`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`APPLE INC.
`Petitioner,
`
`v.
`
`PERSONALIZED MEDIA COMMUNICATIONS LLC
`Patent Owner
`
`______________
`
`Case: IPR2016-00753
`Patent No. 7,752,649
`______________
`
`
`
`DECLARATION OF TIMOTHY D. DORNEY, PH.D., IN SUPPORT OF
`PATENT OWNER’S CONTINGENT MOTION TO AMEND THE CLAIMS
`
`
`
`
`
`PMC Exhibit 2130
`Apple v. PMC
`IPR2016-00753
`Page 1
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`
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`Introduction and Qualifications
`
`1.
`
`I, Timothy D. Dorney, submit the following sworn declaration in
`
`IPR2016-00753 in support of the validity of U.S. Patent No. 7,752,649 (“ ’649
`
`patent”). I am an employee of Patent Owner, Personalized Media
`
`Communications, L.L.C. (“PMC”).
`
`2.
`
`I am currently the Vice President - Intellectual Property of PMC.
`
`where I am responsible for both licensing and litigation support.
`
`3.
`
`I hold a Bachelor of Science degree in Electrical Engineering from
`
`Texas A&M University, a Master of Science in Electrical Engineering and Applied
`
`Physics from Case Western Reserve University, and Ph.D. in Electrical and
`
`Computer Engineering from Rice University. My doctoral thesis was focused on a
`
`signal processing and imaging techniques in the THz spectrum.
`
`4.
`
`I have nearly 10 years of experience working in product development,
`
`design, and advanced architecture of semiconductor memories. I’ve worked as
`
`both a product development engineer and design engineer in video RAM
`
`development, an IC design engineer in application specific DRAM design, and as a
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`circuits center of expertise engineer in memory products design at Texas
`
`Instruments Incorporated.
`
`
`
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`2
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`PMC Exhibit 2130
`Apple v. PMC
`IPR2016-00753
`Page 2
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`5.
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`I have over seven years of experience in circuit and product design of
`
`small wattage AC/DC converters and LED lighting systems as President of my
`
`own company.
`
`6.
`
`I am licensed to practice before the United States Patent & Trademark
`
`Office as a patent agent and I have ample experience drafting and prosecuting
`
`patent applications in various technologies, with an emphasis in technical fields
`
`including memory, analog circuits, processors, and digital systems. I am a named
`
`inventor on at least seven U.S. patents and have authored numerous journal and
`
`conference papers.
`
`7.
`
`A copy of my curriculum vitae is attached as Exhibit 2131.
`
`Motion to Amend
`
`8.
`
`I have been informed and understand that if the Patent Trial and
`
`Appeal Board (“Board”) should accept the Petitioner’s arguments and cancel any
`
`of the issued ’649 patent claims as unpatentable, PMC has made a contingent
`
`motion to amend to substitute the canceled claim(s) with corresponding proposed
`
`substitute claims 103-106.
`
`9.
`
`I have reviewed all relevant papers and exhibits in connection with
`
`IPR2016-00753, including PMC’s Contingent Motion to Amend filed concurrently
`
`herewith.
`
`a. The Proposed Substitute Claims are Supported by the Written
`Description of the Provisional Application
`
`
`
`
`3
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`PMC Exhibit 2130
`Apple v. PMC
`IPR2016-00753
`Page 3
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`10.
`
`I have been informed and understand that to amend the claims, the
`
`Patent Owner must show, among other things, that the substitute claims are
`
`supported by the written description of the original disclosure of the patent, as well
`
`as any patent application to which the claim seeks the benefit of priority.
`
`11. To satisfy the written description requirement, I have been informed
`
`and understand that the substitute claims must be disclosed in sufficient detail such
`
`that a POSA can clearly conclude that the inventor invented the claimed invention
`
`as of the filing date sought.
