Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 1 of 150 PageID #:68
`Case: l:l6—cv—O4826 Document #: 1-5 Filed: 04/29/16 Page 1 of 150 Page|D #:68
`
`
`
`EXHIBIT E
`
`EXHIBIT E
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 2 of 150 PageID #:69
`
`DECLARATION OF ZAYDOON JAWADI
`
`I, Zaydoon Jawadi, hereby declare as follows:
`
`1.
`
`I am an independent computer expert and consultant.
`
`2. As shown in my CV (attached as Exhibit 1), I have a Bachelor of Science in
`
`Electrical Engineering from Mosul University, a Master of Science in Computer
`
`Science from Columbia University, and over 35 years of experience in software
`
`development, engineering, consulting, and management in the fields of computing
`
`systems, Internet, website technologies, data storage, data networking, software
`
`applications, telephony, and telecommunication.
`
`3.
`
`In 2010, I cofounded and am the President of Rate Speeches, Inc., an Internet
`
`company providing online communication rating and evaluation services.
`
`4. From 2001 to 2006, I was President and cofounder of CoAssure, Inc., a provider of
`
`automated web-based telecommunication test services.
`
`5. From 1999 to 2001, I was CEO, Chairman, and founder of Can Do, Inc. an Internet
`
`eCommerce and community company.
`
`6. From 1992 to 1996, I was President and founder of Zadian Technologies, Inc., a
`
`supplier of data storage test systems, with over 50,000 units installed worldwide.
`
`7.
`
`In 1996, Zadian Technologies was acquired by Xyratex International LTD
`
`(NASDAQ: XRTX, which was acquired by Seagate, NASDAQ: STX, in 2014).
`
`1 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 3 of 150 PageID #:70
`
`Following Zadian's acquisition by Xyratex, I became a general manager at Xyratex
`
`until 1998. At Xyratex, I was responsible for a data networking analysis tools
`
`business unit, which designed and built Gigabit Ethernet network protocol analysis
`
`and monitoring products, which were sold, under OEM agreement, by the largest
`
`network protocol analysis and monitoring products supplier.
`
`8. Prior to 1992, I worked as a software consultant, a software engineer, and an
`
`electrical engineer.
`
`9. My experience specifically relevant to the digital signage includes being general
`
`manager of a data networking analysis tools business unit at Xyratex, 1997-1998,
`
`being general manager of a manufacturing test systems division at Xyratex, 1996-
`
`1996, and being president of a manufacturing test systems supplier, Zadian
`
`Technologies, 1992-1996. The Xyratex and Zadian manufacturing test systems
`
`comprised multiple individual test units (each with an independent LCD display
`
`operated by an embedded system) connected through a network to a central control
`
`system; the central control system has the ability to control the displays of the
`
`individual test units. My experience (1984-1992) also includes designing and
`
`implementing networked individual devices (each with an independent display
`
`operated by embedded system or PC) connected through a network to central
`
`control systems that control the display of the individual devices, and includes
`
`designing and implementing database, applications, and system software as well as
`
`drivers and other software for controlling graphics and monitor displays. In addition
`
`2 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 4 of 150 PageID #:71
`
`to my technical work, my background includes being involved with direct marketing
`
`and advertising at Zadian Technologies (1992-1996), at Xyratex (1996-1998), at
`
`Can Do (1999-2001), at CoAssure (2001-2006), and at Rate Speeches (2010-
`
`present).
`
`10. I have been retained by Farney Daniels PC, counsel for T-Rex Property AB. I have
`
`been informed that T-Rex is a company organized and existing under the laws of
`
`Sweden. I have also been informed that T-Rex is the owner of three patents: (1) U.S.
`
`Patent Number RE39,470, entitled “Digital Information System” (2) U.S. Patent
`
`Number 7,382,334, entitled “Digital Information System” and (3) U.S. Patent
`
`Number 6,430,603, entitled “System for Direct Placement of Commercial
`
`Advertising, Public Service Announcements and Other Content on Electronic
`
`Billboard Displays.”
`
`11. I have been asked to assess claims 25 and 26 of the '470 Patent, claims 22 and 32 of
`
`the '334 Patent, and claims 42 and 43 of the '603 Patent, and in particular to
`
`individually assess the specific technologies addressed by each of these claims.
`
`12. My compensation does not depend in any way on a particular litigation outcome.
`
`13. I am over the age of eighteen and am competent to make this declaration. I make
`
`this declaration from my personal knowledge, experience, and education and, if
`
`called to do so, could and would testify competently thereto.
