`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`
`APPLE INC.
`Petitioner,
`
`v.
`
`PERSONALIZED MEDIA COMMUNICATIONS LLC
`Patent Owner
`
`______________
`
`Case: IPR2016-00755
`Patent No. 8,191,091
`______________
`
`
`
`DECLARATION OF TIMOTHY D. DORNEY, PH.D., IN SUPPORT OF
`PATENT OWNER’S CONTINGENT MOTION TO AMEND THE CLAIMS
`
`
`
`
`
`
`
`
`
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 1
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`

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`Introduction and Qualifications
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`1.
`
`I, Timothy D. Dorney, submit the following sworn declaration in
`
`IPR2016-00755 in support of the validity of U.S. Patent No. 8,191,091 (“ ’091
`
`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
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`signal processing and imaging techniques in the THz spectrum.
`
`4.
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`I have nearly 10 years of experience working in product development,
`
`design, and advanced architecture of semiconductor memories. I’ve worked as
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`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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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`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
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`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
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`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 2129.
`
`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 ’091 patent claims as unpatentable, PMC has made a contingent
`
`motion to amend to substitute the canceled claim(s) with corresponding proposed
`
`substitute claims 32-43.
`
`9.
`
`I have reviewed all relevant papers and exhibits in connection with
`
`IPR2016-00755, 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
`
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`3
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 3
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`10.
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`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 ’091 patent are included below:
`
`32. (Substitute for original claim 13, if found unpatentable) A method
`
`of decrypting digital programming at a receiver station, said method
`
`comprising the steps of:
`
`receiving an encrypted digital information transmission
`
`including encrypted digital information and unencrypted digital
`
`information, wherein said encrypted digital information transmission
`
`is unaccompanied by any scrambled analog encoded information;
`
`detecting in said encrypted digital information transmission the
`
`presence of an instruct-to-enable signal;
`
`passing said instruct-to-enable signal to a processor;
`
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`4
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`APPLE EXHIBIT 1059
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`IPR2016-01520
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`determining a fashion in which said receiver station locates a
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`first decryption key by processing said instruct-to-enable signal;
`
`locating said first decryption key based on said step of
`
`determining;
`
`decrypting said encrypted digital information using said first
`
`decryption key;
`
`creating, based on at least a portion of said encrypted digital
`
`information transmission, a digital record including a unique digital
`
`code identifying said receiver station;
`
`automatically transmitting said digital record to a remote
`
`station, wherein said transmitting transmits digital information
`
`unaccompanied by any non-digital information transmission; and
`
`outputting said digital programming based on said step of
`
`decrypting.
`
`
`
`33. (Substitute for original claim 14, if found unpatentable). The
`
`method of claim 32, further comprising the step of computing a
`
`second decryption key, and wherein said step of decrypting comprises
`
`decrypting said encrypted digital information using said first and
`
`second decryption keys.
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`5
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 5
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`34. (Substitute for original claim 15, if found unpatentable). The
`
`method of claim 33, wherein said first and second decryption keys are
`
`used to decrypt a digital video portion of said digital programming,
`
`wherein said digital video portion is absent any scrambled analog
`
`encoded video.
`
`
`
`35. (Substitute for original claim 16, if found unpatentable). The
`
`method of claim 32, further comprising the step of storing information
`
`evidencing said step of decrypting.
`
`
`
`36. (Substitute for original claim 18, if found unpatentable). The
`
`method of claim 32, wherein said encrypted digital information
`
`includes digital television programming, wherein said digital
`
`television programming comprises digital video and digital audio.
