Filed on behalf of: Unified Patents Inc.
`
`By:
`
`Jeff Toler
`Toler Law Group, PC
`8500 Bluffstone CV. Suite A201
`
`Austin, TX 78759
`Telephone:
`(512) 327 —5515
`E~—n1ai1:
`jto1er@tIgip1aw.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC.
`
`Petitioner
`
`V.
`
`FOZGO LLC
`
`Patent Owner
`
`IPR}
`
`US. Patent No. 7,173,651
`Apparatus and System for Prompt Digital Photo
`Delivery and Archival
`
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,173,651
`
`
`
`By:
`
`Jeff Toler
`Toler Law Group, PC
`8500 Bluffstone CV. Suite A201
`
`Austin, TX 78759
`Telephone:
`(512) 327 —5515
`E~—n1ai1:
`jto1er@tIgip1aw.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`UNIFIED PATENTS INC.
`
`Petitioner
`
`V.
`
`FOZGO LLC
`
`Patent Owner
`
`IPR}
`
`US. Patent No. 7,173,651
`Apparatus and System for Prompt Digital Photo
`Delivery and Archival
`
`PETITION FOR INTER PARTES REVIEW OF U.S. PATENT NO. 7,173,651
`
`
`
`TABLE OF CONTENTS
`
`MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(B) .......................
`
`1 —
`
`A
`
`B
`
`C
`
`D.
`
`E
`
`F.
`
`REAL PARTY IN INTEREST ....................................................... ..— 1 -
`
`RELATED MATTERS ..................................................................
`
`PAYMENT OF FEES ........... .{ ........................................................
`
`1 —
`
`2 —
`
`DESIGNATION OF COUNSEL .................................................... ..-— 2 —
`
`SERVICE INFORMATION ........................................................... ..— 2 —
`
`POWER OF ATTORNEY .............................................................. ..-— 2 -
`
`REQUIREMENTS FOR INTER PARTES REVIEW ............................... ..— 2 —
`
`A.
`
`B.
`
`GROUND FOR STANDING ......................................................... ..— 2 -
`
`OVERVIEW OF CHALLENGE AND RELIEF REQUESTED
`
`3 —
`
`1.
`
`2.
`
`Prior Art References .............................................................
`
`3 ~
`
`Grounds for Challenge ......................................................... ..— 4 ~
`
`III.
`
`OVERVIEW OF THE ‘651 PATENT ......................................................
`
`4- -
`
`A.
`
`B.
`
`C.
`
`D.
`
`SUMMARY OF THE ALLEGED INVENTION .......................... ..— 4 -
`
`LEVEL OF ORDINARY SKILL IN THE ART ............................
`
`6 ~
`
`PROSECUTION HISTORY .......................................................... ..— 6 -
`
`CLAIM CONSTRUCTION............................................................
`
`7 -
`
`IV.
`
`SPECIFIC GROUNDS FOR PETITION ................................................. ..— 8 -
`
`A.
`
`Ground 1: Matsumoto anticipates claims 2~5 .................................
`
`8 —
`
`1.
`
`2.
`
`3.
`
`Overview 0fMatsumoto ....................................................... ..~ 8 ~
`
`Claim 2 is anticipated by Matsumoto .................................
`
`10 -
`
`Claim 3 is anticipated by Matsurnoto ................................. ..— 25 --
`
`
`
`4.
`
`5.
`
`Claim 4 is anticipated by Mtztsumoto ................................. ..~ 27 -
`
`Claim 5 is anticipated by Mazfsumoto .................................
`
`27 -
`
`B.
`
`Ground 2: Mcztsumoto in View of Jones renders claim 1
`obvious ..........................................................................................
`
`28 ~
`
`1.
`
`2.
`
`Overview of Jones ..............................................................
`
`29 -
`
`Claim 1 is obvious over Mczzfsumoto in View of Jones .......
`
`29 —
`
`C.
`
`Ground 3: Mczurinus anticipates claims 2-5 .................................
`
`36 —
`
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`
`Overview of Maurinus .......................................................
`
`37 ~
`
`Claim 2 is Anticipated by Maurimzs ..................................
`
`38 -
`
`Claim 3 is Anticipated by Maurinus ..................................
`
`50 -
`
`Claim 4 is Anticipated by Mczurinus ..................................
`
`52 -
`
`Claim 5 is Anticipated by Mczurinus ..................................
`
`52 ~
`
`D.
`
`Ground 4: Mczurinus in View of Jones renders claim 1 obvious.
`
`53 -
`
`1.
`
`Clairm 1 is Obvious over Maurinus in View of Jones .........
`
`53 ~
`
`V.
`
`CONCLUSION .......................................................................................
