UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________
`MICROSOFT CORPORATION, MICROSOFT MOBILE INC., SAMSUNG
`ELECTRONICS AMERICA, INC. AND SAMSUNG ELECTRONICS CO. LTD.
`Petitioners
`
`v.
`
`FASTVDO LLC
`Patent Owner
`_________________
`U.S. Patent No. 5,850,482
`Issued: December 15, 1998
`Application No.: 08/633,896
`Filed: April 17, 1996
`Title: Error Resilient Method And Apparatus For Entropy Coding
`_________________
`DECLARATION OF DR. ROBERT L. STEVENSON IN SUPPORT
`OF PETITIONERS’ PETITION FOR INTER PARTES REVIEW OF
`CLAIMS 1-3, 5-6, 12-14, 16-17, AND 28 OF U.S. PATENT NO. 5,850,482
`
`Page 1 of 49
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`
`_________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________
`MICROSOFT CORPORATION, MICROSOFT MOBILE INC., SAMSUNG
`ELECTRONICS AMERICA, INC. AND SAMSUNG ELECTRONICS CO. LTD.
`Petitioners
`
`v.
`
`FASTVDO LLC
`Patent Owner
`_________________
`U.S. Patent No. 5,850,482
`Issued: December 15, 1998
`Application No.: 08/633,896
`Filed: April 17, 1996
`Title: Error Resilient Method And Apparatus For Entropy Coding
`_________________
`DECLARATION OF DR. ROBERT L. STEVENSON IN SUPPORT
`OF PETITIONERS’ PETITION FOR INTER PARTES REVIEW OF
`CLAIMS 1-3, 5-6, 12-14, 16-17, AND 28 OF U.S. PATENT NO. 5,850,482
`
`Page 1 of 49
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`
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`U.S. Patent No. 5,850,482
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`1.
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`I, Dr. Robert L. Stevenson, declare that all statements made herein of
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`my own knowledge are true and all statements made on information and belief are
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`believed to be true; and further that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable by fine
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`or imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code.
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`2.
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`I have been hired by Klarquist Sparkman, LLP, counsel for Microsoft
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`Mobile Inc. and Microsoft Corporation (“Microsoft”), and Samsung Electronics
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`America, Inc. and Samsung Electronics Co. Ltd. (“Samsung,” collectively
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`“Petitioners”) as an expert witness in the above-captioned proceeding (the “IPR”).
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`I have been asked to provide my opinion regarding U.S. Patent No. 5,850,482 (“the
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`482 patent”).
`
`I.
`
`BACKGROUND AND QUALIFICATIONS
`3. My Curriculum Vitae is attached to this Declaration as Exhibit A.
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`A. Educational Background
`4.
`I have earned a Bachelor's degree in Electrical Engineering from the
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`University of Delaware and a Ph.D. degree in Electrical Engineering from Purdue
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`University. My Ph.D. research was on communications and signal processing.
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`B.
`5.
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`Professional History
`I am presently a Professor in the Department of Electrical Engineering
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`and in the Department of Computer Science and Engineering at the University of
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`U.S. Patent No. 5,850,482
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`Notre Dame. I first joined the faculty at the University of Notre Dame as an
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`Assistant Professor in the Department of Electrical Engineering in 1990. I was
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`granted tenure and promoted to the rank of Associate Professor in August 1996. I
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`attained the rank of Professor in the Department of Electrical Engineering in
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`August 2002, and I continue to serve in that capacity. I have served concurrently as
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`a Professor in the Department of Computer Science and Engineering at the
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`University of Notre Dame since January 2003.
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`6.
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`I spent the summer of 1992 at the Air Force Research Lab in Rome,
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`New York and I spent the summer of 1993 at the Intel® Corporation in Hillsboro,
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`Oregon. Several leading computing companies, including Intel®, Sun
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`Microsystems®, and Apple® Computer have supported my research at Notre
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`Dame. During the past 20 years, I have published over 150 technical papers
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`related to the field of image processing and digital systems.
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`7.
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`I am a member of the Institute of Electronics and Electrical Engineers,
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`The International Society for Optical Engineering, and the Society for Imaging
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`Science and Technology. I am a member of the academic honor societies Eta
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`Kappa Nu, Tau Beta Pi, and Phi Kappa Phi.
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`8.
