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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`HTC Corporation,
`HTC America, Inc.,
`LG Electronics, Inc.,
`Samsung Electronics Co., Ltd., and
`Samsung Electronics America, Inc.
`Petitioners
`
`v.
`
`
`
`Parthenon Unified Memory Architecture LLC
`Patent Owner
`
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,321,368
`Case IPR No.: To Be Assigned
`
`DECLARATION OF HAROLD S. STONE, PH.D., REGARDING
`U.S. PATENT NO. 7,321,368
`
`
`
`
`
`HTC-LG-SAMSUNG 1030
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`Page 1 of 131
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`
`TABLE OF CONTENTS
`
`I. 
`
`II. 
`
`INTRODUCTION ........................................................................................... 1 
`A. 
`Engagement ........................................................................................... 1 
`B. 
`Background and Qualifications ............................................................. 1 
`C. 
`Compensation and Prior Testimony ...................................................... 4 
`D. 
`Information Considered ......................................................................... 5 
`LEGAL STANDARDS FOR PATENTABILITY .......................................... 6 
`A.  Anticipation ........................................................................................... 7 
`B. 
`Obviousness ........................................................................................... 8 
`III.  TECHNOLOGY BACKGROUND ............................................................... 12 
`A. 
`Basics of Computer Architecture & Video Encoding/Decoding ........ 12 
`1. 
`Tom Shanley and Don Anderson, “PCI System
`Architecture,” Third Edition, Addison-Wesley Publishing
`Company, Feb. 1995 (“Shanley”) (Ex. 1019) .......................... 12 
`International Organization for Standardization, “ISO/IEC
`11172-2:1993: Information technology—Coding of
`moving pictures and associated audio for digital storage
`media at up to about 1,5 Mbit/s—Part 2: Video (“MPEG
`Standard”) (Ex. 1004) ............................................................... 17 
`The Consolidation of MPEG and Other Multimedia Device’s
`Memory ............................................................................................... 22 
`1. 
`Intel Corporation “Acceleration Graphics Port Interface
`Specification,” Revision 1.0 (“AGP”) (Ex. 1024) .................... 22 
`Video Electronics Standards Association published the
`“VESA Unified Memory Architecture Hardware
`Specifications Proposal,” Version 1.0p (“VUMA”) (Ex.
`1025) ......................................................................................... 23 
`U.S. Patent No. 5,774,676 to Stearns (“Stearns”) (Ex.
`1007) ......................................................................................... 24 
`U.S. Patent No. 5,797,028 to Gulick (“Gulick 028”) (Ex.
`1023) ......................................................................................... 26 
`IV.  SUMMARY OF THE ’368 PATENT ........................................................... 29 
`A. 
`Effective Filing Date of the ’368 Patent ............................................. 29 
`B. 
`Overview of the ’368 Patent ................................................................ 29 
`C. 
`The Prosecution History of the ’368 Patent ........................................ 32 
`D. 
`Claim Construction ............................................................................. 32 
`LEVEL OF ORDINARY SKILL IN THE ART ........................................... 32 
`V. 
`VI.  OVERVIEW OF THE PRIOR ART REFERENCES ................................... 33 
`A.  U. S. Patent No. 5,546,547 (“Bowes”) (Ex. 1003) .............................. 33 
`-ii-
`
`2. 
`
`B. 
`
`2. 
`
`3. 
`
`4. 
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`B.  MPEG Standard (Ex. 1004) ................................................................ 34 
`S. Rathnam et al., “An Architectural Overview of the
`C. 
`Programmable Multimedia Processor, TM-1,” IEEE
`Proceedings of COMPCON ’96, pp. 12-19 (1996) (“Rathnam”)
`(Ex. 1005) ............................................................................................ 34 
`Stearns (Ex. 1007) ............................................................................... 35 
`D. 
`VII.  COMPARISON OF THE PRIOR ART TO THE ’368 PATENT ................ 36 
`A.  Ground A: Rathnam anticipates, under 35 U.S.C. § 102, claims
`1-3, 5, 7, 13-15, 17-21, and 23-25 ....................................................... 36 
`1. 
`Claim 1 ...................................................................................... 36 
`2. 
`Claim 2 ...................................................................................... 51 
`3. 
`Claim 3 ...................................................................................... 55 
`4. 
