IN THE UNITED STATES PATENT AND TRADEMARK OFFICE
`
`In re Patent of: Racz et al
`
`U.S. Patent No.: 7,334,720
`Issue Date:
`February 26, 2008
`USPTO Control No.: TO BE DETERMINED
`Appl. Serial No.: 11/336,758
`Filing Date:
`January 19, 2006
`DATA STORAGE AND ACCESS SYSTEMS
`Title:
`
`DECLARATION OF DR. JEFFREY A. BLOOM
`
`1. My name is Dr. Jeffrey A. Bloom. I understand that I am submitting a declaration in connection
`with the above-referenced Covered Business Method (“CBM”) review proceeding pending in the
`United States Patent and Trademark Office for U.S. Patent No. 7,334,720 (“the ‘720 Patent”).
`
`
`2. I have been retained on behalf of Samsung Electronics America, Inc. to offer technical opinions
`with respect to the ‘720 patent and the prior art references cited in this CBM review. My
`compensation is not based on the outcome of my opinions.
`
`
`3. I am not a lawyer. However, counsel has advised me of legal concepts that are relevant to CBM
`review proceedings and to the opinions that I offer in this declaration. I understand that, during
`CBM review, claims of the subject patent are given a broadest reasonable interpretation.
`Counsel has advised me that the broadest reasonable interpretation must be consistent with the
`specification, and that claim language should be read in light of the specification and teachings in
`the underlying patent.
`
`
`4. I have reviewed the '720 Patent, including the claims of the patent in view of the specification,
`and I have reviewed the ‘720 Patent's prosecution history. In addition, I have reviewed the
`following documents: U.S. Patent No. 5,915,019 (“Ginter”), U.S. Patent Application No.
`10/111,716 (“the ‘716 application”), PCT Application No. PCT/GB00/04110 (“the ‘110
`application”), and United Kingdom Patent Application GB9925227.2 (“the ‘227.2 application”).
`
`
`5. I am currently Director of System Engineering and Software Development for Conditional
`Access and Identity Management Systems for SiriusXM radio. In my current position at
`SiriusXM, I manage systems that employ many of the industry standard techniques for
`
`USPTO Control No. 95/002,245
`
`
`
`Page 1 of 35
`
`SAMSUNG 1003
`
`

`
`calculating one-way hash functions, encrypting content with both symmetric and asymmetric
`encryption, key management, key generation, zero-knowledge proof, authentication via digital
`signature, and other industry standard security techniques. I lead a team of systems engineers,
`requirement analysts, and software developers responsible for all conditional access (CA)
`security systems. This includes CA systems to control delivery of satellite radio services to
`automobiles and other satellite signal receivers, CA systems to control the delivery of streaming
`audio services over the Internet, and CA systems to control delivery of telematics services to
`automobiles. The systems that I manage rely on cryptographic methods and systems for
`protecting content and managing keys, and include identity management infrastructure such as
`SAML and Auth solutions for sign-on.
`
`
`6. From 1997 to 2000, I worked for Signafy (acquired by NEC) where I developed digital
`watermarking technology for use in rights management systems, and participated in the Data
`Hiding Subgroup of the Copy Protection Technical Working Group. In this role, I became very
`familiar with the field of Digital Rights Management and underlying cryptographic component
`technologies including digital signatures, digital certificates, and public key encryption.
`
`
`7. From 2000 to 2005, I worked with the National Institute of Standards and Technology to develop
`robust tracking technology allowing content owners to identify sources of digital piracy of
`motion picture content.
`
`
`8. In 2012, I worked as a Video and Streaming Consultant for VideoTechResearch LLC of
`Princeton Jct, NJ. VideoTechResearch provides consulting services that include on-site systems
`engineering for multimedia security and streaming, pre-sales business development, project
`management, and strategy and roadmap development. While at VideoTechResearch, I supported
`SiriusXM Satellite Radio, where I worked with the Streaming Services and Products group on
`the architecture of an IP streaming solution based on HLS with associated metadata. I also wrote
`the primary API documentation for the back-end systems and provided support to partner client
`developers implementing clients based on that API. I also supported DAX Technologies, where I
`worked with DAX executives to create a video quality monitoring solution proposal for external
`customers.
`
`
`
`
`
`
`
`Page 2 of 35
`
`

