`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`
`Apple Inc.
`
`Petitioner,
`
`v.
`
`E-Watch, Inc.
`
`Patent Owner.
`
`
`
`
`
`
`
`Case: To Be Assigned
`
`Patent 7,643,168
`
`
`
`
`
`
`
`DECLARATION OF STEVEN J. SASSON
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`
`
`
`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent & Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
`
`
`
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`1. My name is Steven J. Sasson. I am over the age of 21 and am
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`competent to make this declaration. I am a resident of the State of New York and
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`reside at 12 Carefree Lane, Hilton, New York 14468.
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`BACKGROUND
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`2.
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`I am currently an independent consultant. I have been retained to
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`evaluate whether a certain publication discloses to a person of ordinary skill in the
`
`art (“POSA”) the subject matter of the claims of United States Patent No.
`
`7,643,168 (Ex. 1001, “the ’168 patent”) prior to the time of filing the ‘168 patent. I
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`am being compensated at my standard rate of $550 per hour. My compensation
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`does not depend on the outcome of this proceeding.
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`3.
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`In preparing this Declaration, I considered the following materials:
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`U.S. Patent No. 7,643,168 (’168 patent, Ex. 1001) and its file history
`
`(including the Office Action dated October 4, 2007, Ex. 1011);
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`WO 1999/035818 (’818 publication, Ex. 1006); and
`
`U.S. Patent No. 7,365,871 (’871 patent, Ex. 1009) and its file history.
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`4.
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`I received a Bachelor’s Degree in electrical engineering from
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`Rensselaer Polytechnic Institute (“RPI”) in Troy, New York in 1972. Subsequently
`
`I received a Master’s Degree from RPI in 1973.
`
`5.
`
`In June of 1973, I joined Eastman Kodak Company (“Kodak”) as an
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`electrical engineer working in the applied research laboratory which was referred
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`to as Kodak Apparatus Division Research Labs (“Applied Labs”). I was a member
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`of the Electronics Research Group within the Applied Labs and worked primarily
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`on electronics technology from the period of 1973 until 1980. Around 1980 until
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`approximately 1990, I worked in the advanced development arm of consumer
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`engineering for Kodak. My primary work during this time focused on the
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`development of electronic photography and included research and development on
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`image compression and transmission of compressed image data using wired and
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`wireless communication channels. From approximately 1990 through
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`approximately 2004, I took on various management roles at Kodak in which I
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`supervised numerous engineering and other professionals involved in developing
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`and commercializing digital imaging products. During this time, from the eighties
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`through 2004, I was very familiar with the qualifications and levels of skill of
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`ordinary engineers working on the electronic and mechanical aspects of camera
`
`related products due to my personal experience as an engineer and manager of
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`engineers in this field of technology.
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`6.
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`I am a named inventor on nine (9) United States patents. During my
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`time working for Kodak, I was primarily responsible for the development of the
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`first digital camera. My work in developing that digital camera led to the filing and
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`allowance of United States Patent No. 4,131,919. For my work related to the
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`development of the digital camera, I was awarded the Eastman Innovation Award,
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`the Photographic Society of America Innovation Award, the Photographic
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`Manufacturers Association Award for significant contributions to photography, an
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`honorary doctorate from the University of Rochester, and in 2009, the National
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`Medal of Technology and Innovation. A copy of my resume is attached here as
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`Attachment A.
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`7.
`
`I have been asked to review the ‘168 patent including the specification
`
`and claims 1-31 (“Asserted Claims”) of the ‘168 Patent. In this regard, I
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`understand the ‘168 Patent was filed on December 28, 2006 as application serial
`
`number 11/617,509 (“the ‘509 application”). I understand that the ‘509 application
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`was as a continuation of only application 10/336,470, filed January 3, 2003, now
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`U.S. Patent No. 7,365,871 (“the ‘871 patent”). I further understand that the ‘871
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`patent originated from an originally filed application, application 09/006,073,
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`which has an effective filing date of January 12, 1998. However, I have been
`
`informed that the ’168 patent is not entitled to an effective filing date of the ’073
`
`application, and I have been instructed to evaluate the ‘168 patent based on an
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`effective filing date of January 3, 2003, which is the filing date of the ‘871 patent
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`(the parent of the ‘168 patent).