`
`60 ~
`
`iii
`
`
`
`EXHIBIT LIST
`
`
` 651
`Declaration of Charles Eldering, PhD (“Eldering Declaration” or
`
`“EZdering”)
`
`
`
`
`
`1
`
`U.S. Patent No. 6,833,861 (“Matsumoto”) (filed on July 9, 1999,
`issued on Dec. 21, 2004, claims priority to Japanese patent
`application JP 11 9~322114A)
`
`CurriculumVitaeofCharlesEldering,PhD
`TranslationofJapaneseunexaininedpatentapplication
`
`publication JP H 9-322114 A published on Dec. 12, 1997
`(“Matsumoto—JP”) (including translator certification, translator
`affidavit, and original Japanese language Version of JP H 9-
`322114 A)
`U.S. Patent No. 5,606,365 (“Mczurz'nus’°) (filed on Mar. 25, 1995,
`issued on Feb. 25, 1997)
`U.S. Patent No. 5,742,763 (“Jones”) (filed on Dec. 29, 1995,
`issued on Apr. 21, 19981
`Petitioner’s Voluntary Interrogatory Responses
`
`
`
`I
`
`iv
`
`
`
`Inter Pczrtes Review
`United States Patent No. 7,173,651
`MANDATORY NOTICES UNDER 37 C.F.R. § 42.8(B)
`
`I.
`
`A.
`
`REAL PARTY IN INTEREST
`
`Pursuant
`
`to 37 C.F.R.
`
`§ 42.8(b)(l), Unified Patents Inc.
`
`(“Unified” or
`
`“Petitioner”) is the real party-in-interest, and further certifies that no other party
`
`exercised control or could exercise control over Unif1ed’s participation in this
`
`proceeding, the filing of this petition, or the conduct of any ensuing trial. In this
`
`regard, Unified has submitted voluntary discovery. See EX1008 (Petitioner’s
`
`Voluntary Interrogatory Responses).
`
`B.
`
`RELATED MATTERS
`
`U.S. Patent No. 7,173,651 (“the ’651 Patent” (EX100l)) is owned by
`
`FOZGO LLC (“FO2GO” or “Patent Owner”). On January 27, 2015, FOZGO filed
`
`lawsuits asserting the ’65.1. Patent against numerous defendants in the following
`
`cases in the District of Delaware: Adobe Systems Incorporated. (1 ~15~cv—00089),
`
`AOL Inc. (l—l5—cv—00090), Box Inc. (1-l5—cv~00O91), Dropbox Inc. (l~15~cV-
`
`00092), Instagram LLC (l—l5—cv-00093), Linlcedin Corp. (1~l 5-cv-00094),
`
`l\/IySpace LLC (1-15 ~cv-00095), P11otobucket.co1n Inc. (1—15—cV—00O96), Pinterest,
`
`Inc. (l—l5—cV~0O097), Shutterfly, Inc. (1-l5~cv-00098), Sinuginug, Inc. (l~15~cV~
`
`00099), Snapchat Inc. (l~15—cV~00100), Turnblr, Inc. (1—l5~cV—O0101), Twitter,
`
`Inc. (1~15—cV-00102), and Walgreen Co. (1~15—cV—001O3). The suits against Adobe,
`
`1\/IySpace, Pinterest, Smuginug, Snapchat, and Tuniblr are pending. The suits
`
`
`
`Inter Pczrtes Review
`United States Patent No. 7,173,651
`against AOL, Box, Dropbox, Instagram, Linkedin, Photobucket, Shutterfly,
`
`Twitter, and Walgreens have been dismissed.
`
`C.
`
`PAYMENT OF FEES
`
`This Petition is accompanied by a payment of $25,000 and requests inter
`
`partes review of Claims 1-5 of the ’65l Patent. 37 C.F.R. § 42.15. Thus, this
`
`Petition meets the fee requirements under 35 U.S.C. § 312(a)(1).
`
`D.
`
`DESIGNATION OF COUNSEL
`
`Lead Counsel for Petitioner is Jeff Toler (Reg. No. 38,342), of Toler Law
`
`Group, PC. Bacl<—up Counsel is Jonathan Stroud (Reg. No. 72,518), of Unified.
`
`E.
`
`SERVICE INFORMATION
`
`As identified in the attached Certiiicate of Service, a copy of this Petition, in
`
`its entirety, is being served. to the address of the attorney or agent of record in the
`
`Patent Office for the ‘65l Patent. Petitioner may be served at the offices of their
`
`counsel, Jeff Toler, and consents to electronic service at jtoler@tlgiplavv.com and
`
`jonathan@unifiedpatents.com.
`
`F.
`
`POWER OF ATTORNEY
`
`Powers of attorney are being filed with the designation of counsel
`
`in
`
`accordance with 37 CPR § 42.10(b).
`
`II.
