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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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`UNIFIED PATENTS INC.
`Petitioner
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`v.
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`FO2GO
`Patent Owner
`____________
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`Patent No. 7,173,651
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`DECLARATION OF CHARLES ELDERING, PH.D.
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`U.S. PATENT NO. 7,173,651 – CLAIMS 1-5
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`TABLE OF CONTENTS
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`INTRODUCTION ........................................................................................... 1
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`I.
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`II. OVERVIEW OF THE ’651 PATENT ............................................................ 4
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`III. LEVEL OF ORDINARY SKILL IN THE ART ............................................. 6
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`IV. UNDERSTANDING OF LAW ...................................................................... 7
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`V.
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`VI.
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`CLAIM CONSTRUCTION ............................................................................ 9
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`INVALIDITY OF THE CHALLENGED CLAIMS ..................................... 10
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`A. Ground 1: Matsumoto anticipates claims 2-5 ..................................... 10
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`1. Overview of Matsumoto ................................................................. 10
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`2. Claim 2 is anticipated by Matsumoto ............................................. 16
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`3. Claim 3 is anticipated by Matsumoto ............................................. 35
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`4. Claim 4 is anticipated by Matsumoto ............................................. 37
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`5. Claim 5 is anticipated by Matsumoto ............................................. 38
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`6. Claim Chart ..................................................................................... 40
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`B.
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`Ground 2: Matsumoto in view of Jones renders claim 1
`obvious. ............................................................................................... 58
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`1. Overview of Jones ........................................................................... 58
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`2. Claim 1 is obvious over Matsumoto in view of Jones .................... 60
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`3. Claim Chart ..................................................................................... 73
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`C.
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`Ground 3: Maurinus anticipates claims 2-5 ........................................ 87
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`1. Overview of Maurinus .................................................................... 87
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`2. Claim 2 is Anticipated by Maurinus ............................................... 92
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`3. Claim 3 is Anticipated by Maurinus ............................................. 108
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`4. Claim 4 is Anticipated by Maurinus ............................................. 110
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`5. Claim 5 is Anticipated by Maurinus ............................................. 111
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`6. Claim Chart ................................................................................... 113
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`D. Ground 4: Maurinus in view of Jones renders claim 1 obvious. ...... 132
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`1. Claim 1 is Obvious over Maurinus in view of Jones .................... 132
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`2. Claim Chart ................................................................................... 144
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`VII. AVAILABILITY FOR CROSS-EXAMINATION .................................... 159
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`VIII. RIGHT TO SUPPLEMENT ....................................................................... 160
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`IX.
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`JURAT ........................................................................................................ 160
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`I, Charles Eldering, declare as follows:
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`I.
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`INTRODUCTION
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`1. My name is Charles Eldering. I received a B.S. from Carnegie Mellon
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`in Physics, a M.S. From Syracuse University in Solid State Science and
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`Technology, and a Ph.D. in Electrical Engineering from the University of
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`California. A copy of my curriculum vitae, which includes a more detailed
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`summary of my background, experience, patents, and publications, is attached at
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`EX1003.
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`2.
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`I have been retained by Unified Patents Inc. (“Unified”) as an
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`independent expert consultant in the field of computer networks and digital media
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`communications. I am being compensated for the time I spend on this matter, but
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`my compensation is not dependent on and in no way affects the substance of my
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`statements in this declaration.
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`3.
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`I have been involved in computer engineering, fiber-optic, cable-
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`based, and network telecommunications for over 20 years. At Expanse Networks, a
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`company I founded in 2000, I worked extensively on developing designs, systems,
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`and initial system prototypes and products for media communication systems. I
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`also developed network architectures for content delivery and software for devices,
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`such as head-end equipment and consumer electronic devices (e.g., set-top boxes).
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`4. My experience at General Instrument Corporation from 1993 to 1995
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`as the Manager of Fiber-to-the-Curb/Switched Digital Video Systems and
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`Broadband Systems Engineering is also relevant to this matter. At General
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`Instrument, I was involved in digital video system design and development for
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`two-way interactive networks.