`
`9. Since 2012, I also have been an Adjunct Professor of Electrical and Computer Engineering at the
`New Jersey Institute of Technology Newark, NJ. In this role, I have taught graduate-level
`courses in Digital Image Processing
`
`
`10. From 2009 – 2012, I also worked at Dialogic, Inc. in Eatontown, NJ as the Director Video
`Technologies. At Dialogic, I developed the technology and software components for a new QoE
`video quality monitoring and tracking business, enabling monitoring and tracking of video
`quality across VOD and live streaming.
`
`
`11. From 2008 – 2009, I was a research center director at Thomson, Inc. (Technicolor) in Burbank,
`CA, where I managed a research center of 2 administrators and 15 researchers working in the
`areas of content security, signal processing, and content production and management.
`
`
`12. From 2005–2009, I was a content security lab manager at Thomson, Inc. (Technicolor) in
`Princeton, NJ, where I managed an international group of 10 researchers in the US, France, and
`Germany. I led content security R&D efforts including conditional access systems, digital rights
`management systems, and watermarking systems. I also provided content security expertise and
`technical support for all Thomson business units.
`
`
`13. From 2000–2005, I was a technology leader at Sarnoff Corporation in Princeton, NJ. At Sarnoff,
`I lead Sarnoff’s digital watermarking research efforts in tracking watermarks for motion picture
`content, digital cinema watermarking, video database watermarking, and removable visible
`attribution watermarks; authentication watermarks. I also Developed Sarnoff's audio
`fingerprinting technology for audience monitoring and automatic audit log creation.
`
`
`14. From 1998–2000, I was a research scientist at the NEC Research Institute / Signafy, Inc. in
`Princeton, NJ. There, I developed a number of still image watermarking products, and I
`developed two video watermarking technologies designed for broadcast monitoring and copy
`protection, respectively. I also designed, implemented, and executed testing and evaluation
`procedures for video watermarking technologies.
`
`
`15. From 1995-1999, I earned my Ph.D. Electrical and Computer Engineering from University of
`California Davis, CA. My thesis was titled, “The Derivative of Gaussian Transform,” and my
`
`
`
`
`
`Page 3 of 35
`
`

`
`advisor was Todd Reed. I was a U.S. Department of Education GAANN Fellow under a TRW
`Fellowship. My research represented a study of models of the human visual system and the use
`of one such model to design and build 2D and 3D spatial and spatio-temporal transforms for
`images and image sequences. This transform was then used to build image and image sequence
`compression algorithms that are competitive with JPEG and H.261, respectively.
`
`
`16. In 1990, I earned my M.S. Electrical and Computer Engineering from the Worcester Polytechnic
`Institute Worcester, MA. My thesis was entitled, “Feature Extraction and Surface Recognition
`of Arbitrary Surfaces from Range Data.” This research focused on the modeling of surface data
`clouds, as might be obtained from contemporary lidar systems. An adaptive optimization
`method is applied to a standard triangular mesh to align mesh nodes with 3D feature points.
`
`
`17. In 1987, I earned my in B.S. Electrical Engineering from the Worcester Polytechnic Institute in
`Worcester, MA.
`
`
`18. I was an Associate Editor, EURASIP Journal on Information Security, 2006 – 2014, and an
`Associate Editor, Springer LNCS Transactions on Data Hiding and Multimedia Security, 2006 –
`2014. I was involved with the Technical Program Committee, IEEE International Conference on
`Images Processing 2014; the Technical Program Committee, International Workshop on Quality
`of Multimedia Experience (QoMEX), 2010 – 2013; the Technical Program Committee, SPIE
`Security and Watermarking of Multimedia Contents, 2003 – 2014; the IEEE Multimedia Signal
`Processing Technical Committee, 2008-2012.
`
`
`19. I worked as an editor for Transactions on Evolutionary Computation, 2011; European Signal
`Processing Conference (EUSIPCO), 2008-2011; Journal of Digital Forensics, Security and Law,
`2009; and International Journal of Computer Mathematics, 2008.
`
`
`20. I am an author of two books, including a leading textbook in digital watermarking – an image
`processing technology used for DRM, "Digital Watermarking" by Ingemar J. Cox, Matthew L.
`Miller, and Jeffrey A. Bloom, Morgan Kaufmann Publishers, Inc., San Francisco, 2002, and also
`"Digital Watermarking and Steganography, 2nd Edition" by Ingemar J. Cox, Matthew L. Miller,
`Jeffrey A. Bloom, Jessica Fridrich, and Ton Kalker, Morgan Kaufmann Publishers, Inc., San
`Francisco, 2008.
`
`
`
`
`
`Page 4 of 35
`
`