`Claim 5 ...................................................................................... 56 
`5. 
`Claim 7 ...................................................................................... 63 
`6. 
`Claim 13 .................................................................................... 69 
`7. 
`Claim 14 .................................................................................... 71 
`8. 
`Claim 15 .................................................................................... 74 
`9. 
`Claim 17 .................................................................................... 74 
`10.  Claim 18 .................................................................................... 76 
`11.  Claim 19 .................................................................................... 77 
`12.  Claim 20 .................................................................................... 78 
`13.  Claim 21 .................................................................................... 79 
`14.  Claim 23 .................................................................................... 80 
`15.  Claim 24 .................................................................................... 82 
`16.  Claim 25 .................................................................................... 83 
`Ground B: Bowes, in view of MPEG Standard, renders
`obvious, under 35 U.S.C. § 103, claims 1, 5, 7, 13, 15, 18, 20,
`24, and 25 ............................................................................................ 83 
`1. 
`Claim 1 ...................................................................................... 86 
`2. 
`Claim 5 ...................................................................................... 95 
`3. 
`Claim 7 ....................................................................................100 
`4. 
`Claim 13 ..................................................................................105 
`5. 
`Claim 15 ..................................................................................107 
`6. 
`Claim 18 ..................................................................................108 
`7. 
`Claim 19 ..................................................................................108 
`8. 
`Claim 20 ..................................................................................109 
`9. 
`Claim 24 ..................................................................................110 
`10.  Claim 25 ..................................................................................111 
`Ground C: Bowes, in view of MPEG Standard and Rathnam,
`renders obvious, under 35 U.S.C. § 103, claims 17, 19, and 23 ....... 111 
`-iii-
`
`C. 
`
`B. 
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`1. 
`
`A Person Skilled in the Art Would Have Been Motivated
`to Combine Bowes, MPEG Standard, and Rathnam ..............111 
`Claim 17 ..................................................................................113 
`2. 
`Claim 19 ..................................................................................114 
`3. 
`Claim 23 ..................................................................................115 
`4. 
`D.  Ground D: Bowes, in view of MPEG Standard and Stearns,
`renders obvious, under 35 U.S.C. § 103, claims 2, 3, 14, and 21 ..... 116 
`1. 
`Claim 2 ....................................................................................118 
`2. 
`Claim 3 ....................................................................................121 
`3. 
`Claim 14 ..................................................................................123 
`4. 
`Claim 21 ..................................................................................124 
`VIII.  APPENDIX A .................................................................................................. 1 
`
`
`-iv-
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`
`I, Harold S. Stone, Ph.D., declare as follows:
`
`I.
`
`INTRODUCTION
`A. Engagement
`1.
`I have been retained by counsel for the Petitioners to submit this
`
`declaration in connection with Petitioners’ Petition for Inter Partes Review of
`
`claims 1-3, 5, 7, 13-15, 17-21, and 23-25 of U.S. Patent No. 7,321,368 (“’368
`
`Patent”) (Ex. 1001).
`
`B.
`2.
`
`Background and Qualifications
`
`I was awarded a Ph.D. and Master’s Degree in Electrical Engineering
`
`from the University of California-Berkeley in 1963 and 1961, respectively. I
`
`received a Bachelor of Science degree in Electrical Engineering from Princeton
`
`University in 1960.
`
`3.
`
`After my graduation from Berkeley in 1963, I served as a Research
`
`Engineer at Boeing and SRI International. I then held faculty positions at Stanford
`
`University and at the University of Massachusetts, where I served as a professor of
`
`computer science and electrical engineering.
`
`4.
`
`In 1984, I started working for IBM as a Manager of Advanced
`
`Architecture Studies. In 1990, I became a Research Staff Member at IBM. During
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`my time at IBM, I managed and conducted research in the area of memory systems
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`and optical interconnections. I worked at IBM until 1994, when I became a Fellow
`
`at the NEC Research Institute, the highest technical position in the company. At
`1
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`NEC, I conducted research in image processing. I am an inventor of a patent to
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`NEC regarding a technique for decompressing JPEG images in a novel way that
`
`permits images to be searched without fully decompressing them. The
`
`decompression technique is based on inverse discrete cosine transforms, which are
`
`one of the basic elements of MPEG decompression, as described in the Asserted
`
`Patents.