`
`12. The proposed substitute claims of the ’649 patent are included below:
`
`
`
`103. (Substitute for claim 39, if found unpatentable) A method of
`
`processing signals in a television receiver, said television receiver
`
`having a plurality of processors, said method comprising the steps of:
`
`receiving an information transmission including digital
`
`television signals and a message stream, said digital television signals
`
`comprising digital audio signals and digital video signals;
`
`detecting said message stream in said information transmission;
`
`inputting at least a first portion of said message stream to a
`
`control processor;
`
`
`
`
`4
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`PMC Exhibit 2130
`Apple v. PMC
`IPR2016-00753
`Page 4
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`
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`selecting control information in said at least a first portion of
`
`said message stream and communicating said selected control
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`information to at least one register memory;
`
`comparing stored function invoking data to the contents of said
`
`at least one register memory;
`
`inputting said digital television signals to said plurality of
`
`processors on the basis of one or more matches;
`
`processing of said digital television signals simultaneously at
`
`two or more of said plurality of processors, wherein at least one of
`
`said plurality of processors is a central processing unit that operates
`
`according to operating system instructions stored in reprogrammable
`
`nonvolatile memory at said television receiver, said operating system
`
`instructions are reprogrammable by a remote station, said
`
`reprogrammable nonvolatile memory storing digital data comprising
`
`information particular to a subscriber at said television receiver and
`
`originated at said television receiver, said television receiver stores a
`
`unique digital code that identifies said television receiver that may be
`
`transmitted from said television receiver using a digital information
`
`transmission unaccompanied by any non-digital information
`
`transmission; and
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`
`
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`5
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`PMC Exhibit 2130
`Apple v. PMC
`IPR2016-00753
`Page 5
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`displaying television programming included in said digital
`
`television signals, wherein said displaying is capable of showing a
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`graphic overlay on top of said television programming.
`
`104. (Substitute for claim 54, if found unpatentable) A method of
`
`television or video signal processing at a television or video receiver,
`
`said television or video receiver having a plurality of processors,
`
`comprising the steps of:
`
`receiving an information transmission, said information
`
`transmission including a message stream;
`
`receiving a control signal which operates at a transmitter station
`
`to communicate said information transmission to a transmitter; and
`
`transmitting said message stream, said message stream enabling
`
`said receiver station to select control information in said message
`
`stream, compare said control information to a stored function
`
`invoking datum, input selected digital television or digital video
`
`signals to said plurality of processors on the basis of one or more
`
`matches of said control information to said stored function invoking
`
`datum, simultaneously process said selected digital television or
`
`digital video signals at two or more of said plurality of processors,
`
`wherein at least one of said plurality of processors is a central
`
`
`
`
`6
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`PMC Exhibit 2130
`Apple v. PMC
`IPR2016-00753
`Page 6
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`
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`processing unit that operates according to operating system
`
`instructions stored in reprogrammable nonvolatile memory at said
`
`television or video receiver, said operating system instructions are
`
`reprogrammable by a remote station, said reprogrammable nonvolatile
`
`memory storing digital data comprising information particular to a
`
`subscriber at said television or video receiver and originated at said
`
`television or video receiver, and display television programming or
`
`video information included in said selected digital television or digital
`
`video signals, wherein said digital television signals comprise both
`
`digital audio signals and digital video signals, wherein graphic
`
`information may be displayed on top of video of said television
`
`programming or video information using graphic overlay techniques
`
`enabled by graphics hardware.
`
`105. (Substitute for claim 62, if found unpatentable) A method of
`
`processing signals at a receiver station, said receiver station having a
`
`video monitor and a plurality of processors, said method comprising
`
`the steps of:
`
`receiving an information transmission including digital video
`
`signals and control information;
`
`
`
`
`7
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`PMC Exhibit 2130
`Apple v. PMC
`IPR2016-00753
`Page 7
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`detecting said control information in said information
`
`transmission and passing said control information to a control
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`processor, wherein said control processor executes machine language
`
`instructions;
`
`communicating said control information selectively to at least
`
`one register memory;
`
`comparing stored function invoking data to the contents of said
`
`at least one register memory;
`
`communicating said digital video signals to at least one of said
`
`plurality of processors on the basis of one or more matches;
`
`processing said digital video signals simultaneously at two or
`
`more of said plurality of processors, wherein at least one of said
`
`plurality of processors is a central processing unit that operates
`
`according to operating system instructions stored in reprogrammable
`
`nonvolatile memory at said receiver station, said operating system
`
`instructions are reprogrammable by a remote station, said
`
`reprogrammable nonvolatile memory storing digital data comprising
`
`information particular to a subscriber at said receiver station and
`
`originated at said receiver station, said central processing unit
`
`interacting with random access memory and graphics hardware; and
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`
`
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`8
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`PMC Exhibit 2130
`Apple v. PMC
`IPR2016-00753
`Page 8
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`
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`displaying video included in said digital video signals, wherein
`
`graphic information may be displayed on top of said video using
`
`graphic overlay techniques enabled by said graphics hardware.
