Exhibit 2015
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`Zynga, Inc. v. Personalized Media Communications, LLC
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`Case |PR2013-00171 (SCM)
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`Zynga, Inc. v. Personalized Media Communications, LLC
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`Case |PR2013-00171 (SCM)
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`IPR2013-00171
`Patent No. 7,734,251 B1
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________
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`ZYNGA, INC.
`Petitioner
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`V.
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`PERSONALIZED MEDIA COMMUNICATIONS LLC
`Patent Owner
`___________________________
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`Case No. IPR2013-00171
`U.S. Patent No. 7,734,251
`___________________________
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`DECLARATION OF SAMUEL H. RUSS, PH.D.
`PURSUANT TO 37 C.F.R. § 1.68
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`I, Dr. Samuel H. Russ, do hereby declare:
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`IPR2013-00171
`Patent No. 7,734,251 B1
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`1.
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`I am making this declaration at the request of Patent Owner
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`Personalized Media Communications, LLC (“PMC”) in the matter of the Inter
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`Partes Review, No. IPR2013-00171, of U.S. Patent No. 7,734,251 (“the ’251
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`Patent.”)
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`I.
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`QUALIFICATIONS & ENGAGEMENT
`2. My qualifications for forming the opinions set forth in this
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`Declaration are summarized here and explained in more detail in my curriculum
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`vitae, which is attached as part of Exhibit 2019. Exhibit 2019 also includes a list
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`of my publications and the cases in which I have testified at deposition, hearing, or
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`trial during the past four years.
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`3.
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`I received a Bachelor’s degree in Electrical Engineering from the
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`Georgia Institute of Technology (“Georgia Tech”) in 1986 and a Ph.D. in
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`Electrical Engineering from Georgia Tech in 1991.
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`4.
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`From 2007 to the present, I have been a member of the faculty of the
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`University of South Alabama as an Assistant and Associate Professor in the
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`Department of Electrical and Computer Engineering. During that time, I have won
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`awards for excellent teaching and have been actively publishing research in home
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`networking and digital video recording (DVR) technologies. I am active in the
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`Institute of Electrical and Electronic Engineers (IEEE) and am a Distinguished
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`Lecturer for the IEEE Consumer Electronics Society. As a consultant, I have
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`conducted briefings for members of the financial community on technology trends
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`in the cable, satellite, and IPTV sectors. I teach classes in subjects including
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`encryption, digital system design, signal integrity, systems engineering, software
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`development, embedded system development, digital logic design, and computer
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`engineering.
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`5.
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`From 2000 to 2007, I worked for Scientific-Atlanta (now Cisco’s
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`Service Provider Video Tech. Group), where I managed a cable set-top box (STB)
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`design group that designed four STB models, including the Explorer 4200 (non-
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`DVR) and 8300 (DVR) models. Set-top boxes contain numerous features relevant
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`to the Harvey patents, including networking, communications, interactivity, the
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`ability to download software, video and audio processing, and digital audio and
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`video. Both models sold several million units. As design-group manager, I was
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`responsible for managing the design and prototyping activities of the group, for
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`interfacing with other groups (especially integrated-circuit design, procurement,
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`software developers, the factory where prototypes were built, and product
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`managers), and for maintaining the hardware and mechanical development
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`schedule. Since the products were produced in extremely high volumes, the
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`projects had very high visibility in the company, and therefore carried a great deal
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`of responsibility. In order to manage the design of cable set-top boxes, I had to be
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`an expert in communications, signal processing, networking, distributed systems,
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`remote downloading of software, encryption/decryption, and software
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`development, including coding and testing.
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`6.
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`Also while at Scientific-Atlanta, I became a staff expert in home
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`networking, conducting demonstrations of breakthrough wireless video-
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`distribution technology and managing a group that developed a new coaxial home
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`networking system. The coaxial system won a Technology and Engineering
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`Emmy® Award in 2013. I became a staff expert in DVR reliability and led a team
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`that improved the software, hardware, repair, manufacturing processes, and vendor
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`qualifications of DVR set-tops and hard disk drives. I was a named an inventor on
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`forty-eight (48) patent applications that were filed while I was at Scientific-
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`Atlanta, twenty five (25) of which have issued as patents as of the writing of this
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`Declaration.
