`
`‘871 Charts
`
`‘871 Charts
`
`
`
`Kyocera Ex. 1002
`
`Kyocera Ex. 1002
`p. 1
`
`
`
`
`
`Overview of KYOCERA AMP’D JET & ANGEL Infringement of the ’871 Patent
`
`Plaintiff accuses KYOCERA of infringement by making, using, selling, offering for sale and importation the KYOCERA AMP’D JET &
`ANGEL (the “Accused System”), and all substantially similar KYOCERA camera phone (or smart phone) products. The term “Accused
`System” includes the associated computer hardware and internal semiconductors, software and data, and processes and methods related thereto.
`
`The Accused System is accused of directly infringing U.S. Patent No. 7,365,871 (the “'871 Patent”). The term “Accused System”
`includes the associated hardware, computer hardware, internal semiconductors, software and data, and processes and methods related thereto.
`The asserted claims include elements that are implemented, at least in part, by proprietary electronics and software in the Accused System and
`Method. The precise designs, processes, and algorithms used in them are held secret, at least in part, and are not publicly available in their
`entirety. An analysis of KYOCERA’s documentation and/or source code may be necessary to fully and accurately describe all infringing
`features and functionality of the Accused System and, accordingly, Plaintiff reserves the right to supplement these contentions once such
`information is made available to Plaintiff. Furthermore, Plaintiff reserves the right to revise these contentions, including as discovery in the case
`progresses, in view of the Court's final claim construction in this action and in connection with the provision of its expert reports.
`
`
`
`
`
`
`
`
`
`
`
`KYO'871-IC 00001
`
`Kyocera Ex. 1002
`p. 2
`
`
`
`
`
`
`
`
`
`KYOCERA AMP’D JET & ANGEL
`
`
`
`
`KYO'871-IC 00002
`
`Kyocera Ex. 1002
`p. 3
`
`
`
`7,365,871 Claim Language
`
`
`
`
`
`1. A handheld self-contained
`cellular
`telephone
`and
`integrated
`image processing
`system for both sending and
`receiving
`telephonic
`audio
`signals and for capturing a
`visual image and transmitting it
`to
`a
`compatible
`remote
`receiving station of a wireless
`telephone network, the system
`comprising:
`
`
`Accused System and Method – KYOCERA AMP’D JET & ANGEL
`
`includes a
`The Accused System
`portable housing with built in wireless
`connectivity.
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`
`
`
`
`
`KYO'871-IC 00003
`
`Kyocera Ex. 1002
`p. 4
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`
`
`
`
`
`
`
`
`
`The Accused System is capable of sending and receiving audio calls to/from a
`compatible remote receiving station.
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 17 of 95)
`
`
`
`KYO'871-IC 00004
`
`Kyocera Ex. 1002
`p. 5
`
`
`
`Rear Camera
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/user-guides.htm
`
`
`
`
`
`
`
`The Accused System comprises of a rear camera for capturing
`visual images and supported by the portable housing.
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`KYO'871-IC 00005
`
`Kyocera Ex. 1002
`p. 6
`
`
`
`
`
`
`
` manually portable housing;
`
`
`
`
`
`
`The Accused System comprises a manually
`portable housing.
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`
`
`
`
`
`
` a
`
`
`
`
`
`
`
`KYO'871-IC 00006
`
`Kyocera Ex. 1002
`p. 7
`
`
`
`
`
`an integral image capture device
`comprising an electronic camera
`contained within the portable
`housing;
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Rear Camera
`
`Source: http://www.kyocera-wireless.com/kx18-phone/user-guides.htm
`
`
`
`
`
`
`
`
`The Accused System comprises of a rear camera for capturing visual images and
`
`supported by the portable housing.
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page11 of95)
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`KYO'871-IC 00007
`
`Kyocera Ex. 1002
`p. 8
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`
`The Accused System
`comprises
`a
`color
`display and electronic
`camera (rear camera)
`in the same housing
`being
`commonly
`movable when
`the
`housing is moved by
`the user.