`
`
`
`37. (Substitute for original claim 20, if found unpatentable). A
`
`method of decrypting digital programming at a receiver station, said
`
`method comprising the steps of:
`
`
`
`
`6
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
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`receiving an encrypted digital information transmission
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`including encrypted digital information and unencrypted digital
`
`information, wherein said encrypted digital information transmission
`
`is unaccompanied by any scrambled analog encoded information;
`
`detecting in said encrypted digital information transmission the
`
`presence of a first instruct-to-enable signal including first processor
`
`instructions;
`
`executing said first processor instructions of said first instruct-
`
`to-enable signal to provide a first decryption key;
`
`detecting in said encrypted digital information transmission the
`
`presence of a second instruct-to-enable signal including second
`
`processor instructions;
`
`executing said second processor instructions of said second
`
`instruct-to-enable signal to provide a second decryption key;
`
`decrypting said encrypted digital information using said first
`
`and second decryption keys;
`
`storing digital data comprising information particular to a
`
`subscriber at said receiver station and originated at said receiver
`
`station, wherein said receiver station comprises a central processing
`
`unit, said central processing unit interacting with random access
`
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`7
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 7
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`memory, and reprogrammable nonvolatile memory storing said digital
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`data, wherein said receiver station stores a unique digital code capable
`
`of identifying said receiver station; and
`
`outputting said digital programming based on said step of
`
`decrypting, wherein said outputting also outputs information
`
`dependent on said digital data.
`
`
`
`38. (Substitute for original claim 21, if found unpatentable). The
`
`method as in claim 37, further comprising the step of storing
`
`information evidencing said step of decrypting.
`
`
`
`39. (Substitute for claim original 23, if found unpatentable). The
`
`method of claim 37, wherein said first and second decryption keys are
`
`used to decrypt a digital video portion of said digital programming,
`
`wherein said digital video portion is unaccompanied by any analog
`
`encoded video.
`
`
`
`40. (Substitute for claim original 24, if found unpatentable). The
`
`method of claim 37, wherein said encrypted digital information
`
`
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`8
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 8
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`includes digital television programming, wherein said digital
`
`television programming comprises digital video and digital audio.
`
`
`
`41. (Substitute for claim original 26, if found unpatentable). A
`
`method of decrypting digital programming at a receiver station, said
`
`method comprising the steps of:
`
`receiving an encrypted digital information transmission
`
`including encrypted digital information and unencrypted digital
`
`information, wherein said encrypted digital information transmission
`
`is unaccompanied by any scrambled analog encoded information;
`
`detecting in said encrypted digital information transmission the
`
`presence of an instruct-to-enable signal;
`
`passing said instruct-to-enable signal to a processor;
`
`automatically tuning said receiver station to a channel
`
`designated by said instruct-to-enable signal;
`
`receiving enabling information from a remote source based on
`
`said step of tuning;
`
`decrypting said encrypted digital information by processing
`
`said enabling information; and
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`9
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 9
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`outputting said digital programming based on said step of
`
`decrypting and based on user input at a local input of said receiver
`
`station.
`
`
`
`42. (Substitute for claim original 27, if found unpatentable). The
`
`method of claim 41, further comprising the step of storing information
`
`evidencing said step of decrypting.
`
`
`
`43. (Substitute for claim original 30, if found unpatentable). The
`
`method of claim 41, wherein said encrypted digital information
`
`includes digital television programming, wherein said digital
`
`television programming comprises digital video and digital audio.
`
`
`
`13.
`
`It is my understanding that the ’091 Patent is based on U.S.
`
`Application No. 08/485,507 (“ ’507 application”) (Ex.2050). I have reviewed the
`
`’507 application and it is my opinion that a Person of Ordinary Skill in the Art
`
`(“POSA”) reading the ’507 application would have understood that the inventors
`
`of the ’091 patent, Mr. Harvey et al., would have been in possession of the
`
`invention as recited in the substitute claims.
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`10
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 10
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`14. Each limitation of the substitute claims is disclosed in the ’507
`
`application. Support for the proposed substitute ’091 patent claims is shown
`
`below:
`
`Substitute Claim
`
`Disclosure in the 08/485,507 Application (Ex. 2050)
`
`32. A method of
`decrypting digital
`programming at a
`receiver station, said
`method comprising the
`steps of:
`
`288:30-289:3: “In example #7, the program
`originating studio that originates the "Wall Street
`Week" transmission transmits a television signal that
`consists of so-called "digital video" and "digital
`audio," well known in the art. Prior to being
`transmitted, the digital video information is doubly
`encrypted, by means of particular cipher algorithms A
`and B and cipher keys Aa and Ba, in such a way that
`said information requires decryption at subscriber
`stations in the fashion described below.”