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`8.
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`I have also been asked to review the subject matter disclosed by an
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`international published patent application WO 1999/035818 (“the ‘818
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`publication”) and compare its disclosure to the Asserted Claims of the ‘168 patent.
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`The ‘818 publication was published on July 15, 1999. It names David A. Monroe
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`as the inventor and indicates that a claim for priority is made to the ’073
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`application, which has a filing date of January 12, 1998.
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`9.
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`I am an engineer by training and profession. The opinions I am
`
`expressing in this report involve the application of my engineering knowledge and
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`experience to the evaluation of certain prior art with respect to the ‘168 patent. My
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`knowledge of patent law is no different than that of any lay person. Therefore, I
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`have requested the attorneys from Jones Day, who represent Apple, to provide me
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`with guidance as to the applicable patent law in this matter. The paragraphs below
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`express my understanding of how I must apply current principles related to patent
`
`validity to my analysis.
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`10.
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`It is my understanding that in determining whether a patent claim of
`
`an unexpired patent is disclosed by a reference, the Patent Office must first
`
`construe the claim using a broadest reasonable interpretation (BRI) consistent with
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`the specification as a POSA would have understood both the claim term and the
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`specification. It is my understanding that the broadest reasonable interpretation is
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`the plain meaning, i.e., the ordinary and customary meaning, given to the term by a
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`POSA at the time of the invention, taking into account whatever guidance, such as
`
`through definitions, may be provided by the written description in the patent,
`
`without importing limitations from the specification. For the purposes of this
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`review, I have construed each claim term in accordance with its plain meaning, i.e.,
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`its ordinary and customary meaning under the required broadest reasonable
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`interpretation.
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`11.
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`It is my understanding that an analysis comparing patent claims to a
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`reference takes into account the scope and content of the reference and identifies
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`any differences between the claimed subject matter and that disclosed by the
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`reference, based on the level of ordinary skill in the art at the time of the invention.
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`It is my understanding that when interpreting the claims of the ’168 patent I must
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`do so based on the perspective of one of ordinary skill in the art at the relevant
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`priority date of January 3, 2003. However, my analysis of the description of the
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`‘818 publication relative to the claims of the ‘168 patent would be the same
`
`regardless of whether evaluated from the standpoint of a POSA in 1998 or 2003.
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`12. The ‘168 patent generally relates to an apparatus for capturing,
`
`converting and transmitting a visual image signal via a digital transmission system.
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`Based on my experience as an engineer and a manager of engineers in the field of
`
`digital cameras and associated electronics, I conclude that a person of ordinary
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`skill in the subject matter of the ’168 patent as of January 3, 2003 (or January 12,
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`1998), would have been a person having at least a bachelor’s degree in electrical
`
`engineering or electronics (or equivalent) and at least two years of experience
`
`working on digital imaging products. Alternatively, a POSA could have a Master’s
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`Degree in electrical engineering or electronics (or equivalent) and at least one year
`
`of experience working on digital imaging products.
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`13. My own training and experience exceeds that of ordinary skill in the
`
`art. My work experience includes more than 35 years at Kodak, and during much
`
`of that time I worked with and supervised numerous engineering and other
`
`professionals involved in developing and commercializing digital imaging
`
`products. Moreover, I have taught, hired, supervised, and trained engineers having
`
`ordinary skill in the art within several years prior to the ’168 patent’s asserted 2003
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`priority date. From this experience and training, I have evaluated the level of skill
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`required for a POSA.
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`14.
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`In my evaluation of the Asserted Claims, I have first determined the
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`BRI based on the plain and ordinary meaning of the claim terms or phrases (unless
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`otherwise specifically identified) for any claim terms or phrases. I then compared
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`the applicable disclosure of the ‘818 publication to ascertain whether such
`
`disclosure falls within the bounds of the BRI for the claim terms or phrases-at-
`
`issue.
`
`Disclosure of the ’168 Patent
`
`15. The ‘168 patent is generally directed to an image capture,
`
`compression and transmission system for sending visual image transmission over
`
`land line or wireless communications. Image capture is accomplished with a
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`camera, which is integrated with a signal converter such that a converted signal can
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`be transmitted in real time or stored in memory for later recall and sending. The
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`patent describes a modular configuration that provides maximum flexibility such
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`that any or all of the camera, converter and telephone or other transmission device
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`can be configured as integrated or independent units. ’168 patent at col. 2:24-36
`
`(Ex. 1001).
