IPR2015-00499, Paper No. 33
`March 8, 2016
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`trials@uspto.gov
`571-272-7822
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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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`DISH NETWORK L.L.C. and SIRIUS XM RADIO INC.,
`Petitioner,
`
`v.
`
`DRAGON INTELLECTUAL PROPERTY,
`Patent Owner.
`____________
`
`Case IPR2015-004991
`Patent 5,930,444
`____________
`
`Held: February 9, 2016
`____________
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`
`
`
`
`BEFORE: NEIL T. POWELL, STACEY G. WHITE, and
`J. JOHN LEE, Administrative Patent Judges.
`
`The above-entitled matter came on for hearing on Tuesday,
`February 9, 2016, commencing at 1:30 p.m., at the U.S. Patent
`and Trademark Office, 600 Dulany Street, Alexandria, Virginia.
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`
`
`
`1 Case IPR2015-01735 has been joined with this proceeding.
`
`
`March 8, 2016
`
`trials@uspto.gov
`571-272-7822
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`DISH NETWORK L.L.C. and SIRIUS XM RADIO INC.,
`Petitioner,
`
`v.
`
`DRAGON INTELLECTUAL PROPERTY,
`Patent Owner.
`____________
`
`Case IPR2015-004991
`Patent 5,930,444
`____________
`
`Held: February 9, 2016
`____________
`
`
`
`
`
`BEFORE: NEIL T. POWELL, STACEY G. WHITE, and
`J. JOHN LEE, Administrative Patent Judges.
`
`The above-entitled matter came on for hearing on Tuesday,
`February 9, 2016, commencing at 1:30 p.m., at the U.S. Patent
`and Trademark Office, 600 Dulany Street, Alexandria, Virginia.
`
`
`
`
`1 Case IPR2015-01735 has been joined with this proceeding.
`
`
`
`Case IPR2015-00499
`Patent 5,930,444
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`APPEARANCES:
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`ON BEHALF OF THE PETITIONER:
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`ON BEHALF OF PATENT OWNER:
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`ELIOT D. WILLIAMS, ESQ.
`HOPKINS GUY, ESQ.
`JAMIE LYNN, ESQ.
`Baker Botts L.L.P.
`1001 Page Mill Road
`Building One, Suite 200
`Palo Alto, California 94304-1007
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`KAI ZHU, ESQ.
`Dragon Intellectual Property, LLC
`2700 Plumas Street #120
`Reno, NV 89509
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`Case IPR2015-00499
`Patent 5,930,444
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`P R O C E E D I N G S
`- - - - -
`JUDGE POWELL: Good afternoon. This is the
`hearing for IPR2015-00499, which involves U.S. Patent Number
`5,930,444. IPR2015-01735 has been joined with
`IPR2015-00499. Here with me in the hearing room we have
`Judge Lee, and joining us remotely from Dallas we have Judge
`White on the monitor over there to my left.
`Can counsel please state your names for the record.
`MR. WILLIAMS: Good afternoon, Your Honor, Eliot
`Williams with Baker Botts for the Petitioner. With me is
`Hopkins Guy, Jamie Lynn, and in-house director of IP for Dish
`Network Jim Hanft.
`MR. ZHU: Good afternoon, Your Honor, Kai Zhu from
`Dragon representing Dragon Intellectual Property LLC. With me
`is Mr. Lei Mei as an observer.
`MR. MEI: Your Honors, I am just here to observe as a
`member of the public.
`JUDGE POWELL: Okay, thank you. Per the hearing
`order, the Petitioner will have 30 minutes of argument time and
`the Patent Owner will likewise have 30 minutes of argument
`time. We will start with the Petitioner who may reserve time for
`rebuttal. Patent Owner will then respond to Petitioner's
`presentation and we will close then with Petitioner -- with the
`opportunity for Petitioner to use any remaining time to respond to
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`Patent Owner's presentation. When you present, you must
`identify each demonstrative exhibit clearly and specifically, such
`as by slide number or screen number, that is particularly
`important because Judge White cannot view the projection screen
`here in the hearing room.
`With that, are there any questions before we begin?
`(No response.)
`JUDGE POWELL: Okay, we will start with Petitioner.
`Would you like to reserve any time?
`MR. WILLIAMS: Yes, Your Honor, I'll reserve 15
`minutes.
`JUDGE POWELL: Fifteen?
`MR. WILLIAMS: Yes. And I have hard copies of the
`demonstratives if the Board would like them.
