UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`CANON U.S.A., INC.
`Petitioner
`
`v.
`
`CELLSPIN SOFT, INC.
`Patent Owner
`
`______________________
`
`
`Patent No. 9,258,698
`Inter Partes Review No. 2019-00127
`
`______________________
`
`DECLARATION OF DR. MICHAEL FOLEY
`
`
`
`
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`CELLSPIN
`EX. 2009, Page 1
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`TABLE OF CONTENTS
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`
`
`EXHIBIT LIST ....................................................................................................................3
`
`I. INTRODUCTION, BACKGROUND AND QUALIFICATIONS .................................5
`
`II. SUMMARY OF OPINIONS .........................................................................................6
`
`III. LEGAL UNDERSTANDINGS .....................................................................................6
`
`IV. TECHNOLOGY AND THE ’698 PATENT ...............................................................10
`
`A. Background Technology ........................................................................................10
`
`1. The ’698 Patent .................................................................................................10
`2. ‘698 Claims .......................................................................................................11
`
`
`V. THE LEVEL OF ORDINARY SKILL IN THE ART .................................................18
`
`VI. ASSERTED GROUNDS FOR UNPATENTABILITY .............................................19
`
`VII. ANALYSIS ...............................................................................................................20
`
`A. Claim Construction ................................................................................................20
`
`B. Claim Construction Summary ................................................................................33
`
`C. Prior Art Relied Upon by Petitioner .......................................................................33
`
`1. Hiroishi .............................................................................................................33
`2. Takahashi ..........................................................................................................35
`3. Nozaki ...............................................................................................................36
`4. Hollstrom ..........................................................................................................37
`5. Ando ..................................................................................................................38
`
`
`D. Non-Obviousness of Claims 1–20 over Hiroishi and Takahashi (Ground 1) ........38
`
`1. Limitation 1(c) of Independent Claims 1, 5, 8, and 13 .....................................38
`2. Lack of Motivation to Combine ........................................................................53
`
`
`E. Claim 5 and Claim 8 – No Single Application Performing Steps ..........................54
`
`F. Non-Obviousness of Claims 21 and 22 over Hiroishi, Takahashi,
`and Ando (Ground 2) ...................................................................................................56
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`G. Non-Obviousness of Claims 1–22 over Hiroishi, Takahashi,
`and Nozaki (Ground 3) ................................................................................................58
`
`H. Non-Obviousness of Claims 21 and 22 over Hiroishi, Takahashi, Nozaki,
`and Ando (Ground 4). ..................................................................................................59
`
`I. Non-Obviousness of Claims 1, 3–5, 7, 8, 10–13, and 15–20
`over Hollstrom and Takahashi (Ground 5) ..................................................................60
`
`J. Non-Obviousness of Claims 2, 6, 9, 14, 21, and 22 over
`Hollstrom, Takahashi, and Ando (Ground 6) ..............................................................61
`
`
`VIII. SUMMARY AND CONCLUSION ........................................................................62
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`CELLSPIN
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`EXHIBIT LIST
`
`
`Short Name
`No.
`2001 AIRCable
`2002
`‘891 Patent
`2003 RF4CA
`2004 LR-WPANs
`
`CV of Michael Foley, Ph.D.
`Definition of “encryption” from the Techopedia dictionary from
`https://www.techopedia.com/definition/5507/encryption
`
`Definition of “cryptographic” from Academic Press Dictionary
`of Science And Technology 556 (1992) (second edition)
`
`Exhibit
`AIRcable User Manual
`U.S. Patent No. 9.398,891
`Silicon Labs UG103.10 RF4CA Fundamentals
`IEEE Part 15.4 Low-Rate Wireless Personal Area Networks (LR-
`WPANs)
`Glossary of Key Information Security Terms by NIST
`2005 NIST Glossary
`2006 Bluetooth v. 2.1 Bluetooth Core Specification V2.1 + EDR
`2007
`101 Order
`ORDER Invalidating '698 Challenged Claims
`2008 Stallings
`Wireless Communications & Networking, Stallings, 2nd
`2009 Foley
`Declaration of Michael Foley, Ph.D.