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`7.
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`From 1999 to 2000, I was a Staff Electrical Engineer and then Matrix
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`Manager at IVI Checkmate (now Ingenico), where I managed the hardware design
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`team that completed the design of the eN-Touch 1000 payment terminal. This
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`terminal was in widespread use, for example, at the self-checkout at Home Depot®.
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`8.
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`I also served on the faculty of Mississippi State University from 1994
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`to 1999 as an Assistant Professor in the Department of Electrical & Computer
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`Engineering where I taught circuit board design and two-way interactive video
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`classes, among other things. I managed the development of a distributed run-time
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`environment that could run complex physical simulations on networked
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`workstations, and could migrate software between workstations while it was
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`running.
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`9.
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`I have also authored 32 journal articles and conference papers. A
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`recent conference paper on digital video recording won second place in a “best
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`paper” competition at the 2011 International Conference on Consumer Electronics
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`in Las Vegas, NV. A complete list of publications is included in my curriculum
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`vitae, attached as Exhibit 2019.
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`10.
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`In my current capacity as an independent consultant, I have reviewed
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`and verified the operation of a wide variety of technical systems, including
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`processors, personal computers, television devices, smart phones, peripherals, and
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`bus systems.
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`11.
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`In forming the opinions expressed in this Declaration, I have relied
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`upon my education and my 22 years of professional and academic experience.
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`12.
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`I am being compensated for my work in this matter at my standard
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`hourly rate of $300 for consulting services. My compensation for this matter is not
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`determined by or contingent on the outcome of this case.
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`II. MATERIALS REVIEWED AND RELIED UPON
`13.
`In preparing this Declaration, I reviewed and considered the following
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`materials:
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`a.
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`b.
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`The ’251 Patent and its file history;
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`The Petition for Inter Partes Review of the ’251 Patent filed by
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`the Zynga Inc. (“the Petitioner”) (“The Petition” or “Pet.”) and the exhibits
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`that are cited by the Petition, including, the Declaration of Charles J.
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`Neuhauser, Ph.D. (“Neuhauser Declaration”, or “Dr. Neuhauser.” or
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`“Neuhauser Decl.”) (Ex. 1011);
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`c.
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`The Patent Trial and Appeal Board’s (“the Board”) Decision on
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`Institution of Inter Partes Review of the ’251 Patent, dated July 25, 2013
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`(“the Decision” or “Dec.”);
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`U.S. Patent No. 4,204,206 to Bakula (“Bakula”) (Ex. 1010);
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`U.S. Patent No. 4,339,798 to Hedges (“Hedges”) (Ex. 1007);
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`U.S. Patent No. 3,668,312 to Yamamoto (“Yamamoto”) (Ex.
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`d.
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`e.
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`f.
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`1008);
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`g.
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`U.S. Patent No. 4,107,735 to Frohbach (“Frohbach”) (Ex.
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`1009);
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`h.
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`Transcripts of the Deposition of Dr. Neuhauser on October 8-9,
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`2013 (“Neuhauser Dep.”) (Exs. 2013, 2014);
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`i. March 20, 2009 Decision on Appeal by the Board of Patent
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`Appeals and Interference (“March 20, 2009 Decision”) (Ex. 1005);
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`j.
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`June 26, 2009 Decision on Request for Rehearing by the Board
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`of Patent Appeals and Interference (“June 26, 2009 Decision”) (Ex. 1006);
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`and
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`k.
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`All other documents cited and used in my Declaration.
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`14.
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`In addition to the materials above, I have reviewed materials in
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`connection with related inter partes proceedings Case Nos. IPR2013-00156,
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`IPR2013-00162, and IPR2013-00164. The ’251 Patent and the Patents-at-issue in
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`these related cases, U.S. Patent Nos. 7,860,131, 7,797,717, and 7,908,638, which I
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`refer to as the “Harvey Patents” all share a common disclosure directed to the
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`integrated system of programming communication that I describe in the
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`background of the technology section below.