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`For the past 20 years my work has focused on the design of
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`techniques, hardware, and software for the processing of digital signals using
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`digital computing devices. As an academic researcher I attempt to develop novel
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`U.S. Patent No. 5,850,482
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`ideas for systems, then publish and present those ideas to the technical community.
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`My success as an academic is directly related to the insights and techniques which
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`provide the basis for new generations of products. My early work on digital
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`techniques for printing and image capture devices led to significant interaction
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`with companies developing desktop computers products in the early 1990's as they
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`tried to incorporate those ideas into their products.
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`9. My interaction with Apple's Imaging Group focused on various
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`imaging devices such as digital cameras, scanners, and printers and how to best
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`support those devices on desktop computers. At Intel, I worked in Intel's
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`Architecture Lab at the time the MMX multimedia instructions were being
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`incorporated into the Pentium processor. My work there dealt with developing
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`video compression techniques for CD-ROM's and network communications that
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`were well matched to the Pentium architecture. I also gave a series of talks on how
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`advanced communication and video processing techniques could be better
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`supported on the Pentium platform. Similarly, my interaction with Sun
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`Microsystem's group examined how advanced signal processing techniques could
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`be best implemented using Sun's new Visual Instruction Set on the Sparc
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`architecture.
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`10.
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`I have also received significant support for my research from several
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`U.S. Department of Defense Agencies. The Air Force Research Laboratory has
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`funded my work to develop advanced parallel processing algorithms which
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`exploited an ad-hoc network of mixed computers to achieve signification
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`computational advantages over their previously implemented techniques. Other
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`Department of Defense agencies have supported my work in image and video
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`enhancement.
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`11.
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`I have published 33 journal articles, written 9 book chapters, edited
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`the proceedings of 15 conferences, and presented 109 papers at professional
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`conferences.
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`12.
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`I am an inventor of U.S. Patent No. 6,081,552, “Video Coding Using
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`a Maximum A Posteriori Loop Filter,” June 27, 2000.
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`13.
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`If asked, I will testify regarding my qualifications, background and
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`experience in the field of data compression, encoding and decoding.
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`14.
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`I am being compensated at a rate of $600 per hour for my study and
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`testimony in this reexamination. I am also being reimbursed for reasonable and
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`customary expenses associated with my work and testimony. My compensation is
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`not contingent on the outcome of this Petition, the related litigation or the specifics
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`of my testimony.
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`II.
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`STANDARDS
`15. As part of my work in connection with this matter, I have studied the
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`482 patent, including the written description, figures, and claims. I have also
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`reviewed the U.S. Patent and Trademark Office ("USPTO") file history of the 482
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`patent, and certain of the parties’ infringement and invalidity contentions in the
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`related litigation. I have also reviewed the prior art references cited in the Petition,
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`as well as additional background references.
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`16. My opinions are based on my years of education, research and
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`experience, as well as my investigation and study of relevant materials. In forming
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`my opinions, I have considered the materials referred to herein.
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`17. Prior art is generally the state of technology in the relevant field at the
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`time of the invention, including both systems described in publications, such as
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`conference papers, and systems actually in use at some time prior to the patent
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`filings. I understand that reexamination prior art is limited to “patents and printed
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`publications.” I understand that claims in a reexamination are given their broadest
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`reasonable interpretation in light of the specification.
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`18.
`
`I understand that there are two ways in which a prior art patent or
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`printed publication can be used to invalidate a patent. First, the prior art can be
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`shown to “anticipate” the claim. Second, the prior art can be shown to “render
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`obvious” the claim. My understanding of the obviousness legal standards is set
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`forth below.
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`19.
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`I understand that an inventor is not entitled to a patent if his or her
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`invention would have been obvious to a person of ordinary skill in the field of the
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`
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`invention at the time the invention was made. I understand that 35 U.S.C. § 103(a)
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`U.S. Patent No. 5,850,482
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`states:
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`A patent may not be obtained though the invention is not
`identically disclosed or described as set forth in section
`102 of this title, if the differences between the subject
`matter sought to be patented and the prior art are such
`that the subject matter as a whole would have been
`obvious at the time the invention was made to a person
`having ordinary skill in the art to which said subject
`matter pertains. Patentability shall not be negatived by
`the manner in which the invention was made.
