:1-5; 28:35-37;
`and Figure 17.
`(20:5-15) In yet another alternative, a mobile device or tag may measure and generate
`positioning information periodically, storing those results for transmission at a later time.
`Those results may be stored in accordance, or along with, an associated time stamp. The
`results may also be stored with corresponding measurements of other environment
`parameters such as temperature, humidity, ambient RF noise, and the like. The sets of
`generated positioning information, along with any associated data, may be transmitted
`together after motion has been detected (or based upon an alternate triggering event).
`(25:32-42) FIG. 17 depicts an example embodiment of a positioning engine 110. Model
`1720 receives tag data as well as other data, examples of which are detailed above, and is
`used to determine a position for the particular tag in accordance with data stored in database
`1710. A database may include, but is not limited to, known locations of calibration points,
`both static and dynamic, past and present location estimates for one or more objects,
`functions, parameters, etc. for use in position location, and may include any media storage
`such as a hard disk, memory, removable media, floppy disks, CD-ROMS, etc.
`(25:54-67) The space is updated by parameter calculation block 1730 which receives
`network monitor data, as well as other data, as described above. In association with model
`1720, parameters for use with the model may be computed or refined based on the network
`monitor data, in association with the known location for any given network monitor. For
`example, a position location model 1720 using the latest calculated parameters receives
`measured data from a network monitor and determines a location therefrom. If that position
`is different from the known location, the parameters may be updated so that the model
`returns the correct location for that network monitor (or, the overall error may be optimized
`according to some method, such as minimizing least squared error).
`(27:25-36) Each of these methods may return a list of the calibration points nearest (i.e.
`Intellectual Ventures II LLC v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG
`Defendants' Invalidity Contentions, Appendix C01
`
`
`
`7
`
`Exhibit 2104 Page 7
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`

`

`
`
`
`
`’715 Patent Claims
`
`using the modified
`information to track the
`tags through the business
`process.
`
`Disclosure by Smith and/or Other Prior Art
`most accurately representing in signal space) the mobile data. This list may include the
`weighting factor of each calibration point, representing how close the calibration point is to
`the mobile data. To compute the actual location of the mobile device, the positioning engine
`may compute the weighted average of the locations of each calibration point based on their
`weighting factor. In this manner a location coordinate may be obtained. As described
`above, various position location modeling techniques may be deployed in embodiments
`described throughout this specification.
`(27:60-28:5) The system may be retrained periodically based on input data from the
`network monitors. This retraining may record data from the network monitors for a period
`of time and retrain the system using this set of data. In one embodiment, data from the
`network monitors is recorded for a time period and the model is retrained using a
`combination of this set of data and the set of data previously used to retrain the model. In
`this manner, the system is constantly adjusting for changes in the RF environment and
`updating the model appropriately. The combination of old data and new data may be
`accomplished using an averaging technique, Bayesian Filtering, Kalman Filtering, Hidden
`Markov Modeling, or other statistical methods known in the art.
`(28:35-37) In positioning systems, this method is used to determine a location (a state) from
`the information received from the mobile devices and calibration points.
`(Figure 17)
`Smith discloses using the modified information to track the tags through the business process. See,
`e.g., Smith, 1:27-30; 4:25-30; 7:13-23; 8:20-37; 11:15-32; 25:32-42; 25:54-67; 27:25-36; 27:60-67;
`28:1-5; 28:35-37; Figure 4; and Figure 19.
`(1:27-30) Security applications may include locating missing equipment, or preventing the
`loss of equipment.
`(4:25-30) In the example embodiment, object 170 may be any object or asset for which
`tracking is desired. An object 170 may also be referred to herein as a mobile device or a tag.
`A tag may be a device that is attached to the object for which tracking is desired, example
`embodiments of which are detailed below.
`
`Intellectual Ventures II LLC v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG
`Defendants' Invalidity Contentions, Appendix C01
`
`
`
`8
`
`Exhibit 2104 Page 8
`
`