`
`106. (Substitute for claim 67, if found unpatentable) A method of
`
`processing signals in a television receiver, said television receiver
`
`having a plurality of processors, said method comprising the steps of:
`
`receiving an information transmission including digital
`
`television signals and cadence information, wherein said digital
`
`television signals comprise both digital audio signals and digital video
`
`signals, said cadence information enables distinguishing individual
`
`messages and comprises at least one of a header, length token, and
`
`end-of-file signal;
`
`detecting and passing said cadence information to a control
`
`processor;
`
`communicating said cadence information selectively to at least
`
`one register memory;
`
`comparing stored communication control information to the
`
`contents of said at least one register memory;
`
`communicating said digital television signals to said plurality of
`
`processors on the basis of one or more matches;
`
`
`
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`9
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`PMC Exhibit 2130
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`IPR2016-00753
`Page 9
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`processing said digital television signals simultaneously at two
`
`or more of said plurality of processors, wherein at least one of said
`
`plurality of processors is a central processing unit that operates
`
`according to operating system instructions stored in reprogrammable
`
`nonvolatile memory at said television receiver, said operating system
`
`instructions are reprogrammable by a remote station, said
`
`reprogrammable nonvolatile memory storing digital data comprising
`
`information particular to a subscriber at said television receiver and
`
`originated at said television receiver, said central processing unit
`
`interacting with random access memory and graphics hardware; and
`
`displaying television programming included in said digital television
`
`signals, wherein graphic information may be displayed on top of
`
`video of said television programming using graphic overlay
`
`techniques enabled by said graphics hardware.
`
`
`
`13.
`
`It is my understanding that the ’649 Patent is based on U.S.
`
`Application No. 08/449,097 (“ ’097 application”) (Ex.2050). I have reviewed the
`
`’097 application and it is my opinion that a Person of Ordinary Skill in the Art
`
`(“POSA”) reading the ’097 application would have understood that the inventors
`
`
`
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`10
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`PMC Exhibit 2130
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`IPR2016-00753
`Page 10
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`of the ’649 patent, Mr. Harvey et al., would have been in possession of the
`
`invention as recited in the substitute claims.
`
`14. Each limitation of the substitute claims is disclosed in the ’097
`
`application. Support for the proposed substitute ’649 patent claims is shown
`
`below:
`
`Substitute Claim
`
`Disclosure in the 08/449,097 Application (Ex. 2050)
`
`287:22-35: “As FIG. 4 shows, signal processor, 200,
`controls all the aforementioned apparatus. Signal
`processor, 200, controls the tuning of tuners, 214,
`215, and 223; controls the switching of matrix switch,
`258; supplies cipher algorithm and cipher key
`information to and controls the decrypting of
`decryptors, 107, 224 and 230; controls signal stripper,
`229, in selecting transmission locations and/or
`information to strip and in signal stripping; and
`controls signal generator, 230, in selecting
`transmission locations at which to insert signals, in
`generating specific signals to insert, and in inserting.
`“In addition, FIG. 4 also shows divider, 4, monitor,
`202M, decoder, 203, and microcomputer, 205, all of
`which function and are controlled as in FIGS. 1 and
`3.”