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/user-guides.htm
`
`
`
` a
`
` display for displaying an
`image framed by the camera,
`the display being supported by
`the housing, the display and the
`electronic
`camera
`being
`commonly movable
`in
`the
`housing when the housing is
`moved by hand;
`
`KYO'871-IC 00008
`
`Kyocera Ex. 1002
`p. 9
`
`
`
`
`
`
`include a processor
`The Accused System must
`supported by
`the portable housing capable of
`generating an image data signal. The processing
`platform(s) necessarily provide the visual image data in
`a digital format and the execution of the compression
`algorithm necessarily provides compressed visual
`image data. Examples of said circuitry include but are
`not limited to the processor core(s), PowerVR GPUs,
`and DSPs (including but not limited to image signal
`processor(s)).
`
`
`
` a
`
` processor in the housing for
`generating an image data signal
`representing the image framed
`by the camera;
`
`
`
`
`
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`In addition ISP does all the other housekeeping, it controls autofocus, exposure, and white
`balance for the camera system. Recently correcting for lens imperfections like vignetting or
`color shading imparted by the imperfect lens system [...] has been added, along with things
`like HDR recombining, noise reduction, other filtering, face or object detection, and
`conversion between color spaces. There’s variance between the features that ISP does, but
`this is really the controller for getting that bayer data into a workable image array.
`
`
`KYO'871-IC 00009
`
`Kyocera Ex. 1002
`p. 10
`
`
`
`
`Obviously the last part is the human interface part of the equation, which is an ongoing pain
`point for many OEMs. There are two divergent camps in smartphone camera UX – deliver
`almost no options, let the ISP and software configure everything automatically (Apple), and
`offer nearly every option and toggle that makes sense to the user (Samsung). Meanwhile
`other OEMs sit somewhere in-between (HTC, others).
`
`http://www.anandtech.com/show/6777/understanding-camera-optics-smartphone-camera-trends/4
`
`
`
`
`KYO'871-IC 00010
`
`Kyocera Ex. 1002
`p. 11
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/tech-specs.htm
`
`
`
`
`
`
`The Accused System provides a removable memory card slot (supports up
`to 512MB) for storage of visual Images. The memory card is located within and
`supported by the portable housing. The memory may include, but is not limited to,
`one or more of the following: internal memory, embedded flash memory, embedded
`RAM, or cache memory. The memory may be associated with one or more digital
`signal processors (including but not limited to image signal processors) or other
`processing units.
`
`
`
`
`
`
`
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 69 of
`94)
`
`
`
` a
`
` memory associated with the
`processor
`for
`receiving and
`storing
`the digitized framed
`image, accessible for selectively
`displaying
`in
`the
`display
`window and accessible
`for
`selectively transmitting over the
`wireless telephone network the
`digitized framed image;
`
`KYO'871-IC 00011
`
`Kyocera Ex. 1002
`p. 12
`
`
`
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`
`
`
`
`
`
`
`
`
`The Accused System includes both internal as well as external memories which are
`accessible for selectively displaying and transmitting digitized images to the compatible
`remote receiving stations over telephone network.
`
`
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/tech-specs.htm
`
`
`
`
`
`
`
`
`
`
`
`
`
`KYO'871-IC 00012
`
`Kyocera Ex. 1002
`p. 13
`
`
`
`262,000 Color display acting as a user
`interface (Operating System: BREW 3.1.3)
`
`
`
` a
`
` user interface for enabling a
`user to select the image data
`signal
`for
`viewing
`and
`transmission;
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/index.htm
`
`
`
`
`
`
`
`The Accused System provides a user interface where a user can select to view or
`send images via MMS or Email messages.
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`
`KYO'871-IC 00013
`
`Kyocera Ex. 1002
`p. 14
`
`
`
`Transmitting Images via Multimedia Messages:
`
`
`
`
`
`
`
`
`
`
`
`The Accused System provides a user interface to view and select the captured
`images that needs to be transmitted to other remote receiving station via MMS.
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 80 and 82
`of 95)
`
`KYO'871-IC 00014
`
`Kyocera Ex. 1002
`p. 15
`
`
`
`
`
`
`
`
`
`
`
`
`
`The Accused System is capable of sending and receiving audio calls
`to/from a compatible remote receiving station.
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 17 of
`95)
`
`
`
` a
`
`the
`in
`telephonic system
`
`and
`housing
`for
`sending
`receiving digitized audio signals
`and for sending the image data
`signal;
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`KYO'871-IC 00015
`
`Kyocera Ex. 1002
`p. 16
`
`
`
`
`
`Transmitting Images via Multimedia Messages:
`
`
`
`
`
`
`
`
`
`The Accused System provides a user interface to view and select the captured
`images that needs to be transmitted to other remote receiving station via MMS.