`
`
`21. I have also published chapters in two books: Digital Rights Management–Concepts and
`Applications by Kambhammettu (2005) and Multimedia Security by Zeng, Yu and Lin (2006)
`
`
`22. My findings explained below are based on my study, experience, and background
`in the digital rights management industry, and are further informed by my education in electrical
`and computer engineering. This declaration is organized as follows:
`
`
`I. Overview
`II. Terminology
`III. Discussion of the Ginter Reference
`IV. Legal Principles
`
`
`
`
`
`Page 5 of 35
`
`
`
`

`
`I. Overview
`23. The ‘720 Patent claims and describes systems and methods relating to financial activity;
`specifically, for processing payments for data downloads. See ‘720 at Abstract, 1:6-8, claim 14.
`In the words of the Patent Owner, the claims are directed toward “storing and paying for data”
`and toward “providing data from a data supplier to a data carrier [including] reading payment
`data from a data carrier [and] forwarding the payment data to a payment validation system.” See
`‘720 at 1:6-8, claim 14. In more detail, the subject matter of claim 14 covers the abstract idea of
`enabling limited use of paid-for/licensed content (which was done with pen and paper for
`decades prior to the invention of modern computers), and fails to meaningfully limit the scope of
`that coverage. See ‘720 at 1:60-66, 5:25-29, claim 14. Claim 14 is not tied, for example, to a
`specific machine, and it fails to transform an article into a different state or thing. Id. The
`independent claims of the ‘720 Patent do recite computer-related terms such as “data supplier”,
`“data carrier”, and “payment validation system”, but these are generic computer terms referring
`to concepts that were well understood by the ‘720 Patent’s effective filing date. Indeed, as
`described in more detail below, several prior art references show that the claims of the ‘720
`Patent altogether fail to recite a novel and unobvious technological feature, just as they fail to
`recite a technical problem solved by a technical solution.
`
`24. The specification of the ‘720 Patent confirms that the computer-related terms recited in the ‘720
`Patent’s claims do in fact relate to technology that is merely, in the words of the patentee,
`“conventional”: the specification states, for example, that “The data access terminal may be a
`conventional computer or, alternatively, it may be a mobile phone” that terminal memory “can
`comprise any conventional storage device,” and that a “data access device . . . such as a portable
`audio/video player . . . comprises a conventional dedicated computer system including a
`processor . . . program memory . . . and timing and control logic . . . coupled by a data and
`communications bus.” 3:64-65; 16:62-65; 18:24-30. That the ‘720 Patent is concerned with
`financial-related data processing rather than with technological innovation is further confirmed
`by other statements in the specification, explaining that payment data forwarded to a payment
`validation system may be “data relating to an actual payment made to the data supplier, or . . . a
`record of a payment made to an e-payment system” that can be “coupled to banks.” See ‘720 at
`6:58-62, 13:46-58. In short, the ‘720 Patent applies generic computer technology toward the
`solution of a financial problem: enabling limited use of paid-for/licensed content. See ‘317 at
`1:60-66, 5:25-29.
`
`
`
`
`
`Page 6 of 35
`
`