`
`16. The configuration illustrated in Fig. 6B, which is shown below for
`
`convenience, is portable system that includes a battery powered portable module
`
`160 with a self-contained power source 162 and integral RAM as well as
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`removable memory (image card 72). The camera 10 may be integrated into the
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`portable module 160, or it can be a detachable unit. The cellular telephone 164 is
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`provided with a data jack 166 and to connect with the output jack 168 of the
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`module. This permits sending the image data signal via the cellular telephone to a
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`remote facsimile machine using standard cellular and telephone facilities. Id. at
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`col. 11:24-35.
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`17. The components shown in Fig. 6A and 6B (below) of the ’168 patent
`
`are conventional components that were known to a POSA at the time the ’168
`
`patent was filed, and these components are arranged in a straightforward,
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`conventional way.1 In Figure 6A shown below, the camera and the telephone are
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`distinct elements that are connected as part of a desktop system. In Figure 6B
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`shown below, the camera 10 is integrated with the portable system 160 along with
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`the memory 72 and the battery 162, which is connected to a separate cellular phone
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`164. The ’168 patent explains that the modular approach is intended to provide
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`maximum flexibility so that the components can be integrated or separate as
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`desired. See id. at col. 11:24-35, 2:32-36.
`
`
`1 For instance, during prosecution of the ’168 patent, claim 1 (which was
`
`directed to a self-contained image processing system including an image capture
`
`device, a processor for generating a data signal representing the image, a
`
`communications device adapted for transmitting the data signal to a remote
`
`receiving station, and a wireless transmission system between the communications
`
`device and the receiving station) was initially rejected as anticipated by three
`
`separate references. See Office Action dated October 4, 2007 (Ex. 1011), at pp. 4-
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`5, 8-10.
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`Claims 1-31 of the ’168 Patent Are Either Explicitly or Inherently
`Disclosed by the ’818 Publication
`18. From my reading of the ’168 patent and its claims, I do not believe
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`that any claimed components of the cell phone or camera were novel as of the
`
`effective filing date of the ’168 patent or that the claimed combinations in the ‘168
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`patent were novel as of the effective filing date of the ’168 patent, at least because
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`those components and features are disclosed explicitly, or at least inherently, in the
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`‘818 publication. And as noted above, combining conventional components of an
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`image capture device, a processor for generating a data signal representing the
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`image, a communications device for transmitting the data signal to a remote
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`receiving station, and a wireless transmission into a self contained apparatus was
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`otherwise known in the art. I understand inherent disclosure to mean that the claim
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`feature necessarily flows from the disclosure of the ’818 publication.
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`19. The ‘818 publication indicates that it claims priority back to the ’073
`
`application, which is also the parent application of the ‘871 patent. I have
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`compared the specifications of the ‘168 patent and the ‘818 publication and have
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`determined that the figures and written descriptions are substantially identical, with
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`any differences in wording being of no substantive consequence for purposes of
`
`my analysis. Simply stated, the ‘168 patent and the ‘818 publication disclose the
`
`same subject matter. Accordingly, to the extent the claims of the ‘168 patent are
`
`supported by the ‘168 patent specification, they are also disclosed by the ‘818
`
`publication.
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`20.
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`In addition to the foregoing, I have compared the specific subject
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`matter of the ‘168 claims, as construed under BRI, to the disclosure in the ‘818
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`publication. The following analysis identifies specific text supporting my opinion
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`that the subject matter of each limitation of each of the claims 1-31 of the ‘168
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`patent is disclosed by the ‘818 publication. In addition to providing discussion in
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`the paragraphs below explaining how the ‘818 publication discloses each limitation
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`of the independent and dependent claims, I have also provided a claim chart in the
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`body of this document summarizing the evidence for each of the independent
`
`claims.
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`Independent Claim 1
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`a)
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`Claim 1 preamble: “Apparatus comprising”: a portable housing,
`the portable housing being wireless”
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`21. The ‘818 publication provides “an apparatus for capturing, converting
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`and transmitting a visual image via standard facsimile transmissions systems.”
`
`‘818 publication (Ex. 1006) at page 6:13-14.