`
`
`
`3 of 91
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 5 of 150 PageID #:72
`
`14. In preparing this Declaration, I reviewed the '470 Patent and its file history, the '334
`
`Patent and its file history, and the '603 Patent and its file history. I also spoke with
`
`one of the inventors of the patent and one of the engineers who implemented the
`
`technology.
`
`Digital Signage
`
`15. Traditional out-of-home advertising (AKA outdoor advertising), such as billboards,
`
`bulletins, notice boards, posters, banners, brochures, is being replaced with
`
`electronic signage, and, more recently, digital signage. Digital signage utilizes
`
`various digital display technologies, such as LCD, LED, computer monitors, flat
`
`screen monitors, projectors, digital television sets, overhead screens, wall-mounted
`
`screens, and other display devices. Digital signage may be used to display images,
`
`video, text, and other content to convey information, such as transportation
`
`schedules and timetables, passenger information, updates, news, weather, traffic,
`
`corporate and informational messages, warnings, etc. or for advertising. Digital
`
`signage may be deployed in airports, train stations, railway station platforms,
`
`subway stations, subway platforms, ship harbors, bus stations, hospitals, sports
`
`arenas, theaters, movie theaters, concert halls, hotels, stadiums, museums,
`
`conferences, exhibitions, assembly halls, lecture halls, conference rooms, shopping
`
`malls, retail stores, restaurants, corporate buildings, etc. Digital signage allows both
`
`digital information and digital advertising to be displayed in public infrastructures
`
`and places that are accessible to and frequented by a general public. Digital signage
`
`4 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 6 of 150 PageID #:73
`
`technology involves digital display devices, possibly with local computers or
`
`processing devices, connected through communications medium, such as dedicated
`
`cables, local area network (LAN), wide area network (WAN), or wireless. The
`
`devices may be managed remotely. Digital signage technology involves hardware
`
`and software.
`
`Patents Inventors and Technology Implementation
`
`16. DHJ Media AB was founded in 1996 to transform outdoor advertising, by solving
`
`four problems that were inherent in that industry: inefficient distribution, limited
`
`inventory, long lead times, and inflexible medium. By 2001, the company had
`
`raised 180 million Swedish Krona (over $20 million), developed its digital signage
`
`technology, launched multiple installations of its technology, and filed for an initial
`
`public offering (IPO) in Sweden. An additional investment of about 100 Swedish
`
`Krona was later raised, for a total of about $30 million combined investment.
`
`17. The following images demonstrate four of DHJ Media's technology installations.
`
`
`
`5 of 91
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 7 of 150 PageID #:74
`
`Arlanda Express Subway
`
`
`
`
`
`
`
`6 of 91
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 8 of 150 PageID #:75
`
`London City Airport
`
`
`
`
`
`
`
`Stockholm Underground Karlaplan
`
`
`
`7 of 91
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 9 of 150 PageID #:76
`
`
`
`London Underground Test Site
`
`
`
`
`
`
`Patents
`
`18. The '470 Patent, the '334 Patent, and the '603 Patent are directed to digital signage
`
`and address issues specific to digital signage technologies.
`
`19. I understand that the '470 Patent is entitled to a filing date of April 26, 1996.
`
`8 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 10 of 150 PageID #:77
`
`'470 Patent Claim 25
`
`20. Independent claim 25 of the '470 Patent is directed to digital signage.
`
`21. Claim 25 of the '470 Patent generally discloses a method of selectively displaying
`
`digital information at one or multiple locations under the control instructions of
`
`external information mediator(s) through a dynamically-updated exposure list
`
`conveyed through control instructions. Method claim 25 is reproduced below:
`
`25. A method of selectively displaying digital information at one or more of a
`plurality of locations, said method comprising:
`receiving control instructions from at least one external information mediator;
`using said control instructions to generate an exposure list, said exposure list
`specifying three or more of the following items:
`i) what information content is to be displayed;
`ii) at which of said plurality of locations said information content is to be
`displayed;
`iii) when said information content is to be displayed for each location at
`which content is to be displayed; and
`iv) how long said information content is to be displayed for each location at
`which content is to be displayed;
`displaying images at one or more of said locations in accordance with said
`exposure list; and
`permitting said exposure list to be dynamically updated.