`
`289:15-19: “Prior to retransmission, said station
`encrypts the digital audio information of said
`transmission, in a fashion well known in the art, using
`particular cipher algorithm C and cipher key Ca, then
`transmits the information of said program on cable
`channel 13, commencing at a particular 8:30 PM time
`on a particular Friday night.”
`
`receiving an encrypted
`digital information
`transmission including
`encrypted digital
`information and
`unencrypted digital
`information, wherein
`said encrypted digital
`information transmission
`is unaccompanied by
`any scrambled analog
`encoded information;
`
`290:26-30: “then to cause switch, 1, and mixer, 3, to
`select information of a particular master cable control
`channel (that may or may not be cable channel 13)
`from the multi-channel cable system transmission
`inputted to signal processor, 200”.
`
`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
`
`
`
`
`11
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 11
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`Substitute Claim
`
`Disclosure in the 08/485,507 Application (Ex. 2050)
`
`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).")”
`Local-cable-enabling-message (#7) is unencrypted
`digital information.
`
`294:30-295:3: “Executing the instructions of said
`portion causes controller, 20, in the predetermined
`fashion of the said portion, to cause selected
`apparatus of the station of FIG. 4 to receive the cable
`channel 13 transmission, to cause selected apparatus
`to decrypt the audio portion of said transmission, to
`cause selected apparatus to commence waiting to
`receive further enabling information, and to create a
`meter record that documents the decryption of the
`cable audio transmission at the station of FIG. 4.
`
`301:35-302:7: “Executing the instructions of said
`portion causes controller, 20, to cause the apparatus
`of the station of FIG. 4 to cease receiving and
`decrypting the television information of said cable
`channel 13 as digital video and audio, to commence
`receiving said television information as conventional
`analog television, and to prepare to receive particular
`embedded SPAM information at the decoder, 30, of
`signal processor, 200.”
`The digital video and digital audio are both
`encrypted digital information. Neither the above
`unencrypted digital information, nor the
`encrypted digital information, are accompanied by
`scrambled conventional analog television or
`scrambled analog encoded information.
`
`
`
`
`12
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 12
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`Substitute Claim
`
`Disclosure in the 08/485,507 Application (Ex. 2050)
`
`detecting in said
`encrypted digital
`information transmission
`the presence of an
`instruct-to-enable signal;
`
`passing said instruct-to-
`enable signal to a
`processor;
`
`determining a fashion in
`which said receiver
`station locates a first
`decryption key by
`processing said instruct-
`to-enable signal;
`
`289:10-16: “Receiving the "1st-WSW-program-
`enabling-message (#7)" causes controller, 20, to
`execute the aforementioned load-and-run-@20
`instructions, to load the 1st-stage-enable-WSW-
`program instructions of the information segment at
`particular RAM of controller, 20, then to execute the
`information so loaded as the so-called machine
`language instructions of one so-called job.
`
`289:10-16: “Receiving the "1st-WSW-program-
`enabling-message (#7)" causes controller, 20, to
`execute the aforementioned load-and-run-@20
`instructions, to load the 1st-stage-enable-WSW-
`program instructions of the information segment at
`particular RAM of controller, 20, then to execute the
`information so loaded as the so-called machine
`language instructions of one so-called job.
`
`289:17-21: “Executing said 1st-stage-enable-WSW-
`program instructions causes controller, 20, in the
`predetermined fashion of said instructions, to affect a
`first stage of decrypting the video information of the
`"Wall Street Week" program transmission.”
`
`299:1-13: “In the present invention, the preferred
`method of preprogramming subscriber station signal
`processing apparatus is to preprogram each station
`with all authorized information but to vary the
`locations of the information from station to station in
`accordance with station specific information that
`varies from station to station - for example, in
`example #7, Ba cipher information can be
`preprogrammed at eight different RAM locations and
`the particular location that applies at any given station
`that is authorized with such information relates to the
`last three significant digits of the unique digital code
`of said station in the fashion of the above Q quantity
`
`
`
`
`13
`
`
`
`
`
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 13
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`Substitute Claim
`
`Disclosure in the 08/485,507 Application (Ex. 2050)
`
`locating said first
`decryption key based on
`said step of determining;
`
`decrypting said
`encrypted digital
`information using said
`first decryption key;
`
`computation.”