`JUDGE POWELL: Certainly. Whenever you're ready.
`MR. WILLIAMS: Thank you, Your Honor. If it
`pleases the Board, again, my name is Eliot Williams, I represent
`Dish Network, the Petitioner in this action. Before I get into the
`substance of my presentation, I did just want to take a moment to
`acknowledge the Board's final written decision in the Unified
`Patents versus Dragon matter, which is IPR2014-01252, so we
`did see a copy of the Board's final written decision in that
`proceeding late last week.
`I just wanted to note that to the extent that decision does
`address the Goldwasser reference, which is part of the grounds in
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`this proceeding, Petitioner agrees with the Board's conclusions in
`that final written decision, including the conclusion that
`Goldwasser discloses the interruption in the preamble of claim 1
`and 14 of the '444 patent, as well as the Board's conclusions about
`the use of remote control, and specifically I believe the Board
`found that the use of a remote control with play and record
`buttons to invoke the play and record capabilities of time shifting
`devices, such as -- in that case the Ulmer and Goldwasser
`references, was within the level of skill in the art. We agree with
`that discussion. We think that conclusion applies here as well
`and results in unpatentability of the claims for a very similar
`reason.
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`JUDGE POWELL: Well, I would just say, we'll
`consider the merits of this case based on the documents filed in
`this case and the arguments made in this case.
`MR. WILLIAMS: Absolutely, and we hope that the
`Board will, and that's completely our intention.
`Let me just begin by discussing the Goldwasser
`reference. It is Petitioner's argument that the Goldwasser
`reference essentially discloses all of the claimed elements of
`claim 1 and 14 with the exception of the two-key keyboard. So,
`let me just -- and then with respect to the two-key keyboard, it's
`our contention that it would be obvious to use a two-key
`keyboard in place of what Goldwasser does disclose, which is a
`user control panel.
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`So, with that, I'll just begin with our slide 4, which
`shows the preamble of claims 1 and 14, and shows the mapping
`of that to the Goldwasser abstract, and as the Board likely
`recognizes there, the Goldwasser abstract does describe the user
`experience of using the Goldwasser device. It is a time shifting
`device, it permits the user to interrupt playback of broadcast
`content such as when they're interrupted during a recording of
`that content. The user can essentially pause the video, attend to
`the interruption, resume the video without stopping the recording.
`So, this can essentially shows simultaneous recording and
`playback, exactly as recited in the claim preamble, as well as in
`some of the elements of the claim.
`So, the next element that I want to talk about, which is
`sort of the heart, I think, of the parties' arguments in this case is
`the control circuit of claim -- here I'll focus on claim 1, although
`the elements of claim 14 are quite similar.
`So, first, I'll note that the claim does require a control
`circuit that's coupled responsively to a keyboard, and as I
`indicated, we are not contending that Goldwasser does explicitly
`disclose a keyboard, however, Goldwasser does disclose that
`there is a control circuit, and here it's referred to as an address
`controller, and you'll see that at column 6, starting around line 44
`of the Goldwasser patent. And that address controller is
`responsive to commands received from the user control panel.
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`So, Goldwasser essentially has a control circuit that's
`responsive to a user interface, he just doesn't explain in detail
`what that user interface is. The case essentially comes down to
`this: Would it be obvious to take that user control panel that's
`described in Goldwasser and in place of that use a two-key
`keyboard, or another way of thinking about it is how would one
`implement the user control panel that's described in Goldwasser,
`and the evidence is overwhelming that it would be obvious to do
`that with a two-key keyboard that has a play and record button.
`On slide 13, you'll see figure 3 from Goldwasser, which
`shows, again, the address controller. You'll see that the arrow to
`the address controller is running from the user control panel.
`There's further description in the specification -- which I'll show
`you in a moment -- that explains exactly how that control
`function is working, what the user is doing when they're
`controlling the address controller, and the address controller in
`turn controls where the data is read from and recorded into the
`RAM, which is then played back to the display device.
`Goldwasser goes further and explains an algorithm to
`use with that control circuit. So, you'll see that that's -- sorry,
`that's slide number 14 -- where we've shown here an excerpt from
`the patent, as well as figure 4 that shows that figure 4 is an
`algorithm which can be used to control the storage and retrieval
`of digitized video samples.