`
`REQUIREMENTS FOR INTER PAR TES REVIEW
`
`A.
`
`GROUND FOR STANDING
`
`
`
`Inter Partes Review
`United States Patent No. 7,173,651
`Petitioner certifies pursuant to 37 C.F.R. § 4-2.lO4(a) that the patent for
`
`which review is sought is available for inter parzfes review. Petitioner is not barred
`
`or estopped from requesting an inter partes review challenging the patent claims
`
`on the grounds identified in this Petition.
`
`B.
`
`OVERVIEW OF CHALLENGE AND RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. § 42.22(a)(l) and 37 CPR. § 42.l04(b), Petitioner
`
`challenges claims 1~5 of the ’651 Patent.
`
`1.
`
`Prior Art Refereilces
`
`The ’65l Patent issued from a patent application filed prior to enactment of
`
`the America Invents Act (“AIA”). Accordingly, a pre—AIA statutory framework
`
`applies. The following references are pertinent to the grounds of unpatentability
`explainedbelow:
`
`i. US. Patent No. 6,833,861 (“Matsumot0” (EX1004)) (filed on July 9,
`
`1999, issued. on Dec. 21, 2004, U.S. continuation priority date of Mar.
`
`13, 1998, claims priority to Japanese patent application filed. on Mar.
`
`25, 1997 and published on Dec. 12, 1997 (Translation of JP I-I 9-
`
`3221 14A, “Matsumoz'o~JP” (EXl005))). Marsumoto is prior art under
`
`35 U.S.C. § 1.02(e) and Ma2fsumoto~JP is prior art under 35 U.S.C. §
`
`102(a).
`
`
`
`Imfer Parzfes Review
`United States Patent No. 7,173,651
`ii. U.S. Patent No. 5,606,365 (“Maurz'mzs” (EXl006)) (filed on Mar. 25,
`
`1995, issued on Feb. 25, 1997). Maurinus is prior art under 35 U.S.C.
`
`§ 102(b).
`
`iii. U.S. Patent No. 5,742,763 (“Jones” (EX1007)) (tiled on Dec. 29,
`
`1995, issued on Apr. 21, 1998). Jones is prior Art under 35 U.S.C. §
`
`l02(e).
`
`2.
`
`Grounds for Challenge
`
`This Petition, supported by the declaration of Charles Eldering (“Eldering
`
`Declaration” or “Eldering” (EX1002)), requests cancellation of challenged claims
`
`1——5 as invalid under 35 U.S.C. § 102 and/or§ 103. See 35 U.S.C. § 314(a).
`
`III. OVERVIEW OF THE ‘651 PATENT
`
`A.
`
`SUMMARY OF THE ALLEGED INVENTION
`
`The ’651 Patent recognizes that it was known to download a photograph
`
`from a digital camera to a computer, to forward such a photograph to others Via e~
`
`mail, and to incorporate such a photograph on an Internet web page. EX1001 at
`
`1:25~32. The ’651 Patent describes image transfer between the digital camera and
`
`the computer using floppy disk, memory card, or infrared. Id. at l:33—52. The ’65l
`
`Patent also recognizes that an Internet archival service for conventional film
`
`processing was available, but states that there is no known ‘similar service for
`
`digital photos. Id. at
`
`l:57~2:3. The ’651 Patent further recognizes that it was
`
`-4-
`
`
`
`I Inter .Pczrtes Review
`United States Patent No. 7,173,651
`
`possible to assemble a portable device which can transfer data files to a destination
`
`computer, although such a system would require user input of a destination phone
`
`number for modern dialing or a host internet protocol (IP) address or an e-mail
`
`address to send an image to. Id. at 2:57-64.
`
`In View of the above-recognized aspects, the ’651 Patent is directed to a
`
`system that requires comparatively less user input for configuration and operation.
`
`Id. at 2:64-67. The ’65l Patent teaches that a Wireless camera device includes a
`
`digital camera to create a digital image, a memory to store a delivery IP address
`
`and a list of nicknames, and a radio frequency (RF) communications device. Id. at
`
`4:51-67. The Wireless camera device transmits a message to a server at the delivery
`
`IP address, Where the message includes a recipient code (nickname) and at least
`
`one digital image. Id.
`
`The ’65l Patent fiirther teaches that the server at the delivery IP address can
`
`store the received message or the server can forward the received message to
`
`another IP address. Id. at 3:53-57. The server can resolve between nicl<:names, e-
`
`mail addresses, and IP addresses. Id. at 3:12-l9.
`
`Thus, the ’65l Patent teaches that a user of the wireless camera device can
`
`select a nickname to be sent with an image to a server, and that the server can
`
`cause the image received from the wireless camera device to be delivered to an e-
`
`mail address or an IP address (corresponding to the nickname). Id. at 3:53-57,
`
`
`
`3:l2~19, 4:51-67.