`
`299:1-13: “In the present invention, the preferred
`method of preprogramming subscriber station signal
`processing apparatus is to preprogram each station
`with all authorized information but to vary the
`locations of the information from station to station in
`accordance with station specific information that
`varies from station to station - for example, in
`example #7, Ba cipher information can be
`preprogrammed at eight different RAM locations and
`the particular location that applies at any given station
`that is authorized with such information relates to the
`last three significant digits of the unique digital code
`of said station in the fashion of the above Q quantity
`computation.”
`
`299:13-25: “Automatically, controller, 20, transfers
`said decryption cipher key Ba information to a
`selected decryptor, 224, and causes decryptor, 224, to
`commence decrypting any received information,
`using said key information and selected decryption
`cipher algorithm B, and outputting decrypted
`information to matrix switch, 258. Automatically,
`controller, 20, causes matrix switch, 258, to transfer
`the information of the aforementioned video output
`inputted from said tuner, 215, to the output that
`outputs to decryptor, 224, thereby causing said
`decryptor, 224, to receive the information of said
`video portion (said information being, as explained
`above, encrypted digital video), to decrypt said
`information”.
`
`creating based on at least
`a portion of said
`encrypted digital
`information
`transmission, a digital
`
`294:30-295:3: “Executing the instructions of said
`portion causes controller, 20, in the predetermined
`fashion of the said portion, to cause selected
`apparatus of the station of FIG. 4 to receive the cable
`channel 13 transmission, to cause selected apparatus
`
`
`
`
`14
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`
`
`
`
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 14
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`Substitute Claim
`
`Disclosure in the 08/485,507 Application (Ex. 2050)
`
`record including a
`unique digital code
`identifying said receiver
`station;
`
`to decrypt the audio portion of said transmission, to
`cause selected apparatus to commence waiting to
`receive further enabling information, and to create a
`meter record that documents the decryption of the
`cable audio transmission at the station of FIG. 4.
`
`28:6-10: “In the present invention, the signal
`processor-26 in FIG. 2; 26 in the signal processor
`system of FIG. 2D; in the signal processor system,
`71, of FIG. 6; 200 in FIG. 7; and elsewhere-is focal
`means for the controlling and monitoring subscriber
`station operations.
`
`33:7-12: “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, uniquely; an automatic dialing device
`24; and a telephone unit, 22.”
`
`292:31-293:4: “Executing said enable-CC13
`instructions at controller, 20, in this fashion, causes
`controller, 20, to sample selected preprogrammed
`SPAM information of the station of FIG. 4 and
`determine whether unauthorized tampering has
`occurred at said station. Automatically, in the
`predetermined fashion of the said instructions,
`controller, 20, selects information of the unique
`digital code at ROM, 21, that identifies signal
`processor, 200, and the subscriber station of FIG. 4
`uniquely;”
`
`294:29-295:3: “Executing the instructions of said
`portion causes controller, 20, in the predetermined
`fashion of the said portion, to cause selected
`apparatus of the station of FIG. 4 to receive the cable
`
`
`
`
`15
`
`
`
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 15
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`Substitute Claim
`
`Disclosure in the 08/485,507 Application (Ex. 2050)
`
`channel 13 transmission, to cause selected apparatus
`to decrypt the audio portion of said transmission, to
`cause selected apparatus to commence waiting to
`receive further enabling information, and to create a
`meter record that documents the decryption of the
`cable audio transmission at the station of FIG. 4.”