`
`5.
`
`I have authored, coauthored, or edited 9 books in various technical
`
`areas, the most recent of which appeared in 2011. My textbooks have sold over
`
`100,000 copies. My work on the use of the perfect shuffle interconnections for
`
`supercomputers is widely recognized, and many supercomputers based on these
`
`interconnections were developed and marketed. For this work and my textbook
`
`contributions to the field, I was elected an IEEE Fellow and ACM Fellow, and
`
`received the IEEE Piore Field Award, the IEEE Computer Society Taylor Booth
`
`Award, and the Charles Babbage Award. I am the principal inventor or co-
`
`inventor of 27 patents, including seven in the area of computer architecture -
`
`U.S. Patent Nos. 4,989,131, 5,065,310, 5,163,149, 5,611,070, 5,742,785,
`
`5,790,823, and 6,311,260.
`
`6.
`
`I have served as a consultant to industry while holding my academic
`
`positions and have extensive experience in computer design for embedded
`
`computers as a consequence, including low-power computers for use in satellites
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`and ultra-reliable computers for use in nuclear submarine navigation systems. In
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`recent years I have been a member of two Division Review Committees at Los
`
`Alamos National Laboratory in the area of Nuclear Nonproliferation and a
`
`consultant to NASA in the area of satellite image processing.
`
`7. My work influenced the industry to develop several different
`
`“hypercube” computers in the 1980s, all of which had interconnections based on
`
`the perfect shuffle. In the 1990s, near when the Asserted Patents were filed, Intel,
`
`Sun, HP, and MIPS Technologies, Inc., introduced extension instruction sets for
`
`multimedia applications, all of which incorporated perfect shuffle data movement
`
`operations. The shuffle and its inverse are common operations used by MPEG
`
`software algorithms in processors that have multimedia instructions sets.
`
`8.
`
`In 1977, together with W. Kahan and J. Coonen, I authored the
`
`original proposal (“the KCS proposal”) to the working group charged for
`
`developing a floating-point standard, which is now known as the IEEE 754
`
`Floating Point Standard. The standard that emerged is that proposal with small
`
`changes and additions. It has been implemented in several billion processors.
`
`9. My Curriculum Vitae is submitted herewith as Ex. 1029.
`
`3
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`C. Compensation and Prior Testimony
`10.
`I am being compensated at a rate of $500 per hour for my study and
`
`other work in this matter, plus actual expenses. My compensation is not contingent
`
`on the outcome of this matter or the specifics of my testimony.
`
`11.
`
`I am also acting as an expert in the pending litigation between Patent
`
`Owner and Petitioners.
`
`12. Previously, I have testified either by deposition or at trial in the
`
`following litigation matters. The list below includes all deposition and trial
`
`testimony within the last five years:
`
` Parthenon Unified Memory Architecture LLC v. Samsung
`
`Electronics Co., Ltd. et al. (U.S. District Court, Eastern District of
`
`Texas), Case No. 2:14-cv-00902-JRG-RSP;
`
` Advanced Internet Technologies, Inc. v. Dell, Inc. (U.S. District
`
`Court, Eastern District of North Carolina), Case No. 5:07-cv-
`
`00426-H;
`
` Microunity Systems Engineering Inc v. Acer Inc et al. (U.S.
`
`District Court, Eastern District of Texas), Case No. 2:10-cv-00091-
`
`LED-RSP;
`
`4
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` Technology Service Corporation v. Mountcastle et al. (U.S.
`
`District Court, Eastern District of Virginia – Alexandria), Case
`
`No. 1:10-cv-00901-TSE-TCB;
`
` BIAX Corporation v. Motorola Solutions, Inc. et al. (U.S. District
`
`Court, District of Colorado – Denver), Case No. 1:10-cv-03013-
`
`PAB-KLM;
`
` Certain Computing Devices with Associated Instructions Sets and
`
`Software (International Trade Commission), Inv. 337-TA-812;
`
` Stragent, LLC et al. v. Intel Corporation (U.S. District Court,
`
`Eastern District of Texas – Tyler), Case No. 6:11-cv-00421-TBD-
`
`JDL; and
`
` Convolve Inc. et al. v. Compaq Computer Corporation et al., (U.S.
