Google Inc. v. Traffic Information LLC

Filing 50

Joint Statement of Claims Construction Chart. Filed by Google Inc.. (Attachments: # 1 Exhibit Exhibit A) (Markley, Julia)

Claim
u.s.6.466.862 1. A system for providing traffic information to a plurality of mobile users connected to a network, comprising:

lle Sta'tement tmnortance

EXHIBIT A bf Proposed Construction
Google "Traffic information" should be construed in the context of "traffic information representative of said signals transmitted by said traffic monitors" as we do below.

Tra*
.:::::::::::

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Inf.O. itio.a.=t=fugi

Traffic lnformation
Statement of lmportance
The accused product/system

The accused oroduct does not provide " lr affic information, " and thus does not meet this element as properly construed.

traffic information

provides information regarding traffic conditions, and therefore meets this element as properly construed.

Traffic Information
"traffi c information" means data regarding traffic conditions, which data can include, but is not limited to, the speed, velocity, motion, density, flow, frequency of vehicles on a road, and/or other data representative of the movement of vehicles on a road. Google A stationary device capable of determining the current speed, frequency, or flow of multiple vehicles traveling along a road

(a) a plurality of traffic monitors, each said traffic monitor comprising at least a detector and a transmitter, . .

traffic monitors

The accused product does not provide a stationary device capable of determining the current speed, frequency, or flow of multiple vehicles traveling along a road, and thus does not meet this eremeru as properly

traffic monitors

Traffic Information "traffic monitors" means any
device used to sense, measure, detect, and,/or determine vehicular movement and transmit and/or provide a signal representative vehicular movement.

The accused product/system includes devices used to sense, measure, detect, and/or determine vehicular movement and transmit and/or provide a signal representative of vehicular movement, and therefore meets this element as properly construed.

of

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Google Terms ldentified
. . . said detector providing a signal including data representative of vehicular movement and said transmitter transmittins said signals;

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,

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Proposed Construction Google
The current speed, frequency, or flow of multiple vehicles traveling along a road as detected by one or more

Traffic Information Terms ldentified
vehicular movement

The accused product does not provide a signal representative

ofthe current speed, frequency, or flow of multiple
vehicles traveling along a road, and thus does not meet this element as properly construed.

traffic monitors Traffic Information "Vehicular movement" means the velocity, speed, position, and/or change in position of a
vehicle.

.Traffic Information Statement of Importance The accused product/system includes devices that provide a signal representative ofthe velocity. speed, position, andlor change in position of a vehicle and therefore meets this element as properly
construed.

(b) a receiver, remotely located from said transmitter, that receives said signals transmitted by said traffic monitors: and (c) a computer system

Goosle No construction necessarv

comDuter svstem

Traffic Information
"computer system" means a computer or computers that receive data representative of vehicular movement from the traffic monitors and send traffic information representative of said signals transmitted by said traffrc monitors to the mobile user stations by way of the network.

The accused product/system includes a computer or computers that receive data representative of vehicular movement from the traffic monitors and sends traffic information representative of the signals transmitted by the traffic monitors to the mobile user stations by way of the network and therefore meets this element as properly construed.

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GooEIe Terms ldCntified

Google

Importance

Statementof
r,
,

'

Traffic lnformation Terms Identified
Google No construction necessary
interconnected

. . . interconnected with said receiver and said network:

Traffic Information
"interconnected" means the computer system facilitates the continuous or periodic movement of data from the receiver to the network. Google A mobile device, distinct from a traffic monitor, capable of determining and displaying traffic information

af fi.e_=Tn= ma.tie.=nStatement of Impoitance The accused product/system includes a computer system that facilitates the continuous or periodic movement of data from the receiver to the network and therefore meets this element as properly construed.

,,Jf

(d) a mobile user station connected to a global positioning system receiver, a display, and a communicating device; and

mobile user station

Google provides only the Nexus One mobile device and, therefore, the accused product cannot meet this element, as properly construed, as to mobile devices not supplied by

Traffic Information
"mobile user station" means an easily moving or movable device that can transmit data to and/or receive data from the network. The mobile user station may be a cellular phone or other handheld unit, or may be installed within a
car.