`
`20. The following standards govern the determination of whether a claim
`
`in a patent is obvious. I have applied these standards in my evaluation of whether
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`the claims in the 482 patent are obvious.
`
`21. A claim in a patent is obvious when the differences between the
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`subject matter sought to be patented and the prior art are such that the subject
`
`matter as a whole would have been obvious at the time the invention was made to a
`
`person having ordinary skill in the art to which the subject matter pertains.
`
`22.
`
`I understand that obviousness may be shown by considering more
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`than one item of prior art. I also understand that the relevant inquiry into
`
`obviousness requires consideration of four factors (although not necessarily in the
`
`following order):
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` The scope and content of the prior art;
`
` The differences between the prior art and the claims at issue;
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` The level of ordinary skill in the pertinent art; and
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` Whatever objective factors indicating obviousness or non-obviousness
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`may be present in any particular case.
`
`23.
`
`In addition, I understand that the obviousness inquiry should be done
`
`through the eyes of a person of ordinary skill in the relevant art at the time the 482
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`patent application was filed (in this case, April 17, 1996).
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`OPINIONS REGARDING THE
`SUBJECT MATTER OF THE 482 PATENT
`III. BACKGROUND AND STATE OF THE ART
`24. The 482 patent (Ex. 1001)1 relates to methods and apparatus for
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`compression using entropy encoding on quantized data. In particular the 482
`
`patent uses unequal levels of error coding for different subsets of a larger quantized
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`data set. The background of the 482 patent admits that compression techniques
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`such as transform-based compression were known to those skilled in the art, as
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`were quantization techniques, entropy coding and decoding. The background also
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`admits that using “Unequal Error Protection (UEP)” was also known to those of
`
`skill in the art. Nonetheless, the 482 patent claims the combination of these
`
`
`1 All Exhibit numbers in this Declaration refer to the Exhibits attached to the
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`accompanying Petition for Inter Partes Review (the “Petition”).
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`7
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`techniques into its claimed methods and its corresponding computer readable
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`memory for performing those methods.
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`25. There were a number of entropy coding techniques that were already
`
`well-known prior to the 482 patent application. As noted in the 482 patent, prior
`
`art entropy coding uses variable length coding to reduce the number of bits used to
`
`represent a data set. It accomplishes this by using variable length code words to
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`represent symbols, with shorter code words for the most commonly occurring
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`symbols. The most common entropy coding techniques are Huffman coding and
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`arithmetic coding, with the main difference being that Huffman codes use an
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`integer number of bits, while arithmetic codes can produce fractional numbers of
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`bits.
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`26. The patent acknowledges that all of this was already known to those
`
`of skill in the art. See Ex. 1001, 482 patent, 4:36-50.
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`27. There were a number of known examples of transforming data before
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`encoding prior to the 482 application, as the 482 patent states. Id., 2:11-25.
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`28. Additionally, quantizing transformed data, including quantizing such
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`data for subsequent entropy coding, was also well known, as the 482 patent also
`
`acknowledges. Id., 3:36-46.
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`29. Also, the idea of applying unequal error protection (UEP) to subsets
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`of data having unequal importance was also already well-known. See, e.g., id.,
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`5:34-46.
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`30. The 482 patent further acknowledges that splitting a code word into
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`prefix and suffix fields was known in the art. Id., 16:28-32.
`
`31. The patent goes on to state that “the proposed codes have not
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`previously been separated in order to provide error resiliency as provided by the
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`method and apparatus of the present invention.” Ex. 1001, 482 patent, 16:33-35.
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`As shown below in the discussion of the Kato prior art, this is simply not the case.
`
`IV. OVERVIEW OF THE 482 PATENT
`32.
`In the preferred embodiment, the 482 patent discusses employing
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`known techniques for transforming and quantizing image data. This is done to
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`provide fewer unique coefficients to represent the data before encoding, storing
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`and/or transmitting the resulting quantized data using the techniques described
`
`below. See, generally, id., 9:30 – 13:3.
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`33. A block diagram purporting to show an encoder implementing the
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`claimed combination of an entropy encoder with unequal error protection is
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`illustrated in Figure 2 of the 482 patent. Figure 2 includes steps for entropy
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`encoding: a) “quantized coefficients using split field coding” (35) and b) “run
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`length values” (37), and applying unequal error protection to the encoded data
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`(38), wherein, e.g., “encoded run lengths” and “prefix fields” have “higher error
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`protection” and “suffix fields” have “lower … or no error protection.”