`

`
`
`
`
`’715 Patent Claims
`
`Disclosure by Smith and/or Other Prior Art
`(7:13-23) To determine the location of devices 170 in any given facility, the radio
`frequency (RF) environment in the facility may be measured. During this calibration
`procedure, one or more network monitors are placed at known locations in the facility. RF
`data from each device is measured and transmitted to positioning engine 110 (also referred
`to as a Location Positioning Engine (LPE)). A network monitor is also referred to as a
`conditioner, sensor, calibrator, or calibration device. The RF data is recorded along with the
`actual location of the network monitor to produce an RF data map of the environment. Such
`a data map is one example of a mapped space.
`(8:20-37) In this example, the APs transmit beacons periodically, for example, every 100
`ms. The network monitors regularly (e.g. once a minute) listen for these beacons, measure
`the signal strength from them, and transmit this information (AP ID and signal strength) to
`the Location Positioning Engine. The LPE builds a model of the RF environment using a
`Radial Basis Function, although other neural network algorithms may be employed. In this
`example, some tags are configured to transmit location data when they stop moving. Other
`tags are configured to transmit location data on regular intervals (e.g. once per day). This
`configuration can be changed by a user on a remote machine. A configuration may be
`applied to multiple tags. When the battery on a tag falls below a predefined threshold the
`tag wakes up and transmits an alert message to a user. The tags also transmit alert messages
`when detached from assets. These aspects, along with many others, are detailed further
`below.
`(11:15-32) FIG. 4 depicts example method 400 for creating a mapped space, such as for
`example system 100. This method may be applied to continuously (including periodically
`or intermittently) updating the mapped space. The process begins in block 410, where
`beacons are transmitted throughout the facility or area in which objects are to be tracked.
`Note that each beacon need not be receivable throughout the entire facility, but a facility
`may incorporate multiple beacons, one or more of which generally should be receivable at
`each location within the desired tracking area. Beacons may be transmitted as known
`signals, and may be any other noise source or jammer signal as well, as described above. In
`block 420, various devices throughout the facility, such as network monitors 120, measure
`the beacons or mobile devices to be tracked 170. The beacons may be measured at network
`
`Intellectual Ventures II LLC v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG
`Defendants' Invalidity Contentions, Appendix C01
`
`
`
`9
`
`Exhibit 2104 Page 9
`
`

`

`
`
`
`
`’715 Patent Claims
`
`Disclosure by Smith and/or Other Prior Art
`monitors, static mobile stations, access points, beacon emitters, any device containing a
`combination of one or more of the above, etc.
`(25:32-42) FIG. 17 depicts an example embodiment of a positioning engine 110. Model
`1720 receives tag data as well as other data, examples of which are detailed above, and is
`used to determine a position for the particular tag in accordance with data stored in database
`1710. A database may include, but is not limited to, known locations of calibration points,
`both static and dynamic, past and present location estimates for one or more objects,
`functions, parameters, etc. for use in position location, and may include any media storage
`such as a hard disk, memory, removable media, floppy disks, CD-ROMS, etc.
`(25:54-67) The space is updated by parameter calculation block 1730 which receives
`network monitor data, as well as other data, as described above. In association with model
`1720, parameters for use with the model may be computed or refined based on the network
`monitor data, in association with the known location for any given network monitor. For
`example, a position location model 1720 using the latest calculated parameters receives
`measured data from a network monitor and determines a location therefrom. If that position
`is different from the known location, the parameters may be updated so that the model
`returns the correct location for that network monitor (or, the overall error may be optimized
`according to some method, such as minimizing least squared error).
`(27:25-36) Each of these methods may return a list of the calibration points nearest (i.e.
`most accurately representing in signal space) the mobile data. This list may include the
`weighting factor of each calibration point, representing how close the calibration point is to
`the mobile data. To compute the actual location of the mobile device, the positioning engine
`may compute the weighted average of the locations of each calibration point based on their
`weighting factor. In this manner a location coordinate may be obtained. As described
`above, various position location modeling techniques may be deployed in embodiments
`described throughout this specification.
`(27:60-28:5) The system may be retrained periodically based on input data from the
`network monitors. This retraining may record data from the network monitors for a period
`of time and retrain the system using this set of data. In one embodiment, data from the
`network monitors is recorded for a time period and the model is retrained using a
`Intellectual Ventures II LLC v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG
`Defendants' Invalidity Contentions, Appendix C01
`
`
`
`10
`
`Exhibit 2104 Page 10
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`