Goosle.

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Claim
t

j

(e) said computer systpm, in
response to a request

for

traffic information from one of said mobile user stations.

Google Statement of f mnortance The accused product provides information to the recipient after the recipient interacts with a device, and thus does not meet this element as properly construed.

Proposed Construction Google Should be construed as part of "providing in response thereto"

Traffic fnfoimation fermi
rn response to

Traffic Information "in response to" means that
the computer system, rather than only arbitrarily sending

traffic information
representative of said signals

transmitted by said traffic monitors, is capable of sending traffi c information representative of said signals transmitted by said traffic monitors to a mobile user station as a result of the mobile user station sending a request for traffic inforrnation to the comnuter svstem.

The computer system of the accused product/system, rather than only arbitrarily sending traffi c information representative of the signals transmitted by the traffic monitors, is capable of sending traffi c information representative of the signals transmitted by the traffic monitors to a mobile user station as a result of the mobile user station sending a request for traffic information to the computer system and therefore meets this element as properly construed.

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. . . providing in response thereto to said one of said mobile user stations . . .

Traffic Informatioil
providing in response thereto

i;*iri;;

Traffic Information
Statement of Imnoriance

The accused product provides information to the recipient after the recipient interacts with a device, and thus does not meet this element as properly construed.

Google In response to a commuter's request, providing relevant traffic information for display by the mobile user station to minimize manipulation by the commuter while drivins

Traffic Information
"providing in response thereto to said one of said mobile user stations" means the computer system supplies traffic information in response to (as defined above) a request from a mobile user station.

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Claim

...trafficinformation
representative of said signals

transmitted by said traffic monitors;

traffic information representative of said signals transmitted by said traffic
monitors

Google'statement of Imnortahce The indefiniteness of the term "usef" renders the claim invalid pursuant to 35 U.S.C. $ 112; alternatively, the accused product does not provide the current speed, frequency, or flow of multiple vehicles traveling along a road as detected by one or more traffic monitors, and thus does not meet this element as properly construed.

i=Tr.a
Google Indefinite; altematively, the current speed, frequency, or flow of multiple vehicles traveling along a road as detected by one or more traffic monitors

nfo,! fuidn@m5
See

Traffic lnformationl
"traffic information,

traffic information

above.

Traffic Information
"traffrc information representative of said signals transmitted by said traffic monitors" does not need a construction. However. if one is required, "traffic information representative of said signals transmitted by said traffic monitors" means "traffi c information," as defined above. Google Represented other than in text format Traffic Information "displayed graphically" means that information representative of the map database and the traffrc information are displayed in a pictorial format, such as a drawing, on the display of the mobile user station. Other information may be displayed, as well.

(f) wherein said traffic information transmitted by
said computer system is displayed graphically on said display; and

displayed graphically

The accused oroduct does not

displayed graphically

display graphical information alone. and thus does not meet this element as properly construed.

The accused product/system displays information representative of the map database and the traffic information in a pictorial format, such as a drawing, on the display of the mobile user station and therefore meets this element as properly construed.

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,,,,

Google Terms Identified

Proposed Construction Google No construction necessary

Traffic lnformation Terms
IdentifiCd
map database

(g) wherein said computer system has a map database, and said computer system, in response to said request for information, transmits map information representative of a portion of said map database, and said map information representative of said map database is displayed graphically together with said traffic information.

Traffic Information
"map database" means a collection of map data representative of, but not limited to, roads, streets, highways, latitude and longitude information, and/or other geographical information. Goosle Represented other than in text format, as defined above

The accused product/system includes a collection of map data representative of, but not limited to, roads, streets, highways, latitude and longitude information, and/or other geographical information and therefore meets this element as properly construed.
See "displayed graphically,

The accused product does not

displayed graphically

"

display graphical information alone, and thus does not meet this element as properly construed.

above.

Traffic Information
"displayed graphically" means that information representative of the map database and the traffic information are displayed in a pictorial format, such as a drawing, on the display of the mobile user station. Other information may be displayed, as well.

4. The system of claim 1 wherein said traffic detector detects vehicular speed.

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Claim
9. The system of claim 1 wherein said user provides latitude and longitude information. . .