`
`
`25. This subject matter was, at the ‘720 Patent’s effective filing date, already well known in the prior
`art. Indeed, the reference discussed in this declaration, Ginter, provides robust description of the
`very subject matter that the ‘720 Patent claims.
`
`
`26. Ginter, for example, describes digital rights management (“DRM”) achieved through a “virtual
`distribution environment” (“VDE”) that controls, using payment and other information, use of
`electronically disseminated and stored content objects. Ginter at Abstract. Ginter’s objects may
`be delivered to end users in “containers” that contain both digital content (which may include,
`for example, textual, audio, video, and/or software elements) and associated control information.
`See Ginter at 13:50-67, 43:24-30, 58:57-65, FIG. 5B. The control information, which may
`include both use status data and use rules, is used in conjunction with budgeting, metering,
`and/or other DRM methods. Ginter at 14:49-15:9. End users interface with Ginter’s VDE
`through “electronic appliances,” which implement these methods to ensure that content is
`accessed and used only in authorized ways. In Ginter, an electronic appliance “may be
`practically any kind of electrical or electronic device,” including, for example, a personal
`computer or a computerized portable device like a smart card or media player. Ginter at
`Abstract, 60:19-30, FIGS. 8, 71. In great detail, Ginter explains that these electronic appliances
`may be used together to facilitate access and authorization; a user may, for example, browse,
`select, and pay for digital content using a terminal that is connected to a portable media player,
`with digital content being ultimately downloaded to, and accessed through, the media player.
`See Ginter at 230:20-42, 40:64-41:16.
`
`
`
`II.
`Terminology
`28. A POSITA1 would understand that the term “payment data,” as described by, and used in the
`claims of the ‘720 Patent, retains its ordinary meaning, and that it encompasses data that relates
`to previous, present, and/or prospective payment. See e.g. ‘720 at Abstract, 1:60-2:3, 4:45-52,
`3:49-64, 4:36-38, 4:59-5:3, 5:4-11, 5:17-2 , claims 2, 3, 12, and 14. A POSITA would
`
`
`1 The term “POSITA”, as used in this declaration, refers to a Person of Ordinary Skill In the Art at the
`
`‘720 Patent’s effective filing date.
`
`
`
`
`
`Page 7 of 35
`
`

`
`understand, for example, that payment data includes information that can be used to make
`payment, and/or to check and validate that payment was made. See e.g.,‘720 at Abstract, 1:60-
`2:, 6:55-61, 13:35-55.
`
`
`III. Discussion of the Ginter Reference
`29. Ginter describes DRM achieved through a “virtual distribution environment” that controls, using
`payment and other information, use of electronically disseminated and stored content objects.
`Ginter at Abstract. In some implementations, Ginter’s content objects are delivered to end users
`in “containers,” which, as depicted by Ginter’s FIG. 5B, contain both information content (which
`may include, for example, textual, audio, video, and/or software elements) and associated control
`information; in other implementations, Ginter’s control information is delivered separately from
`the content with which it is associated. Ginter at 13:50-67, 43:24-30, 58:57-65, FIG. 5B.
`
`
`30. In either case, controls on access to and/or the use of information content may be enforced
`through budgeting, metering, and/or other methods that involve use status data and use rules.
`
`
`
`
`
`
`
`Page 8 of 35
`
`