`
`Claim 25: Problems Solved and Prior Art
`
`22. It is my opinion that claim 25 of the '470 Patent solves specific needs and problems
`
`over other technologies that existed in 1996. The specific needs and problems
`
`include, among other things, controlling and coordinating digital signage displays in
`
`concrete, specific ways beyond merely scheduling content to be displayed on remote
`
`9 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 11 of 150 PageID #:78
`
`screens. The inventors came up with a specific solution to resolve these and other
`
`particular problems.
`
`23. Prior to the inventions disclosed in claim 25 of the '470 Patent, for example, there
`
`was no flexible way for external information mediators/suppliers (such as
`
`advertising agencies, broadcasters, movie producers, companies, and individuals
`
`who wish to utilize digital signage for commercial reasons or for the display of
`
`information that concerns the general public) to dynamically control and coordinate,
`
`display devices located in different places. Content from external information
`
`mediators could not be directly displayed; instead, displaying such content required
`
`administrative processing and manual intervention to update the display systems.
`
`Even when the administration of information was processed with the aid of modern
`
`computer technology, the available display time would nevertheless contain dead
`
`time due to, among other things, back-logging caused by the manual process.
`
`24. Furthermore, prior to the inventions disclosed in claim 25 of the '470 Patent, for
`
`example, there was no flexible way to dynamically control and coordinate what,
`
`where, when, and how long to display content (such as images, videos, messages,
`
`and announcements) on display devices located in different places. Instead, content
`
`display was not coordinated, and individual items were controlled and updated
`
`separately, often manually. If any minimal control and coordination capability even
`
`existed, it was only the administrator, but not the external information mediators,
`
`who had access to such control and coordination.
`
`10 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 12 of 150 PageID #:79
`
`25. Moreover, prior to the inventions disclosed in claim 25 of the '470 Patent, for
`
`example, the computer controls of prior art systems were complicated. As a result,
`
`control and coordination of content display often had to be carried out by experts;
`
`content display had to be planned and coordinated carefully beforehand; mediators
`
`had very little chance of influencing the display. Despite the need for doing so,
`
`updating and changing content display quickly was not feasible.
`
`26. Claim 25 of the '470 Patent solves these problems, and, in doing so, claim 25
`
`embodies and improved the operation of digital signage that existed in 1996.
`
`Elements of claim 25 were not previously employed in the prior art. In fact,
`
`elements of claim 25, individually and in combination, have practical significance,
`
`and these elements represented new and useful innovation and improvement to
`
`digital signage over the prior art.
`
`27. The combination of the elements of claim 25 of the '470 Patent imposes meaningful
`
`limitations to improve existing digital signage technology by, for example, allowing
`
`external information mediator(s) to dynamically control and coordinate display
`
`devices located in different places, extending the usefulness of the digital signage
`
`technology. The combination of the elements of claim 25 together is distinct and
`
`different from other technologies.
`
`28. To solve the above and other problems and to achieve this technological innovation,
`
`claim 25 of the '470 Patent incorporates unique, innovative, non-conventional, non-
`
`11 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 13 of 150 PageID #:80
`
`generic elements, including, for instance: receiving control instructions from
`
`external information mediator(s); generating an exposure list based on the control
`
`instructions; specifying through the exposure list what, where, when, and how long
`
`to display; displaying images at location(s) in accordance with the exposure list; and
`
`permitting the exposure list to be dynamically updated.
`
`29. The functions, application, and implementations of these elements inherently and
`
`necessarily are rooted in and require computer technology, communication
`
`technology, and digital display technology in order to overcome specific problems
`
`arising in the realm of digital signage in 1996. Claim 25 discloses inventive,
`
`concrete, and tangible acts requiring intricate computer programming—acts that
`
`must be performed through computers. But, the claim goes beyond the mere
`
`concept of simply using a computer to perform distributed signage. This is because
`
`computers, communication interfaces, and digital display devices are not ancillary
`
`or incidental additions but germane and integral parts of the inventions disclosed by
`
`claim 25 of the '470 Patent.
`
`30. In particular, the claimed inventions of claim 25 of the '470 Patent relate to the
`
`functioning of hardware and software technology for digital signage. The claim
`
`addresses a technical challenge (controlling and coordinating displays) that is
`
`particular to digital signage. In particular, the claimed inventions are directed
`
`towards dynamically controlling and coordinating display devices located in
`
`different places through control instructions and exposure lists by external
`
`12 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 14 of 150 PageID #:81
`
`information mediators. The claim discloses receiving control instructions from
`
`external information mediator(s); generating an exposure list based on the control
`
`instructions; specifying through the exposure list what, where, when, and how long
`
`to display; displaying images at location(s) in accordance with the exposure list; and
`
`permitting the exposure list to be dynamically updated. The claimed actions are
`
`inextricably tied to digital signage computer technology, communication
`
`technology, and digital display technology.