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`So, this is essentially the loop that's going on within that
`control circuit, while the record process is taking place. It allows
`sort of sequential recording so the broadcast is continuing to be
`recorded, using the write pointer, while at the same time the read
`pointer can be manipulated by the user via the interrupt function,
`shown in block 112, and that permits the user to change the way
`that the playback is occurring, such as deposit or to fast forward,
`rewind, what have you.
`Again on slide 15, you will see the abstract again,
`because Goldwasser explains not only the control circuit and the
`algorithm that executes on it, but the user experience as that's
`taking place. And again, as I explained, that shows that the user
`can pause the video essentially so that they can resume after some
`interruption in the playback, precisely as claimed the claim
`control circuit does.
`So, the only thing that seems to be missing, the parties
`are disagreeing about, is whether there's a keyboard in
`Goldwasser, and as I said, we don't contend that there is a
`keyboard, but we do contend that there is a control circuit, so the
`only question is how to implement it. And that's where we think
`the evidence is overwhelming that it was simply well known to
`use buttons such as playback and record to invoke functionality
`of time shifting devices, such as Goldwasser.
`So, on slide 11, you'll see a couple of the references that
`we cited in the petition, and there is supporting evidence in this
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`proceeding, the Shimada patent which describes a VCR with an
`enhanced remote functionality is shown, as well as the Vogel
`patent. We also make reference there to the Skerlos and
`Sandbank patents that are discussed in our petition, but
`additionally the inventors themselves admitted that these sort of
`functionalities were known in the art.
`So, the specification has a description beginning at
`column 6, line 27, of these sorts of user interface controls that
`were available at the time for VCRs and other time shifting
`devices, and admits that those types of buttons used to invoke
`functionality was well known.
`So, we think that essentially ends the case. I mean, it
`proves that one of skill in the art knows how to implement these
`kind of devices, using function keys, to carry out the functions
`that the device was designed to do. That's essentially the guts of
`our argument.
`I'll give you one other citation, which I think goes to
`this in a little more detail, which is shown on slide 17, the bottom
`left of slide 17, here is a description of Goldwasser about how
`that user control panel is actually being used to control that
`algorithm I showed you earlier, and what you'll see is that control
`panel lets the user interrupt the playback of the recording so they
`can vary the speed of the recording, which would include things
`like fast forwarding, or pausing.
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`Petitioner has submitted expert evidence from its expert
`that the initiation of recording based on a user issue and recording
`command was well known, was well within the level of skill in
`the art, it was an obvious design choice for a user interface, and
`that's really the only question that's presented here. Would it be
`obvious to implement this control panel with a two-button user
`interface, the answer is overwhelmingly yes. There's nothing
`unpredictable about that, that's exactly how controls have been
`used in the prior art, that's how one would approach Goldwasser.
`JUDGE WHITE: Counselor? I would like to hear you
`speak to the rationale for combining these two references. Patent
`Owner has brought up an argument that the references operate in
`such a very different way that one of skill in the art would not
`have been led to combine these teachings.
`MR. WILLIAMS: Sure, yeah, happy to address that.
`So, I mean, just as an initial matter, you know, you don't have to
`even look at the functionality of Yifrach really to understand the
`argument we're making. The point of using Yifrach as the
`reference for combining with Goldwasser is just that they're both
`time shifting devices. They're both designed to allow a user to
`change or delay the playback of broadcast information.
`So, they're clearly both analogous references and that's
`why we're using Yifrach. Let me just pull up the figure from
`Yifrach. That's our slide 8. So, what Yifrach is doing is actually
`very similar to what's claimed. In fact, we would say that it
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`certainly has the playback and freeze keys that are being claimed
`and the record keys that are being claimed in the '444 patent, but
`essentially, the idea is when the user presses the freeze button,
`they transfer broadcast data into RAM, which is stored there, it's
`recorded in that RAM for them to later play back.
`So, to us, there's really no difference between the
`operation of these devices in that sense. They are both time delay
`playback. The user experience would be a little different in terms
`of what broadcast content is being played back, we concede that,
`but it's clear that the references themselves operate very similarly,
`so there is a clear motivation to look to the Yifrach reference in
`deciding how you would implement a user interface of a time
`shifting device such as the Goldwasser patent.
`So, I think that's the first answer. The second answer is,
`you know, there's really no dispute, Patent Owner has not
`disputed that the Goldwasser patent does exactly the claimed
`functionality. It does have the ability for a user to begin time
`delay playback of the recording, it has the ability of the user to
`initiate recording.