`
`Ginter at 14:49-15:9. Control information that is associated with one or more of these methods
`may, for example, include: (i) information specifying rights associated with content; (ii)
`information specifying limitations on usage of content and how usage will be paid for; and (iii)
`information specifying how usage of content will be metered, billed, and audited. See Ginter at
`58:66-59:35, FIG. 5B.
`
`31. End users interface with Ginter’s VDE through electronic appliances, which implement these
`methods to ensure that content is accessed and used only in authorized ways; an electronic
`appliance “may be practically any kind of electrical or electronic device,” including, for
`example, a personal computer or smart card. Ginter at Abstract, 60:19-30, FIGS. 8, 71.
`
`32. Ginter describes several variations of its electronic appliances. The electronic appliance 600
`features a Secure Processing Unit (“SPU”) 500 that performs secure data management processes
`including “governing usage of, auditing of, and where appropriate, payment for VDE objects
`300.” Ginter at 63:27-41. Performance of these processes involves the use of control
`information (for example, use status data and use rules) that is maintained in a secure database
`610, which may be stored in non-volatile memory of the SPU itself. See Ginter at 63:27-41,
`65:61-67. The control information may alternatively be stored in a secondary storage 652 that
`stores content objects 300 to which the control information pertains. See Ginter at FIG. 8.
`
`
`
`
`
`
`Page 9 of 35
`
`

`
`
`
`
`
`33. Ginter recognizes that its electronic appliances may be portable. Ginter at 228:37-38. Indeed,
`Ginter contemplates smart card implementations in the form of portable electronic appliances
`that can dock with other electronic appliances, such as personal computers and merchant
`terminals. Ginter at 40:64-41:7, 41:13-16. When connected, a portable smart card electronic
`appliance and a terminal “can securely exchange information related to a transaction, with credit
`and/or electronic currency being transferred to a merchant and/or clearinghouse and transaction
`information flowing back to the card.” Ginter at 41:7-12.
`
`34. With reference to FIG. 71, Ginter describes a specific example of a Portable Electronic
`Appliance (“PEA”) 2600 that stores control information in a non-volatile memory of the PEA’s
`
`
`
`
`
`Page 10 of 35
`
`

`
`SPU 500, in addition to content objects that are separately stored in another non-volatile
`memory, removable/replaceable memory 2622. See Ginter at 228:36-231:65.
`
`
`
`35. SPU 500 includes a non-volatile memory that may store control information, including use status
`data and use rules, in a secure database 610. See Ginter at 65:61-67. SPU 500 may, for example,
`store audit information indicating user payments for VDE content objects, in addition to control
`information used to determine whether a user is authorized to access content objects. See, e.g.,
`Ginter at 65:61-67.
`
`
`
`
`36. Removable/replaceable memory 2622 is yet another separate non-volatile memory that may
`serve as secondary storage for content objects that include content and, in some implementations
`but not in others, control information that is associated with content. See Ginter at 13:50-67,
`14:49-15:9, 230:15-19, 65:61-67.
`
`
`Page 11 of 35
`
`
`
`

`
`
`37. In some embodiments, the PEA is a device that is used by Ginter in combination with another
`electronic appliance 600 (for example, a personal computer or other data terminal). See, e.g.,
`Ginter at 230:20-42, 40:64-41:16.
`
`38. A user of the PEA or the user of another electronic appliance to which the PEA is coupled can
`browse a catalog of content objects stored locally or at a remote object repository and select a
`particular content object for purchase and/or downloading. Ginter at 289:27-35. Payment for a
`selected content object, and the auditing of such a payment, may be made “through the use of
`prepayments, credits, real-time electronic debits from bank accounts and/or VDE node currency
`token deposit account.” Ginter at 63:34-41.
`
`39. Upon selection of a particular content object, the PEA or a coupled electronic appliance can
`transmit to a clearinghouse audit information reflecting a payment made for the selected object.
`See, e.g., Ginter at 41:7-12, 161:42-64.
`
`40. After validating the audit information, the clearinghouse transmits an administrative response
`back to the PEA or electronic appliance. Ginter at 161:65-162:8. Subsequently, the selected
`VDE content object and accompanying control information is downloaded from the object
`repository and stored in memory of the PEA. See Ginter at 289:67-290:2, 161:42-162:6 .
`
`
`41. Once downloaded to the PEA responsive to the validated user purchase, a content object stored
`in the PEA’s removable/replaceable memory may be accessed responsive to a user request.
`Ginter at 230:48-59, 183:24-30. Providing access may involve updating audit information stored
`in the PEA’s SPU. See Ginter at 48:65-49:14, 136:7-19, 142:43-143:22. This may involve, for
`example, updating a meter method User Data Element (“meter method UDE”) that indicates
`usage of the content object, calculating a cost based on a cost per access of the content object
`stored in a billing Method Data Element (“billing MDE”) and then comparing the calculated cost
`with an aliased budget value stored in a budget method UDE to determine whether an access
`limit has been exceeded. See Ginter at 172:32-35, 185:57-59, 186:15-24, 264:62-265:16.
`
`
`42. If access is permitted, the content object may be played or otherwise accessed for the user. See
`Ginter at 58:33-34.
`
`
`
`
`
`Page 12 of 35
`
`