`
`District Court, Southern District of New York – Foley Square),
`
`Case No. 1:00-cv-05141-GBD-JCF.
`
`D.
`Information Considered
`13. My opinions are based on my years of education, research, and
`
`experience, as well as my investigation and study of relevant materials. In forming
`
`my opinions, I have considered the materials I identify in this declaration and those
`
`listed in Appendix A.
`
`5
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`14.
`
`I may rely upon these materials and/or additional materials to respond
`
`to arguments raised by the Patent Owner. I may also consider additional
`
`documents and information in forming any necessary opinions — including
`
`documents that may not yet have been provided to me.
`
`15. My analysis of the materials produced in this investigation is ongoing
`
`and I will continue to review any new material as it is provided. This declaration
`
`represents only those opinions I have formed to date. I reserve the right to revise,
`
`supplement, and/or amend my opinions stated herein based on new information
`
`and on my continuing analysis of the materials already provided.
`
`II. LEGAL STANDARDS FOR PATENTABILITY
`16.
`In expressing my opinions and considering the subject matter of the
`
`claims of the ’368 Patent, I am relying upon certain basic legal principles that have
`
`been explained to me.
`
`17. First, I understand that for an invention claimed in a patent to be
`
`found patentable, it must be, among other things, new and not obvious from what
`
`was known before the invention was made.
`
`18.
`
`I understand the information that is used to evaluate whether an
`
`invention is new and not obvious is generally referred to as “prior art” and
`
`generally includes patents and printed publications (e.g., books, journal
`
`publications, articles on websites, product manuals, etc.).
`
`6
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`19.
`
`I understand that the prior art includes patents and printed publications
`
`that existed before the earliest filing date (the “effective filing date”) of the claim
`
`in the patent. I also understand that a patent will be prior art if it was filed before
`
`the effective filing date of the claimed invention, while a printed publication will
`
`be prior art if it was publicly available before that date.
`
`20.
`
`I understand that there are two ways in which prior art may render a
`
`patent claim unpatentable. First, the prior art can be shown to “anticipate” the
`
`claim. Second, the prior art can be shown to have made the claim “obvious” to a
`
`person having ordinary skill in the art. My understanding of the two legal
`
`standards is set forth below.
`
`A. Anticipation
`21.
`I understand that the following standards govern the determination of
`
`whether a patent claim is “anticipated” by the prior art.
`
`22.
`
`I have applied these standards in my evaluation of whether the claims
`
`of the ’368 Patent would have been anticipated by the prior art.
`
`23.
`
`I understand that, for a patent claim to be “anticipated” by the prior
`
`art, each and every requirement of the claim must be found, expressly or
`
`inherently, in a single prior art reference as recited in the claim. I understand that
`
`claim limitations that are not expressly described in a prior art reference may still
`
`be there if they are “inherent” to the thing or process being described in the prior
`
`7
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`art. For example, an indication in a prior art reference that a particular process
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`complies with a published standard would indicate that the process must inherently
`
`perform certain steps or use certain data structures that are necessary to comply
`
`with the published standard.
`
`24.
`
`I understand that if a reference incorporates other documents by
`
`reference, the incorporating reference and the incorporated reference(s) should be
`
`treated as a single prior art reference for purposes of analyzing anticipation.
`
`25.
`
`I understand that it is acceptable to consider evidence other than the
`
`information in a particular prior art document to determine if a feature is
`
`necessarily present in or inherently described by that reference.
`
`B. Obviousness
`26.
`I understand that a claimed invention is not patentable if it would have
`
`been obvious to a person having ordinary skill in the field of the invention at the
`
`time the invention was made.
`
`27.
`
`I understand that the obviousness standard is defined in the patent
`
`statute (35 U.S.C. § 103(a)) as follows:
`
`A patent may not be obtained though the invention is not
`
`identically disclosed or described as set forth in section
`
`102 of this title, if the differences between the subject
`
`matter sought to be patented and the prior art are such
`
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`that the subject matter as a whole would have been
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`obvious at the time the invention was made to a person
`
`having ordinary skill in the art to which said subject
`
`matter pertains. Patentability shall not be negatived by
`
`the manner in which the invention was made.
`
`28.