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`15. An additional basis for my opinions is my own experience as an
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`engineer, acquired, for example, while I was a manager and a staff expert at
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`Scientific-Atlanta (“S-A”). As noted above, I have managed the design of four
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`electronic products that entered mass production (three cable set-top boxes, the
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`Explorer 1840, 4200, and 8300, and one point-of-sale retail terminal, the eN-Touch
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`1000). Two of those products (the Explorer 4200 and 8300) were produced in
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`million-unit quantities. I also became a staff expert in home networking and DVR
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`reliability and performance, as well as all aspects of cable, satellite, and IPTV
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`“Pay-TV“ networks.
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`16.
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`I have also relied on my years of education, teaching, research, and
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`experience concerning software, circuit design, signal integrity, computer
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`architecture, digital logic design and synthesis, embedded systems, distributed
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`computing, computer and network security, and networking.
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`III. SUMMARY OF CONCLUSIONS
`17. As described in detail below, it is my opinion that claims 17-19, 22-
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`24, and 28 of the ’251 Patent are novel and non-obvious over the prior art cited by
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`the Petitioner, including Bakula, Hedges, Frohbach and Yamamoto.
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`18. Also, for the reasons set forth below, I conclude that a person of
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`ordinary skill in the art at the time of the invention would not have had reason to
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`modify the prior references in the manner stated in the Petition and in the
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`Neuhauser Declaration, that are relied upon by the Board in its Decision.
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`IV. LEGAL STANDARDS
`19.
`I am not an attorney. I have been advised of the following general
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`principles of patent law to be considered in formulating my opinions as to whether
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`the claims of the ’251 Patent are anticipated or would have been obvious to a
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`person of ordinary skill in the art at the time of the invention in view the prior art.
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`20.
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`It is my understanding that in determining whether a patent claim is
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`anticipated or obvious in view of the prior art, the Patent Office must construe the
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`claim by giving the claim its broadest reasonable interpretation consistent with the
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`specification. For the purposes of this review, I have construed each claim term in
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`accordance with its plain and ordinary meaning under the required broadest
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`reasonable interpretation.
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`A. Anticipation
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`21.
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`It is my understanding that anticipation under 35 U.S.C. § 102
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`requires that a single prior art reference or product, discloses or contains, expressly
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`or inherently, every limitation of the claimed invention. The standards for
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`anticipation from 35 U.S.C. §102(a) and (b) are reproduced below:
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`a.
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`The invention was known or used by others in this country, or
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`patented or described in a printed publication in this or a foreign country,
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`before the invention thereof by the applicant for patent, or
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`b.
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`The invention was patented or described in a printed
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`publication in this or a foreign country or in public use or on sale in this
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`country, more than one year prior to the date of the application for patent in
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`the United States.
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`(35 U.S.C. §§102(a)-(b) (2012).)
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`22.
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`I understand that, in general, the anticipation analysis under 35 U.S.C.
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`§ 102 is limited to the use of a single reference. I further understand that portions
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`of additional documents may be relied upon as part of the anticipation analysis if
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`the primary reference incorporates the additional documents by reference. In order
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`for the primary reference to incorporate additional documents by reference, the
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`primary reference must identify with detailed particularity what specific material it
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`incorporates, and clearly indicate where that material is found in the additional
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`documents. A mere reference to another document is insufficient to incorporate
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`that document by reference.
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`23.
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`I understand that a claimed invention is anticipated under 35 U.S.C. §
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`102(e) if that invention is described in another U.S. Patent that was filed earlier,
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`unless the inventor of the claimed invention conceived of the claimed invention
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`before the other U.S. Patent was filed.
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`B. Obviousness
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`24.
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`It is my understanding that a claim is invalid for obviousness under 35
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`U.S.C. § 103 if two or more prior art references in combination disclose, expressly
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`or inherently, every claim limitation so as to render the claim, as a whole, obvious.