Gooele Terms Identified
said user

nst11+
The indefiniteness of the term "user" renders the claim invalid pursuant to 35 U.S.C. $ 112; altematively, persons using the accused product do not provide latitude and

Google Indefinite; alternatively, a person who operates a mobile user station

Traffic Information
"said user" does not need a construction. However, if a construction is required, "said user" means said mobile user station of claim 1. Goosle No construction necessary

longitude information, and
thus does not meet this element as propedy construed.

to said computer system.

computer system

See "computer system,"

above.

Traffic Information
10. The system of claim 1 wherein said computer system

. . . selects said traffic information. . .

The indefiniteness of the term "user" renders the claim invalid pursuant to 35 U.S.C. $ 112; altematively, the accused product does not provide the current speed, frequency, or flow of multiple vehicles traveling along a road as detected by one or more trafftc monitors, and thus does not meet this element as oronerlv construed.

Google Indefinite; altematively, the current speed, frequency, or flow of multiple vehicles traveling along a road as detected by one or more traffrc monitors

traffic information

S

ee

"traffic information."

above.

Traffic Information "fiafftc information" has the same meaning as in claim 1,
above.

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:=
mobile user station
Google provides only the Nexus One mobile device and. therefore. the accused product cannot meet this element, as properly construed, as to mobile devices not supplied by Google. The accused product does not

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Traffic Information Teims Identified
Google A mobile device, distinct from a traffic monitor, capable of determining and displaying traffic information Traffic Information o'mobile user station" has the same meaning as in claim 1,
above.

Traffic lnformation
Statement of lmnortance

. . . to provide to said mobile user station based on a signal received from said global positioning system receiver.

A system for providing traffic information to a
21.

Google

traffic information

See

"traffic information,"

plurality of mobile users connected to a network. comprising:

provide "traffi c information," and thus does not meet this element as properly construed.

"Traffic information" should
be construed in the context

above.

of

"traffic information representative of said signals transmitted by said traffic monitors" as we do below. Traffic Information "traffic information" has the same meaning as in claim 1,
above.

(a) a plurality of mobile user stations" each mobile user station being associated with a

mobile user station

display, a global positioning system receiver and a communicating device to allow each of said mobile user stations to send and receive signals;

Google provides only the Nexus One mobile device and. therefore. the accused product cannot meet this element, as properly construed. as to mobile devices not supplied by Goosle.

Google

A mobile device, distinct from a traffic monitor, capable of
determining and displaying

traffic information Traffic Information "mobile user station" has the same meaning as in claim l,
above.

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Traffic Information Terms i ldentifiCd
Google No construction necessary computer system
See "computer system,"

(b) a computer system interconnected with another communicating device and a network, said computer system being capable of sending and receiving signals to and from said mobile user stations;

above.

Traffic Information
"computer system" has the same meaning as in claim 1, above. Google No construction necessarv

interconnected

See "interconnected," above.

Traffic Information
"interconnected" has the same meaning as in claim 1, above.

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,,

:,' Claim

',

T,r*fS nform iCIn.T==.
Google No construction necessarv
map database

Traffic lnformation Statement of Importance
See "map database," above.

(c) said computer system including a map database and a traffi,c information database, said traffic information database containing data representative oftraffic at a plurality of locations;

Traffic Information
"map database" has the same meaninq as in claim 1. above. Google The term should be construed as part ofthe larger phrase "traffi c information database containing data representative of traffic" and consistent with our definition below of "data reoresentative of traffi c."
The accused product/system includes a collection of traffic

The accused product does not display the current speed, frequency, or flow of multiple vehicles traveling along a road, and thus does not meet this element as properly construed.

traffi c information database

information and therefore meets this element as properly construed.

Traffic Information
"traffi c information database" means a collection of traffic information. Goosle Indefinite; altematively, the current speed, frequency, or flow of multiple vehicles traveling along a road

data representative of traffic

The indefiniteness of the term "user" renders the claim invalid pursuant to 35 U.S.C. $ 1 12; the accused product does not display the current speed, frequency, or flow of multiple vehicles traveling along a road, and thus does not meet this element as properly construed.