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 80 and 82
`of 95)
`
`KYO'871-IC 00016
`
`Kyocera Ex. 1002
`p. 17
`
`
`
`
`
`alphanumeric input keys in the
`housing for permitting manually
`input digitized alphanumeric
`signals
`to be
`input
`to
`the
`processor, the telephonic system
`further used for sending the
`digitized alphanumeric signals;
`
`
`
`
`
`The Accused System includes
`a display with alphanumeric
`input keys which are operated
`by
`the user
`for
`sending
`alphanumeric signals.
`
`
`QWERTY
`Keyboard
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`
`
`
`KYO'871-IC 00017
`
`Kyocera Ex. 1002
`p. 18
`
`
`
`
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`
`
`
`
`
`
`
`
`
`
`
`The Accused System is capable of sending digitized signals to the
`compatible remote receiving stations over data network.
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/tech-specs.htm
`
`
`
`
`
`
`
`
`
`
`
`
`
` a
`
`communications
` wireless
`device adapted for transmitting
`any of the digitized signals to
`the compatible remote receiving
`station; and
`
`KYO'871-IC 00018
`
`Kyocera Ex. 1002
`p. 19
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/tech-specs.htm
`
`
`
`Accused
`The
`System includes a
`power
`supply
`(900mAh Li-Ion
`battery)
`for
`powering
`the
`system (Phone).
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 9 of 95)
`
`
`
` a
`
` power supply for powering the
`system.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`KYO'871-IC 00019
`
`Kyocera Ex. 1002
`p. 20
`
`
`
`
`
`
`
`self-contained cellular
`2.The
`telephone and integrated image
`processing system of claim 1,
`wherein the display for framing
`the image to be captured by the
`image
`capture
`device
`is
`operable to display the image at
`the system whereby the image
`can be viewed and framed prior
`to capture in the memory.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 34 of 95)
`
`
`
`includes a
`The Accused System
`display which is operable to display
`the image to be captured. Also, the
`image can be viewed and framed on
`the display prior to capture in the
`memory.
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`
`KYO'871-IC 00020
`
`Kyocera Ex. 1002
`p. 21
`
`
`
`
`
`
`
`3. The self-contained cellular
`telephone and integrated image
`processing system of claim 1,
`wherein the display is operable
`to
`display
`for
`viewing
`alphanumeric messages input at
`the alphanumeric keys.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Display Window
`
`Alphanumeric
`Keys
`
`
`
`
`
`The Accused System includes a display which is operable to display
`
`alphanumeric message entered by the user via alphanumeric keys.
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`
`
`KYO'871-IC 00021
`
`Kyocera Ex. 1002
`p. 22
`
`
`
`
`
`4. The self-contained cellular
`telephone and integrated image
`processing system of claim 1,
`further comprising a removable
`memory module in addition to
`the memory, said removable
`memory able to be removably
`housed
`in
`the housing
`for
`storing captured
`image data
`signals.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/tech-specs.htm
`
`
`
`
`
`
`The Accused System provides a removable memory card slot (supports up
`to 512MB) for storage of visual Images. The memory card is located within
`and supported by the portable housing.
`
`
`
`
`
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 69 of
`94)
`
`
`
`KYO'871-IC 00022
`
`Kyocera Ex. 1002
`p. 23
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`5. The self-contained cellular
`telephone and integrated image
`processing system of claim 1,
`wherein the display is operable
`to display for viewing incoming
`image data signals.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`The Accused System includes a display
`for viewing
`incoming
`image data
`signals or multimedia message.
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 80 and 82
`of 95)
`
`
`
`KYO'871-IC 00023
`
`Kyocera Ex. 1002
`p. 24
`
`
`
`7,365,871 Claim Language
`
`
`
`
`
`6.A handheld cellular telephone
`having an integrated electronic
`camera for both sending and
`receiving
`telephonic
`audio
`signals and for capturing a
`visual
`image, converting
`the
`visual
`image
`to a digitized
`image
`data
`signal
`and
`transmitting digitized
`image
`data
`signal via a cellular
`telephone network, the cellular
`telephone comprising
`
`
`
`Accused System and Method – Kyocera Amp’d Jet & Angel
`
`includes a
`The Accused System
`portable housing with built in wireless
`connectivity.