`
`28:6-29:2: “the signal processor – 26 in FIG. 2 … is
`focal means for the controlling and monitoring
`subscriber station operations. It meters
`communications and enables owners of information
`to offer their information to subscribers in many
`fashions on condition of payment. It has capacity for
`regulating communications consumption by
`selectively decrypting or not decrypting encrypted
`programming and/or control signals ... It has capacity
`for identifying the subject matter of each specific unit
`
`103. A method of
`processing signals in a
`television receiver, said
`television receiver
`having a plurality of
`processors, said method
`comprising the steps of:
`
`
`
`
`
`
`11
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`PMC Exhibit 2130
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`IPR2016-00753
`Page 11
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`Substitute Claim
`
`Disclosure in the 08/449,097 Application (Ex. 2050)
`
`of programming available on each of many
`transmission channels at each subscriber station as
`said unit becomes available for use and/or viewing
`which enables subscriber station apparatus to
`determine automatically whether the subject matter of
`said unit is of interest and if so, to tune automatically
`to said programming. It has capacity at each station,
`for receiving-monitor information that identifies what
`programming is available, what programming is used,
`and how said programming is used and capacity for
`assembling and retaining monitor records that
`document said availability and usage … It has
`capacities for processing information in many other
`fashions”.
`
`33:7-11: “Signal processor, 26, has a controller
`device which includes programmable RAM
`controller, 20; ROM, 21, that may contain unique
`digital code information capable of identifying signal
`processor, 26, and the subscriber station of said
`processor, 26,”.
`Signal processor 26 is the same as signal processor
`200. See 28:6-12
`
`11:13-21: “…the present invention has capacity for
`transmitting to standardized programming that is very
`simple for subscribers to play an understand … the
`present invention has capacity for transmitting data
`and control instructions in the same information
`stream to many different apparatus at a given
`subscriber station … for causing receiver apparatus to
`operate on the basis of programming and information
`received.”
`
`288:30-33: “In example #7, the program originating
`studio that originates the ‘Wall Street Week’
`transmission transmits a television signal that consists
`
`receiving an information
`transmission including
`digital television signals
`and a message stream,
`said digital television
`signals comprising
`digital audio signals and
`digital video signals;
`
`
`
`
`
`12
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`PMC Exhibit 2130
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`IPR2016-00753
`Page 12
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`Substitute Claim
`
`Disclosure in the 08/449,097 Application (Ex. 2050)
`
`of so-called ‘digital video’ and ‘digital audio,’ well
`known in the art.”
`
`13:25-6: “The present invention employs signals
`embedded in programming.”
`
`14:16-25: “…the signals may accompany
`conventional print or data programming in the
`conventional transmission stream but will include
`instructions that receiver station apparatus are
`preprogrammed to process that instruct receiver
`apparatus to separate the signals from the
`conventional programming and process them
`differently. In all cases, signals may convey
`information in discrete words, transmitted at separate
`times or in separate locations, that receiver apparatus
`must assemble in order to receive one complete
`instruction.”
`
`17:30: “FIG. 2I shows one instance of a SPAM
`message stream.”
`
`291:9-20: “In the interval between said commence-
`enabling time and said 8:30 PM time, said head end is
`caused, in a predetermined fashion, to transmit a
`particular enabling SPAM message that consists of a
`"01" header, execution segment information that
`matches said enable-next-program-on-CC13
`information, particular meter-monitor information,
`information segment information of particular enable-
`CC13 instructions and particular enable-WSW
`instructions that include particular enable-WSW-
`programming information, and an end of file signal
`on the frequency of said master control channel.
`(Hereinafter said message is called the "local-cable-
`enabling-message (#7).")”
`
`
`
`
`
`13
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`PMC Exhibit 2130
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`Substitute Claim
`
`Disclosure in the 08/449,097 Application (Ex. 2050)
`
`detecting said message
`stream in said
`information
`transmission;
`
`
`297:20-29: “Subsequently, but still in the interval
`between said commence-enabling time and said 8:30
`PM time, said program originating studio embeds in
`the audio portion and·transmits a particular SPAM
`message that consists of a "01" header, execution
`segment information that matches said enable-WSW-
`programming information, particular meter-monitor
`information, particular lst-stage-enable-WSW-
`program instructions as the information segment
`information, and an end of file signal. (Hereinafter
`said message is called the "1st-WSW-program-
`enabling-message (#7). ").”
`
`91:21-8: “In each example, the apparatus of FIG. 3
`are preprogrammed to detect embedded signal
`information, to transfer said information to addressed
`apparatus, and to operate under control of said
`information. Apparatus of decoder, 203, are
`preprogrammed to detect signal information
`embedded in the normal transmission pattern and to
`correct, convert and transfer said information to its
`addressed apparatus.”