Traffic Information "data representative of traffic"
does not need a construction. However, if one is required,

"data representative of traffic"
means traffic information.

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.Giiogle

Google Statement of

Tra{fi:e=-Infoiryaf,,i

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Traffic Infoimation
Statement of Importance

lmportance

::="'':

Identifidi

(d) at least one of said mobile user stations providing a request to said computer system for information together with a respective geographic location of said one of said mobile user stations. . . . and in response thereto, said computer system providing to said one of said mobile user stations . . .

in response thereto [to a requestl providing to said one of said mobile user stations

The accused product provides information to the recipient after the recipient interacts with a device, and thus does not meet this element as properly constnred.

Google In response to a commuter's request, providing relevant traffic information for display by the mobile user station to minimize manipulation by the commuter while driving, the request and the response must occur simultaneously

Traffic Information "in response thereto" has the same meaning as "in response to." in claim 1. above.
"providing to said one ofsaid mobile user stations" does not
need a construction. However, if one is required, "providing to said one of said mobile user stations" means

that the computer system supplies data to the mobile user station

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Google Terms ldentified
. . . information representative of selected portions of said map database and selected

information representative of . . selected portions ofsaid traffi.c information database

.

portions of said traffic information database based on said respective geographic location of said one of said mobile user stations; and

$bpgle $tatefient q.f=Importance The indefiniteness of the term "user" renders the claim invalid pursuant to 35 U.S.C. $ 1 12; the accused product does not display the current speed, frequency, or flow of multiple vehicles traveling along a road, and thus does not meet this element as properly construed.
r

Traffic Information Terms Identified
Google Indefinite in identification of selecting entity (i.e. user or system) and kind of information selected; alternatively, the current speed, frequency, or flow of multiple vehicles traveling along a road as detected by the traffic monitors, a subset of which is selected bv the commuter

-]r4{ft:In{o=*= ff io+ j
Statement of Imbortance

Traffic Information
"information representative of selected portions of said map database and selected portions of said traffic information database" means that certain data from the map database and certain data from the traffi c information database are transmitted to the mobile
user station.

(e) said one of said mobile user stations displaying graphically on said display rntormation representative of said selected portions of said map database and said selected portions of said traffi c information database.

The accused product does not di splay graphical information alone. and thus does not meet this element as properly construed.

Google
Represented other than in text

displaying graphically

See "displayed

graphically,"

above.

format, as defined above

Traffic Information "displaying graphically" has the same meaning as in claim
1. above.

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:

Claim

GooefC Terms tOentinef,

Google StatemCnt of,

Imnortance
22. The system of claim 21 wherein said computer system is connected to a plurality of traffic monitors, and said traffi c information database contains data derived from said traffic monitors. Google No construction necessary

Traffic lnformation Terms Identified
comDuter svstem

Traffic Information
Statement of Importance See "computer system" above.

Traffic Information
"computer system" has the same meaning as in claim 1, above. Goosle A stationary device capable of determining the current speed, frequency, or flow of multiple vehicles traveling along a road

The accused product does not provide a stationary device capable of deterrnining the current speed, frequency, or flow of multiple vehicles traveling along a road, and thus does not meet this element as properly construed.

traffic monitors

See

"traffic monitors," above.

Traffic Information "traffic monitors" has the same meaning as in claim
above.

1

The accused product does not display the current speed, frequency, or flow of multiple vehicles traveling along a road, and thus does not meet this element as properly construed.

Google The term should be construed as part ofthe larger phrase " traffi,c information database containing data representative of traffic" and consistent with our definition above of "data representative of traffic." - See comrnent above on this same term.

traffic information database

See

"traffic information

database," above.

Traffic Information
affic information databa s e" has the same meaning as in
" tr

claim2l.

above.

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Google Statement of

PropoiCd Colstruction
Statement of Importance Google No construction necessarv
computer system
See "computer system,"

Importance
23.The system of claim22 wherein said computer system updates said traffic intbrmation database based on data received from said mobile user stations.
mobile user station

above.

Traffic Information
"computer system" has the same meaning as in claim 1,
above.