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`Alternatively, a claim can be invalid under 35 U.S.C. § 103 if a single prior art
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`reference combined with the knowledge of one of ordinary skill in the art discloses
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`every claim limitation so as to render the claim, as a whole, obvious. The relevant
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`standard for obviousness is as follows:
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`a.
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`A patent may not be obtained even though the invention is not
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`identically disclosed or described as set forth in section 102 of this title, if
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`the differences between the subject matter sought to be patented and the
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`prior art are such that the subject matter as a whole would have been obvious
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`at the time the invention was made to a person having ordinary skill in the
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`art to which said subject matter pertains. Patentability shall not be negated
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`by the manner in which the invention was made.
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`(35 U.S.C. §103(a) (2012).)
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`25.
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`I understand that in determining whether or not a patented invention
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`would have been obvious, the following factors should be considered: (a) the scope
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`and content of the prior art; (b) the differences between the prior art and the claims
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`at issue; (c) the level of ordinary skill in the art; and (d) whatever “secondary
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`considerations” may be present.
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`26.
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`I understand that certain “secondary considerations” may be relevant
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`in determining whether or not an invention would have been obvious, and that
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`these secondary considerations may include commercial success of a product using
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`the invention, if that commercial success is due to the invention; long-felt need for
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`the invention; evidence of copying of the claimed invention; industry acceptance;
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`initial skepticism; failure of others; praise of the invention; and the taking of
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`licenses under the patents by others.
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`27.
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`I understand that a patent composed of several elements is not proved
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`obvious merely by demonstrating that each of its elements was, independently,
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`known in the prior art. But multiple prior art references or elements may, in some
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`circumstances, be combined to render a patent claim obvious. I understand that I
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`should consider whether there is an “apparent reason” to combine the prior art
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`references or elements in the way the patent claims. To determine whether such an
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`“apparent reason” to combine the prior art references or elements in the way a
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`patent claims, it will often be necessary to look to the interrelated teaching of
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`multiple patents, to the effects of demands known to the design community or
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`present in the marketplace, and to the background knowledge possessed by a
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`person having ordinary skill in the art.
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`28.
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`I also understand that when the prior art “teaches away” from
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`combining prior art references or certain known elements, discovery of a
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`successful means of combining them is more likely to be non-obvious. A prior art
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`reference may be said to “teach away” from a patent when a person of ordinary
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`skill, upon reading the reference, would be discouraged from following the path set
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`out in the patent or would be led in a direction divergent from the path that was
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`taken by the patent. Additionally, a prior art reference may “teach away” from a
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`claimed invention when substituting an element within that prior art reference for a
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`claim element would render the claimed invention inoperable.
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`29.
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`I also understand that it is not permissible to use hindsight in assessing
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`whether a claimed invention is obvious. Rather, I understand that, to assess
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`obviousness, you must place yourself in the shoes of a person having ordinary skill
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`in the relevant field of technology, at the time the inventions were made, who is
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`trying to address the issues or solve the problems faced by the inventor, and ignore
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`the knowledge you currently now have of the inventions.
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`C.
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`30.
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`Persons of Ordinary Skill in the Art
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`I believe that the ’251 Patent is addressed to a person with at least the
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`equivalent of a first college degree in digital electronics, electrical engineering,
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`computer engineering, computer science, or a related technical degree, with several
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`years (e.g., 2-5 years) of post-degree experience in a similar field. In determining
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`who would be a person of ordinary skill, I considered at least the following criteria:
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`(a) the type of problems encountered in the art; (b) prior art solutions to those
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`problems; (c) the rapidity with which innovations are made; (d) the sophistication
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`of the technology; and (e) the education level of active workers in the field.
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`V. BACKGROUND TECHNOLOGY OF THE ’251 PATENT AND
`RELATED PATENTS
`31. The ’251 Patent foresaw a world in which control signals enabled the
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`merger of multimedia content with, for example, broadcast television to provide
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`graphical content and audio content, tailored to the needs of individual subscribers.