`
`297:3-19: “Finally, controller, 20, completes
`execution of all information of the information
`segment of local-cable-enabling-message (#7) loaded
`at controller, 20, then in the fashion of the first
`message of example #4, controller, 20, processes
`automatically the information of the meter-monitor
`segment as meter information, causes a meter record
`of prior programming to be transferred from
`buffer/comparator, 14, and recorded at recorder, 16,
`(and causes the aforementioned signal record transfer
`sequence if recorder, 16, equals or exceeds if
`predetermined level of fullness); causes information
`of the meter-monitor segment to be placed at
`particular locations of buffer/ comparator, 14, thereby
`creating a meter record that records the decryption of
`the audio portion of the "Wall Street Week" program
`transmission; and causes monitor information to be
`recorded by onboard controller, 14A, if the station of
`FIG. 4 is preprogrammed to collect monitor
`information.”
`
`automatically
`transmitting said digital
`record to a remote
`station, wherein said
`transmitting transmits
`digital information
`unaccompanied by any
`non-digital information
`transmission; and
`
`92:35-93:16: “In each example, the recorder, 16, of
`signal processor, 200, has reached a level of fullness
`where the recording of the next signal record received
`from the buffer/comparator, 14, of signal processor,
`200, will cause the quantity of signal records
`recorded at recorder, 16, to equal or exceed the
`particular fullness information of said recorder, 16.
`Whenever said quantity equals or exceeds said
`fullness information, recorder, 16, is preprogrammed
`
`
`
`
`16
`
`
`
`
`
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 16
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`Substitute Claim
`
`Disclosure in the 08/485,507 Application (Ex. 2050)
`
`to commences a particular telephone signal record
`transfer sequence that is fully automatic for which
`recorder, 16; controller, 20; auto dialer, 24; and 30
`telephone connection, 22, are each preprogrammed.
`Under control of the preprogrammed instructions of
`said sequence, signal processor, 200, telephones one
`or more remote billing station computers and/or one
`or more remote monitor information collection station
`computers and transfers selected record information
`to said computers.”
`
`294:9-19: “Executing said portion causes said
`controller, 20, to cause the auto dialer, 24, and
`telephone connection, 22, to establish telephone
`communications with a particular predetermined
`remote station, in the fashion described above in
`"Operating Signal Processor Systems ... Signal
`Record Transfer," and causes controller, 20, then to
`transmit information of the aforementioned unique
`digital code at ROM, 21, that identifies said station
`and signal processor, 200, of said station uniquely as
`well as particular predetermined appearance-of-
`tampering information.”
`
`310:3-24: “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 cease transferring the decrypted video
`information inputted from decryptor, 231, to the
`output that outputs to said third alternate contact of
`switch, 1, and to commence transferring said video
`information inputted from said decryptor, 231, to
`divider, 4, thereby causing divider, 4, to transfer said
`
`outputting said digital
`programming based on
`said step of decrypting.
`
`
`
`
`17
`
`
`
`
`
`
`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 17
`
`

`

`Substitute Claim
`
`Disclosure in the 08/485,507 Application (Ex. 2050)
`
`decrypted video information to microcomputer, 205,
`and to decoder, 203. Automatically, controller, 20,
`causes decoder, 203, to discard any previously
`received SPAM information; to commence detecting
`SPAM information in the inputted decrypted video
`information and waiting to receive SPAM header
`information; and to cause microcomputer, 205, to
`commence transferring the decrypted information of
`the transmitted video image to monitor, 202M,
`thereby causing monitor, 202M, to commence
`displaying, at its television picture tube, the
`information of the transmitted television image.”
`
`304:35-305:16: “Executing said instructions causes
`the transfer of the information of said message to
`controller, 20, in the fashion of the local-cable-
`enabling-message (#7).
`“Receiving said 2nd-WSW-program-enabling-
`message (#7) causes controller, 20, to execute the
`aforementioned load-and-run-@20 instructions, to
`load the 2nd-stage-enable-WSW-program instructions
`of the information segment at particular RAM of
`controller, 20, then to execute the information so
`loaded as the machine language instructions of one
`job.
`“Executing said 2nd-stage-enable-WSW-program
`instructions causes controller, 20, in the
`predetermined fashion of said instructions, to strip
`particular SPAM information from said "Wall Street
`Week" program transmission, to generate and insert
`particular information into said transmission, and to
`affect a second and last stage of decrypting the digital
`video information of the "Wall Street Week" program
`transmission.”