`
`291:21-32: “In the fashions described above, so
`transmitting said SPAM message causes signal
`processor, 200, at decoder, 30, (to which said master
`control channel is inputted), to detect the information
`of said message, select the information of the
`execution segment in said message, and determine
`that said selected information matches the
`aforementioned instance of enable-next-program-on-
`CC13 information at said particular controlled-
`function-invoking information location. So
`determining a match causes the control processor,
`39J, to execute particular preprogrammed transfer-
`this-message- to-controller-20 instructions that are
`associated with the instance of information at said
`
`
`
`
`14
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`PMC Exhibit 2130
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`IPR2016-00753
`Page 14
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`Substitute Claim
`
`Disclosure in the 08/449,097 Application (Ex. 2050)
`
`inputting at least a first
`portion of said message
`stream to a control
`processor;
`
`
`particular location.”
`
`297:30-298:5: “In the fashions described above, so
`transmitting said SPAM message causes signal
`processor, 200, at the digital detector, 38, of decoder,
`30, to detect the information of said message and at
`the control processor, 39J, to select the information of
`the execution segment in said message and determine
`that said selected information matches the
`aforementioned instance of enable-WSW-
`programming information at said particular
`controlled-function-invoking information location. So
`determining a match causes said control processor,
`39J, to execute the aforementioned transfer-this-
`message-to controller-20 instructions.”
`
`291:21-32: “In the fashions described above, so
`transmitting said SPAM message causes signal
`processor, 200, at decoder, 30, (to which said master
`control channel is inputted), to detect the information
`of said message, select the information of the
`execution segment in said message, and determine
`that said selected information matches the
`aforementioned instance of enable-next-program-on-
`CC13 information at said particular controlled-
`function-invoking information location. So
`determining a match causes the control processor,
`39J, to execute particular preprogrammed transfer-
`this-message- to-controller-20 instructions that are
`associated with the instance of information at said
`particular location.”
`
`297:30-298:5: “In the fashions described above, so
`transmitting said SPAM message causes signal
`processor, 200, at the digital detector, 38, of decoder,
`30, to detect the information of said message and at
`the control processor, 39J, to select the information of
`
`
`
`
`15
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`PMC Exhibit 2130
`Apple v. PMC
`IPR2016-00753
`Page 15
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`Substitute Claim
`
`Disclosure in the 08/449,097 Application (Ex. 2050)
`
`selecting control
`information in said at
`least a first portion of
`said message stream and
`communicating said
`selected control
`information to at least
`one register memory;
`
`
`the execution segment in said message and determine
`that said selected information matches the
`aforementioned instance of enable-WSW-
`programming information at said particular
`controlled-function-invoking information location. So
`determining a match causes said control processor,
`39J, to execute the aforementioned transfer-this-
`message-to controller-20 instructions.”
`
`290:15-21: “At a particular commence-enabling time
`that is a predetermined interval prior to the
`aforementioned 8:30 PM time (when said originating
`studio commences transmitting the "Wall Street
`Week" program), controller, 20, causes all apparatus
`of the TV signal decoder, 30, to delete from memory
`all information of received SPAM information”.
`
`291:21-32: “In the fashions described above, so
`transmitting said SPAM message causes signal
`processor, 200, at decoder, 30, (to which said master
`control channel is inputted), to detect the information
`of said message, select the information of the
`execution segment in said message, and determine
`that said selected information matches the
`aforementioned instance of enable-next-program-on-
`CC13 information at said particular controlled-
`function-invoking information location. So
`determining a match causes the control processor,
`39J, to execute particular preprogrammed transfer-
`this-message-to-controller-20 instructions that are
`associated with the instance of information at said
`particular location.”