`
`Inter Pczrzfes Review
`United States Patent No. 7,173,651
`
`As the prior art demonstrates, technologies that enable a camera user to
`
`select a recipient and send an image to a server with a relatively small amount of
`
`user inpu.t were well~l<nown prior to the effective filing date of the °65l Patent.
`
`Additionally, storing of images on a server and distributing images from a server to
`
`other devices were also well-known prior to the effective filing date of the ’65l
`
`Patent. EXlO02 atfll 14.
`
`B.
`
`LEVEL OF ORDINARY SKILL IN THE ART
`
`A person of ordinary skill in the art for the ’65l Patent would have a
`
`Master’s Degree in electrical engineering, computer science, or a related subject or
`
`the equivalent, and would also have at least three years of experience working with
`
`electronic
`
`devices,
`
`user
`
`interfaces,
`
`computer
`
`networks,
`
`and
`
`digital
`
`communications, or the equivalent. EX1002 at'{[ 15.
`
`C.
`
`PROSECUTION HISTORY
`
`The ’65l Patent
`
`includes
`
`5 claims and corresponds
`
`to U.S. Patent
`
`Application No. 09/324,249 (“’249 Application”), filed on June 2, 1999 including
`
`18 originally~f1led claims. The ’249 Application was mistakenly filed as a
`
`continuation~in~part of U.S. Provisional Application No. 60/087,745 (“’745
`
`Provisional Application”), which was filed on June 2, 1998 and included 15
`
`claims. However, the ’249 Application included 3 additional pages of disclosure
`
`
`
`Inter Pczrtes Review
`United States Patent No. 7,173,651
`and different claims as compared to the ’745 Provisional Application. Thus, the
`
`effective filing date for the claims of the ’651 Patent may be different (e.g., June 2,
`
`1999 or June 2, 1998) based on whether each of the claims is supported by the ’745
`
`Provisional Application.
`
`Prosecution of the ’249 Application concluded with a Notice of Allowance
`
`mailed on October 4, 2006. In the Notice of Allowance, the Examiner did not
`
`identify the allowable aspects of the claims, and instead simply stated that
`
`“[c]laims 36, 62, and 75-77 are allowable over the prior art of record in View of the
`
`Applicant’s argument tiled on 12/14/2005.” Claim 36 was issued as claim 1 of the
`
`’651 Patent and claim 62 was issued as claim 2 of the ’65l Patent. Claims 75-77
`
`issued as claims 3—5 of the ’651 Patent.
`
`D.
`
`CLAIM CONSTRUCTION
`
`A patent claim of an unexpired patent during inter parzfes review receives the
`
`broadest reasonable construction in light of the specification of the patent in which
`
`it appears. 37 C.F.R. § 42.100(b); In re Cuozzo Speed Teons, LLC, 778 F.3d. 1271,
`
`127981 (Fed. Cir. 2015). Claim terms are given their ordinary and customary
`
`meaning as would be understood by one of ordinary skill in the art unless that
`
`meaning is inconsistent with the specification of the patent. In re Translogic Tech,
`
`Inc., 504 F.3d 1249, 1257 (Fed. Cir. 2007). In the following, claim terms are given
`
`their broadest reasonable interpretation in light of the specification. For those terms
`
`
`
`which lack a definition in the specification,
`
`In ter Parzfes Review
`United States Patent No. 7,173,651
`the terms are given the broadest
`
`reasonable interpretation that is consistent with the interpretation that one skilled in
`
`the art would have applied at the effective filing date of the ’65l Patent.
`
`IV.
`
`SPECIFIC GROUNDS FOR PETITION
`
`A. Ground 1: Matsumoto anticipates claims 2-5
`
`1.
`
`Overview of Matsumoto
`
`Matsumoto discloses a digital photo processing system that includes a digital
`
`camera and a plurality of photo processing locations. See EXIOO4 at Title; EX1002
`
`at 1] 28. Matsumozfo discloses that a digital still camera 49 can wirelessly transmit
`
`digital images to reception equipment 60 for transfer to user selected printing
`
`equipment 10. EXl0O4 at FIG. 5; EXl002 at fll 29. The user selected printing
`
`equipment 10 prints and delivers the images to a user—selected delivery location.
`
`EXlOO4 at FIG. 5; EX1002 at 1] 29. The printing equipment 10 or the delivery
`
`place can be selected using a “place name” instead of an address. EXIOO4 at FIG.
`
`5, 6:49-54, and 7:8-29; EXlO02 at 1[ 29.