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`5.
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`I am not an attorney and offer no legal opinions, but in my work,
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`including my work as a patent agent, I have had experience studying and analyzing
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`patents and patent claims from the perspective of a person skilled in the art, and
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`have developed patent portfolios. I have previously served as a patent analyst and
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`research consultant and I am a named inventor on many patents.
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`6.
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`I have reviewed the specification, the claims, and the prosecution
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`history of U.S. Patent No. 7,173,651 to Knowles (“’651 Patent” (EX1001)).
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`7.
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`I have reviewed and understand the following references:
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`i. U.S. Patent No. 6,833,861 to Matsumoto et al. (“Matsumoto”)
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`(EX1004). Matsumoto claims priority to Japanese Patent Application No. 9-
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`072008, which was filed on March 25, 1997 and published as Japanese Patent
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`Publication No. JP H 9-322114A on December 12, 1997 ( EX1005 includes a
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`certified translation of JP H 9-322114A, referred to herein as “Matsumoto-JP”);
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`ii. U.S. Patent No. 5,606,365 to Maurinus et al. (“Maurinus”) (EX1006);
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`and
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`iii. U.S. Patent No. 5,742,763 to Jones (“Jones”) (EX1007)
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`8.
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`I have been asked to consider whether the references listed above in
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`paragraph 7 disclose or suggest the features recited in the claims of the ’651 Patent.
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`I have also been asked to consider the state of the art and the prior art available
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`before the effective filing date of the ’651 Patent. I have been informed that U.S.
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`Patent Application No. 09/324,249 (“’249 Application”), which issued as the ’651
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`Patent on February 6, 2007, was filed on June 2, 1999. I have also been informed
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`that the ’249 Application claims priority to U.S. Provisional Patent Application
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`No. 60/087,745 (“’745 Provisional Application”) filed on June 2, 1998. I have
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`further been informed that because descriptive material was added and the claims
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`were changed in the ’249 Application relative to the ’745 Provisional Application,
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`the claims of the ’651 Patent may have different effective filing dates. For
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`example the effective filing date for a claim may be June 2, 1999 or June 2, 1998,
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`depending on the claim is supported by the ’745 Provisional Application.
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`9. My opinions are provided in this declaration.
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`10. To the best of my knowledge, I have no financial interest in Petitioner.
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`Petitioner’s counsel has informed me that FO2GO (“FO2GO” or “Patent Owner”)
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`purports to own the ’651 Patent. To the best of my knowledge, I have no financial
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`interest in FO2GO, and I have had no contact with FO2GO or the named inventor
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`of the patent, Andrew T. Knowles. To the best of my knowledge, I similarly have
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`no financial interest in the ’651 Patent. To the extent any mutual funds or other
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`investments I own have a financial interest in the Petitioner, Unified Patents Inc.,
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`or the ’651 Patent, I am not aware of, nor do I have control over, any financial
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`interest that would affect or bias my judgment.
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`II. OVERVIEW OF THE ’651 PATENT
`11. The ’651 Patent recognizes that it was known to download a
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`photograph from a digital camera to a computer, to forward such a photograph to
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`others via e-mail, and to incorporate such a photograph on an Internet web page.
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`EX1001 ’651 Patent at 1:25-32. However, the ’651 Patent states that image
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`transfer between the digital camera and the computer via floppy disk, memory
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`card, or infrared is convenient. Id. at 1: 33-52. The ’651 Patent also recognizes that
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`an Internet archival service for conventional film processing was available, but
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`states that there is no known similar service for digital photos. Id. at 1:57-2:3. The
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`’651 Patent further recognizes that it was possible to assemble a portable device
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`which can transfer data files to a destination computer, although such a system
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`would require user input of a destination phone number for modem dialing or a
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`host internet protocol (IP) address or an e-mail address to send an image to. Id. at
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`2:57-64.
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`12.