`Those functions are clearly built in Goldwasser. The
`only question is how would you build these interfaces to
`implement them, and using buttons to implement them is the
`obvious choice. It's what everyone of ordinary skill in the art has
`done. It's the obvious design choice. There was clear motivation
`and direction to use such a thing. It's not even clear what other
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`methods could be used to implement the control panel of
`Goldwasser, besides some type of button.
`So, that, I think, goes to the motivation to combine and
`answers the objection that was raised. Patent Owner really wants
`to attack the functionality of Yifrach and argue that its control
`circuit is different than what's claimed, but we have never argued
`that the Yifrach control circuit is the same as the claimed control
`circuit. That, I think, is just a red herring.
`JUDGE JOHN LEE: Mr. Williams, what evidence did
`you present in the record to indicate that modifying the control
`circuit in Yifrach and/or the address controller in Goldwasser to
`perform as the control circuit in the challenged claims, that that
`would be something as within the skill of someone with ordinary
`skill in the art?
`MR. WILLIAMS: So, some of it is what I just showed
`to you in slide 11, which is the prior art disclosures of these types
`of user interfaces. It was well known on how to build such a user
`interface to control a control circuit and time shifting device.
`That's one piece. The examiner's -- sorry, the inventor's
`admissions in the specification also established that, that there
`was clear evidence that someone of ordinary skill in the art knew
`how to implement these kind of control functions using buttons.
`And that's all we're really talking about here.
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`How do you turn that function on? How do you invoke
`that function? You do it with a button press, and that was clear in
`the record.
`We also have the expert testimony, so that's Exhibit
`110, of Tony Wechselberger. So, he addresses the combination
`in a few places. His specific discussion of the Goldwasser
`control panel is at paragraph 132, which we cite at page 46 of our
`petition. And there he explains how that Goldwasser control
`circuit could be -- could be controlled using essentially users
`interacting with the control circuit via the control panel.
`Then at paragraph 152 of Exhibit 110, which again is
`the Wechselberger declaration, he talks about -- he states the
`initiation of recording based on the user issuing a record
`command, for example, by a button press, was well known in the
`art. There he's discussing how one might implement that control
`panel of Goldwasser, so that testimony has really gone
`unchallenged.
`JUDGE JOHN LEE: Although 152 concerns your
`ground combining Goldwasser and the Truog reference.
`MR. WILLIAMS: The first part of that paragraph does,
`but the last sentence I don't think is limited to the particular
`combination of Goldwasser with Truog.
`JUDGE JOHN LEE: Okay, so my question is a little bit
`different.
`MR. WILLIAMS: Okay.
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`JUDGE JOHN LEE: Because you're asking us to
`consider a proposed combination of Goldwasser, that device, its
`functionality, and adapting an interface with particular buttons
`that's disclosed in Yifrach, and there's a particular control circuit
`in Yifrach that you contend corresponds, and as I understand your
`contention, you're saying that a person of ordinary skill would
`know how to combine those two systems to produce the recited
`system of the challenged claims, and I'm not necessarily seeing,
`and maybe you can direct me, where in this expert testimony he
`says that a person of ordinary skill would be able to make that
`modification, to take the Yifrach interface, the buttons in Yifrach,
`and adapt them to control the functions that are disclosed in
`Goldwasser.
`MR. WILLIAMS: Sure. So, let me just unpack that
`question a little bit. You said something that I don't think I agree
`with, which is that the Yifrach control circuit is somehow
`relevant to our argument, because it's not. We have never
`contended that the Yifrach control circuit is the claimed control
`circuit. We focused our arguments, both in the petition and the
`reply, on the Goldwasser control circuit, which is itself controlled
`by a control panel.
`So, the only argument we've been making is how would
`you implement that control panel, would it be within the level of
`skill in the art to implement Goldwasser's control panel with
`buttons? And as an example of doing so, we point to Yifrach.
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`Yifrach did exactly that, it had a similar circuit, it did something
`quite similar, it was a time shifting circuit, and it was invoked --
`the functionality of that was invoked through buttons. That in
`and of itself is clear evidence that it's within the level of skill in
`the art to control these type of control circuits using two buttons,
`such as a record and a playback button.
`So, I see I'm up to my rebuttal time, so with that I think
`I will reserve the balance.