`
`
`43. Ginter recognizes that its electronic appliances, which may function as multimedia terminals,
`may be portable. See Ginter at 34:1-6, 228:37-38, FIGS 8 and 71. Indeed, Ginter contemplates
`smart card implementations in the form of portable electronic appliances that can dock with other
`electronic appliances, such as personal computers and merchant terminals. Ginter at 40:64-41:7.
`With reference to FIG. 71, Ginter describes an example of a handheld PEA 2600 that stores
`content objects (which may contain multimedia content data), in addition to use rules that control
`user access to stored content. See 228:36-231:65, 229:18-34, 230:20-42, FIG. 71; see also
`Ginter at 34:1-6, 40:64-41:7, 100:50-55, 109:2-4, 228:36-231:65, 229:18-20, 230:7-47.
`
`44. As FIG. 71 depicts, PEA 2600 includes an external bus interface 2606, an interface for reading
`and writing data from and to PEA 2600. See Ginter at 228:39-50, 41:13-16, 230:20-42, FIGS. 8
`and 71; see also Ginter at 62:30-33, 224:61-225:6, 282:64-283:2. External bus interface 2606
`may interface with a host system, for example, electronic appliance 600, that includes a data
`carrier interface (for example, a mating connector, electronic connector bus interface, and/or
`system bus). See Ginter at 41:13-16, 230:20-42, 228:39-50, FIGS. 8 and 71.
`
`45. PEA 2600 may further include a wireless interface (for example, a communications controller
`666) configured to interface with a wireless network for accessing a remote computer system, for
`example, another electronic appliance 600 functioning as an external object repository, a data
`supplier. See Ginter at 62:30-33, 226:55-227:1, 224:61-225:6, 229:18-34, FIGS. 8, 70; see also
`Ginter at 34:1-6, 100:50-55, 109:2-4, 161:5-11, 233:53-57, 224:14-16, 224:61-225:6, 226:63-
`227:2, 280:63-281:2.
`
`46. PEA 2600 includes removable/replaceable memory 2622, a non-volatile content data memory
`that is configured to store content objects and that is coupled to external bus interface 2606
`and/or communications controller 666 by bus 2610. See Ginter at 230:15-19, 229:18-34, 65:61-
`67; see also Ginter at 62:41-45; 62:64-65, FIG. 8. Content objects stored in PEA 2600’s
`removable/replaceable memory 2622 may contain multimedia content data, for example, music
`data and video data. See Ginter at 230:47-58, 58:57-62.
`
`
`47. PEA 2600 also includes a content access PIN memory (for example, RAM 534) to store a PIN
`number (for example, unique identifier, key, and/or password) for controlling access to
`
`
`
`
`
`Page 13 of 35
`
`