`Declaration
`2010 Foley CV
`2011 Techopedia
`definition for
`encryption
`2012 Science
`Dictionary
`definition of
`cryptographic
`Excerpt from Bruce Schneier, Applied Cryptography: Protocols,
`2013 Schneier
`Algorithms and Source Code in C, 2nd Edition, 1996, pp. 1-2.
`Excerpt
`2014 Stallings Excerpt Excerpt from W. Stallings, "Cryptography And Network
`Security", 2nd, Edition, Chapter 13, IP Security, Jun. 8, 1998,
`pp. 399-440.
`Excerpt from CNSSI No. 4009, which is a Committee on
`National Security Systems Glossary
`Excerpt from NISTIR 7298, Revision 2, entitled “Glossary of
`Key Information Security Terms,” which was published by the
`National Institute of Standards and Technology
`Security Analysis of Zigbee
`Bluetooth v2.1 + EDR Core Specification
`Definition of “authentication” from the Techopedia dictionary from
`https://www.techopedia.com/definition/342/Authentication
`
`2015 CNSSI Excerpt
`
`2016 NISTIR Excerpt
`
`2017 ZigBee Analysis
`2018 Bluetooth v2.1
`2019 Techopedia
`definition for
`authentication
`2020 Techopedia
`Definition of “graphical user interface” from the Techopedia
`dictionary from https://www.techopedia.com/
`definition for
`definition/5435/graphical-user-interface-gui
`GUI
`‘802 Application U.S. Patent Application No. No. 11/901,802
`2021
`2022 Webster
`Definition of “along with” from the Merriam-Webster
`Definition of
`dictionary: https://www.merriam-
`“along with”
`webster.com/dictionary/along%20with
`
`
`
`CELLSPIN
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`Short Name
`No.
`2023 Bluetooth BIP
`Profile
`
`Exhibit
`Bluetooth Basic Imaging Profile, Interoperability Specification,
`dated July 30, 2003
`
`
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`CELLSPIN
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`I, Dr. Michael Foley, declare as follows:
`
`I.
`
`INTRODUCTION, BACKGROUND AND QUALIFICATIONS
`
`1.
`
`My name is Michael Foley, and I am currently the CEO of Innovative Yachtter
`
`Solutions, which provides consulting services relating to Internet-of-Things products, for example
`
`products that utilize Bluetooth Low Energy.
`
`2.
`
`Canon U.S.A., Inc. (“Petitioner” or “Canon”) filed a Petition (Paper 1, “Pet.”) to
`
`institute an inter partes review (“IPR”) of claims 1–22 (“challenged claims”) of U.S. Patent No.
`
`9,258,698 (“’698 patent”). Ex. 1001. The Petition is supported by the Declaration of Dr. Vijay
`
`Madisetti (“Madisetti Declaration,” Ex. 1003). The Patent Trial & Appeal Board (“PTAB” or
`
`“Board”) has instituted inter parties review. (Paper 11, “Institution Decision”).
`
`3.
`
`I have been asked by Patent Owner Cellspin Soft, Inc. (“Cellspin”) to provide my
`
`opinions and analysis responsive to certain issues raised by Petitioner, the Madisetti Declaration
`
`and/or the Institution Decision. If an issue addressed herein that should not imply that Cellspin or
`
`I agree with the contentions being expressed by Petitioner, Dr. Madisetti, or in the Institution
`
`Decision. For this work I am being compensated at the rate of $400 per hour. The amount of my
`
`compensation is not dependent upon the substance of my opinions or upon the outcome of this
`
`matter.
`
`4.
`
`A true and correct copy of my CV is at Ex. 2010. I received a Bachelor of Science
`
`degree in Electrical Engineering (“EE”) from the University of Iowa, and a Master’s degree and
`
`Ph.D. in EE from Arizona State University.
`
`5.
`
`From 1999 to 2004, I worked at Microsoft Corporation as a wireless systems
`
`architect, where I worked on integrating wireless technology into Windows® and WinCE®
`
`platforms. I was also the Microsoft representative to several standards groups, including the
`CELLSPIN
`EX. 2009, Page 6
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`Bluetooth Special Interest Group (“SIG”), the WAP Forum, and the Wi-Fi Alliance.