`
`33. The method of
`claim 32, further
`comprising the step of
`computing a second
`decryption key, and
`wherein said step of
`decrypting comprises
`decrypting said
`encrypted digital
`information using said
`first and second
`decryption keys.
`
`34. The method of
`claim 33, wherein said
`
`288:33-289:3: “Prior to being transmitted, the digital
`video information is doubly encrypted, by means of
`
`
`
`
`18
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`
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`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 18
`
`

`

`Substitute Claim
`
`Disclosure in the 08/485,507 Application (Ex. 2050)
`
`first and second
`decryption keys are used
`to decrypt a digital video
`portion of said digital
`programming, wherein
`said digital video portion
`is absent any scrambled
`analog encoded video.
`
`particular cipher algorithms A and B and cipher keys
`Aa and Ba, in such a way that said information
`requires decryption at subscriber stations in the
`fashion described below.”
`
`299:13-27: “Automatically, controller, 20, transfers
`said decryption cipher key Ba information to a
`selected decryptor, 224, and causes decryptor, 224, to
`commence decrypting any received information,
`using said key information and selected decryption
`cipher algorithm B, and outputting decrypted
`information to matrix switch, 258. Automatically,
`controller, 20, causes matrix switch, 258, to transfer
`the information of the aforementioned video output
`inputted from said tuner, 215, to the output that
`outputs to decryptor, 224, thereby causing said
`decryptor, 224, to receive the information of said
`video portion (said information being, as explained
`above, encrypted digital video), to decrypt said
`information, and to transfer decrypted information of
`said video portion to matrix switch, 258.”
`
`307:1-8: “Automatically, controller, 20, selects
`information of the aforementioned first three of the
`last four significant digits of the binary information of
`the aforementioned unique digital code at ROM, 21
`and computes a particular Q quantity according to a
`particular formula that is preprogrammed in said 2nd-
`stage-enable-WSW-program instructions. The
`information of said Q quantity is the decryption key
`Aa.”
`
`309:34-310:24: “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,
`
`
`
`
`19
`
`
`
`
`
`
`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 19
`
`

`

`Substitute Claim
`
`Disclosure in the 08/485,507 Application (Ex. 2050)
`
`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 cease transferring the decrypted video
`information inputted from decryptor, 231, to the
`output that outputs to said third alternate contact of
`switch, 1, and 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. Automatically, controller, 20,
`causes decoder, 203, to discard any previously
`received SPAM information; to commence detecting
`SPAM information in the inputted decrypted video
`information and waiting to receive SPAM header
`information; and to cause microcomputer, 205, to
`commence transferring the decrypted information of
`the transmitted video image to monitor, 202M,
`thereby causing monitor, 202M, to commence
`displaying, at its television picture tube, the
`information of the transmitted television image.”
`The transmission includes encrypted digital audio,
`encrypted digital video, and SPAM messages,
`absent any scrambled analog encoded video.
`
`310:33-311:9: “Finally, controller, 20, completes
`execution of said 2nd-stage-enable-WSW-program
`instructions then processes the information of the
`meter-monitor segment of said message as meter
`information; causes selected information of said
`meter-monitor segment to be placed at particular
`locations of buffer/comparator, 14, thereby
`incrementing the information of the aforementioned
`meter record that records the decryption of the
`
`35. The method of
`claim 32, further
`comprising the step of
`storing information
`evidencing said step of
`decrypting.
`
`
`
`
`20
`
`
`
`
`
`
`APPLE EXHIBIT 1059
`APPLE v. PMC
`IPR2016-01520
`Page 20
`
`

`

`Substitute Claim
`
`Disclosure in the 08/485,507 Application (Ex. 2050)
`
`36. The method of
`claim 32, wherein said
`encrypted digital
`information includes
`digital television
`programming, wherein
`said digital television
`programming comprises
`digital video and digital
`audio.
`
`program transmission of the "Wall Street Week"
`program originating studio; and causes monitor
`information to be recorded by onboard controller,
`14A, if the station of FIG. 4 is preprogrammed to
`collect monitor information.”
`
`309:34-310:24: “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