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`KYO'871-IC 00024
`
`Kyocera Ex. 1002
`p. 25
`
`
`
`
`
`
`
`
`
`
`
`
`
`The Accused System is capable of sending and receiving audio calls to/from a
`compatible remote receiving station.
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 17 of
`95)
`
`
`
`KYO'871-IC 00025
`
`Kyocera Ex. 1002
`p. 26
`
`
`
`Rear Camera
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/user-guides.htm
`
`
`
`
`
`
`
`The Accused System comprises of a rear camera for capturing
`visual images and supported by the portable housing.
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`KYO'871-IC 00026
`
`Kyocera Ex. 1002
`p. 27
`
`
`
`
`
` a
`
`
` manually portable housing
`the
`supporting
`cellular
`telephone and
`the
`integrated
`electronic camera, the cellular
`telephone and
`the
`integrated
`electronic
`camera
`being
`movable in common with the
`housing
`
`
`
`
`
`
`
`
`
`
`
`
`The Accused System comprises a manually portable housing supporting both
`cellular telephone and electronic camera which is commonly movable with the
`ho sing
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf
`
`
`
`
`
`
`
`KYO'871-IC 00027
`
`Kyocera Ex. 1002
`p. 28
`
`
`
`7,365,871 Claim Language
`
`12. A combination of handheld
`wireless telephone and digital
`camera comprising:
`
`
`
`Accused System and Method – Kyocera Amp’d Jet & Angel
`
`The Accused System is a
`handheld
`device with
`built
`in
`wireless
`connectivity and camera.
`
`
`
`
`
`System
`Accused
`The
`comprises of a VGA camera
`
`(rear camera) for capturing
`visual images.
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/tech-specs.htm
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf(Page 1 of 1)
`
`
`
`
`
`KYO'871-IC 00028
`
`Kyocera Ex. 1002
`p. 29
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf(Page 1 of 1)
`
`
`
`
`
`
`
`
`
`
`
`
`The Accused System is capable of sending digitized
`signals to the compatible remote receiving stations
`over wireless data networks.
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 16 of 95)
`
`
`
`
`
`
`
`
`
`
`
`
`KYO'871-IC 00029
`
`Kyocera Ex. 1002
`p. 30
`
`
`
`a handheld housing which
`supports both
`the wireless
`telephone
`and
`the
`digital
`camera, the wireless telephone
`and electronic camera being
`commonly movable with the
`housing;
`
`includes a
`The Accused System
`portable housing with built in wireless
`connectivity.
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf(Page 1 of 1)
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf(Page 1 of 1)
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf (Page 16 of
`
`
`
`KYO'871-IC 00030
`
`Kyocera Ex. 1002
`p. 31
`
`
`
`95)
`
`
`
`
`
`
`
`
`
`
`
`
`
`The Accused System is capable of sending and receiving audio calls to/from a
`compatible remote receiving station.
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 17 of 95)
`
`KYO'871-IC 00031
`
`Kyocera Ex. 1002
`p. 32
`
`
`
`Rear
`Camera
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/tech-specs.htm
`
`
`
`The Accused System comprises of a rear camera for capturing
`visual images and supported by the portable housing.
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf(Page 1 of 1)
`
`
`
`
`
`KYO'871-IC 00032
`
`Kyocera Ex. 1002
`p. 33
`
`
`
`the
`in
`a display supported
`housing for framing an image to
`be captured and for viewing the
`image, whereby an operator can
`view and frame the image prior
`to capture;
`
`262,000 display acting as a
`user
`interface
`(Operating
`System: BREW).
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/index.htm
`
`
`
`
`
`
`
`The Accused System provides a user interface where a user can select to view or
`send images via MMS or Email messages.
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf(Page 1 of 1)
`
`
`
`
`
`KYO'871-IC 00033
`
`Kyocera Ex. 1002
`p. 34
`
`
`
`
`
`
`
`
`
`
`
`The Accused System includes a display which is operable to display the
`image to be captured. Also, the image can be viewed and framed on the
`display prior to capture in the memory.