`
`34. The 482 patent describes “split field coding” as the generation of a
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`code word that includes a first portion (which the patent calls a “prefix field”) and
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`a second portion (which the patent calls a “suffix field”). See id., 13:36-43.
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`35. These prefix fields contain information “representative of a
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`predetermined characteristic” of their corresponding suffix fields, including
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`information representative of the length of the corresponding suffix field, e.g., the
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`number of bits for the suffix field. See id., 7:18-25; see generally, id., Abstract;
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`7:8-10, 15-17; 13:56-63; and 15:47-57.
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`36. The 482 patent states that, as a result of this split field coding, even if
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`the suffix fields are provided with a “lower level of error protection” (see, e.g., id.,
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`7:30-40), the effect of any errors in a given suffix field will be minimized, and will
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`not carry forward to other code words (assuming that the prefix field with which
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`that suffix field is associated is decoded correctly). Id., 15:61-16:9.
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`37. The 482 patent further describes an embodiment in which unequal
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`error protection can be provided by storing the prefix fields using a higher level of
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`error protection than is used (if any is used) for the suffix fields. Id., 482 patent,
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`17:15-23.
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`38. The 482 patent also describes an embodiment in which unequal error
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`protection is provided by transmitting prefix fields over a first data link that is error
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`protected, and by transmitting the suffix fields over a second data link that is not
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`(or that is protected “to a lesser degree”). Id., 17:28-35.
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`39. Thus, the 482 patent combines what it acknowledges are known
`
`techniques for entropy coding quantized image data (Ex. 1001, 482 patent, 4:36-
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`39) with known “unequal error protection techniques” (id., 6:35-36) by using
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`another known technique which the patent refers to as “split field coding” (id. at
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`13:50). According to the patent, this “isolates the effects of a bit error to a single
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`code word” (id., 6:38-39). However, this combination of admittedly prior art
`
`techniques was, itself, taught in the Kato reference.
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`V. CLAIM CONSTRUCTION
`A. LEVEL OF ORDINARY SKILL IN THE ART
`40. Consistent with the background and standards set forth above, and in
`
`view of the prior art discussed herein, it is my belief that a person of ordinary skill
`
`in the relevant art of the 482 patent at the time the application that issued as the
`
`482 patent was filed (“POSA”) would have had an undergraduate degree in
`
`computer science, computer engineering, or electrical engineering, as well as two
`
`years’ experience or a graduate degree with focus in the area of data compression,
`
`encoding, and decoding. A POSA would have been familiar with and able to
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`implement and recognize well-known data compression techniques. In particular,
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`a POSA would have been familiar with techniques for both entropy coding and
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`channel coding, including techniques for unequal error protection (UEP). A POSA
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`would also have been able to recognize and implement variations of encoding
`
`techniques in the prior art. A POSA would have understood the different terms
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`with which variations of these techniques had been explained. A POSA would
`
`also have been aware that various encoding techniques could be combined in
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`parallel or in series and would have been able to adapt and combine well-known
`
`compression techniques.
`
`41.
`
`It is my understanding that the 482 patent expired on April 17, 2016,
`
`and therefore is not subject to amendment, and that based on that, for purposes of
`
`this Petition, the claims are construed pursuant to Phillips v. AWH Corp., 415 F.3d
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`1303, 1312-13 (Fed. Cir. 2005) (words of a claim “are generally given their
`
`ordinary and customary meaning” as understood by a person of ordinary skill in
`
`the art in question at the time of the invention), whose qualifications I have
`
`discussed above.
`
`B.
`
`Terms That Appear In All Claims
` “code word”
`1.
`42. The term “code word” is present, either directly, or through
`
`dependence in all challenged claims. The 482 patent describes the process of
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`assigning code words in entropy coding using a codebook: “The assignment of
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`code words for entropy coding is typically governed by means of a codebook
`
`which must be known to both the encoder and decoder.” Ex. 1001, 482 patent,
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`4:51-54 (emphasis added). The 482 patent further explains that according to the
`
`present invention, these code words represent “quantized image data.” Id., 13:36-
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`41 (“According to the present invention, an entropy encoder 16 and, more
`
`preferably, code word generating means 26 generates a plurality of code words
`
`which are representative of the quantized significant coefficients. Accordingly, the
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`plurality of code words effectively represent the quantized image data.”