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`In view of the above-recognized aspects, the ’651 Patent is directed to
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`a system that requires comparatively less user input for configuration and
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`operation. Id. at 2:64-67. The ’651 Patent teaches that a wireless camera device
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`includes a digital camera to create a digital image, a memory to store a delivery IP
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`address and a list of nicknames, and a radio frequency (RF) communications
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`device. Id. at 4:51-67. The wireless camera device transmits a message to a server
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`at the delivery IP address, where the message includes a recipient code (nickname)
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`and at least one digital image. Id.
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`13. The ’651 Patent further teaches that the server at the delivery IP
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`address can store the received message or forward the received message to another
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`IP address. Id. at 3:53-57. The server can resolve between nicknames, e-mail
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`addresses, and IP addresses. Id. at 3:12-19.
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`14. Thus, the ’651 Patent teaches that a user of the wireless camera device
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`can select a nickname and the server can cause an image received from the wireless
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`camera device to be delivered to an e-mail address or an IP address (corresponding
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`to the nickname). Id. at 3:53-57, 3:12-19, and 4:51-67.
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`15. As the prior art demonstrates, technologies that enable a camera user
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`to select a recipient and send an image to a server with reduced user input were
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`well-known prior to the effective filing date of the ’651 Patent. Additionally,
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`storing images on a server and distributing images from a server to other devices
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`were also well-known prior to the effective filing date of the ’651 Patent.
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`III. LEVEL OF ORDINARY SKILL IN THE ART
`16.
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`I have considered certain issues from the perspective of a person of
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`ordinary skill in the art at the effective filing date of the’651 Patent. In my opinion,
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`a person of ordinary skill in the art for the ’651 Patent would have a Master’s
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`Degree in electrical engineering, computer science, or a related subject or the
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`equivalent, and would also have at least three years of experience working with
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`electronic
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`devices,
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`user
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`interfaces,
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`computer
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`networks,
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`and
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`digital
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`communications, or the equivalent.
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`IV. UNDERSTANDING OF LAW
`17.
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`I have considered certain issues from the perspective of a person of
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`ordinary skill in the art at the time of the effective filing date of the ’651 Patent.
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`18.
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`I am not an attorney. For the purposes of this declaration, Petitioner’s
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`counsel have informed me about certain aspects of the law that are relevant to my
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`opinions.
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`19. Petitioner’s counsel have informed me that a patent claim may be
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`“anticipated” if each element of that claim is present either explicitly or inherently
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`in a single prior art reference. Petitioner’s counsel have informed me that to be
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`inherently present, the prior art reference must necessarily disclose the limitation,
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`and the fact that the reference might possibly practice or contain a claimed
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`limitation is insufficient to establish that the reference inherently teaches the
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`limitation.
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`20. Petitioner’s counsel have informed me that a patent claim can be
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`considered to have been obvious to a person of ordinary skill in the art at the time
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`of the effective filing date of the patent claim. This means that, even if all of the
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`requirements of a claim are not found in a single prior art reference, the claim is
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`not patentable if the differences between the subject matter in the prior art and the
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`subject matter in the claim would have been obvious to a person of ordinary skill in
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`the art at the time of the effective filing date.
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`21. Petitioner’s counsel have informed me that a determination of whether
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`a claim would have been obvious should be based upon several factors, including,
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`among others: the level of ordinary skill in the art at the time of the effective filing
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`date; the scope and content of the prior art; and what differences, if any, existed
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`between the claimed invention and the prior art.
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`22. Petitioner’s counsel have informed me that a single reference can
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`render a patent claim obvious if any differences between that reference and the
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`claims would have been obvious to a person of ordinary skill in the art.