`
`Matsumoto includes two embodiments of digital still cameras, which are
`
`designated digital still camera 49 (in FIGS. 3 and 5) and digital still camera 9 (in
`
`FIG. 1). The digital still camera (9 or 49) includes a camera section (12 or 50)
`
`including an imaging section l5 and an image processor 16. EXl004 at FIGS.
`
`1
`
`and 3 and 2:48-55; EXl002 at 1] 31. The imaging section l5 captures analog
`
`signals of an image, and the image processor 16 processes/converts the captured.
`
`-8-
`
`
`
`Inter Parzfes Review
`United States Patent No. 7,17 3,651
`analog signals into digital image data. EXlO04 at FIGS.
`1 and 3 and 2:48~55;
`
`EXl002 at 1] 31. The digital still camera 49 also includes a data communication
`
`section 13, including a data terminal 20 a.nd a sending data memory 22. EXIOO4 at
`
`FIGS.
`
`1 and 3, 2:63-65, and 5:15-18; EXIOO2 at 1] 32. The data terminal 20
`
`includes a modem and a radio sender—receiver for sending and receiving data
`
`through radio telephony. The sending data memory 22 stores addresses of the
`
`photo labs, which in some examples include the reception equipment 60 and the
`
`printing equipment 10. EXIOO4 at 6:16-18; EXlOO2 at 1] 32.
`
`The digital still camera 49 sends digital images and data to the reception
`
`equipment 60. EXIOO4 at 3:11—22; EX1002 at ‘H 33. The digital still camera 49 also
`
`stores “place names” of the printing equipment 10 and delivery places. EXIOO4 at
`
`6:l6~l8 and 6:53~59; EXlOO2 at
`
`1] 33. The place names may be nicknames
`
`associated with the actual addresses of the printing equipment
`
`l.0 and delivery
`
`places. Id. The digital still camera 49 includes an LCD panel 52 and l<:ey input 21
`
`for displaying the place names and for user selection and input of the place names.
`
`EXlO04 at FIG. 5, 7:3—5, and 7:l6~l7; EXl002 at ll 33. Thus, Matsumoto discloses
`
`that the place name and the digital image are sent, for example in a message, from
`
`the digital still camera (9 or 49) to the reception equipment 60 via the radio sender—
`
`receiver of the data terminal 20.
`
`The reception equipment 60 receives the image data from the digital still
`
`
`
`Inter Pczrtes Review
`United States Patent No. 7,173,651
`camera 49 and stores the image data and control data at the buffer memory 62,
`
`including the place names. EX1004 a.t 6:27-32; EX1002 at fll 36. Matsumoto
`
`discloses that the reception equipment 60 includes “a table for correlating place
`
`names with the addresses of the printing equipment 10 of the respective
`
`geographical areas, so the nearest printing equipment 10 to the present location of
`
`the camera 49 is selected based on the place name entered through the key input
`
`21.” EXlO04 at 6:53~59; EX1002 at ‘ll 37. Thus, Matsumoto describes that the
`
`reception equipment 60 can use the table to determine an address of the printing
`
`equipment 10 corresponding to the place name selected by a user. The reception
`
`equipment 60 sends a data file to the address of the printing equipment 10
`
`corresponding to the user~selected place name. EXlOO4 at 6:37-59; EXl002 at ‘ll
`
`38. The data file includes the digital image and in some examples can also include
`
`a decoded delivery place (other than the printing equipment 10). EXl0O4 at 6:37~
`
`59; EXlO02 at ‘H 38. The printing equipment 10 receives the data file and prints the
`
`digital images according to data file. If the data. file includes a decoded deliver
`
`place, the printing equipment 10 can deliver the digital image prints to the decoded
`
`delivery place. EXl0O4 at 7:8~30; EX1002 at ‘H 38.
`
`2.
`
`Claim 2 is anticipated by Matsumoto
`
`a. “[cl]igitalphoto processing system”
`
`Matsumoro discloses a “system for transferring image data from a camera to
`
`_1()_
`
`
`
`Inter Partes Review
`United States Patent No. 7,173,651
`a printing system.” EX1004 at Title and FIGS. 1, 3, and 5; see also EX1005 at
`
`[O005]; EXIOOZ at 1] 41. The system includes a digital camera (9 or 49), reception
`
`equipment 60, and printing equipment 10. See EXl004 at FIGS. 1, 3, and 5; see
`
`also EX.1005 at [0005] ; EX1002 at '1] 41. The digital camera 49 can transmit image
`
`data Wirelessly to the reception equipment 60, which transfers the image data to the
`
`printing equipment 10 selected by the user. See EXIOO4 at Abstract and FIG. 5;
`
`see also EX1005 EX1002 at [OOOS]; EX1002 at fl 41. The printing equipment 10
`
`selected by the user processes the digital images and can deliver the processed
`
`digital images to a delivery location selected by the user. See EX1004 at Abstract
`
`and FIG. 5; see also EX1005 at [OOOS]; EXIOOZ at 1] 41. By describing the digital
`
`camera 49, the reception equipment 60, and the printing equipment 10, Mcastzmoto
`
`discloses a “digital photo processing system.”