`
`removable/replaceable memory 2622. See Ginter at 229:13-18, 237:34-48, 229:18-34; see also
`Ginter at 62:64-65, 229:18-20, 235:3-29.
`
`48. PEA 2600 further includes, in non-volatile memory of SPU 500, a secure database portion 610
`that contains use rules (for example, billing method MDE and/or budget method UDE) and use
`status data (for example, meter method UDE) for controlling user access to multimedia content
`contained in content objects. See Ginter at 65:61-67, 59:17-23, 289:57-290:2, 58:33-34, 136:28-
`34, 190:45-57, 264:62-265:16, 128:23-36, 169:4-6, 229:18-20, 230:7-19, 126:36-44, 181:7-12,
`186:56-62, 187:52-57, 62:64-67. Secure database 610 may also function as a payment data
`memory that stores payment data (for example, audit information) that can be provided to a
`payment validation system (for example, a clearinghouse and/or external object repository). See
`Ginter at 169:4-6, 184:65-185:2, 231:64-232:1, 232:19-24, FIG. 71; see also Ginter at 9:24-32,
`62:64-67, 63:34-41, 126:36-44, 161:42-161:6, 163:38-61, 175:3-22, 175:47-176:1, 229:18-20,
`230:7-19, 184:65-185:2, FIG. 8. Like removable/replaceable memory 2622, PEA 2600’s SPU
`500 is coupled by bus 2610 to external bus interface 2606 and/or communications controller 666.
`See Ginter at FIG. 71, 48:65-49:14, 63:34-41, 169:4-6.
`
`49. When PEA 2600 and electronic appliance 600 are electronically coupled (for example,
`wirelessly, or through PEA 2600’s external bus interface 2606 and electronic appliance 600’s
`data carrier interface) electronic appliance 600 may read data from PEA 2600’s secure database
`610 and may write data to PEA 2600’s removable/replaceable memory 2622. See Ginter at 41:7-
`16, 48:65-49:14, 65:61-67.
`
`50. PEA 2600 includes a program store, ROM 2617, storing processor control code (for example,
`software instructions). See Ginter at 229:34-60, 229:41-67, 63:8-15, 65:42-51, FIGS. 8, 9, 71;
`see also Ginter at 60:49-62; 63:8-25; 65:42-66:2.
`
`
`51. PEA 2600 also includes processors, SPU 500 and CPU 2616, that implement code in ROM 2617
`and that are coupled to ROM 2617, removable/replaceable memory 2622, secure database 610,
`and to external bus interface 2606 and/or communications controller 666. See Ginter at 65:42-
`66:2, 229:34-67, FIGS. 8, 71; see also Ginter at 60:31-35, 62:13-17, 62:25-28, 62:56-58, 63:8-
`15, 75:35-37, 79:60-67.
`
`
`
`
`
`
`Page 14 of 35
`
`

`
`52. PEA 2600 further includes a user interface made up of multiple components, which may include
`a keypad, user input buttons, printer 2624, and one or more display devices 2618. See Ginter at
`229:61-230:19; see also Ginter at 60:31-35. PEA 2600’s user interface enables users to, for
`example, browse, select, retrieve, and access item(s) of multimedia content data that are
`available for retrieving and/or that are stored locally in removable/replaceable memory 2622.
`See Ginter at 169:51-55, 183:24-30. Indeed, PEA 2600’s user interface is operable to enable a
`user to make multiple selections of multimedia content items, the items potentially being
`available from more than one source. See Ginter at 169:51-55, 183:24-30, 177:10-18; see also
`Ginter at 60:31-35, 82:32-41, 169:51-55, 177:10-18, 183:24-30, 237:49-237:2, 238:50-64,
`289:41-64, FIG. 72D. PEA 2600’s user interface is also operable to enable a user to access
`selected items of multimedia content, responsive to control code permitting access to the items.
`See Ginter at 57:51-58:62; see also Ginter at 81:46 51, 99:43-58.
`
`53. The user interface may, for example, be operable to play multimedia content items selected by a
`user. See Ginter at 60:31-35, 230:48-59. PEA 2600’s display, which may include printer 2624
`and one or more display devices 2618, may be used, for example, to present selected items of
`multimedia content to a user, in addition to data relating to the multimedia content (for example,
`a name, access unit size, cost per access unit, and/or text description of the content). See Ginter
`at 229:61-230:19, 230:48-59, 81:46-51; see also Ginter at 57:67-58:34, 58:33-34, 60:31-35,
`99:43-58, 286:57-287:4, 229:61-230:19, FIGS. 72A-D.
`
`54. Ginter discloses that a user of an electronic appliance, for example, PEA 2600, may use the
`electronic appliance to access identifier data (for example, a catalog) identifying locally and/or
`remotely stored content objects that are available for purchase, the catalog providing content
`information pertaining to the content objects that it identifies (for example, content titles, text
`descriptions, abstracts, cost data including pricing, and other information). See Ginter at 237:49-
`60, 287:59-288:2, 289:27-35, FIGS. 72B, 72D; see also Ginter at 102:59-67, 238:50-64, 287:59-
`288:2, 289:27-35. An example catalog is depicted in Ginter’s FIG. 72D, which is reproduced
`below.
`
`
`55. In more detail, PEA 2600’s SPU 500 and/or CPU 2616 implement code to request a catalog
`identifying items of multimedia content that are stored in removable/replaceable memory 2622
`and/or that are available for retrieving from an external source via a wireless interface (for
`
`
`
`
`
`Page 15 of 35
`
`