`MR. ZHU: Good afternoon, Your Honor, again my
`name is Kai Zhu from Dragon, representing Dragon. So, this
`slide number 4 of our presentation shows claim 1. So, claim 1 of
`the '444 patent has a keyboard limitation, and the control circuit
`limitation, which is coupled responsively to the keyboard. Those
`two limitations, when standing alone, however, do not
`sufficiently characterize innovation or novelty of this patent.
`Particularly, it's the interaction between the control circuit and the
`keyboard that really summarize the novelty of this patent.
`Here, shown as limitation (g) on this slide, is a very
`specific way at how the control circuit actually control -- controls
`and interacts with keyboard. So, I would go through the details a
`little bit.
`So, as you can see from the first red highlight here, the
`said control circuit being configured to -- configured so that, and
`there are several -- at least several steps or functions how that
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`control works. As the first blue highlight shows, a user can first
`press the record key to begin a recording. So, that's the first step.
`And then, the user can subsequently and solely actuate
`the playback key to begin time-delayed playback of the
`recording, which apparently here refers back to the A recording in
`the first blue highlight. So, the second thing is that you can press
`-- subsequently and solely press the playback key to do the time
`shifting of the playback.
`And the next one is the second blue highlight here,
`which further requires that the time shifting is exactly the same as
`the time interval between where you actuate the first record key
`and when you actuate the playback key. So, this is the -- just one
`of the most important things about this invention.
`So, the next slide, so this is slide number 5. Our expert
`Mr. Goldberg testified that the control circuit of the '444 patent
`really enables so-called one-key seamless playback feature. If we
`may go back to the earlier slide, that one-key seamless playback
`corresponds to the limitation in the second highlight, which says
`playback key is subsequently and solely actuated to begin
`time-delayed playback.
`I want to read into the record that Exhibit 1008, which
`is the file history of the supplemental examination of this '444
`patent, page 147 of Exhibit 1008, in paragraph 11, the panel of
`the supplemental exam found that during the prosecution of the
`'444 patent, it was the addition of the term "and solely" to the
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`independent claim 13, which is now the ultimate claim 1 here,
`that "and solely" term, which is shown here in the second
`highlight, that's really made this claim allowable. So, on the
`record, I want to just read that.
`So, this is slide number 6 of our presentation. The
`Petitioner admitted, and this Board actually found in its
`institution decision, paper number 7, at page 14 and 15 that
`Goldwasser does not disclose a keyboard with the two keys.
`Instead, Goldwasser only disclose the so-called user control
`panel. However, Goldwasser does not provide detail as to the
`controls provided on that user control panel.
`Instead, the Board found that the Petitioner relies on the
`Yifrach reference to provide a disclosure of that keyboard with
`two specific keys. The Board found that in Goldwasser there is
`an address controller circuit 58, which is in the red box here on
`the left side of the circuit, list address control 58, just interact
`with the user control panel. The Patent Owner does not dispute
`this interaction. However, the interaction between this address
`controller 58 and the user control panel is very specific and it's
`very different from what we just saw in limitation (g) of claim 1,
`which we'll show.
`So, the next slide, slide number 7, so our expert testified
`that the way that address controller in Goldwasser interact with
`the user control panel is that it handles certain so-called interrupts
`from that user control panel. All the disclosures from Goldwasser
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`specifically with respect to say the algorithm that Petitioner just
`mentioned in their presentation is figure 4, the algorithm. Here,
`the interrupt was received from the user control panel and the
`address controller, as its name suggests, just take the interrupt
`when you play the memory address location for the playback
`process.
`And actually, throughout the whole Goldwasser
`reference, the disclosure on the interaction between address --
`address controller and the user interface -- user control panel
`never goes beyond this teaching of the interrupt of the playback
`process.
`In their presentation, they highlight several portions of
`the Goldwasser patent, but the Petitioner was not able to point to
`anything beyond this interrupt of the playback process.
`If we may go to their presentation for a moment. So,
`Your Honor, this is the presentation that we just saw from the
`Petitioner. So, on their slide 4, which they just showed, they
`highlight abstract of Goldwasser patent, and the second highlight
`here says that the user can also interrupt the playback of a
`program. So, this is all about the interrupt of the playback.
`If we may go to slide number 15 of their presentation.
`Again, they show the abstract of Goldwasser. Now, they
`highlight a different portion of that abstract, and this time, it says,
`"This allows, for example, playback of previously recorded
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`Case IPR2015-00499
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`material to be temporarily stopped and then resumed." Again,
`this just about interrupt of the playback process.