`
`31. For example, the '470 Patent excerpts below exemplify some of the specific
`
`problems that claim 25 solves over other 1996 era technologies.
`
`"Thus, present-day systems [prior art] do not enable information to be updated
`dynamically for display in real time. Neither do present-day systems enable
`external mediators to update information for display in a central control system,
`nor yet the administrator who makes the display of information available, but that
`it is the administrator who determines when, where and how the information shall
`be displayed." (The '470 Patent at 1:53-60.)
`
`"An object of the present invention is to provide a flexible system in which
`external information mediators are able to dynamically control in real time the
`transmission of display instructions to a larger public in different places situated at
`any chosen distance apart through projectors which project information onto
`displays intended therefor." (Id. at 2:39-45.)
`
`"Another object of the invention is to enable pictures, images, messages and
`announcements to be configured in accordance with modern digital technology,
`therewith providing rapid communication." (Id. at 2:46-49.)
`
`"A further object of the invention is to enable a picture, image or other information
`to be changed in practice as often as is desired, in real time, therewith providing
`direct and immediate communication, and to enable similar or specific information
`
`13 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 15 of 150 PageID #:82
`
`to be displayed in places that are mutually far apart and to enable message
`information to be alternated with advertising spots, for instance." (Id. at 2:50-56.)
`
`"Information display subscribers are connected to a computerized control centre
`via computer and telecommunication interfaces for all-day-round transmission of
`information, wherein the control centre has a communication interface against
`with computerized devices situated in connection with said places for projector
`coordination and control." (Id. at 2:64-3:3.)
`
`"The display list, which includes control instructions, coordinates and controls the
`projectors concerned with regard to what shall be displayed, when it shall be
`displayed, where it shall be displayed and for how long it shall be displayed, and
`causes each projector, independently of other projectors, to receive the same or
`different information for display through respective projectors and through the
`computerized devices, in accordance with the display list." (Id. at 3:11-18.)
`
`"The administrator of the digital information system is able to update the display
`list with desired information at any time whatsoever, wherein the dynamic
`booking can be changed or delayed." (Id. at 3:19-23.)
`
`"The administrator controls internally how, what, when or where the information
`shall be displayed by the projectors 22. An important feature in this context,
`however, is that external information mediators 24 are able to give control
`instructions to the projectors 22 with regard to the information that the external
`mediators 24 desire the system 10 to display via the projectors 22, each on its own
`initiative and communication-wise transparent via modems 26." (Id. at 5:6-13.)
`
`"At present a mediator which wishes to display information in public places is
`normally forced to wait about two weeks, perhaps longer, before his order can be
`implemented and the information publicly displayed." (Id. at 5:23-27.)
`
`"This constitutes an alternative to the insertion of the entire information bit from
`an external mediator 24 in a specific time interval in the exposure list, and enables
`the provision of an exposure list that contains much less information and which is
`thus easier to handle, and to accelerate transmission of the list between computers
`and databases included in the system." (Id. at 7:44-51.)
`
`"When the information mediator 24 is an advertising agency and the
`advertisements are to be displayed are in picture form, the advertising subscriber is
`14 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 16 of 150 PageID #:83
`
`able to buy a number of spots which are shown in the exposure list." (Id. at 9:14-
`18.)
`
`"The control centre 12 sends picture packets/information to the station computer
`34 together with an exposure list. The exposure list includes a series of
`instructions as to what shall be shown, where it shall be shown, when it shall be
`shown and for how long, etc. The station computer 34 then provides each
`projector computer 38 with the material to be exposed. Thus, one and the same
`information material can be shown on all screens, or certain screens can be chosen
`for specific information display. This facility is controlled via the exposure list or,
`when the need is acute, directly from the control centre 12." (Id. at 9:56-67.)
`
`32. Furthermore, the prosecution history of the '470 Patent, excerpts below, exemplify
`
`some of the specific problems that claim 25 solves over other technologies and the
`
`prior art.