`
`example, via communications controller 666). See Ginter at 238:50-64, FIG. 72D; see also
`Ginter at 65:61-67, 102:17-22, 282:34-57, 288:20-29. A catalog may, for example, be wirelessly
`requested and received from a data supplier and/or clearinghouse. See Ginter at 237:49-60,
`238:50-64, 287:59-288:2, FIGS. 72B, 72D; see also Ginter at 65:61-67, 102:17-22, 102:59-67,
`238:50-64, 282:34-57, 287:59-288:29, 289:27-35.
`
`56. SPU 500 and/or CPU 2616 implement code to display identified items of multimedia content that
`are available for retrieving and/or that are available from removable/replaceable memory 2622.
`See Ginter at 81:46-51, 229:18-34, 229:61-230:19, 238:50-64, FIGS. 72A-D; see also Ginter at
`65:61-67, 81:46-51, 102:17-22, 237:49-60, 238:50-64, 282:34-57, 287:59-288:29, 289:27-35. A
`received catalog of available content objects may, for example, be displayed to a user through
`PEA 2600’s display device 2618. See Ginter at 230:10-13, 81:46-51, 229:18-34, FIG. 72D.
`
`57. SPU 500 and/or CPU 2616 implement code to receive user selections of stored items of
`multimedia content that are available for retrieving from an external source and/or that are
`available from removable/replaceable memory 2622. See Ginter at 177:10-18. 183:24-30,
`287:59-288:2; see also Ginter at 82:32-41, 237:49-237:2, 238:50-64, 289:41- 64, FIG. 72D. SPU
`500 and/or CPU 2616 further implement code to, responsive to one or more user selections of
`multimedia content items, transmit, via a wireless interface (for example, communications
`controller 666) audit information relating to payment for the selected items for validation by a
`payment validation system (for example, a clearinghouse). See Ginter at 63:34-41, 161:42-
`162:6, 163:38-61, 175:3-22, 175:47- 176:1.
`
`
`58. In more detail, and as explained above, Ginter provides that payment for a selected content
`object, and the auditing of such a payment, may be made “through the use of prepayments,
`credits, real-time electronic debits from bank accounts and/or VDE node currency token deposit
`account.” Ginter at 63:34-41. After receiving a user selection of a particular content object,
`PEA 2600 transmits to a clearinghouse, for purposes of validation, audit information reflecting a
`payment made for the selected object. See Ginter at 161:42-64; see also Ginter at 41:7-12, 48:65-
`49:14, 126:8-35, 169:4-6, 172:32-35, 185:57-59, 186:15-24, 264:62-265:16.
`
`59. SPU 500 and/or CPU 2616 implement code to receive, via a wireless interface, payment
`validation data defining if the payment validation system has validated payment for the selected
`
`
`
`
`
`Page 16 of 35
`
`

`
`item(s) of multimedia content. See Ginter at 163:38-6