`
`b)
`
`claim 1 (b): “a portable housing, the portable housing being
`wireless”
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`22. As disclosed by the ‘818 publication, “[t]he configuration shown in
`
`Fig. 6B is a basic portable system, with a battery powered portable module 160
`
`having a self-contained power source 162. The system may include an integral
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`RAM and/or the removable memory module as indicated by the image card 72.
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`The camera 10 may be an integral feature of the portable module 160.” Id. at page
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`15:1-4. Moreover, Fig. 7A of the ’818 publication shows a hand held “camera
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`body 190 [that] is similar to a standard 35 millimeter type camera housing.” Id. at
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`page 15:22-23. “In addition, where desired, an integral cellular phone can be
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`incorporated in the camera housing and transmission can be sent directly from the
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`camera housing to a remote receiving station. The keypad for the telephone is
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`indicated at 202.” Id. at page 15:29-31. To the extent the phrase “wireless housing”
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`can be given meaning, the housing disclosed in the “818 publication is wireless
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`because the wireless cellular phone is contained in the housing shown in Fig. 7A of
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`the ‘818 publication. See id. at Fig. 7A, 7B.2 The characteristics for a housing of
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`portability and being wireless are both disclosed by the ‘818 publication. The ‘818
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`publication discloses the claimed limitation to a POSA.
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`c)
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`claim 1 (c): “an image collection device supported by the
`portable housing, the image collection device being operable to
`provide visual image data of a field of view”
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`23. The ‘818 publication discloses that the image capture device
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`“incorporates a camera,” Id. at page 2:24-27, and the “preferred embodiment
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`permits capture of a video image using a digital camera, an analog camera, or a
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`video camera such as a camcorder.” Id. at page 3:1-2. Visual image data can be
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`viewed with viewfinder 194 shown in Fig. 7A. Id. at 15:22-23. The ‘818
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`publication discloses the claimed limitation to a POSA.
`
`d)
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`claim 1 (d): “a display supported by the portable housing, the
`display being operable to display for viewing by a user a
`perceptible visual image, the perceptible visual image being
`generated from the visual image data”
`
`24. The ‘818 publication discloses a viewfinder: “Turning now to Figs.
`
`7A and 7B, the camera body 190 is similar to a standard 35 millimeter camera
`
`
`2 The plain language of the phrase “wireless housing” is meaningless. A
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`POSA would be unable to ascribe a definite interpretation to the phrase “wireless
`
`housing” because the characteristic of “wireless” does not apply to a housing in
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`this context.
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`housing and is adapted to receive a standard lens 192 with a viewfinder 194.” Id. at
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`page 15:22-23. The ‘818 publication further discloses that “[w]hen incorporating
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`the circuitry of Fig. 5, the cellular phone may be used as both an input and an
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`output device, and incoming data or stored images may be viewed through the
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`viewfinder 170.” Id. at page 15:8-10. The ‘818 publication further discloses a
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`viewfinder schematic incorporating a cathode ray tube display driver for image
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`display. Id. at Fig. 8A-1. The ‘818 publication discloses the claimed limitation to a
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`POSA.
`
`e)
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`claim 1 (e): “memory supported by the portable housing, the
`memory being suitable to receive visual image data in digital
`format, the memory being suitable to retain the visual image
`data in digital format”
`
`25. The ‘818 publication discloses a memory for storing images: “Once
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`the image is captured by the camera 10 and is presented at 44 to the memory
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`device 46, it is stored for later recall and transmission.” Id. at page 9:19-20. The
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`memory retains the visual image data in digital format because it is digital
`
`memory: “The specific type of memory device is optional and may include, for
`
`example, an SRAM device, a DRAM, Flash RAM, hard drive, floppy disk,
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`PCMCIA format removable memory (see, for example, the PCMCIA card 50 in
`
`Fig. 7A), writeable optical media or other storage device.” Id. at page 9:20-24
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`(referring to Fig. 2). The memory is suitable to receive the visual image data in
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`digital format because “[a]n analog to digital (A/D) converter 74 converts the
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`video portion of the analog signal from the camera and produces the digital signal
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`for output at line 76. The digital output data on path 76 is introduced into a data
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`multiplexer circuit 81 and into the RAM memory unit(s) 71, 72.” Id. at page 11:15-
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`17 (referring to Fig. 5). Moreover, in an alternative embodiment the ‘818
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`publication discloses that the camera may be a digital camera. Id. at page 8:11-12.