`
`6.
`
`From 2004 to 2012, I worked at the Bluetooth SIG as Executive Director and CEO.
`
`My responsibilities as Director and CEO of the Bluetooth SIG included, but were not limited to,
`
`directing strategy, member relations, operations, and technology development, expanding the
`
`Bluetooth SIG into Europe and Asia, and managing Bluetooth SIG board meetings.
`
`II.
`
`SUMMARY OF OPINIONS
`
`7.
`
`In my opinion, the references and combination of refences do not disclose many of
`
`the teachings of the ‘698 patent. Indeed, these key points are not shown or rendered obvious by
`
`any of the materials in which I have reviewed including the prior art cited by Petitioner:
`
` Paired wireless connection between a digital camera and a mobile device;
`
` Cryptographic authentication of the mobile device by the camera;
`
` Using HTTP to upload received media file and additional data;
`
` GUI’s in general and specifically not for image deletion on the wirelessly connected digital
`
`camera; and
`
` For claims 5 and 8, a single mobile application performing all the required functions (e.g.,
`
`request, store, HTTP media upload, delete using GUI).
`
`
`
`8.
`
`In the analysis that follows, I present my detailed analyses of each reference cited
`
`providing clear rational as to why these items are not disclosed.
`
`III.
`
`LEGAL UNDERSTANDINGS
`
`9.
`
`I am not a lawyer. My legal understandings stated in this “Legal Understanding”
`
`section come from Cellspin’s counsel. I understand that in this proceeding, it is the Petitioner’s
`
`
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`CELLSPIN
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`burden to prove by a preponderance of the evidence that each challenged claim of the ‘698 patent
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`is obvious.
`
`10.
`
`I understand that a patent claim is unpatentable as obvious if the differences
`
`between the claimed subject matter 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. Throughout this declaration, including when I address
`
`obviousness, and including when I reference a “POSITA,” I am writing from the viewpoint and
`
`perspective of a person of ordinary skill in the art at the time the invention was made in the art to
`
`which said subject matter of the ‘698 patent pertains.
`
`11.
`
`I understand that the ultimate determination of obviousness is a question of law,
`
`but that determination is based on underlying factual findings. I understand that such underlying
`
`factual findings comprise the scope and content of the prior art, the differences between the prior
`
`art and the claims at issue, the level of ordinary skill in the pertinent art, and (if applicable) the
`
`presence of secondary considerations of nonobviousness such as commercial success, long felt but
`
`unsolved need, failure of others and unexpected results.
`
`12.
`
`I understand that in satisfying its burden of proving obviousness, Petitioner cannot
`
`employ mere conclusory statements. I understand that Petitioner must instead articulate specific
`
`reasoning, based on evidence of record, to support the conclusion of obviousness.
`
`13.
`
`I understand that, in assessing the prior art, one must consider whether a POSITA
`
`would have been motivated to combine the prior art to achieve the claimed invention. I understand
`
`that it can be important to identify a reason that would have prompted a POSITA in the relevant
`
`field to combine the elements in the way of the claimed invention at the relevant time of the priority
`
`date.
`
`
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`14.
`
`I understand that I may consider whether the prior art teaches away from combining
`
`elements in the prior art.
`
`15.
`
`16.
`
`I understand that proving obviousness cannot involve hindsight reconstruction.
`
`I also understand that modifications that render the prior art unsatisfactory for its
`
`intended purpose may not be obvious.
`
`17.
`
`I understand that a patent composed of several elements is not proved obvious
`
`merely by demonstrating that each of its elements was, independently, known in the prior art.
`
`18.
`
`I understand that there are factors relevant to determining the level of ordinary skill
`
`in the pertinent art, including the educational level of active workers in the field at the time of the
`
`invention, the sophistication of the technology, the type of problems encountered in the art, and
`
`the prior art solutions to those problems. I understand that the level of skill in the art can be
`
`evidenced by prior art references, including those of record or those upon which invalidation is
`
`sought.
`
`19.