`
`
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 34 of 95)
`
`
`
`
`
`
`
`KYO'871-IC 00034
`
`Kyocera Ex. 1002
`p. 35
`
`
`
`
`
`a processor for processing the
`image framed by the camera for
`generating a digitized framed
`image as displayed
`in
`the
`display;
`
`The Accused System must be having a processor
`supported by
`the portable housing capable of
`generating an image data signal. The processing
`platform(s) necessarily provide the visual image data in
`a digital format and the execution of the compression
`algorithm necessarily provides compressed visual
`image data. Examples of said circuitry include but are
`not limited to the processor core(s), PowerVR GPUs,
`and DSPs (including but not limited to image signal
`processor(s)).
`
`
`
`
`
`The Accused System includes a display which is
`operable to display the image to be captured. Also,
`the image can be viewed and framed on the display
`prior to capture in the memory.
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf(Page 1 of 1)
`
`In addition ISP does all the other housekeeping, it controls autofocus, exposure, and white
`balance for the camera system. Recently correcting for lens imperfections like vignetting or
`color shading imparted by the imperfect lens system [...] has been added, along with things
`like HDR recombining, noise reduction, other filtering, face or object detection, and
`conversion between color spaces. There’s variance between the features that ISP does, but
`this is really the controller for getting that bayer data into a workable image array.
`
`KYO'871-IC 00035
`
`Kyocera Ex. 1002
`p. 36
`
`
`
`
`Obviously the last part is the human interface part of the equation, which is an ongoing pain
`point for many OEMs. There are two divergent camps in smartphone camera UX – deliver
`almost no options, let the ISP and software configure everything automatically (Apple), and
`offer nearly every option and toggle that makes sense to the user (Samsung). Meanwhile
`other OEMs sit somewhere in-between (HTC, others).
`
`
`
`
`http://www.anandtech.com/show/6777/understanding-camera-optics-smartphone-camera-trends/4
`
`KYO'871-IC 00036
`
`Kyocera Ex. 1002
`p. 37
`
`
`
`a memory associated with the
`processor
`for
`receiving and
`storing
`the digitized framed
`image,
`for
`selectively
`displaying
`in
`the
`display
`window and
`for selectively
`transmitting over a wireless
`telephone network the digitized
`framed image;
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/tech-specs.htm
`
`
`
`
`
`
`The Accused System provides a removable memory card slot (supports up
`to 512MB) for storage of visual Images. The memory card is located within and
`supported by the portable housing. The memory may include, but is not limited to,
`one or more of the following: internal memory, embedded flash memory, embedded
`RAM, or cache memory. The memory may be associated with one or more digital
`signal processors (including but not limited to image signal processors) or other
`i
`
`i
`
`
`
`
`
`
`
`
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 69 of
`94)
`
`
`
`KYO'871-IC 00037
`
`Kyocera Ex. 1002
`p. 38
`
`
`
`Transmitting Images via Multimedia Messages:
`
`
`
`The Accused System provides a user
`interface
`to view and select
`the
`captured images that needs to be
`transmitted to other remote receiving
`station via MMS.
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 80 and 82
`of 95)
`
`
`
`
`
`KYO'871-IC 00038
`
`Kyocera Ex. 1002
`p. 39
`
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf (Page 1 of 1)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`The Accused System is capable of sending
`digitized signals (Here: MMS) to the compatible
`remote receiving stations over wireless data
`networks.
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 16 of 95)
`
`
`
`
`
`
`
`
`
`
`KYO'871-IC 00039
`
`Kyocera Ex. 1002
`p. 40
`
`
`
`telephone being
`the wireless
`selectively operable to accept
`and digitize audio signals to be
`transmitted,
`the
`wireless
`telephone
`being
`selectively
`operable
`to convert received
`digitized audio signals
`into
`acoustic audio,
`the wireless
`telephone
`being
`selectively
`operable to transmit and receive
`non-audio digital signals, the
`non-audio
`digital
`signals
`including a selected digitized
`framed image;
`
`
`
`
`
`
`
`
`
`
`
`
`The Accused System is capable of sending and receiving audio calls to/from a
`compatible remote receiving station.
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 17 of 95)
`
`
`
`KYO'871-IC 00040
`
`Kyocera Ex. 1002
`p. 41
`
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf(Page 1 of 1)
`
`
`
`
`
`
`
`
`
`
`The Accused System is capable of sending
`digitized signals
`to
`the compatible remote
`receiving stations over wireless data networks.