`
`The ‘818 publication discloses the claimed limitation to a POSA.
`
`f)
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`claim 1 (f): “an input device supported by the portable housing,
`the input device being operable by the user”
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`26. The ‘818 publication discloses a “camera body 190 [that] is similar to
`
`a standard 35 millimeter camera housing” with “operator interface button keys”
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`that are “housed within the housing and may be positioned on the back plate 196 of
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`the body.” Id. at page 15:22-26, Figs. 7A and 7B. The ‘818 publication discloses
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`the claimed limitation to a POSA.
`
`g)
`
`claim 1 (g): “operation of the input device by the user enabling
`the memory to retain the visual image data in digital format, the
`memory being suitable to provide retained visual image data in
`digital format”
`
`27. The ‘818 publication discloses that “when the camera is activated
`
`either by the operator or by automation, the system processor 86 detects the
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`initiation of the camera and capture sequence and sends a signal via line 88 to the
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`read/write control 84. The read/write control then monitors the incoming video
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`signal 83 to find the horizontal and vertical sync pulse to identify the beginning of
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`a frame. The read/write control then initiates writing to memory at the RAM
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`devices to initiate capture of the frame.” Id. at pages 11:28-31, 12:1 (referring to
`
`Fig. 5). The ‘818 publication discloses the claimed limitation to a POSA.
`
`h)
`
`claim 1 (h): “media supported by the portable housing, the
`media being suitable to embody at least one compression
`algorithm”
`
`28. The ‘818 publication discloses that “the processor executes a code for
`
`performing a bi-level compression of the data,” Id. at page 14:21-22 (referring to
`
`Fig. 5), and the “circuitry supporting the processor comprises the processor chip 86
`
`and the control store memory (ROM, Flash RAM, PROM, EPROM or the like) 92
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`for storing the software program executed by the processor.” Id. at page 12:8-10.
`
`See also, e.g., id. at Fig. 3, page 10:1-13. The ‘818 publication discloses the
`
`claimed limitation to a POSA.
`
`i)
`
`claim 1 (i): “at least one processing platform supported by the
`portable housing, the at least one processing platform being
`operable to execute the at least one compression algorithm, the
`at least one processing platform being provided the retained
`visual image data in digital format, execution of the at least one
`compression algorithm providing compressed visual image
`data”
`
`29. The ‘818 publication discloses that “the processor accesses the RAM
`
`and manipulates the data representing each frame image. For example, the
`
`processor will perform the gray scale to half tone conversions described in
`
`connection with Figs. 1-4 to prepare the signal for facsimile transmission. The
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`processor can also perform image compression and output the image as a gray
`
`scale.” Id. at page 14:16-20 (referring to Fig. 5). The ‘818 publication discloses the
`
`claimed limitation to a POSA.
`
`j)
`
`claim 1 (j): “a mobile phone supported by the portable housing,
`the mobile phone being operable to send to a remote recipient a
`wireless transmission, the wireless transmission conveying the
`compressed digital image data”
`
`30. The ‘818 publication discloses that “[t]he system of the present
`
`invention also contemplates wireless transmission over a cellular telephone, radio
`
`frequency, satellite transmission or the like.” Id. at page 13: 20-21. In the preferred
`
`embodiment, “the system includes a video camera and an integral cellular
`
`telephone, wherein the telephone using the standard audio mode or future digital
`
`modes, can be used to transmit and receive visual image signals. Id. at page 3:18-
`
`20.
`
`31. Schematics in Figs. 1-4 of the ‘818 publication show that “the signal
`
`generated at 22 by the binary bit map 20 is input into a Group-III encoding and
`
`compression network 24 for generating an output signal at 26 which is introduced
`
`into a Group-III protocol transmission device 28.” Id. at page 8:20-22. Moreover,
`
`Figs. 7A and 7B show a “camera body 190 [that] is similar to a standard 35
`
`millimeter type camera housing,” Id. at page 15:22-23, wherein, “an integral
`
`cellular phone can be incorporated in the camera housing and transmission can be
`
`sent directly from the camera housing to a remote receiving station,” Id. at page
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`15:29-31. The ‘818 publication discloses the claimed limitation to a POSA.