The accused product does not display the curent speed, frequency, or flow of multiple vehicles traveling along a road, and thus does not meet this element as properly construed.

Google The term should be construed as part ofthe larger phrase "traffrc information database containing data representative of traffic" and consistent with our definition above of "data representative of traffi c." - See comment above on this
same ter:rn.

traffi c information database

See

"traffic information

database," above.

Traffic Information
"traffi c information database"
has the same meaning as in claim2l. above.

Google provides only the Nexus One mobile device and, therefore, the accused product cannot meet this element, as properly construed, as to mobile devices not supplied by Google.

Google A mobile device, distinct from a traffic monitor, capable of determining and displaying traffic information

Traffic Information
"mobile user station" has the same meaning as in claim 1,
above.

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25. The system of claim 21 wherein said computer system updates said traffic information database based on data received from said mobile user stations.

Google Terms ldentified mobile user station Google No construction necessary computer system

Traffic InforyIation
Statement of lmnortance See "computer system,"
above.

Traffic Information
"computer system" has the same meaning as in claim 1, above. Google The term should be construed as part ofthe larger phrase "traffi c information database containing data representat ive of traffic" and consistent with our definitionbelow of "data representative of traffic." - See comment above on this same term.

The accused product does not display the current speed,

traffi c information database

See "traffi c

information

database." above.

frequency, or flow of multiple
vehicles traveling along a road, and thus does not meet this element as properly construed.

Traffic Information
"traffi c information database"
has the same meaning as in claim2l. above.

Google provides only the Nexus One mobile device and, therefore, the accused product cannot meet this element, as properly construed, as to mobile devices not supplied by Goosle.

Google

A mobile device, distinct from a traffic monitor, capable of
determining and displaying traffic information

Traffic Information
"mobile user station" has the same meaning as in claim 1,
above.

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31. The system of claim 21 wherein said location of said one of said mobile user stations is displayed graphically.

mobile user station

Google Statement of Importance provides only the Google Nexus One mobile device and, therefore, the accused product cannot meet this element, as properly construed, as to mobile devices not supplied by Goosle.
The accused product does not

"P-F.6-* dConstr.uttio*
Goosle

Ti*f fi cIn{o.?.*Eio$erfi
Identified

s

.=-lf+-affi c Info.i:= Atioa:'' Statement of Importance

A mobile device. distinct from atrafftc monitor, capable of
determining and displaying

traffic information Traffic Information "mobile user station" has the same meaning as in claim 1,
above.

display graphical information alone, and thus does not meet this element as properly construed.

Goosle Represented other than in text format. as defined above

displayed graphically

S

ee "displayed graphically,

above."

Traffic Information
"displayed graphically" has the same meaning as in claim I, above. Google A mobile device, distinct from atraffi,c monitor, capable of determining and displayi ng traffic information

32.The system of claim 31 wherein said displayed location of said one of said mobile user stations changes based on movement of said mobile user station.

mobile user station

Google provides only the Nexus One mobile device and, therefore, the accused product cannot meet this element, as properly construed, as to mobile devices not supplied by

Traffic Information
"mobile user station" has the same meaning as in claim 1,
above.

Goosle.

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Gooels::Ti|Pdentilied
6.785.606 22. A system for providing

Goo$

$taternent of
I ,.=

Pi.4o.$@,C..o.E=..*1.?.n

:.,,.: ,{mportiluce

Trailic,{ufOr@tiO-T.=G.@s Identified traffrc information
S

Tr.c-t
=:::.

lnfo.ry4 4tio

StatGffent

oflfup.it

ti' I
anas

us

traffic information to a plurality of mobile users
connected to a network.

The accused product does not provide "traffi c information," and thus does not meet this element as properly construed.

Google
The term should be construed as part ofthe larger phrase

ee

"traffic information,

above.

"traffic information
representative of said signals transmitted by said traffic monitors" consistent with what have set out below.

comprising:

Traffic Information "traffic information" has the same meaning as set fbrth above with regard to the '862
Datent.

(a) a plurality of traffic monitors, each said traffic monitor comprising at least detector and a transmitter, .

traffic monitors
a
.

The accused product does not provide a stationary device capable of determining the current speed, frequency, or flow of multiple vehicles traveling along a road, and thus does not meet this element as properly construed.