`
`12. “at least one wireless digital camera apparatus, wherein each said apparatus
`includes a processor, a memory”
`
`Malsamoto discloses that the digital still camera (9 or 49) includes a camera
`
`section (12 or 50), a data communication section (13 or 53), and a system
`
`controller 14. EXIOO4 at FIGS.
`
`1 and 3; 2:43—49; see also EXIOOS at [0008]-
`
`[0009]; EXIOOZ at ‘H 44. The camera section 12 includes an image processor 16.
`
`EXIOO4 at FIGS. 1 and 3; 2:43~49; see also EX1005 at [O0O8]—[O0O9]; EXlOO2 at
`
`‘H 44. The data. communication section (13 or 53) includes a sending data memory
`
`22. EXIOO4 at FIGS. 1 and 3; 2:43~49; see also EXl0O5 at [O008]~[00O9]; EXIOOZ
`
`-11..
`
`
`
`Inter Parzfes Review
`United States Patent No. 7,173,651
`at ‘H 44. By describing that the digital still camera 9 or 49 (“a wireless digital
`
`camera apparatus”) includes the image processor 16 (“processor”) and the sending
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`data memory 22 (“memory”), Matsumoio discloses “at least one wireless digital
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`camera apparatus, wherein each said apparatus includes a processor, a memory.”
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`c. “a destination address”
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`.Maz‘sumo!o discloses that the sending data memory 22 stores “addresses of
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`the pluralityof photo labs” (“destination address”). EXIOO4 at FIG. 5; 6:16-20; see
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`also EXl005 at [003-4]; EXlOO2 at 1] 47 . Maisumoto describes that the “addresses
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`of the plurality of photo labs” (“destination address”) can include a telephone
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`number of a transmission destination, such as the reception equipment 60 or a
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`photo lab, EXIOO4 at FIG. 5; 5:26-31; see also EX1005 at [0O30]; EXlO02 at‘[[ 47.
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`Additionally, Malsamoto describes that in some embodiments the photo lab can
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`include reception equipment 60. EX1004 at FIG. 5; 6:l6~20; see also EXlOO5 at
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`[O034]; EXl002 at
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`‘H 47. By describing that
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`the sending data memory 22
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`(“memory”) stores addresses of the plurality of photo labs (“destination address”),
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`Malsamolo discloses “a destination address.”
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`d. “and one or more previously defined recipient codes stored in said memory”
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`As explained above, by describing that the sending data memory 22 stores
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`addresses of photo labs, Maisamoio discloses “a destination address.” EX1004 at
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`FIG. 3; 5:26—3Il; see also EXIOOS at [OO30]; EXIOO2 at ‘H 50.
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`"12-
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`Inter Partes Review
`United States Patent No. 7,173,651
`Additionally, Mazfsumoto discloses that a place name (“recipient code”) may
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`be used. instead of an actual address. EXl0O4 at 6:53~59; see also EXlO05 a.t
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`[0036]; EXlO02 at 1] 51. In Matsumoto, place names (“recipient codes”) may be
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`used for designating the printing equipment 10 and may be used for designating a
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`delivery destination. EXl0O4 at 6:53—59, 7:8-30; See also EXl005 at
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`[O036],
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`[0037]; EXlOO2 at ‘H 51. A delivery destination may include, for example, a
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`location where the user would like to pick up photographs or Where the user would
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`like the photographs to be delivered. EXl004 at 7:8—30; see also EXl0O5 at
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`[O037]; EXlOO2 at 1] 51. Place names are displayed on an LCD panel 52 of the
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`digital still camera 49. EXlO04 at FIG. 3; 7:3-5 and 7:16-17; see also EXIOOS at
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`[O036]—[0037]; EXlOO2 at 1] 51. A person skilled in the art would understand the
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`disclosure in Matsumoto of place names (“recipient codes”) being displayed on the
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`LCD panel 52 of the digital still camera 49 as disclosing that the place names
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`(“recipient codes”) are stored in memory, such as the sending data memory 22. For
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`example, the place names stored in memory would be retrieved from the memory
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`and provided to the LCD panel 52 for display. Additionally or alternatively, the
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`place name may be stored in a memory or buffer of the LCD panel 52.
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`By describing place names (“recipient codes”) being stored in memory,
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`Matsamoto discloses “one or more previously defined recipient codes stored in a
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`memory.”