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`Alternatively, the teachings of two or more references may be combined as
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`disclosed in the claims, if such a combination would have been obvious to one
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`having ordinary skill in the art. In determining whether a combination based on
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`multiple references would have been obvious, it is appropriate to consider, among
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`other factors: whether the teachings of the prior art references disclose known
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`concepts combined in familiar ways, and when combined, would yield predictable
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`results; whether a person of ordinary skill in the art could implement a predictable
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`variation, and would see the benefit of doing so; whether the claimed elements
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`represent one of a limited number of known design choices, and would have a
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`reasonable expectation of success by those skilled in the art; whether a person of
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`ordinary skill would have recognized a reason to combine known elements in the
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`manner described in the claim; whether there is some teaching or suggestion in the
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`prior art to make the modification or combination of elements claimed in the
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`patent; and whether the innovation applies a known technique that had been used
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`to improve a similar device or method in a similar way.
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`23. Petitioner’s counsel have informed me that one of ordinary skill in the
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`art has ordinary creativity, and is not an automaton. Petitioner’s counsel have
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`informed me that in considering obviousness, it is important not to determine
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`obviousness using the benefit of hindsight derived from the patent being
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`considered.
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`V. CLAIM CONSTRUCTION
`24.
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`I have been advised that the first step of assessing the validity of a
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`patent claim is to interpret or construe the meaning of the claim.
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`25.
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`I have been further advised that in post-grant review proceedings
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`before the U.S. Patent and Trademark Office, a patent claim receives the broadest
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`reasonable construction in light of the specification of the patent in which it
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`appears. I have also been advised that this means the claim terms are given their
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`ordinary and customary meaning as would be understood by one of ordinary skill
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`in the art unless that meaning is inconsistent with the specification of the patent.
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`26.
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`In my analysis I have given the claim terms their broadest reasonable
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`interpretation in light of the specification. I have considered whether any claim
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`term has been defined in the specification, and for those terms which lack a
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`definition in the specification, I have similarly applied the broadest reasonable
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`interpretation that is consistent with the interpretation that one skilled in the art
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`would have applied at the time of the effective filing date of the ’651 Patent.
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`VI. INVALIDITY OF THE CHALLENGED CLAIMS
`A. Ground 1: Matsumoto anticipates claims 2-5
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`27.
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`In this section, I explain why every element of claims 2-5 of the ’651
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`Patent is found in U.S. Patent No. 6,833,861 (“Matsumoto,” EX1004), as arranged
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`in the claims. Matsumoto claims priority to Japanese Patent Application No. 9-
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`072008, which was filed on March 25, 1997 and published as Japanese Patent
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`Publication No. JP H 9-322114A. EX1005 includes a certified translation of
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`JP H 9-322114A and is referred to herein as “Matsumoto-JP.”
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`1. Overview of Matsumoto
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`28. Matsumoto discloses a digital photo processing system that includes a
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`digital camera and a plurality of photo processing locations. See EX1004
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`Matsumoto at Title. FIG. 5 of Matsumoto shows an exemplary digital photo
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`processing system including a digital still camera 49 in wireless communication
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`with reception equipment 60 and printing equipment 10.
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`29. Matsumoto discloses that the digital still camera 49 can wirelessly
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`transmit digital images to the reception equipment 60 for transfer to user selected
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`printing equipment 10. Id. at FIG. 5. The user selected printing equipment 10 can
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`then print the digital images and deliver the images to a user selected delivery
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`location. Id. at FIG. 5. The user may select the printing equipment 10 or the
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`delivery place by using a “place name” instead of an address. Id. at FIG. 5, 6:49-
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`54, and 7:8-29.
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`30. FIG. 3 of Matsumoto discloses the digital still camera 49. Id. at FIG.
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`3.
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`31. Matsumoto includes two embodiments of digital still cameras, which
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`are designated digital still camera 49 (in FIGS. 3 and 5) and digital still camera 9
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`(in FIG. 1). The digital still camera (9 or 49) includes a camera section (12 or 50)
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`including an imaging section 15 and an image processor 16. Id. at FIGS. 1 and 3
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`and 2:48-55. The imaging section 15 captures analog signals of an image using a
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`triple plate sensor. Id. The image processor 16 processes/converts the captured
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`analog signals into digital image data. Id.