Google

A stationary device capable of
determining the current speed, frequency, or flow of multiple vehicles traveling along a road

Traffic Information "traffic monitors" has the same meaning as set forth above with regard to the'862
Datent.

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e.hiff
. . . said detector providing a signal including data representative of vehicular movement and said transmitter transmittins said signals;

Google Statement of

Proposed Construction Google The current speed, frequency, or flow of multiple vehicles traveling along a road as detected by one or more traffic monitors

Imnortince
The accused product does not provide a signal representative of determining the current speed, frequency, or flow of multiple vehicles traveling along a road, and thus does not meet this element as properly construed.

,.'f-t*..fffl nft$q1@T
vehicular movement

er o

Traffic lnformation
Statement of Imporfance See "vehicular movement, above.

Traffic Information
"vehicular movement" has the same meaning as set forth above with regard to the '862
Datent.

(b) a receiver that receives said signals transmitted by said traffic monitors, (c) a computer system. Google No construction necessary computer system
See "computer system,"

above.

Traffic Information
"computer system" has the same meaning as set forth above with regard to the '862
Datent.

. . . interconnected with said receiver and said network:

Google No construction necessary

interconnected

See "interconnected." above.

Traffic Information
"interconnected" has the same
meaning as set forth above with resard to the '862 oatent.

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Claim
(d) a mobile user station includes a display, and a receiving device; mobile user station

ooglC' $-ta:t-.e +nJ

of
Google A mobile device, distinct from a traffic monitor, capable of detemining and displaying traffic information Traffic Information "mobile user station" has the same meaning as set forth above with regard to the '862
patent.

.::..,...--T..1,,,.4,,

lmportance
The accused product does provide a mobile device,

c r.n imationj StatCrnent of lmportance

distinct from a traffic monitor, capable of determining and displaying "trafftc information," and thus do not meet this element as properly construed.

(e) said computer system providing to said one of said mobile user stations . . .

providing to said one of said mobile user stations

The accused product provides information to the recipient after the recipient interacts with a device, and thus does not meet this element as properly construed.

Goosle Providing relevant traffic information for display by the mobile user station to minimize manipulation by the commuter while drivins

Traffic Information "providing to said one of said mobile user stations" does not need a construction. However, if one is required, "providing to said one of said mobile user stations" has the same meaning as set forlh above with regard to the '862
patent.

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Google Statement of
. . . traffic inforrnation representative of said signals transmitted by said traffic

Proposed Construction Google Indefinite; alternatively, the current speed, frequency, or flow of multiple vehicles traveling along a road as detected by the traffic monitors Traffic Information "traffic information representative of said signals transmitted by said traffic monitors" does not need a construction. However, if one is required, "traffic information representative of said signals transmitted by said traffic monitors" has the same meaning as set forth above with regard to the '862
Datent.

monitors:

traffic information representative of said signals transmitted by said traffic monitors

The indehniteness of the term "user" renders the claim invalid pursuant to 35 U.S.C. $ 1 12; the accused product does not display the current speed, frequency, or flow of multiple vehicles traveling along a road, and thus does not meet this element as properly construed.

=

Importance=
traffic information
See "traffi c information,

above.

(0 said traffi,c information
transmitted by said computer system is displayed graphically on said display; and

The accused oroduct does not

display graphical information alone, and thus does not meet this element as properly construed.

Google Represented other than in text format

displayed graphically

S

ee "displayed

graphically,"

above.

Traffic Information
"displayed graphically" has the same meaning as set forth above with regard to the'862 natent.

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(g) wherein less than all available traff,rc information is displayed by said display.

Google StatemCnt of ImportanceThe indefiniteness of the term "user" renders the claim invalid pursuant to 35 U.S.C. $ 112.

ProposCd Construction

Google Indefinite in degree (i.e. amount of information) and kind of information

less than all available traffic

information

Traffic Information
"less than all available traffic information" means that the computer system may send traffic information corresponding to only some of the traffic monitors.

The computer system of the accused product/system may send traffi c information corresponding to only some of the traffic monitors and therefore meets this element as properly construed.

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