`
`I understand that the in this IPR proceeding the PTO will give terms their broadest
`
`reasonable interpretation in light of the specification. I understand that the correct inquiry in giving
`
`the broadest reasonable interpretation in light of the specification involves an interpretation that
`
`corresponds with what and how the inventor describes his invention in the specification, i.e., an
`
`interpretation that is “consistent with the specification.” I understand that the correct inquiry is not
`
`whether the specification proscribes or precludes some broad reading of the claim term, and it is
`
`not simply an interpretation that is not inconsistent with the specification. I further understand that
`
`even when giving claim terms their broadest reasonable interpretation, one cannot construe the
`
`claims so broadly that its constructions are unreasonable under general claim construction
`
`principles or that are divorced from the specification and the record evidence.
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`IV.
`
`TECHNOLOGY AND THE ’698 PATENT
`
`A.
`
`20.
`
`Background Technology
`
`The ‘698 patent states that, prior to the ‘698 invention, “A user may need to capture
`
`and publish data and multimedia content on the internet in real time. Typically, the user would
`
`capture an image using a digital camera or a video camera, store the image on a memory device of
`
`the digital camera, and transfer the image to a computing device such as a personal computer (PC).
`
`In order to transfer the image to the PC, the user would transfer the image off-line to the PC, use
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`a cable such as a universal serial bus (USB) or a memory stick and plug the cable into the PC. The
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`user would then manually upload the image onto a website which takes time and may be
`
`inconvenient for the user.” Ex. 1003, 1:46–55.
`
`1.
`
`21.
`
`The ’698 Patent
`
`The application for ‘698 patent, which is application no. 14/533,104 was filed on
`
`November 5, 2014. It is a continuation of application no. 14/295,352, which is a continuation of
`
`application no. 14/172,913, which is a continuation of application no. 13/740,214, which is a
`
`continuation of application no. 12/333,303, filed on December 11, 2008. The ‘698 patent also
`
`claims priority to provisional application No. 61/017,202, filed on December 28,2007. For
`
`purposes of this declaration and analysis, I will assume that the claims of the ‘698 patent are
`
`entitled to a priority date of December 28, 2007. However, my opinions herein would be the same
`
`if priority date was December 11, 2008.
`
`22.
`
`The ’698 patent is directed to certain specific claimed methods and apparatuses
`
`comprising “distribution of multimedia content” and also comprising other claim limitations. Ex.
`
`1001, 1:40–41: 11:54-16:36. Such methods and apparatuses comprise, among other things,
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`sending or transferring data from an Internet-incapable capture device to an Internet-capable
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`mobile device over a previously-established paired wireless connection
`
`through a
`
`request/response, cryptographically authenticating a mobile device identity, and translating
`
`captured data into HTTP format in transit to the publishing web site. See, e.g., Ex. 1001, claim 1.
`
`23.
`
`The ‘698 specification describes embodiments comprising digital data capture
`
`device 201, e.g., a digital camera, paired with a physically separate mobile device 202, e.g., a
`
`Bluetooth enabled cellular phone with client application 203. See Ex. 1001, 3:39-46. Figure 2
`
`“illustrates a system for utilizing a digital data capture device in conjunction with a Bluetooth
`
`enabled mobile device.” Id., 3:14–18. As stated in the specification, Bluetooth “pairing occurs
`
`when the BT communication device 201a agrees to communicate with the mobile device 202 in
`
`order to establish a connection.” Id., 4:1-3. As noted hereinbelow, a POSITA understands that
`
`Bluetooth pairing involves other aspects as well.
`
`24.
`
`In one embodiment, “In order to initiate the pairing process between the BT
`
`communication device 201a and the mobile device 202, a common password known as a passkey
`
`is exchanged between the BT communication device 201a and the mobile device 202. Id., 4:5-7.
`
`25.
`
`As stated in the specification, “[a] passkey is a code shared by the Bluetooth
`
`communication device 201a and the mobile device 202.” Id., 4:7-8.
`
`26.
`
`In request/response mode, client application 203 on the cellular phone (i.e., mobile
`
`device 202) detects the captured image on the digital camera (i.e., digital data capture device 201),
`
`and, over the established, paired Bluetooth connection, initiates transfer of the captured image and
`
`associated files. Id., Abstract, 2:35-37, 6:36-40, & 8:37-40. Digital data capture device 201
`
`responds by transferring the captured image and associated files to client application 203 on mobile
`
`device 202. Id., 8:40-42.