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`32. The digital still camera 49 also includes a data communication section
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`13, including a data terminal 20 and a sending data memory 22. Id. at FIGS. 1 and
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`3, 2:63-65, and 5:15-18. The data terminal 20 includes a modem and a radio
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`sender-receiver for sending and receiving data through radio telephony. The
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`sending data memory 22 stores addresses of the photo labs. In some examples, a
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`photo lab includes the reception equipment 60 and the printing equipment 10. Id. at
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`6:16-18
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`33. The digital still camera 49 can send digital images and data to the
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`reception equipment 60, Id. at 3:11-22, which may be included in a photo lab
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`which houses the printing equipment 10. The digital still camera 49 also stores
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`“place names” of the printing equipment 10 and delivery places. Id. at 6:16-18 and
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`6:53-59. The place names may be nicknames associated with the actual addresses
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`of the printing equipment 10 and delivery places. Id. The digital still camera 49
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`includes an LCD panel 52 and key input 21 for displaying the place names and for
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`user selection and input of the place names. Id. at FIG. 5, 7:3-5, and 7:16-17.
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`34. Thus, Matsumoto discloses that the place name and the digital image
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`are sent, for example in a message, from the digital still camera (9 or 49) to the
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`reception equipment 60 via the radio sender-receiver of the data terminal 20.
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`35. FIG. 5 of Matsumoto also illustrates the reception equipment 60.
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`36. The reception equipment 60 includes a buffer memory 62, a data
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`receiver 61 and a data sender 66. Id. at FIG. 5 and 6:20-24. The reception
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`equipment 60 includes a system controller 67 for controlling the reception
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`equipment 60. Id. at FIG. 5 and 6:20-28. The reception equipment 60 receives the
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`image data from the digital still camera 49 and stores the image data and control
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`data at the buffer memory 62, including the place names. Id. at 6:27-32.
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`37. Matsumoto discloses that the reception equipment 60 includes “a table
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`for correlating place names with the addresses of the printing equipment 10 of the
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`respective geographical areas, so the nearest printing equipment 10 to the present
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`location of the camera 49 is selected based on the place name entered through the
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`key input 21.” Id. at 6:53-59. Matsumoto also discloses that “[t]he address decoder
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`63 decodes the address of the delivery place appointed by the user, that is included
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`in the print delivery commands of the received data,” Id. at 6:30-32, which may be
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`designated by place name. Id. at 7:8-30. Thus, Matsumoto describes that the
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`reception equipment 60 can use the table to determine an address of the printing
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`equipment 10 corresponding to the place name selected by a user.
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`38. The reception equipment 60 sends a data file to the address of the
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`printing equipment 10 corresponding to the user-selected place name. Id. at 6:37-
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`59. The data file includes the digital image and in some examples can also include
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`a decoded delivery place (other than the printing equipment 10). Id. The printing
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`equipment 10 receives the data file and prints the digital images according to data
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`file. If the data file includes a decoded deliver place, the printing equipment 10
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`can deliver the digital image prints to the decoded delivery place. Id. at 7:8-30.
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`2. Claim 2 is anticipated by Matsumoto
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`39. Claim 2 recites: Digital photo processing system comprising:
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`at least one wireless digital camera apparatus, wherein each said apparatus
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`includes a processor, a memory, and a destination address and one or more
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`previously defined recipient codes stored in said memory; user interface connected
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`to said processor for at least displaying one or more said recipient codes and
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`receiving signals indicating user selection of a displayed recipient code; a digital
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`camera connected to said processor for capturing one or more digital images in
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`response to signals from said user interface; a RF communications device
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`connected to said processor; and processor control means, responsive to signals
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`received from said user interface, for transmitting a message, including at least said
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`selected recipient code and one said digital image, to said destination address via
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`said RF communications device; and
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`a server associated with said destination address and responsive to messages
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`received at said destination address from each said wireless digital camera
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`apparatus; a database storing account configuration data including recipient code
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`data; a server communication device; and server control means for parsing said
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`recipient code from each said message, retrieving from said database account
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`configuration data that is associated with said recipient code, and processing each
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`said message according to said account configuration data.