`
`k)
`
`claim 1 (k): “movement by the user of the portable housing
`commonly moving the image collection device”
`
`32. The ‘818 publication discloses common movement of the housing and
`
`the camera “as incorporated in a standard 35 millimeter type camera housing.” Id.
`
`at page 14:27-28. The ‘818 publication discloses the claimed limitation to a POSA.
`
`l)
`
`claim 1 (l): “movement by the user of the portable housing
`commonly moving the display”
`
`33. The ‘818 publication discloses common movement of the housing and
`
`the viewfinder “as incorporated in a standard 35 millimeter type camera housing.”
`
`Id. at page 14:27-28. The ‘818 publication discloses the claimed limitation to a
`
`POSA.
`
`34. Based on the above referenced disclosure, the subject matter of each
`
`and every limitation of claim 1 is disclosed to a POSA by the ‘818 publication.
`
`This is summarized in the claim chart below:
`
`
`
`Claim 1
`
`claim 1 preamble (a):
`“Apparatus comprising:”
`
`‘818 Publication
`
`“It is, therefore, an object and feature of the invention
`to provide an apparatus for capturing, converting and
`transmitting a visual image via standard facsimile
`transmissions systems.” ‘818 publication (Ex. 1006) at
`page 6:13-14.
`
`Claim 1 (b): “a portable
`housing, the portable
`
`“The configuration shown in Fig. 6B is a basic portable
`system, with a battery powered portable module 160
`having a self-contained power source 162. The system
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`housing being wireless” may include an integral RAM and/or the removable
`memory module as indicated by the image card 72. The
`camera 10 may be an integral feature of the portable
`module 160.” Id. at page 15:1-4.
`
`“Turning now to Figs. 7A and 7B, the camera body 190
`is similar to a standard 35 millimeter camera housing
`….” Id. at page 15:22-23.
`
`“In addition, where desired, an integral cellular phone
`can be incorporated in the camera housing and
`transmission can be sent directly from the camera
`housing to a remote receiving station. The keypad for
`the telephone is indicated at 202.” Id. at page 15:29-31.
`See also Figs. 7A, 7B.
`
`“The subject invention is an image capture,
`compression and transmission system that …
`incorporates a camera ….” Id. at page 2:24-27.
`
` “The preferred embodiment permits capture of a video
`image using a digital camera, an analog camera, or a
`video camera such as a camcorder.” Id. at page 3:1-2.
`
`“Turning now to Figs. 7A and 7B, the camera body 190
`is similar to a standard 35 millimeter camera housing
`and is adapted to receive a standard lens 192 with a
`viewfinder 194.” Id. at page 15:22-23.
`
`“When incorporating the circuitry of Fig. 5, the cellular
`phone may be used as both an input and an output
`device, and incoming data or stored images may be
`viewed through the viewfinder 170.” Id. at page 15:8-
`10.
`
`See also Fig. 8A-1 (“VIEW FINDER” schematic with
`“CRT DRIVER”).
`
`claim 1 (c) “an image
`collection device
`supported by the portable
`housing, the image
`collection device being
`operable to provide
`visual image data of a
`field of view”
`
`claim 1 (d) “a display
`supported by the portable
`housing, the display
`being operable to display
`for viewing by a user a
`perceptible visual image,
`the perceptible visual
`image being generated
`from the visual image
`data”
`
`claim 1 (e) “memory
`supported by the portable
`
`“Once the image is captured by the camera 10 and is
`presented at 44 to the memory device 46, it is stored for
`
`
`
`-19-
`
`Apple Ex. 1010
`
`

`

`housing, the memory
`being suitable to receive
`visual image data in
`digital format, the
`memory being suitable to
`retain the visual image
`data in digital format”
`
`claim 1 (f) “an input
`device supported by the
`portable housing, the
`input device being
`operable by the user”
`
`later recall and transmission.” Id. at page 9:19-20.
`
` “The specific type of memory device is optional and
`may include, for example, an SRAM device, a DRAM,
`Flash RAM, hard drive, floppy disk, PCMCIA format
`removable memory (see, for example, the PCMCIA
`card 50 in Fig. 7A), writeable optical media or other
`storage device.” Id. at page 9:20-24 (referring to Fig.