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`(Emphasis added.)) And, the patent describes entropy coding as using symbols to
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`represent that information. Id., 14:27-31 (“As known to those skilled in the art,
`
`entropy coding achieves a reduction in the number of bits required to represent a
`
`data set by assigning shorter code words to symbols which occur frequently and
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`longer code words to symbols which occur less frequently.” (Emphasis added.)).
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`43. Accordingly, one of ordinary skill in the art would have understood
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`“code word” in the 482 patent to mean: “code from a code book representing a
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`symbol”.
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`“first portion of each code word”
`2.
`44. The term “first portion of each code word” is present, either directly,
`
`or through dependence in all challenged claims. The patent expressly defines “first
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`portion” as a “prefix field” (Ex. 1001, 482 patent, 13:41-43), and further explains
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`that this first portion is “a first or prefix field which is susceptible to bit errors”
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`(id., 6:52-55 (emphasis added)). As the patent further explains in the Summary of
`
`the Invention, “[T]he code words can be generated such that a bit error in the
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`prefix field of a code word could result in a potential loss of code word
`
`synchronization.” Id., 6:56-59 (emphasis added).
`
`45. Accordingly, one of ordinary skill in the art would have understood
`
`“first portion of each code word” in the 482 patent to mean: “prefix field of a code
`
`word generated in a manner such that a bit error in the field could result in a
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`potential loss of code word synchronization”.
`
` “[associated] second portion of each code word”
`3.
`46. The term “[associated] second portion of each code word” is present,
`
`either directly, or through dependence in all challenged claims. The patent
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`expressly defines “[associated] second portion” as “an associated second or suffix
`
`field which is resilient to bit errors.” Ex. 1001, 482 patent, 6:52-56. The 482
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`patent further explains what is meant by the phrase “resilient to bit errors.”
`
`Namely, the patent explains that
`
`In particular, the code words can be generated such that a bit
`error in the suffix field of a code word will not result in a loss
`of code word synchronization, but the resulting misdecoded
`value shall, instead, fall within a predetermined interval about
`the correct value.
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`Id., 6:60-65 (emphasis added).
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`47. Further, during prosecution, applicants explained that in the event of
`
`bit errors in the suffix field, “the code words are generated such that a bit error in
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`the suffix field of a code word will not result in a loss of code word
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`synchronization, but the resulting misdecoded value shall, instead, fall within a
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`predetermined range about the correct value.” Ex. 1003, 482 file history, Jan. 23,
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`1998 Amendment, p. 414 (emphasis added). In other words, one of ordinary skill
`
`in the art would understand that even in the presence of some decoding error in the
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`second portion, the misdecoded value would be close to the actual value, with the
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`value falling within some predetermined range of the actual value.
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`48. Accordingly, one of ordinary skill in the art would have understood
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`“[associated] second portion of each code word” in the 482 patent to mean:
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`“[associated] suffix field of a code word generated in a manner such that a bit error
`
`in the field results in a miscoded value that falls in a predetermined range about the
`
`correct value.”
`
`VI. SUMMARY OF THE PRIOR ART TO THE 482 PATENT
`49. The attached Petition primarily relies on two pieces of prior art to
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`challenge claims of the 482 patent, in addition to prior art and admissions showing
`
`the state of the art at the time of the 482 patent application’s filing.
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`A. Kato Combines Entropy Coding, Split
`Field Coding, And Unequal Error Protection
`50. Kato states that its invention “relates to a method of efficient encoding
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`which can reduce the total number of bits of recorded or transmitted data.” Ex.
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`1002, Kato, 1:8-10. Kato describes that in “prior-art JPEG efficient encoding of
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`the DCT (discrete cosine transform) type,” a frame represented by image data is
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`divided into blocks of 8 x 8 pixels. This data is then subjected to a DCT transform,
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`which generates a set of DCT coefficients, each of which includes one DC
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`coefficient and 63 AC coefficients. Each of these DCT coefficients is quantized,
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`and: “The resultant quantized AC coefficients are two-dimensionally encoded into
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`a Huffman code. The resultant quantized DC coefficient is predictively encoded.”
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`Id., 1:22-43.
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`51.