`
`I understand that the following standards govern the determination of
`
`whether a claim in a patent is obvious. I have applied these standards in my
`
`evaluation of whether the asserted claims of the ’368 Patent would have been
`
`considered obvious as of the effective filing date of the claims in the ’368 Patent.
`
`29. When considering the issue of obviousness, I understand that I am to
`
`do the following: (i) determine the scope and content of the prior art; (ii) ascertain
`
`the differences between the prior art and the claims at issue; (iii) resolve the level
`
`of ordinary skill in the art; and (iv) consider objective evidence of non-obviousness
`
`(also known as “secondary considerations” of non-obviousness). Examples of
`
`evidence of secondary considerations of non-obviousness include evidence of
`
`commercial success, long-felt but unsolved needs, failure of others, and
`
`unexpected results. I am not presently aware of any evidence of “objective factors”
`
`suggesting any of the challenged claims of the ’368 Patent are not obvious, and
`
`reserve my right to address any such evidence if it is identified in the future.
`
`9
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`30.
`
`I understand that a person having ordinary skill is also a person of
`
`ordinary creativity.
`
`31. My understanding is that not all innovations are patentable. Even if a
`
`claimed product or method is not disclosed in its entirety in a single prior art
`
`reference, the patent claim is invalid if the invention would have been obvious to a
`
`person having ordinary skill in the art at the time of the invention. In particular, I
`
`understand that a patent claim is normally invalid as obvious if it would have been
`
`a matter of “ordinary innovation” within the relevant field to create the claimed
`
`product or method at the time of the invention.
`
`32.
`
`I also understand that the following exemplary scenarios would
`
`support a conclusion that a claimed product or method would have been obvious:
`
` Combining prior art elements according to known methods to yield
`
`predictable results;
`
` Simple substitution of one known element for another to obtain
`
`predictable results;
`
` Use of known technique to improve similar devices (methods, or
`
`products) in the same way;
`
` Applying a known technique to a known device (method, or
`
`product) ready for improvement to yield predictable results;
`
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` “Obvious to try” – choosing from a finite number of identified,
`
`predictable solutions, with a reasonable expectation of success;
`
` Known work in one field of endeavor may prompt variations of it
`
`for use in either the same field or a different one based on design
`
`incentives or other market forces if the variations are predictable to
`
`one of ordinary skill in the art;
`
` Some teaching, suggestion, or motivation in the prior art that
`
`would have led one of ordinary skill to modify the prior art
`
`reference or to combine prior art reference teachings to arrive at
`
`the claimed invention.
`
`33.
`
`I understand that sometimes it will be necessary to look to interrelated
`
`teachings of multiple patents; the effects of demands known to the design
`
`community or present in the marketplace; and the background knowledge
`
`possessed by a person having ordinary skill in the art. I understand that all these
`
`issues may be considered to determine whether there was an apparent reason to
`
`combine the known elements in the fashion claimed by the patent at issue.
`
`34.
`
`I understand that an invention that might be considered an obvious
`
`variation or modification of the prior art may be considered non-obvious if one or
`
`more prior art references discourages or lead away from the line of inquiry
`
`disclosed in the reference(s). A reference does not “teach away” from an invention
`
`11
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`simply because the reference suggests that another embodiment of the invention is
`
`better or preferred. My understanding of the doctrine of teaching away requires a
`
`clear indication that the combination should not be attempted (e.g., because it
`
`would not work or explicit statements saying the combination should not be made).
`
`III. TECHNOLOGY BACKGROUND
`A. Basics of Computer Architecture & Video Encoding/Decoding
`1.
`Tom Shanley and Don Anderson, “PCI System
`Architecture,” Third Edition, Addison-Wesley Publishing
`Company, Feb. 1995 (“Shanley”) (Ex. 1019)
`35. Tom Shanley and Don Anderson, “PCI System Architecture,” Third
`
`Edition, Addison-Wesley Publishing Company, Feb. 1995 (“Shanley”), was
`
`publically available at least by January 29, 1996. See Ex. 1019. I understand
`
`Shanley qualifies as prior art to the ’368 Patent at least under 35 U.S.C. § 102(a)
`
`and/or (b).
`
`36.
`
`Shanley describes PC architectures having a PCI bus. At the time of
`
`the alleged invention, the PCI bus, as defined in the PCI Special Interest Group’s
`
`PCI Local Bus Specification Revision 2.1, was a high performance industry
`
`standard bus. See, e.g., Ex. 1019 at 58-60.