`2).
`
`“An analog to digital (A/D) converter 74 converts the
`video portion of the analog signal from the camera and
`produces the digital signal for output at line 76. The
`digital output data on path 76 is introduced into a data
`multiplexer circuit 81 and into the RAM memory
`unit(s) 71, 72.” Id. at page 11:15-17 (referring to Fig.
`5).
`
`“Turning now to Figs. 7A and 7B, the camera body 190
`is similar to a standard 35 millimeter camera housing
`and is adapted to receive a standard lens 192 with a
`viewfinder 194. The electronics are housed in the
`casing in the area normally occupied by the film and
`film advancing implements. The operator interface
`button keys 98 are housed within the housing and may
`be positioned on the back plate 196 of the body.” Id. at
`page 15:22-26, Figs. 7A and 7B.
`
`claim 1 (g) “operation of
`the input device by the
`user enabling the
`memory to retain the
`visual image data in
`digital format, the
`memory being suitable to
`provide retained visual
`image data in digital
`format”
`
`“When the camera is activated either by the operator or
`by automation, the system processor 86 detects the
`initiation of the camera and capture sequence and sends
`a signal via line 88 to the read/write control 84. The
`read/write control then monitors the incoming video
`signal 83 to find the horizontal and vertical sync pulse
`to identify the beginning of a frame. The read/write
`control then initiates writing to memory at the RAM
`devices to initiate capture of the frame.” Id. at pages
`11:28-31, 12:1 (referring to Fig. 5).
`
`
`
`-20-
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`Apple Ex. 1010
`
`

`

`claim 1 (h) “media
`supported by the portable
`housing, the media being
`suitable to embody at
`least one compression
`algorithm”
`
`claim 1 (i) “at least one
`processing platform
`supported by the portable
`housing, the at least one
`processing platform
`being operable to
`execute the at least one
`compression algorithm,
`the at least one
`processing platform
`being provided the
`retained visual image
`data in digital format,
`execution of the at least
`one compression
`algorithm providing
`compressed visual image
`data”
`
`claim 1 (j) “a mobile
`phone supported by the
`portable housing, the
`mobile phone being
`operable to send to a
`remote recipient a
`wireless transmission,
`the wireless transmission
`conveying the
`compressed digital image
`
`“[T]he processor executes a code for performing a bi-
`level compression of the data….” Id. at page 14:21-22
`(referring to Fig. 5).
`
`“The circuitry supporting the processor comprises the
`processor chip 86 and the control store memory (ROM,
`Flash RAM, PROM, EPROM or the like) 92 for storing
`the software program executed by the processor.” Id. at
`page 12:8-10.
`
`See also, e.g., id. at Fig. 3, page 10:1-13.
`
`“[T]he processor accesses the RAM and manipulates
`the data representing each frame image. For example,
`the processor will perform the gray scale to half tone
`conversions described in connection with Figs. 1-4 to
`prepare the signal for facsimile transmission. The
`processor can also perform image compression and
`output the image as a gray scale.” Id. at page 14:16-20
`(referring to Fig. 5).
`
`“The system of the present invention also contemplates
`wireless transmission over a cellular telephone, radio
`frequency, satellite transmission or the like.” Id. at
`page 13:20-21.
`
`“In the preferred embodiment of the invention, the
`system includes a video camera and an integral cellular
`telephone, wherein the telephone using the standard
`audio mode or future digital modes, can be used to
`transmit and receive visual image signals.” Id. at page
`
`
`
`-21-
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`

`

`data”
`
`3:18-20.
`
`“The signal generated at 22 by the binary bit map 20 is
`input into a Group-III encoding and compression
`network 24 for generating an output signal at 26 which
`is introduced into a Group-III protocol transmission
`device 28.” Id. at page 8:20-22.
`
`“Turning now to Figs. 7A and 7B, the camera body 190
`is similar to a standard 35 millimeter camera
`housing….” Id. at page 15:22-23.
`
`“In addition, where desired, an integral cellular phone
`can be incorporated in the camera housing and
`transmission can be sent directly from the camera
`housing to a remote receiving station.” Id. at page
`15:29-31.
`
`“Figs. 7A and 7B illustrate the subject invention as
`incorporated in a