`
`In predictive encoding, as Kato explains, based on the value for “the
`
`immediately-preceding input data,” an estimate is generated for a subsequent piece
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`of data Di. Id., 1:55-57. This estimate or prediction Pi is generated based on
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`previously encoded image data. When Pi is subtracted from the actual value for
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`the input data Di, this generates what Kato refers to as an “estimation error” or
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`“prediction error” Si, which is equal to the difference between the actual data Di
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`and the prediction Pi. Id., 1:44-53. Because the difference values are usually
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`smaller than the actual data values they can be encoded more compactly than the
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`actual data values.
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`52. Kato goes on to describe techniques for efficiently encoding this
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`prediction error in an efficient manner. To do so, Kato teaches combining
`
`techniques for entropy coding and split field coding, and providing unequal error
`
`protection to the first and second portions into which given a code word is split.
`
`Kato Shows Combining Entropy Coding And Split Coding
`1.
`53. Kato describes the benefits of variable-length coding, such as
`
`Huffman coding, which it calls “inherently efficient.” Ex. 1002, Kato, 2:45. Kato
`
`then goes on to identify and address the same shortcomings with error propagation
`
`in variable length encoding purportedly addressed years later by the 482 patent:
`
`According to such variable-length encoding and related decoding, if
`an error occurs in the transmission of code words from an encoding
`side to a decoding side, the lengths of code words following the error
`can not be detected and also the boundaries between the code words
`following the error can not be detected. Thus, in the presence of an
`error, the code words following the error can not be accurately
`decoded. This problem is referred to as error propagation (see C.
`Yamamitsu, et al, “AN EXPERIMENTAL STUDY FOR A HOME-
`USE DIGITAL VTR”, IEEE Trans. CE-35, No. 3, Aug. 1989, pp 450-
`457).
`Id., 2:59-3:2 (emphasis added).
`
`54. Kato offers a number of solutions to address these shortcomings,
`
`many of which were later mirrored in the 482 patent. Among them, Kato teaches
`
`that individual code words can be split into first and second portions, wherein the
`
`first portion contains information about the second portion, such as its length, or
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`U.S. Patent No. 5,850,482
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`the range of values in which it is located, which aids in preventing error
`
`propagation.
`
`55. Kato’s first embodiment is directed to the creation of coded data (Ci)
`
`to represent the difference (Si) between a given estimate (Pi) and the actual input
`
`data for which the estimate is made. Ci itself consists of two portions. The first
`
`portion (CJi) is entropy encoded from a category index (Ji). The second portion,
`
`(CEi), is generated from remainder data (Ei). See generally Ex. 1002, Kato, 7:1-
`
`59; 8:6-8; 9:38-10:4; and 17:32-34.
`
`56. First, an estimate Pi is generated for the input data (Di). Subtracting
`
`Pi from Di generates an estimation error Si, as previously described. Id., 6:60-64.
`
`57. Second, this estimation error Si is classified according to a
`
`classification table, as set forth, e.g., in TABLE 1:
`
`
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`18
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`
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`Id., TABLE 1, 7:34-54.
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`U.S. Patent No. 5,850,482
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` Kato first describes determining a “category index (the category
`
`number) Ji denoting the range or the category where an estimation
`
`error Si [for input data Di] is present.” Id., 7:5-7.
`
` From this, divisor data (OUi) is calculated, which as shown in
`
`TABLE 1, “corresponds to the category index Ji in a one-to-one
`
`manner.” Id., 7:16-17.
`
` Then, remainder data Ei is calculated by dividing Di by OUi and
`
`determining the remainder. Id., 7:21-28.
`
` Finally, “the category index Ji and the remainder data Ei are
`
`encoded.” Id., 7:29-30.
`
`58. Thus, the category index Ji and remainder data Ei represent the
`
`estimation error Si for the original data Di. These Ji and Ei values are
`
`subsequently separately encoded to generate values CJi and CEi, which are
`
`combined to form a code word Ci, as shown in a portion of Kato’s Figure 1(a):
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`19
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`U.S. Patent No. 5,850,482
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`CJi – “first portion”
`
`
`
`59. First, Kato teaches that Ji is encoded to generate a first portion of code
`
`word Ci – called CJi – by “encod[ing] the category index Ji into a Huffman code
`
`(an entropy coding technique). The sub encoding circuit 109 outputs the Huffman
`
`code in a bit serial format. The output signal from the sub encoding circuit 109 is
`
`the coded data CJi.” Id., 10:45-49.