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`Prior to the ’251 Patent, the art of the era involved terminals connected to
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`mainframes, standalone computers, or broadcast television. The ’251 Patent
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`combined this functionality in a novel manner to provide personalized, and
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`interactive combined medium programming.
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`32. At a high level, the ’251 Patent describes an integrated system of
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`programming communication, and it involves the fields of computer processing,
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`computer communications, television, radio, and other electronic communications.
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`(’251 Patent, 1:20-27.) The inventors understood that there was great potential for
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`combining the capacity of broadcast communications media to convey ideas with
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`the capacity of computers to process and output user specific information. For
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`example, such a system could combine the capacity for conveying general
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`information to large audiences (such as telling them that stock prices rose today in
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`heavy trading) with information of specific relevance to each particular user in the
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`audience (such as telling a particular person “but the value of your stock portfolio
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`went down. ”). (’251 Patent, 1:52-60.)
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`33. As the patents explains,
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`Unlocking this potential is desirable because these new media will add
`substantial richness and variety to the communication of ideas,
`information and entertainment. Understanding complex subjects and
`making informed decisions will become easier.
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`To unlock this potential fully requires means and methods for
`combining and controlling receiver systems that are now separate.
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`(’251 Patent, 1:63-2:3.)
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`34. While the ’251 Patent describes what could be a large and
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`complicated system for delivering many types of personalized programming, the
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`inventors recognized that in specific situations fewer functions would be required,
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`and that, in such situations, one or more of the specific operating elements
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`described in the patent could be omitted. Indeed, a central objective of the
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`invention was to provide flexibility regarding the installed equipment. By
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`including such a capacity for wide variation, individual subscribers were given the
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`widest range of information options at the least cost in terms of installed
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`equipment. The inventors described a system with flexibility for expanding the
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`capacity of installed systems through transmitted software, for altering installed
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`systems in a modular fashion by adding or removing components, and for
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`restricting the programming to only certain subscribers if such was desired. (’251
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`Patent, 9:1-16.)
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`35. The specification is organized around a set of examples that show
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`numerous ways in which the inventions can be practiced. The patent specification
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`shared by the ’251 Patent begins by describing an example that creates a
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`personalized presentation using the “Wall Street Week” television program
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`combined with local data about the subscriber’s own stock portfolio. That
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`introductory example is then followed with eleven additional examples that show
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`applications of the inventions to such areas as the sale of pork bellies, the
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`preparation of Indian food, and the coordination of farming activities.
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`36. One of the examples described in the patent involves the television
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`show Wall Street Week. As the patents explain, with the patented invention, Wall
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`Street Week goes from being a television show that merely conveys general stock
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`market information to a wide audience to become instead a personalized combined
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`media experience in which each individual viewer sees his or her own individual
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`stock portfolio performance in combination with the general stock market
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`information. For this to work, the subscriber needs more than just a television set.
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`The subscriber station described in this example includes a microprocessor or
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`microcomputer and a disk drive. Stored on this disk drive is a file that contains
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`information about the subscriber’s stock portfolio. (’251 Patent, 11:29-58.)
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`37. The microcomputer accesses this data file and calculates the
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`performance of the subscriber’s stock portfolio. The microcomputer then
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`constructs a graphic image showing that individual performance. The system
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`accesses a local “portfolio data file” for information, and calculates the
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`performance of the subscriber’s personal stock portfolio to prepare a graphic image
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`of that performance. (’251 Patent, 13:24-29.) An example of such a graphic image
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`is shown in Figure 1A of the patent.
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`38. While these calculations are occurring, the conventional television
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`image and the sound of the transmitted “Wall Street Week” program are presented
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`on the TV monitor. During this time, the program may show the “talking head” of
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`the host as he describes the behavior of the stock market over the course of the
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`week. At some point, the host says, “Now as we turn to the graphs, here is what
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`the Dow Jones Industrials did in the week just past,” and a studio generated
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`graphic is transmitted. (’251 Patent, 13:58-66.) An example of a graphic image
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`showing the general stock market condition is shown in Figure 1B of the patent.