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`a)
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` “[d]igital photo processing system”
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`40.
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`In my opinion, Matsumoto discloses this limitation.
`
`41. Matsumoto discloses a “system for transferring image data from a
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`camera to a printing system.” Matsumoto at Title and FIGS. 1, 3, and 5; see also
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`Matsumoto-JP [0005]. The system includes a digital camera (9 or 49), reception
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`equipment 60, and printing equipment 10. See Matsumoto at FIGS. 1, 3, and 5; see
`
`also Matsumoto-JP at [0005]. The digital camera 49 can transmit image data
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`wirelessly to the reception equipment 60, which transfers the image data to the
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`printing equipment 10 selected by the user. See Matsumoto at Abstract and FIG. 5;
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`see also Matsumoto-JP at [0005]. The printing equipment 10 selected by the user
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`processes the digital images and can deliver the processed digital images to a
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`delivery location selected by the user. See Matsumoto at Abstract and FIG. 5; see
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`also Matsumoto-JP at [0005].
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`42. Thus, in my opinion, by describing the digital camera 49, the
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`reception equipment 60, and the printing equipment 10, Matsumoto discloses a
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`“digital photo processing system.”
`
`b)
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`“at least one wireless digital camera apparatus, wherein each said
`apparatus includes a processor, a memory”
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`43.
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`In my opinion, Matsumoto discloses this limitation.
`
`44. Matsumoto discloses that the digital still camera (9 or 49) includes a
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`camera section (12 or 50), a data communication section (13 or 53), and a system
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`controller 14. Matsumoto at FIGS. 1 and 3; 2:43-49; see also Matsumoto-JP at
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`[0008]-[0009]. The camera section 12 includes an image processor 16. Id. The data
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`communication section (13 or 53) includes a sending data memory 22. Id. A person
`
`of ordinary skill in the art would understand that the image processor 16 teaches
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`the processor of claim 2 of the ‘651 Patent.
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`45. Thus, in my opinion, by describing that the digital still camera 9 or 49
`
`(“a wireless digital camera apparatus”) includes the image processor 16
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`(“processor”) and the sending data memory 22 (“memory”), Matsumoto discloses
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`
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`“at least one wireless digital camera apparatus, wherein each said apparatus
`
`includes a processor, a memory.”
`
`c)
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`“a destination address”
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`46.
`
`In my opinion, Matsumoto discloses this limitation.
`
`47. Matsumoto discloses that the sending data memory 22 stores
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`“addresses of the plurality of photo labs” (“destination address”). Matsumoto at
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`FIG. 5; 6:16-20; see also Matsumoto-JP at [0034]. Matsumoto describes that the
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`“addresses of the plurality of photo labs” (“destination address”) can include a
`
`telephone number of a transmission destination, such as the reception equipment
`
`60 or a photo lab, Matsumoto at FIG. 5; 5:26-31; see also Matsumoto-JP at [0030].
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`Additionally, Matsumoto describes that in some embodiments the photo lab can
`
`include reception equipment 60. Matsumoto at FIG. 5; 6:16-20; see also
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`Matsumoto-JP at [0034].
`
`48. Thus, in my opinion, by describing that the sending data memory 22
`
`(“memory”) stores addresses of the plurality of photo labs (“destination address”),
`
`Matsumoto discloses “a destination address.”
`
`d)
`
`“and one or more previously defined recipient codes stored in said
`memory”
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`49.
`
`In my opinion, Matsumoto discloses this limitation.
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`50. As explained above, In my opinion, by describing that the sending
`
`data memory 22 stores addresses of photo labs, Matsumoto discloses “a destination
`
`address.” Matsumoto at FIG. 3; 5:26-31; see also Matsumoto-JP at [0030].