`
`297:30-298:5: “In the fashions described above, so
`transmitting said SPAM message causes signal
`processor, 200, at the digital detector, 38, of decoder,
`30, to detect the information of said message and at
`
`
`
`
`16
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`PMC Exhibit 2130
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`Page 16
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`Substitute Claim
`
`Disclosure in the 08/449,097 Application (Ex. 2050)
`
`comparing stored
`function invoking data to
`the contents of said at
`least one register
`memory;
`
`
`the control processor, 39J, to select the information of
`the execution segment in said message and determine
`that said selected information matches the
`aforementioned instance of enable-WSW-
`programming information at said particular
`controlled-function-invoking information location. So
`determining a match causes said control processor,
`39J, to execute the aforementioned transfer-this-
`message-to controller-20 instructions.”
`The decoder contains the register.
`
`291:21-32: “In the fashions described above, so
`transmitting said SPAM message causes signal
`processor, 200, at decoder, 30, (to which said master
`control channel is inputted), to detect the information
`of said message, select the information of the
`execution segment in said message, and determine
`that said selected information matches the
`aforementioned instance of enable-next-program-on-
`CC13 information at said particular controlled-
`function-invoking information location. So
`determining a match causes the control processor,
`39J, to execute particular preprogrammed transfer-
`this-message-to-controller-20 instructions that are
`associated with the instance of information at said
`particular location.”
`
`297:30-298:5: “In the fashions described above, so
`transmitting said SPAM message causes signal
`processor, 200, at the digital detector, 38, of decoder,
`30, to detect the information of said message and at
`the control processor, 39J, to select the information of
`the execution segment in said message and determine
`that said selected information matches the
`aforementioned instance of enable-WSW-
`programming information at said particular
`controlled-function-invoking information location. So
`
`
`
`
`17
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`PMC Exhibit 2130
`Apple v. PMC
`IPR2016-00753
`Page 17
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`
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`Substitute Claim
`
`Disclosure in the 08/449,097 Application (Ex. 2050)
`
`inputting said digital
`television signals to said
`plurality of processors
`on the basis of one or
`more matches;
`
`
`determining a match causes said control processor,
`39J, to execute the aforementioned transfer-this-
`message-to controller-20 instructions.”
`
`309:30-310:15: “… causes the controller, 20, of the
`station of FIG. 4 (and causes controllers, 20, at other
`stations where so determining occurs) to execute
`particular additional 2nd-stage-enable-WSW-program
`instructions, and executing said instructions causes
`controller, 20, to cause the apparatus of the station of
`FIG. 4 to commence transferring the decrypted
`television information of the “Wall Street Week”
`program to microcomputer, 205, and monitor, 202M.
`Automatically, controller, 20, causes matrix switch,
`258, to transfer the decrypted audio information
`inputted from decryptor, 107, to monitor, 202M,
`thereby causing monitor, 202M, to commence
`receiving said audio information and emitting sound
`in accordance with said audio information.
`Automatically, controller, 20, causes matrix switch,
`258, … to commence transferring said video
`information inputted from said decryptor, 231, to
`divider, 4, thereby causing divider, 4, to transfer said
`decrypted video information to microcomputer, 205,
`and to decoder, 203.”
`
`processing of said digital
`television signals
`simultaneously at two or
`more of said plurality of
`processors, wherein at
`least one of said
`plurality of processors is
`a central processing unit
`that operates according
`to operating system
`instructions stored in
`
`309:30-310:15: “… causes the controller, 20, of the
`station of FIG. 4 (and causes controllers, 20, at other
`stations where so determining occurs) to execute
`particular additional 2nd-stage-enable-WSW-program
`instructions, and executing said instructions causes
`controller, 20, to cause the apparatus of the station of
`FIG. 4 to commence transferring the decrypted
`television information of the “Wall Street Week”
`program to microcomputer, 205, and monitor, 202M.
`Automatically, controller, 20, causes matrix switch,
`258, to transfer the decrypted audio information
`
`
`
`
`18
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`Apple v. PMC
`IPR2016-00753
`Page 18
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`Substitute Claim
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`Disclosure in the 08/449,097 Application (Ex. 2050)
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`reprogrammable
`nonvolatile memory at
`said television receiver,
`said operating system
`instructions are
`reprogrammable by a
`remote station, said
`reprogrammable
`nonvolatile memory
`storing digital data
`comprising information
`particular to a subscriber
`at said television
`receiver and originated
`at said television
`receiver, said television
`receiver stores a unique
`digital code that
`identifies said television
`receiver that may be
`transmitted from said
`television receiver using
`a digital information
`transmission
`unaccompanied by any
`non-digital information
`transmission; and
`
`inputted from decryptor, 107, to monitor, 202M,
`thereby causing monitor, 202M, to commence
`receiving said audio information and emitting sound
`in accordance with said audio information.