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`39. So far, nothing personalized has been presented to the subscriber. But
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`then the host says, “And here is what your portfolio did,” and the viewer becomes
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`engaged in a personalized media presentation. A signal instructs the
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`microcomputer to overlay the personalized graphic information of Figure 1A onto
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`the received information of Figure 1B and transmit the combined information to a
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`monitor, which displays an image showing the subscriber’s own portfolio
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`performmance overllaid on thee graphic describing tthe markett at large. ((’251 Patennt,
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`IPR2013-000171
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`Patent NNo. 7,734,2551 B1
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`13:67-14:15; 230:9-16.)
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` (’251 PPatent, Fig.. 1B; Fig. 11C.)
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`440. As thhe patent exxplains, this process
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`would nott be a one-ttime event
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`: “In
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`actualityy, the proccess of conttrolling computer-baased combiined mediaa operationns is
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`continuous and involves sysstematic inpputting andd maintainning of up-tto-date useer
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`specificc data at eaach subscribber stationn.” For exaample, onlyy at subscrriber statio
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`where uuser specifiic stock daata is mainttained systtematicallyy and up-too-date can tthe
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`system generate immages thatt actually s
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`how the peerformancee of the poortfolios of f the
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`subscribbers. (’2511 Patent, 2330:45-54.))
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`441. Anotther exampple provideed is the “EExotic Meaals of Indiaa” programm and
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`advertissements forr pork belllies. As wiith the Walll Street WWeek exampple, portio
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`of the cooking shoow are commmon to alll of the subbscribers.
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`the pateented invenntion, the ccooking shoow becom
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`es a personnalized expperience, aand
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`the pateent gives twwo examples of that ppersonalizaation. In oone examplle, the pricce of
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`17
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`pork bellies varies from person to person based on the supermarket that is nearest
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`IPR2013-00171
`Patent No. 7,734,251 B1
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`that individual, the “spot” price of pork bellies, and the transportation costs to the
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`customer. By accessing user specific information, the system is able to calculate
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`an individualized pork belly price for each viewer of the cooking program. During
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`a commercial break, an announcer promises to “deliver to you, at cost, all the pork
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`you need to entertain five hundred people for this low, low price” -- at which point
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`your personalized price appears on the screen. Using the patented invention, each
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`subscriber can be shown a different, personalized price on his or her TV monitor.
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`(’251 Patent, 252:19-38.)
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`42. When the cooking show returns from the commercial break, the
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`announcer says that the special ingredients for tonight’s show are available for
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`delivery from a local supermarket chain. And, once again, the cooking show
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`becomes a personalized experience. The system uses user specific information to
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`determine the telephone number of the supermarket that is nearest your house, and
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`the number of that supermarket is displayed on the screen. Other features of this
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`example described in the patents include the ability for each subscriber to see
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`different food choices based on their personal tastes (such as mild or spicy) and the
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`ability to transmit a personalized shopping list back to the supermarket when the
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`user enters a special code at the subscriber station. (’251 Patent, 253:65-254:33.)
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`18
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`43. As discussed above, the inventions in the ’251 Patent are explained
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`IPR2013-00171
`Patent No. 7,734,251 B1
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`using numerous examples and platforms as illustrations, but, as the ’251 Patent
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`also explains, the inventions are not limited to just those examples and platforms.
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`The disclosed system has wide applicability, involving “the fields of computer
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`processing, computer communications, television, radio, and other electronic
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`communications. ” (’251 Patent, 1:20-27.) “The programming may be delivered
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`by any means including over-the-air, hard-wire, and manual means. ” (’251
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`Patent, 7:6-8.) The term “programming” is defined broadly: “The present
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`invention consists of an integrated system of methods and apparatus for
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`communicating programming. The term ‘programming’ refers to everything that is
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`transmitted electronically to entertain, instruct, or inform, including television,
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`radio, broadcast print, and computer programming was well as combined medium
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`programming.” (’251 Patent, 6:24-29.)