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`..13_
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`Inter Partes Review
`United States Patent No. 7,173,651
`e. “user interface connected to saidprocessorfor at least displaying one or more
`said recipient codes”
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`Matsumoto discloses that the digital still camera 49 includes the LCD panel
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`52 and a key input 21 controlled by a system controller 14 (collectively a “user
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`interface”). Matsumoto describes that the LCD panel 52 can display a list of place
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`names (“recipient codes”). EXl0O4 at FIG. 3; 7:16-17; see also EXl005 at [OO37];
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`EXlOO2 at 1] 54. By describing that the LCD panel 52 displays a list of place names
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`(“recipient codes”), Matsumoto discloses a “user interface connected to said
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`processor for at least displaying one or more said recipient codes.”
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`f.‘ “and receiving signals indicating user selection ofa displayed recipient code”
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`Matsumoto discloses that the digital still camera 49 includes the LCD panel
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`52 and a key input 21 controlled by a system controller 14 (collectively a “user
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`interface”). In Matsumoto, the place names can be entered through the key input
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`21. EXl004 at FIGS. 3-5; 6:53-59; see also EXl0O5 at [O036]; EXIOO2 at 1] 57. By
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`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 saidprocessorfor capturing one or more
`digital images in response to signals from said user interface”
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`Matsumoto discloses that the digital still camera 49 includes a camera
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`section (12 or 50). EXlOO4« at FIGS. 1, 3; 2243-49, 5:22~25; see also EXl005 at
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`[0008]-[OOO9], [OO29]; EXlOO2 at ‘H 60. The camera section (12 or 50) includes an
`
`-14.
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`
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`In ter Parties Review
`United States Patent No. 7,173,651
`imaging section 15 (“digital camera”) for capturing digital images connected to the
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`image processor 16 (“processor”). EXl004 at FIGS. 1, 3; 2:43-49; see also
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`EXlOO5 at
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`[0008]-[OOO9]; EX1002 at '1] 60. The imaging section 15 (“digital-
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`camera”) can includ.e a triple-plate type sensor for capturing image signals. ”).
`
`EXl004 at FIGS. 1, 3; 2:43-49; see also EX1005 at [OOO8]~[O0O9]; EX1002 at fi[
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`60. Matsumoto discloses, and FIGS. 1 and 3 of Matsnmozo depict, that the system
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`controller 14 controls the imaging section 15 and receives input (“signals”) from
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`the key input 21. ”). EXl0O4 at FIGS. 1, 3; 2:43~49; see also EXlOO5 at [0008]-
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`[O009]; EX1002 at 1] 60. Accordingly, the imaging section 15 captures digital
`
`images in response to input from the key input 21, which as explained above, is
`
`part of the “user interface.” By describing an imaging section 15 (“digital
`
`camera”), connected to the image processor 16 (“processor”), for capturing digital
`
`images in response to input (“signals”) from the key input 21, Matsumolo discl.oses
`
`“a digital camera connected to said processor for capturing one or more digital
`
`images in response to signals from said user interface.”
`
`/1. “a RF communications device connected to saidprocessor”
`
`Matsumoto discloses that
`
`the digital still camera 49 includes the data
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`communication section 13. EXlO04 a.t FIGS. 1, 3; 2:43~49; see also EXl0O5 at
`
`[0008]-[0009]; EX1002 at 11 63. The data commination section 13 includes a data
`
`terminal 20. EXlOO4 at FIGS. 1, 3; 2:63~65; see also EXl005 at [O010]; EX1002
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`-15..
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`
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`Inter Partes Review
`United States Patent No. 7,173,651
`at 11 63. l\/Iatsumoto describes the data terminal 20 includes a modem and a radio
`
`sender~receiver. EXIOO4 at FIGS. 1, 3; 3:5-22; see also EX1005 at
`
`[O0l2];
`
`EX1002 at 1] 63. Matsamoto discloses the digital still camera 49 can communicate
`
`with the reception equipment 60 via a radio communication channel 11. EXl0O4 at
`
`FIGS. 1, 3; 3:5—22; see also EX1005 at [0012]; EX1002 at 11 63. By describing the
`
`data communication section 13 (including the data terminal 20, a modem, and a
`
`radio sender-receiver) connected to the image processor 16, Matsamoto discloses
`
`“a RF communications device connected to said processor.”