`Automatically, controller, 20, causes matrix switch,
`258, … to commence transferring said video
`information inputted from said decryptor, 231, to
`divider, 4, thereby causing divider, 4, to transfer said
`decrypted video information to microcomputer, 205,
`and to decoder, 203.”
`
`21:5-14: “At said subscriber station, microprocessor,
`205, contains a conventional 5 1/4'' floppy disk at a
`designated one of its disk drives that holds a data file
`recorded in a fashion well known in the art. Said file
`contains information on the portfolio of financial
`instruments owned by the subscriber that identifies
`the particular stocks in the portfolio, the number of
`shares of each stock owned at the close of business of
`each business day from the end of the previous week,
`and the closing share prices applicable each day.”
`
`474:8-13: “Automatically, microcomputer, 205,
`accesses its A:DATA-OF.URS file, in a fashion well
`known in the art, and selects the aforementioned
`information that specifies the size of the family of the
`subscriber of said station together with the tastes and
`dietary habits of the members of said family”.
`
`22:30-23:2: “microcomputer, 205, (and all other
`subscriber station microcomputers simultaneously) to
`interrupt the operation of its central processor
`unit (hereinafter, "CPU") and any designated other
`processors; then to record the contents of the registers
`of its CPU and any other designated processors either
`at a designated place in random access memory
`(hereinafter, "RAM") or on the contained disk”.”
`
`
`
`
`19
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`Apple v. PMC
`IPR2016-00753
`Page 19
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`
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`Substitute Claim
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`Disclosure in the 08/449,097 Application (Ex. 2050)
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`
`516:16-517:2: “So-called "operating systems" are
`well known in the art and generally comprise the
`most basic form of processor control instructions. In
`order to control fundamental aspects of the
`processing of any given data file, such as a DATA-
`OF.ITS or DATA-OF.URS file, under control of any
`given computer program, such as a PROGRAM.EXE
`program, a computer is usually preprogrammed with
`an operating system that controls such fundamental
`aspects as, for example, so-called "input/output"
`functions. One such system that is commonly known
`as "PC-DOS". or "MS-DOS" is an operating system
`of the IBM personal computer, commonly known as
`the "IBM PC." (PC-DOS or MS-DOS is described in
`Disk Operating System of the IBM Personal
`Computer Computer Language Series.)
`“Many computers are designed to hold operating
`system instructions at RAM. The IBM PC is one
`such computer. When power is turned on to an IBM
`PC, under control of particular instructions that are
`permanently recorded at ROM and are commonly
`known as "ROM BIOS", said PC accesses a disk at a
`particular disk drive and loads the instructions of a
`particular prerecorded file from said disk to particular
`locations of RAM in a fashion well known in the art
`that is commonly known as "booting."
`Microprocessor 205 is common between these
`embodiments. The one or more disks
`(reprogrammable nonvolatile memory) holds the
`operating system and information particular to a
`subscriber, which is loaded into RAM for the CPU
`to execute.
`
`33:7-24: “Signal processor, 26, has a controller
`device which includes programmable RAM
`controller, 20; ROM, 21, that may contain unique
`
`
`
`
`20
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`Apple v. PMC
`IPR2016-00753
`Page 20
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`Substitute Claim
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`Disclosure in the 08/449,097 Application (Ex. 2050)
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`digital code information capable of identifying signal
`processor, 26, and the subscriber station of said
`processor, 26, uniquely; an automatic dialing device
`24; and a telephone unit, 22. A particular portion of
`ROM, 21, is erasable programmable ROM
`(hereinafter, "EPROM") or other forms of
`programmable nonvolatile memory. Under control
`particular preprogrammed instructions at that portion
`of ROM, 21, that is not erasable, signal processor, 26,
`has capacity to erase and reprogram said EPROM in a
`fashion that is described more fully below.
`Controller, 20, has capacity for controlling the
`operation of all e