`Similarly, in slide number 17 of their presentation, they
`again show the same thing. So, all we can see from the whole
`Goldwasser patent, it's just the address controller only teaches
`about the interrupt of the playback process, which is based on the
`interrupt signal received from user control panel. It does not
`mention anything about how to begin a recording, much less the
`specific way in claim limitation (g) in claim 1, that very specific
`matter for the control circuit to control the keyboard. All those
`elements were not presented anywhere in Goldwasser patent.
`Particularly, the subsequently and the solely limitation
`and the interval -- time shift interval being the same as time
`between actuating the record key and the time actuating the
`playback key. Because Goldwasser does not have any of those
`two keys at all.
`JUDGE JOHN LEE: Mr. Zhu, let me just make sure I
`understand what you are saying. So, are you saying that
`Goldwasser teaches beginning a recording of the broadcast but
`the control panel does not control that process or start that
`process? Are you saying the address controller is not involved in
`starting that process? What exactly are you saying?
`MR. ZHU: Okay, Your Honor, that's a good question.
`So, as you may recall, limitation (g) of claim 1 says begin a
`recording. I want to read into the record here, here the recording
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`Case IPR2015-00499
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`here is a noun. It's a recording. So, it's not about begin
`recording, which is a verb. So, that's a big difference right there.
`So, in Goldwasser, it mention recording, which is a
`verb, never teach anything about how to begin a recording. It just
`doesn't exist anywhere in the Goldwasser reference at all.
`JUDGE JOHN LEE: So, you're saying that Goldwasser
`teaches the action of recording a broadcast, but not the product of
`that action, i.e. a recording noun of that broadcast? Is that your
`contention?
`MR. ZHU: What I just said is that Goldwasser mention
`the recording of the program -- just program information,
`broadcast program information, but how that process was started,
`it didn't specify. And much less how to actuate a record key to
`begin a recording, it's not just mentioned at all in Goldwasser.
`JUDGE JOHN LEE: So, just so I understand you, you
`don't dispute that Goldwasser teaches recording a broadcast, or
`beginning recording a broadcast, you just dispute whether or not
`Goldwasser teaches how or if the control panel starts that process
`or causes that process to occur?
`MR. ZHU: Not quite so, Your Honor. What we don't
`dispute is that Goldwasser does mention recording as a verb of
`broadcast information, but does not mention anything how to
`specifically begin a recording as a noun, because it's indisputable
`that when you say "a recording," it means a specific piece of
`information, and that's a noun, it's not an action.
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`So, we don't dispute that in Goldwasser it does mention
`the action recording, but it does not teach anything about how to
`begin a specific recording. That's what. And in our patent, in
`claim 1, that means that you have to press a record key to
`specifically begin a recording. That's what the claim language
`says.
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`JUDGE WHITE: Counselor, could you explain to me
`what your understanding is of figure 4 of Goldwasser, because
`when I look at that figure, when you look at the description in the
`text of Goldwasser, they say that figure 4 describes how the
`address controller is to work, and figure 4 shows storing
`information at a particular point in the -- in the memory, and then
`reading information out of the memory. So, wouldn't that be the
`recording and the playback?
`MR. ZHU: Well, in this figure 4, it's really about a
`group of how to handle the interrupt from the user control panel.
`And in the companion language for this figure 4, in Goldwasser,
`it only mentions, read right from this slide, at block 112, which is
`the one step in this figure, "any interrupt from the user control
`panel is detected; such an interrupt might indicate, for example,
`that the orderly playback process implemented by blocks 106 and
`108 is to be varied. If so, at block 114, the read pointer is
`changed to implement the command received via the interrupt."
`So, all the disclosure here is about how to, when you
`play the one read pointer, I believe, to vary the delay of the
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`playback. So, that's not surprising, as the title of this patent,
`which is page 1 of Exhibit 1005, the title just says that variable
`delay video recorders. So, this particular algorithm and the
`disclosure -- related disclosure is really about how to change or
`just when you play the playback process, so that you can rewind,
`forward, and so on. Just, you know, and that's implemented
`through this so-called read pointer, which is really about the
`memory address.
`And that's exactly what that control circuit called 58,
`called address controller. It only does when you play the memory
`pointer, and nothing else. It doesn't do anything like how to have
`the subsequently and solely press the playback key and the time
`shifting interval between -- time shifting interval being the same
`as when you actuated the record key and when you actuated the
`playback key.
`Here, there's no playback key or record key at all in
`Goldwasser. And the disclosure simpl
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