`
`a. On March 29, 2002, applicant clarified the differences between claim 25 and
`
`U.S. Patent 6,122,642 (Mehovic), one of the prior art references cited during
`
`prosecution:
`
`"Mehovic does not teach or suggest a system or method for selectively
`displaying digital information at one or more of a plurality of locations as
`recited by independent claims 25 and 26. Mehovic pertains to propagating
`airline reservation data to a relational database management system so that
`the data can be retrieved by an end user and is not concerned with
`displaying information in publicly assessable places. The end user in
`Mehovic requests information from the reservation system , 12 through a
`VAX front-end 106 (see column 5, lines 27-30). In contradiction, the end
`users in the present invention (i.e., the public) are passive viewers of
`displayed images.
`
`Mehovic fails to disclose the claimed exposure list that specifies display
`content, display location, display timing and display duration. The
`Examiner argues that the Passenger Name Record ("PNR") of Mehovic is
`equivalent to the exposure list. However, the PNR is a mix of textual and
`parametric data related to airline reservations such as airlines, departure
`cities, arrival cities, passenger data and the like. There is no information
`
`15 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 17 of 150 PageID #:84
`
`relating to display content, display location, display timing and display
`duration as required by claims 25 and 26.
`
`In addition, there is no teaching that the PNR is generated from control
`instructions received from an information mediator, as is required for the
`exposure list of claims 25 and 26.
`
`Furthermore, Mehovic fails to show the claimed element of displaying
`images at one or more locations. Even if one argues that Mehovic displays
`data on the PC client 26 or output means 100, there is no suggestion that the
`system displays images in accordance with an exposure list, as required by
`claims 25 and 26. Instead, each PC client 26 presumably operates
`independently, displaying particular data as requested by the individual end
`users." (The File History of the '470 Patent, Amendment of March 29, 2002
`at 3-4.)
`
`b. On May 14, 2003, applicant clarified the differences between claim 25 and
`
`U.S. Patent 6,006,159 (Schmier), one of the prior art references cited during
`
`prosecution:
`
`"Schmier et al fails to anticipate either one of independent claims 25 and
`26. While Schmier et al generally relates to a method and system for
`displaying digital information, this reference does not disclose all of the
`recitations of claims 25 and 26. In particular, claim 25 recites the step of
`generating an exposure list that specifies display content, display location,
`display timing and display duration. The Examiner alleges that the transit
`data table computed by the central processor 22 of Schmier et al
`corresponds to the claimed exposure list. However, the transit data table
`contains predicted vehicle time intervals, arrival times and passenger load
`levels. This information is broadcast by the central processor 22 to the
`display modules 30 for display thereon. As such, the transit data table
`merely specifies display content and does not specify display location,
`display timing and display duration as required by claim 25. For example,
`Schmier at al contemplates displaying all or some of the information in the
`data transfer table (see column 5, lines 12-15). Schmier at al also describes
`continually updating the information in near real time (column 10, lines 3-
`6). Because the information is updated, and thus changed, as soon as it is
`received by the central processor 22, the duration of a given display is
`controlled by the frequency of the updates, not by anything in the transit
`
`16 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 18 of 150 PageID #:85
`
`data table. Also. while Schmier et al mentions displaying other types of
`information (such as news and advertising) at selective displays, there is no
`indication in Schmier at al that the specific location and timing of such
`displays would be controlled by the transit data table.
`
`Accordingly, applicant respectfully submits that Schmier at al does not
`disclose an exposure list specifying display location, display timing and
`display duration and thus fails to anticipate claim 25." ('470 File History,
`Amendment of May 14, 2003 at 3-4.)
`
`c. On February 2, 2004, applicant amended claim 25 and further clarified the
`
`differences between claim 25 and the prior art of record:
`
`"Schmier et al fails to teach or suggest the step of receiving control
`instructions from at least one external information mediator." ('470 File
`History, Amendment of February 2, 2004 at 7.)
`
`"Claim 25 also recites the step of using the control instructions to generate
`an exposure list. The claim has been amended to recite that the exposure list
`specifies three or more of the following items:" (Id..)
`
`"While the [Schmier] transit data table contains information relating to
`predicted time intervals between adjacent transit stops and predicted times
`of arrival, the transit data table does not specify where a piece of
`information is to be displayed, when the information is to be displayed, and
`how long the information is to be displayed. These aspects are dictated by
`other factors. For example, Schmier et al describes continually updating the
`information in near real time (column 10, lines 3-6). Because the
`information is updated, and thus changed, as soon as it is received by the
`central processor 22, how long a piece of information is displayed is
`controlled by the frequency of the updates, not by anything in the transit
`data table. Also, while Schmier et al mentions displaying other types of
`information (such as news and advertising) at selective displays, there is no
`indication in Schmier et al that the specific location and timing of such
`displays would be controlled by the transit data table." (Id. at 8.)