`
`37.
`
`Shanley Figures 1-2 and 1-3 depict the application of a three-way real-
`
`time video teleconference with four video streams (one local video preview stream,
`
`two remote video streams, and a larger graphical stream).
`
`12
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`Ex. 1019 at p. 42.
`Ex. 1019 atp. 42.
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`Ex. 1019 at p. 43.
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`38. The PCI bus enabled such applications. An example of a PC
`
`employing the PCI bus is shown below in Figure 2-4.
`
`
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`Ex. 1019 at p. 57 (Figure 2-4, annotated).
`
`39. As shown in Figure 2-4, the system includes a PCI bus that links a
`
`motion video peripheral, audio peripheral, graphics adapter, and other devices.
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`The motion video peripheral (red) has its own video memory (also red) that is
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`separate from the main memory (blue).
`
`40. Arbitration for access to main memory is largely left up to the
`
`designer. Ex. 1019 at pp. 92-127. In the PCI specification, each potential bus
`
`master’s interface has a set of lines to handle arbitration, REQ# and GNT#. Ex.
`
`1019 at p. 69. The REQ# and GNT# are separately routed from each potential bus
`
`master to the arbitration mechanism:
`
`Ex. 1019, Shanley at p. 93 (Figure 6-1).
`
`16
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`41. The arbiter may be a separate component or may be integrated into
`
`another device, such as the PCI chip set. See Ex. 1019 at p. 92 (“Although the
`
`arbiter is shown as a separate component, it usually is integrated into the PCI chip
`
`set; specifically, it is typically integrated into the host/PCI or the PCI/expansion
`
`bus bridge chip.”)
`
`42.
`
`Shanley describes one particular implementation of a system using the
`
`VLSI VL82C59x SuperCore PCI chipset. Ex. 1019 at pp. 187-220.
`
`43.
`
`In the VL82C59x chipset, the VL82C591 Pentium System Controller
`
`in combination with the two VL82C592 Pentium Processor Data Buffers
`
`incorporate the “PCI and host bus arbiters” for memory accesses by the peripherals
`
`or CPU/processor. Ex. 1019 at pp. 189-190.
`
`44. Arbitration must be present in any system that shares access to a
`
`resource (e.g., a memory) via a bus to prevent conflicts (i.e., two devices
`
`attempting to access a memory over a bus at the same time). Ex. 1020 at 4-6. I
`
`described this in my book, “Microcomputer Interfacing,” first published in 1982 by
`
`Addison-Wesley Publishing Company (Ex. 1020): “the role of the arbitration lines
`
`is then very clearly defined. They guarantee that, at most, one module at a time
`
`transmits on the bus.” Ex. 1020 at 4-6.
`
`2.
`
`International Organization for Standardization,
`“ISO/IEC 11172-2:1993: Information technology—Coding of
`moving pictures and associated audio for digital storage media
`
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`at up to about 1,5 Mbit/s—Part 2: Video (“MPEG Standard”)
`(Ex. 1004)
`
`45.
`
`I understand that the International Organization for Standardization,
`
`“ISO/IEC 11172-2:1993: Information technology—Coding of moving pictures and
`
`associated audio for digital storage media at up to about 1,5 Mbit/s—Part 2:
`
`Video,” 1st ed., August 1, 1993 (“MPEG Standard”), was publically available as
`
`of August 1993, and qualifies as prior art to the ’368 Patent at least under
`
`35 U.S.C. § 102(a) and (b).
`
`46. MPEG Standard describes a video compression standard using two
`
`forms of compression: spatial and temporal. Like JPEG, spatial compression in
`
`MPEG involves compressing a single image based on blocks of pixels within the
`
`image in which the pixels have similar characteristics. Because MPEG deals with
`
`video, MPEG further includes temporal compression to compress an image based
`
`on similarities to other frames in the video sequence. As described by MPEG
`
`Standard:
`
`Ex. 1004 at 5 (§ 0.2 Overview of the algorithm).
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`18
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`47. The 16-pel by 16-line (16x16 pixel region) referenced above referred
`
`to as a macroblock and may vary in data size depending on the color format. Ex.
`
`1004 at 17 (§ 2.1.86 macroblock [video]).