`

`
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`
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`’715 Patent Claims
`
`4. The method of claim 1
`wherein the tags are
`associated with products
`which carry the tags, and
`wherein the products are
`handled in a supply chain
`during which the
`products and their tags
`pass several tag reading
`points, and further
`comprising adjusting the
`supply chain as a
`function of the modified
`information in the
`database.
`
`Disclosure by Smith and/or Other Prior Art
`combination of this set of data and the set of data previously used to retrain the model. In
`this manner, the system is constantly adjusting for changes in the RF environment and
`updating the model appropriately. The combination of old data and new data may be
`accomplished using an averaging technique, Bayesian Filtering, Kalman Filtering, Hidden
`Markov Modeling, or other statistical methods known in the art.
`(28:35-37) In positioning systems, this method is used to determine a location (a state) from
`the information received from the mobile devices and calibration points.
`(Figure 4)
`(Figure 19)
`Smith discloses the method of claim 1 wherein the tags are associated with products which carry
`the tags, and wherein the products are handled in a supply chain during which the products and
`their tags pass several tag reading points, and further comprising adjusting the supply chain as a
`function of the modified information in the database. See, e.g., Smith 2:11-13; 4:25-30; 6:43-45;
`11:7-14; 25:32-36; 25:54-56; and 31:28-30. Smith discloses an object 170 which may be a tag or
`device “that is attached to the object for which tracking is desired.” Id. at 4:25-29. In particular,
`“when an object 170 is tracked or located within the system, the measurements received from the
`object may be used to determine a location” of the associated product throughout the facility, or
`mapped space. Id. at 2:11-13 and 6:43-45. In addition, the mapped space itself “may be modified
`in response” to the sensor measurements from objects 170. Id. at 11:7-14.
`
`(2:11-13) An accurate position location and tracking system suitable for a wide range of
`facilities in variable environments is disclosed.
`(4:25-30) In the example embodiment, object 170 may be any object or asset for which
`tracking is desired. An object 170 may also be referred to herein as a mobile device or a tag.
`A tag may be a device that is attached to the object for which tracking is desired, example
`embodiments of which are detailed below.
`(6:43-45) Thus, when an object 170 is tracked or located within the system, the
`measurements received from the object may be used to determine a location in accordance
`
`Intellectual Ventures II LLC v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG
`Defendants' Invalidity Contentions, Appendix C01
`
`
`
`11
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`Exhibit 2104 Page 11
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`’715 Patent Claims
`
`5. The method of claim 4
`wherein adjusting the
`supply chain comprises
`varying the supply of
`additional products to the
`supply chain as a
`function of the modified
`information in the
`database.
`
`Disclosure by Smith and/or Other Prior Art
`with an updated or current measurement of the environment.
`(11:7-14) The mapped space may be modified in response to various changes and
`uncertainties in the environment. Then the measurements from the object 170 may be used
`to project into the modified space. This may be performed in addition to attempting to
`modify or compensate for environmental changes in measurements from an object 170.
`(25:32-36) FIG. 17 depicts an example embodiment of a positioning engine 110. Model
`1720 receives tag data as well as other data, examples of which are detailed above, and is
`used to determine a position for the particular tag in accordance with data stored in database
`1710.
`(25:54-56) The space is updated by parameter calculation block 1730 which receives
`network monitor data, as well as other data, as described above.
`(31:28-30) In addition to the techniques described herein, sensors may be deployed
`throughout a facility that detects the presence of a tracked asset as it passes.
`Smith discloses the method of claim 4 wherein adjusting the supply chain comprises varying the