`
`
`
`17 of 91
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 19 of 150 PageID #:86
`
`Claim 25: Terms and Limitations
`
`33. External Information Mediator
`
`Claim 25 references "external information mediator" in the first claim element
`
`(emphasis added):
`
`"receiving control instructions from at least one external information
`mediator;"
`
`The following excerpts from the '470 Patent specification provide context for the
`
`term "external information mediator."
`
`"The information channel cannot be subscribed to directly for the display of
`external information suppliers, such as advertising bureaux, the authorities,
`newspapers, etc., but is processed administratively and fed manually into
`the information display systems." (The '470 Patent at 1:42-48.)
`
`"The control centre is able to create and update a display list in real time
`with control instruction fields via booking information for display
`dynamically in time from mediators having drive routine means which are
`connected to the subscription and which are transparent for the transmission
`of information to the drive routine means of the control centre for
`transmission of information in the system." (Id. at 3:4-10.)
`
`"The administrator controls internally how, what, when or where the
`information shall be displayed by the projectors 22. An important feature in
`this context, however, is that external information mediators 24 are able to
`give control instructions to the projectors 22 with regard to the information
`that the external mediators 24 desire the system 10 to display via the
`projectors 22, each on its own initiative and communication-wise
`transparent via modems 26." (Id. at 5:6-13.)
`
`"The term information mediator (24) used in the following shall be
`interpreted in its widest meaning, i.e. as not only referring to advertising
`agencies but to all companies and private persons who wish to utilize the
`system 10 for commercial reasons or for the display of information that
`
`18 of 91
`
`
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 20 of 150 PageID #:87
`
`concerns a general public. At present a mediator which wishes to display
`information in public places is normally forced to wait about two weeks,
`perhaps longer, before his order can be implemented and the information
`publicly displayed. With the inventive digital information system 10, the
`information can be displayed principly in real time, i.e. at the time of
`making the order, possibly with a short delay due to processing, fully-
`booked exposure lists and other quickly passing causes. Furthermore, an
`external information mediator 24 is able to put through information to the
`system 12 twenty-four hours a day, whereupon the information can be
`included instantaneously in an exposure list, as illustrated in more detail
`below. (Id. at 5:18-35.)
`
`"Those external information mediators which connect to the control centre
`12 via modems are, in one embodiment of the invention, connected to the
`control centre via specially designed interfaces (drive routine means) for
`data and telecommunication. In this way, only external mediators 24 having
`the correct interface are able to connect transparently to the control centre
`12 for delivering control instructions in the projectors 22," " (Id. at 5:36-
`43.)
`
`"The exposure handler 3 carries out the important object of the invention
`with regard to the possibility of an external mediator 24 to organize the
`information delivered to the station 16, 18, 20 via an exposure list," (Id. at
`7:10-15.)
`
`"A data message of this kind connected to each individual information
`exposure enables known HASH or switching methods to find information
`included in the exposure time intervals in the exposure list both effectively
`and quickly. A First Class® server can be used conveniently for
`communications transmission between external information mediators 24
`and the control centre 12. Each external information mediator is then able
`to send an e-mail with included information material in any chosen format,
`which provides the advantage of not needing to write in any new software
`for the communication transmission function. As before mentioned, the
`system also incorporates a safety aspect, whereby each external information
`mediator that has an office or when subscribes to the system must possess a
`coded drive means or a coded drive routine in order to connect to the
`control centre 12." (Id. at 7:55-8:3.)
`
`
`
`19 of 91
`
`

`

`Case: 1:16-cv-04826 Document #: 1-5 Filed: 04/29/16 Page 21 of 150 PageID #:88
`
`"In order for external information mediators 24 to be able to deliver
`complete pictures/films, the mediator will preferably have its own versions
`of the software that the exposure handler 3 uses for enabling pictures/films
`to be introduced transparently into the exposure list without processing via
`the working stations 32 in the control centre 12." (Id. at 8:4-9.)
`
`"In accordance with the aforegoing, external information mediators 24 that
`have access to the exposure program are able to deliver complete picture
`series/films which can be processed automatically and inserted into the
`exposure list, or optionally personnel administering the working stations 32
`are able to pick external mediator information from the queues, or lines,
`and process this information so that it can be inserted into the exposure list
`via the exposure handler 3. In order to be able to distinguish information
`that must be processed via the working