`
`1'. “andprocessor control means, responsive to signals receivetlfrom said user
`interface, for transmitting a message, ”
`
`‘ll/[atsamoto discloses that
`
`the system controller 14 (“processor control
`
`means”) controls the camera section (12 or 50) and the data communication section
`
`(13 or 53). EXIOO4 at FIGS. 1, 3; 2:45-47; see also EX1005 at [O008]; EXlO02 at
`
`11 66. The system controller 14 receives inputs from the key input 21 and controls
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`the data terminal 20. EXIOO4 at FIGS. 1, 3; 2:45-47; see also EXl005 at [OOO8];
`
`EXlO02 at ‘H 66. Matsamoto describes a manual transfer mode for transmitting
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`digital images to the reception equipment 60. EX1004 at 5:61-63; see also EXIOOS
`
`at [0032]; EXIOOZ at ‘H 66. Accordingly, the system controller 14 (“processor
`
`control means”) receives input from the key input 21 for transmitting digital
`
`images via the data terminal 20. In Matsamoto, “[t]he address decoder 63 decodes
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`the address of the delivery place [recipient code] appointed by the user, that is
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`-16-
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`
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`Inter Partes Review
`United States Patent No. 7,173,651
`included in the print delivery commands of the received data.” EXIOO4 at 6:30-32;
`
`see also EXl0O5 at [0O35]; EXIOO2 at 1] 66. Accordingly,
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`the print delivery
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`commands, including the place name, are sent with digital images.
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`By describing a system controller 14 (“processor control means”) that
`
`receives input (“signals”) from the key input 21 (“user interface”) for transmitting
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`digital images and print delivery commands (“message”), Matsumoto discloses
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`“processor control. means, responsive to signals received from said user interface,
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`for transmitting a message.”
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`j. “including at least said selected recipient code and one ofsaid digital image, to
`said destination address, ”
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`Matsamoto discloses the data terminal 20, including the modem and the
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`radio sender-receiver, sends the digital images and control data to the reception
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`equipment 60. Malsamoto discloses that place names are included in the control
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`data. To illustrate, the control data includes print order data. EXlO04 at 3:9~ll;
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`EXlOO2 at '1] 69. The print order data includes print delivery commands, EXI 004 at
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`3:23~29, which include the place name of the delivery place. EXlOO4 at 6:27—33;
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`EX1002 at 1] 69. Maisamoto describes that the user selects a place name from a list
`
`of place names displayed on the LCD panel 52. EXlOO4 at FIGS. 3, 5 ; 7 :8~l7 ; see
`
`also EXIOOS at [O037]; EXlOO2 at '1] 69. In Maisamoto, the user may identify the
`printing equipment 10 or the delivery place based on the selected place name.
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`EXIOO4 at FIGS. 3, 5; 7:8~l7; see also EXIOOS at
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`[OO37]; EXl002 at ‘H 69.
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`-17-
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`Inter Pczrzfes Review
`United States Patent No. 7,173,651
`Matsumoto describes that an address decoder 63 of the reception equipment 60
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`decodes the address of the delivery place selected by the user. EXl004 at FIG. 5;
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`6:28-32; see also EXl0O5 at
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`[OO35]; EXlO02 at 1] 69. Accordingly,
`
`the user
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`selected place name is sent along with the digital images.
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`By describing that the digital still camera 49 sends a place name (“recipient
`
`code”) and digital images to the telephone address (“destination address”) of the
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`reception equipment 60 via a data terminal 20 (“RF communications device”) over
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`a radio communication channel 11, Mcztsumozfo discloses a message “including at
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`least said selected recipient code and one of said digital image, to said destination
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`address.”
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`k. “via said RF comm unications device”
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`Matsumozfo discloses that the data terminal 20, including the modem and the
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`radio sender~receiver, sends the digital images and control data to the reception
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`equipment 60. Mczzsumoto discloses that place names may be included in the
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`control data. To illustrate, the control data includes print order data. EXlOO4 at
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`3 :9—l 1; EXl 002 at ‘H 72. The print order data can include print delivery commands,
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`EXl004 at 3:23~29, which can include the place name of the delivery place.
`
`EXl0O4~ at 6:27—33; EXl0O2 at ‘H 72. Mczisumoto describes that the user may select
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`a place name from a list of place names displayed on the LCD panel 52. EXIOO4 at
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`FIGS. 3, 5; 7:8~l7 see also EXl0O5 at [OO37]; EXlOO2 at 1] 72. I11.MczZSum0t0, the
`
`..18..
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`
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`Inter Partes Review
`United States Patent No. 7,173,651
`user may identify the printing equipment 10 or the delivery place based on the
`
`selected place name. EXlOO4 at FIGS. 3, 5; 7:8~17 see also EXl0O5 at [OO37];
`
`EXlO02 at 1] 72. Matsamoto describes that an address decoder 63 of the reception
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`equipment 60 decodes the address of the delivery place selected by the user.
`
`EXIOO4 at FIG. 5; 6:28~32; see also EXlO05 at
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`[OO35]; EXlO02 at
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`‘H 72.
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`Accordingly, the user selected place name is sent along with the digital images.
`
`By describing that the digital still camera 49 sends a place name (“recipient
`
`code”) and digital images to the telephone address (“destination address”) of the
`
`re
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