`supply of additional products to the supply chain as a function of the modified information in the
`database. For instance Smith discloses an object 170, tag or device, attached to objects for tracking
`within the facility, or mapped space, which may be modified in response to the sensor
`measurements from objects 170. See, e.g., Smith 2:11-13; 4:25-30; 6:43-45; 11:7-14; 25:32-36;
`25:54-56; and 31:28-30.
`To the extent it is alleged that Smith does not expressly disclose varying the supply of additional
`products, it would have been obvious to one of ordinary skill in the art to combine the teachings of
`Smith and Bauer in order to vary the supply of additional products to the supply chain based on
`modified information in a database, such as to restock inventory to account for successfully
`delivered items. For instance, Bauer discloses varying the supply of additional products by adding
`products to the supply chain when IIMS 105 determines a product has reached a low stock level
`and takes steps to cause the restocking of depleted inventory items. See, e.g., Bauer 36:49-51; and
`36:55-61.
`(36:49-51) Environment 110-1 may also determine whether a number of items of any type
`
`Intellectual Ventures II LLC v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG
`Defendants' Invalidity Contentions, Appendix C01
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`12
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`Exhibit 2104 Page 12
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`’715 Patent Claims
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`Disclosure by Smith and/or Other Prior Art
`in inventory 170 is below a predetermined level (Step 520).
`(36:55-61) If so, (Step 520; YES), an appropriate item below stock level process may be
`performed (Step 530). This process may include providing an alert message to a user via an
`output device (e.g., display 204, a pager, cell phone, etc.) indicating which item type needs
`restocking and the location of the depleted items in environment 110-1.
`See also Brown 2:22-35; Loosmore 9:10-16; and Lucas ¶ [0082].
`(Brown 2:22-35) In another embodiment, the server computer system notifies a user
`through a network interface, telephone interface, or wireless interface of the movement of
`an object (and/or the association of the movement of the object with an identity). Such
`reports may be made for authorized and/or unauthorized movements. Objects may be
`automatically replenished or returned or a party may be billed as a result of the notification.
`For example, in one embodiment, the server computer system automatically notifies an
`organization’s pre-existing inventory control system that an object has been removed from
`a confined space (e.g., from inventory) by a particular entity. Based on this information, the
`inventory control system may automatically take steps to replenish the object that was
`removed.
`(Loosmore 9:10-16) With pre-determined parameters, when inventories fall below set
`levels, the system alerts the tag of a purchasing agent, to replenish stock of the identified
`item. When a production line goes down, or when urgent issues arise, the two-way paging
`ability of the tag significantly increases efficiency.
`(Lucas ¶ [0082]) While the present invention can monitor inventory use and automatically
`order new inventory when necessary, a customer may anticipate a need for additional
`inventory based on parameters outside the scope of the present invention. By way of
`example, without intending to limit the present invention, if the present invention is used in
`a hospital, and the Olympics was held in or near the city in which the hospital is located, a
`hospital administrator may foresee the need to order additional quantities of frequently used
`supplies. Client software can provide a customer with the ability to quickly place such
`orders.
`7. The method of claim 4 Smith discloses the method of claim 4 wherein adjusting the supply chain comprises adjusting the
`Intellectual Ventures II LLC v. FedEx Corp. et al.
`Civil Action No. 2:16-CV-980-JRG
`Defendants' Invalidity Contentions, Appendix C01
`
`
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`13
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`Exhibit 2104 Page 13
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`’715 Patent Claims
`wherein adjusting the
`supply chain comprises
`adjusting