`
`48. The compression disclosed in MPEG Standard is useful for storage
`
`and/or transmission. Videos can be encoded to reduce bandwidth or memory
`
`requirements during storage or transmission and subsequently decoded for display.
`
`Ex. 1004 at 62 (Figure D.1, annotated).
`
`49. To permit predictive and non-causal interpolative temporal
`
`processing, MPEG Standard defines three picture types:
`
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`Ex. 1004 at 5 (§ 0.2.1 Temporal processing).
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`50. As stated above, I-pictures are coded without reference to other
`
`pictures, P-pictures are coded with reference to past pictures, and B-pictures are
`
`coded with reference to past and future pictures and are never used as references
`
`for prediction. See supra ¶ 49.
`
`51. The following figure illustrates the relationship between the three
`
`picture types:
`
`
`
`Ex. 1004 at 5 (Figure 1).
`
`52. Note that in decoding, if a B-picture was encoded with reference to a
`
`previous P-picture and a subsequent P-picture (in sequence), the two P-pictures are
`
`decoded in time (but not displayed in time) prior to the decoding of the B-picture:
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`Ex. 1004 at 24-25.
`
`53. MPEG Standard depicts a simplified decoder implementation:
`
`
`
`
`
`
`
`Ex. 1004 at 66 (Figure D.7).
`
`54. As shown above, the decoder receives an encoded or compressed
`
`bitstream from a source (e.g., a memory). The VLC decoder, inverse zig-zag and
`
`quantizer, and inverse DCT blocks decode the bitstream, and then the various
`
`motion compensation blocks act (for the various picture types). Two frame stores
`
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`are present, one for past and one for future frames to facilitate decoding of B-
`
`pictures. Once a frame is no longer needed, it may be output to a display buffer for
`
`display. Note that the MPEG Standard does not restrict the location of the picture
`
`stores. In the absence of such a constraint conforming implementations could use
`
`shared memory or a combination of shared and dedicated memory.
`
`B.
`
`The Consolidation of MPEG and Other Multimedia Device’s
`Memory
`55. One widely recognized goal in computing reducing cost. As detailed
`
`below, one well known technique to reduce cost was to eliminate dedicated
`
`memory associated with an MPEG or other media device.
`
`1.
`
`Intel Corporation “Acceleration Graphics Port
`Interface Specification,” Revision 1.0 (“AGP”) (Ex. 1024)
`
`56.
`
`Intel Corporation “Acceleration Graphics Port Interface
`
`Specification,” Revision 1.0 (“AGP”), was published on July 31, 1996. See Ex.
`
`1024.
`
`57. AGP’s stated purpose was to control costs by sharing memory:
`
`In general, 3D rendering has a voracious appetite for
`
`memory bandwidth, and continues to put upward
`
`pressure on memory footprint as well. As 3D hardware
`
`and software become more pervasive, these two trends
`
`are likely to accelerate, requiring high speed access to
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`ever larger amounts of memory, thus raising the bill of
`
`material costs for 3D enabled platforms. Containing these
`
`costs while enabling performance improvements is the
`
`primary motivation for the A.G.P.. By providing up to an
`
`order of magnitude bandwidth improvement between
`
`the graphics accelerator and system memory, some of
`
`the 3D rendering data structures may be effectively
`
`shifted into main memory, relieving the pressure to
`
`increase the cost of the local graphics memory.
`
`Ex. 1024 at p. 11 (Motivation) (emphasis added).
`
`2.
`
`Video Electronics Standards Association published
`the “VESA Unified Memory Architecture Hardware
`Specifications Proposal,” Version 1.0p (“VUMA”) (Ex. 1025)
`58. Video Electronics Standards Association published the “VESA
`
`Unified Memory Architecture Hardware Specifications Proposal,” Version 1.0p
`
`(“VUMA”), was published October 31, 1995. See Ex. 1025.
`
`59. VUMA’s stated purpose was to eliminate the need for a component to
`
`incorporate a dedicated memory by instead using a shared system memory to serve
`
`as the component’s memory:
`
`The concept of VESA Unified Memory Architecture
`
`(VUMA) is to share physical system memory (DRAM)
`
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`between system and an external device, a VUMA device;
`
`as shown in Figure 1-1. A VUMA device could be any
`
`type of controller which needs to share physical sys