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 16 of 95)
`
`
`
`
`
`
`
`
`
`
`
`
`
`KYO'871-IC 00041
`
`Kyocera Ex. 1002
`p. 42
`
`
`
`a set of input keys supported by
`the
`housing
`to
`permit
`alphanumeric
`signals
`to be
`manually input by an operator
`into the wireless telephone, the
`alphanumeric
`signals
`being
`presented in the display for
`viewing by the operator;
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 11 of 95)
`
`Alphanumeric
`Keyboard
`
`
`
`
`
`
`
`The Accused System includes a Keyboard with alphanumeric input keys which are
`operated by the user for sending alphanumeric signals.
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf(Page 1 of 1)
`
`
`
`KYO'871-IC 00042
`
`Kyocera Ex. 1002
`p. 43
`
`
`
`a power supply supported by the
`housing;
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/tech-specs.htm
`
`
`
`Accused
`The
`System includes a
`power
`supply
`(900mAh Li-Ion
`battery)
`for
`powering
`the
`system (Phone).
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf (Page 9 of
`95)
`
`KYO'871-IC 00043
`
`Kyocera Ex. 1002
`p. 44
`
`
`
`the wireless telephone including
`a wireless transmitter/receiver
`for transmitting digital signals
`sent from and receiving digital
`signals sent
`to
`the wireless
`telephone; and
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf(Page 1 of 1)
`
`
`
`
`
`
`
`
`
`
`The Accused System is capable of sending digitized
`signals to the compatible remote receiving stations
`over wireless data networks including 3G.
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 16 of 95)
`
`
`
`
`
`
`
`
`
`
`
`
`
`KYO'871-IC 00044
`
`Kyocera Ex. 1002
`p. 45
`
`
`
`
`
`Transmitting and Receiving Images via Multimedia Messages:
`
`
`
`The Accused System provides a user
`interface where a user can transmit
`images via multimedia messages.
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 80 and 82
`of 95)
`
`
`
`KYO'871-IC 00045
`
`Kyocera Ex. 1002
`p. 46
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`The Accused System provides a display window where a user can
`view the received multimedia messages and can save the
`attachments to the phone’s memory.
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 82 and 83
`of 95)
`
`
`
`KYO'871-IC 00046
`
`Kyocera Ex. 1002
`p. 47
`
`
`
`
`
`least one camera control
`at
`circuit connected to an input
`device for controlling at least
`one of the following functions:
`gain, pedestal, setup, white clip,
`lens focus, white balance, lens
`iris, lens zoom.
`
`
`
`The Accused system includes an electronic camera for visually framing
`the subject to be captured.
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 34 of 95)
`
`
`
`The Accused System includes a display
`which is operable to display the image to be
`captured and camera controls. White
`Balance can be controlled by tapping their
`respective buttons on the viewfinder screen
`of the camera.
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 33 of 95)
`
`
`
`
`
`
`
`KYO'871-IC 00047
`
`Kyocera Ex. 1002
`p. 48
`
`
`
`13. The combination of claim
`12 and further comprising: a
`removable memory module
`removably
`housed
`in
`the
`housing for storing captured
`images.
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/tech-specs.htm
`
`
`
`
`
`
`The Accused System provides a removable memory card slot (supports up
`to 512MB) for storage of visual Images. The memory card is located within
`and supported by the portable housing.
`
`
`
`
`
`
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf(Page 69 of
`95)
`
`KYO'871-IC 00048
`
`Kyocera Ex. 1002
`p. 49
`
`
`
`
`
`14. The combination of claim
`12 and further comprising: the
`display also being operable for
`viewing images received by the
`receiver.
`
`Display window
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/index.htm
`
`
`
`
`
`
`
`The Accused System includes a display for viewing incoming image data signals or
`multimedia message.
`
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/kx18-phone/pdf/jet_product_brochure.pdf(Page 1 of 1)
`
`
`
`KYO'871-IC 00049
`
`Kyocera Ex. 1002
`p. 50
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`The Accused System provides a display window where a user can
`view the received multimedia messages and can save the
`attachments to the phone’s memory.