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`44. Further, a key feature of the disclosed inventions is expandability:
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`“Yet another objective is expandability. As the operating capacities of computer
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`hardware have grown in recent decades, increasingly sophisticated software
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`systems have been developed to operate computers. Often incompatibilities have
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`existed between newly developed operating system software and older generations
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`of computer hardware. It is the objective of the system of signal composition of
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`the present invention to have capacity for expanding to accommodate newly
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`developed subscriber station hardware while still serving older hardware
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`IPR2013-00171
`Patent No. 7,734,251 B1
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`generations.” (’251 Patent, 22:54-63.)
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`45. Flexibility is another key feature: “A central objective of the present
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`invention is to provide flexibility in regard to installed station apparatus. At any
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`given time, the system must have capacity for wide variation in individual station
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`apparatus in order to provide individual subscribers the widest range of
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`information options at the least cost in terms of installed equipment. Flexibility
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`must exist for expanding the capacity of installed systems by means of transmitted
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`software and for altering installed systems in a modular fashion by adding or
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`removing components.” (’251 Patent, 9:5-14.)
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`46. The inventors saw “great potential” in their disclosed inventions, and
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`they believed that unlocking that potential would “add substantial richness and
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`variety to the communication of ideas, information and entertainment.” (’251
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`Patent, 1:52–1:67.) Their objective was “to unlock this great potential in the fullest
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`measure.” ( ’251 Patent, 2:42-45.) The illustrations they used to show how that
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`potential could be unlocked were “presented by way of example only. ” (’251
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`Patent, 161:63, 286:67.) The invention was “not to be unduly restricted” by those
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`examples “since modifications may be made in the structure of the various parts or
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`in the methods of their functioning without functionally departing from the spirit of
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`the invention.” (’251 Patent, 285:38-41.)
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`VI. BAKULA
`47.
`I have been asked to consider whether Bakula anticipates claims 18,
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`IPR2013-00171
`Patent No. 7,734,251 B1
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`19, 22-24 and 28 of the ’251 Patent. As I describe below, I conclude that none of
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`the claims are anticipated. I conclude that the Petitioner failed to demonstrate that
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`Bakula – when understood from the perspective of a person of ordinary skill in the
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`art at the time of the invention – discloses independent claim 1 of the ’251 Patent
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`and its dependent claims.
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`48. U.S. Patent 4,204,206 to Bakula et al. (“Bakula“) was filed on August
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`30, 1977 and issued on May 20, 1980.
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`49. Bakula describes a “video display terminal” allowing an editor to “call
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`up a story entered into the data base storage,” “view the story on his display screen
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`and make whatever editing corrections he requires,” and “actuate a send key” to
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`cause the edited story to “be stored at the data base storage.” (Bakula, 4:3-25.)
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`The terminal displays “data characters stored in main memory” by routing the data
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`characters “to the character generator where the data characters are decoded to
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`obtain the proper video dot pattern for display on the CRT screen.” (Bakula, 5:28-
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`33.)
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`A. Claim 18
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`50. Claim 18 recites:
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`IPR2013-00171
`Patent No. 7,734,251 B1
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`18. A method of outputting a video presentation at a receiver station,
`said method comprising the steps of:
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` receiving at least one information transmission at said receiver
`station, said at least one information transmission including a first
`discrete signal and a second discrete signal;
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`detecting said first discrete signal and said second discrete signal in
`said at least one information transmission;
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`passing said detected at least one first discrete signal and said second
`discrete signal to at least one processor;
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`organizing information included in said at least one first discrete
`signal with information included in said second discrete signal to
`provide an organized signal at said receiver station;
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`generating an image in response to said organized signal by
`processing at least one user specific subscriber datum, said at least one
`user specific subscriber datum being stored at said receiver station
`prior to said step of organizing and based on information supplied by
`a user of said receiver station, said generated image including at least
`some information content that does not include any information from
`said discrete signals; and
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`outputting said video presentation to said user, said video presentation
`comprising, firs
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