`
`CEi – “second portion”
`
`60. Next, Kato teaches that Ei is encoded to generate a second portion of
`
`the code word Ci – called CEi – using “[t]he sub encoding circuit 110,” which
`
`“determines a bit number Mi of tile [sic] remainder data Ei in accordance with the
`
`category index Ji by reference to Table 1” and then “outputs Mi lower bits of the
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`20
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`U.S. Patent No. 5,850,482
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`remainder data Ei in a bit serial format. The output signal from the sub encoding
`
`circuit is the coded data CEi.” Id., 10:65-11:2. And, Kato makes clear that CEi
`
`represents Ei: “The reason why only the Mi lower bits of the remainder data Ei are
`
`outputted is that the remainder data Ei can be represented by Mi bits.” Id., 11:2-4.
`
`61. Thus, for any given set of remainder data Ei associated with a given
`
`category index Ji, Table 1 sets a “remainder word length” for CEi – which Kato
`
`refers to as Mi – based solely on the value of Ji. For example, referring to
`
`TABLE 1 above, for an estimation error Si that generates a category index value Ji
`
`of 4, the “remainder word length” Mi for CEi coded from the remainder data Ei
`
`would be 3. Id., 14:51 (“Since Ji=4, Mi=3”).
`
`Ci – “code word”
`
`62. Kato goes on to state that once CJi and CEi are separately encoded,
`
`they are sent to a multiplexer, where they are combined into coded data Ci (id.,
`
`9:66-10:4), which is subsequently transmitted by an output terminal (108 in Fig.
`
`1(a)) (id., 11:9-11).
`
`2.
`
`Kato’s Fourth Embodiment
`Shows Unequal Error Protection (UEP)
`For First And Second Code Word Portions
`63. Kato’s fourth embodiment further describes a transmitter that arranges
`
`one or more code words Ci into a data transmission format that separates the code
`
`words into first portions Pi and second portions Ri. Id., 23:46-57; 24:40-45 (note
`
`21
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`U.S. Patent No. 5,850,482
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`that Pi in embodiment 1, supra, represented the predicted value, but in embodiment
`
`4 Pi refers to a first portion of a code word).
`
`64.
`
`In Fig. 6(a), and its accompanying discussion, Kato teaches using an
`
`encoding circuit 602 to encode input data using a variable-length code, and placing
`
`that code in a data store region within a data transmission format.” Id., 23:54-57.
`
`Kato further teaches providing an ECC encoder 603 that “adds an error correction
`
`code to the output data from the encoding circuit.” Id., 23:57-59.
`
`65. Kato further teaches that these first portions Pi and second portions Ri
`
`can be separately stored in different areas within a data store region, such as the
`
`example shown in Figure 7:
`
`
`
`Id., Fig. 7; see also id., 24:66-25:8.
`
`66. Alternatively, Kato teaches that instead of using a single data store
`
`region for the first code word portions Pi and the second code word portions Ri,
`
`these portions can each be stored in separate data store regions:
`
`22
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`U.S. Patent No. 5,850,482
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`According to a second example of the other arrangements of variable-
`length code words into a data store region, first portions Pi and second
`portions Ri are arranged in separate data store regions.
`Id., 32:35-39.
`
`67. Kato teaches and claims that the first portions Pi in one portion of the
`
`data store region (or in their own data store region) are preferably provided with a
`
`higher level of error protection than the second portions Ri. Id., 31:65-67 (“It is
`
`preferable that the data portions which are made higher in error-correction ability
`
`agree with the first portions Pi.”); see also id., claim 9, 35:18-21 (“an ability of
`
`error correction with respect to the first portions in the data store region is higher
`
`than an ability of error correction with respect to the second portions in the data
`
`store region.”); see generally id., 31:51-62.
`
`68. Additionally, Kato teaches that it is preferable to limit these first
`
`portions Pi to the smallest size which can be used to determine the length of the
`
`code word:
`
`It is preferable that a first portion Pi is limited to a smallest portion
`which enables the determination of the word length of a variable-
`length code word. This design minimizes the area occupied by first
`portions which can undergo error propagation, and thus minimizes the
`value “x” so that it is possible to withstand an error at a highest
`degree.
`Id., 32:14-20. An example of such a code word
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