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/pdf/kx18_jet_user_guide.pdf (Page 82 and
`
`83 of 95)
`
`KYO'871-IC 00050
`
`Kyocera Ex. 1002
`p. 51
`
`
`
`
`
`
`15. The combination of claim
`12 and further comprising: the
`housing having a first portion,
`the housing having a second
`portion
`joined
`to
`the
`first
`portion, at least one of the first
`portion and the second portion
`being moveable in relation to
`the other of the first portion and
`the second portion, the first
`portion and the second portion
`also being commonly movable
`by hand when fixed in relation
`to each other.
`
`the
`First portion of
`housing consisting of
`display and camera.
`
`
`the
`Second portion of
`housing
`consisting of
`keypad
`
`
`
`
`Source:http://www.kyocera-wireless.com/kx18-phone/
`
`KYO'871-IC 00051
`
`Kyocera Ex. 1002
`p. 52
`
`
`
`
`
`Overview of KYOCERA BRIO Infringement of the ’871 Patent
`
`Plaintiff accuses KYOCERA of infringement by making, using, selling, offering for sale and importation the KYOCERA
`BRIO (the “Accused System”), and all substantially similar KYOCERA camera phone (or smart phone) products. The term “Accused
`System” includes the associated computer hardware and internal semiconductors, software and data, and processes and methods
`related thereto.
`
`The Accused System is accused of directly infringing U.S. Patent No. 7,365,871 (the “'871 Patent”). The term “Accused
`System” includes the associated hardware, computer hardware, internal semiconductors, software and data, and processes and
`methods related thereto. The asserted claims include elements that are implemented, at least in part, by proprietary electronics and
`software in the Accused System and Method. The precise designs, processes, and algorithms used in them are held secret, at least in
`part, and are not publicly available in their entirety. An analysis of KYOCERA’s documentation and/or source code may be necessary
`to fully and accurately describe all infringing features and functionality of the Accused System and, accordingly, Plaintiff reserves the
`right to supplement these contentions once such information is made available to Plaintiff. Furthermore, Plaintiff reserves the right to
`revise these contentions, including as discovery in the case progresses, in view of the Court's final claim construction in this action and
`in connection with the provision of its expert reports.
`
`
`
`
`
`
`
`
`
`
`
`KYO'871-IC 00052
`
`Kyocera Ex. 1002
`p. 53
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Kyocera Brio
`
`KYO'871-IC 00053
`
`Kyocera Ex. 1002
`p. 54
`
`
`
`
`
`
`
`
`7,365,871 Claim Language
`
`
`
`1. A handheld self-contained
`cellular
`telephone
`and
`integrated
`image processing
`system for both sending and
`receiving
`telephonic
`audio
`signals and for capturing a
`visual image and transmitting it
`to
`a
`compatible
`remote
`receiving station of a wireless
`telephone network, the system
`comprising:
`
`Accused System and Method – Kyocera Brio
`
`includes a
`The Accused System
`portable housing with built in wireless
`connectivity.
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/brio-phone/
`
`
`Source: http://www.kyocera-wireless.com/brio-phone/specs/
`
`
`
`
`
`
`KYO'871-IC 00054
`
`Kyocera Ex. 1002
`p. 55
`
`
`
`
`Source: http://www.kyocera-wireless.com/brio-phone/pdf/Brio_payLo_User_Guide_en.pdf (Page
`19 of 121)
`
`
`
`The Accused System is
`capable of sending and
`receiving
`audio
`calls
`a
`to/from
`compatible
`remote receiving station.
`
`
`Source: http://www.kyocera-wireless.com/brio-phone/pdf/Brio_payLo_User_Guide_en.pdf (Page
`30 of 121)
`
`Source: http://www.kyocera-wireless.com/brio-phone/pdf/Brio_payLo_User_Guide_en.pdf (Page
`31 of 121)
`
`
`
`KYO'871-IC 00055
`
`Kyocera Ex. 1002
`p. 56
`
`
`
`
`
`Source: http://www.kyocera-wireless.com/brio-phone/pdf/Brio_payLo_User_Guide_en.pdf (Page
`16 of 121)
`
`
`
`The Accused System comprises of a 1.3
`megapixel rear camera for capturing visual
`images and supported by the portable
`housing.
`
`Source: http://www.kyocera-wireless.com/brio-phone/specs/
`
`
`
`KYO'871-IC 00056
`
`Kyocera Ex. 1002
`p. 57
`
`
`
`
`
` manually portable housing;
`
`The Accused System comprises a manually
`portable
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