`
`51. Additionally, Matsumoto discloses that a place name (“recipient
`
`code”) may be used instead of an actual address. Matsumoto at 6:53-59; see also
`
`Matsumoto-JP at [0036]. In Matsumoto, place names (“recipient codes”) may be
`
`used for designating the printing equipment 10 and may be used for designating a
`
`delivery destination. Matsumoto at 6:53-59 and 7:8-30; see also Matsumoto-JP at
`
`[0036] and [0037]. A delivery destination may include, for example, a location
`
`where the user would like to pick up photographs or where the user would like the
`
`photographs to be delivered. Matsumoto at 7:8-30; see also Matsumoto-JP at
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`[0037]. Place names are displayed on an LCD panel 52 of the digital still camera
`
`49. Matsumoto at FIG. 3; 7:3-5 and 7:16-17; see also Matsumoto-JP at [0036] and
`
`[0037]. In my opinion, a person skilled in the art would understand the disclosure
`
`in Matsumoto of place names (“recipient codes”) being displayed on the LCD
`
`panel 52 of the digital still camera 49 as disclosing that the place names (“recipient
`
`codes”) are stored in memory, such as the sending data memory 22. For example,
`
`the place names stored in memory would be retrieved from the memory and
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`
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`provided to the LCD panel 52 for display. Additionally or alternatively, the place
`
`name may be stored in a memory or buffer of the LCD panel 52.
`
`52. Thus, in my opinion, by describing place names (“recipient codes”)
`
`being stored in memory, Matsumoto discloses “one or more previously defined
`
`recipient codes stored in a memory.”
`
`e)
`
`“user interface connected to said processor for at least displaying
`one or more said recipient codes”
`
`53.
`
`In my opinion, Matsumoto discloses this limitation.
`
`54. Matsumoto discloses that the digital still camera 49 includes the LCD
`
`panel 52 and a key input 21 controlled by a system controller 14 (collectively a
`
`“user interface”). Matsumoto describes that the LCD panel 52 can display a list of
`
`place names (“recipient codes”). Matsumoto at FIG. 3; 7:16-17; see also
`
`Matsumoto-JP at [0037].
`
`55. Thus, in my opinion, by describing that the LCD panel 52 displays a
`
`list of place names (“recipient codes”), Matsumoto discloses a “user interface
`
`connected to said processor for at least displaying one or more said recipient
`
`codes.”
`
`f)
`
`
`
`
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`“and receiving signals indicating user selection of a displayed
`recipient code”
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`21
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`56.
`
`In my opinion, Matsumoto discloses this limitation.
`
`57. Matsumoto discloses that the digital still camera 49 includes the LCD
`
`panel 52 and a key input 21 controlled by a system controller 14 (collectively a
`
`“user interface”). In Matsumoto, the place names can be entered through the key
`
`input 21. Matsumoto at FIGS. 3-5; 6:53-59; see also Matsumoto-JP at [0036].
`
`58. Thus, in my opinion, by describing the ability of a user to select a
`
`displayed place name (“recipient code”) using a key input 21, Matsumoto discloses
`
`“receiving signals indicating user selection of a displayed recipient code.”
`
`g)
`
`“a digital camera connected to said processor for capturing one or
`more digital images in response to signals from said user interface”
`
`59.
`
`In my opinion, Matsumoto discloses this limitation.
`
`60. Matsumoto discloses that the digital still camera 49 includes a camera
`
`section (12 or 50). Matsumoto at FIGS. 1 and 3; 2:43-49 and 5:22-25; see also
`
`Matsumoto-JP at [0008]-[0009] and [0029]. The camera section (12 or 50)
`
`includes an imaging section 15 (“digital camera”) for capturing digital images
`
`connected to the image processor 16 (“processor”). Matsumoto at FIGS. 1 and 3;
`
`2:43-49; see also Matsumoto-JP at [0008]-[0009]. The imaging section 15 (“digital
`
`camera”) can include a triple-plate type sensor for capturing image signals. Id.
`
`Matsumoto discloses