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`
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`27.
`
`User information and translation to HTTP are applied in transit and on mobile
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`device 202. See id., ‘794/8:52-55 & 9:61-10:9. The captured data is then transferred via HTTP
`
`from client application 203 of mobile device 202 to publishing service 401 via network 402,
`
`including as illustrated in FIG. 4. Id., 5:9-11 & 8:43-50.
`
`28.
`
`A Bluetooth device that wants to communicate only with a trusted device can
`
`cryptographically authenticate the identity of another Bluetooth device. Id., 3:59-61. In a preferred
`
`embodiment communication is authenticated cryptographically using the passkey noted above. Id.,
`
`4:3-7.
`
`29.
`
`Transfer protocols compatible with the invention include “one or a combination of
`
`Bluetooth profile protocols such as the object exchange (OBEX) protocol, the generic object
`
`exchange profile (GOEP) protocol” or the “media transfer protocol (MTP), the picture transfer
`
`protocol (PTP), and the PictBridge protocol implemented using a USB.” Id. at 4:42–48.
`
`2.
`
`‘698 Claims
`
`30.
`
`The claims of the ’698 patent are as follows:
`
`Element
`1(a)
`1(b)
`
`
`
`1(c)
`
`
`
`1(d)
`
`1(e)
`1(f)
`
`Claim Language
`A machine-implemented method of media transfer, comprising:
`for a digital camera device having a short-range wireless capability
`to connect with a cellular phone,
`wherein the cellular phone has access to the internet,
`performing in the digital camera device:
`establishing a short-range paired wireless connection between the digital
`camera device and the cellular phone,
`wherein establishing the short-range paired wireless connection comprises,
`the digital camera device cryptographically authenticating identity of the
`cellular phone;
`acquiring new-media, wherein the new media is acquired after establishing
`the short-range paired wireless connection between the
`device and the cellular phone;
`creating a new-media file using the acquired new-media;
`storing the created new-media file in a first non-volatile memory of the
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`digital camera device;
`receiving a data transfer request initiated by a mobile software application
`on the cellular phone, over the established short-range paired wireless
`connection,
`wherein the data transfer request is for the new-media file, and
`wherein the new-media file was created in the digital camera device before
`receiving the data transfer request; and
`transferring the new-media file to the cellular phone, over the established
`short-range paired wireless connection,
`wherein the cellular phone is configured to receive the new-media
`file,
`wherein the cellular phone is configured to store the received new- media
`file in a non-volatile memory device of the cellular phone,
`wherein the cellular phone is configured to use HTTP to upload the
`received new-media file along with user information to a user media
`publishing website, and
`wherein the cellular phone is configured to provide a graphical user
`interface (GUI) in the cellular phone,
`wherein the graphical user interface (GUI) is for the received new media
`file and to delete the created new media file.
`The machine implemented method of claim 1, further comprising,
`performing in the digital camera device:
`creating an associated file, wherein the associated file comprises data
`associated with the new-media;
`storing the associated file in the first non-volatile memory of the digital
`camera device; and
`transferring the associated file to the cellular phone, over the established short-
`range paired wireless connection, wherein the cellular phone is configured to
`receive the associated file and store the received associated file in the non-
`volatile memory device of the cellular phone.
`The machine-implemented method of claim 1, wherein
`the user information corresponds to user related information used by the user
`media publishing website to publish the new-media file.
`The machine implemented method of claim 1, wherein
`the new-media comprises one or more of video data and image data.
`A short-range wireless enabled digital camera device, comprising:
`a first non-volatile memory device;
`a first processor coupled to said first non-volatile memory device;
`a short-range wireless communication device
`configured to control the first processor to establish a short-range paired
`wireless connection between the short-range wireless enabled digital camera
`device and a short-range wireless enabled cellular phone,
`wherein establishing the short-range paired wireless connection comprises, the
`digital camera device cryptographically authenticating identity of the cellular
`
`CELLSPIN
`EX. 2009, Page 13
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`1(g)
`
`
`
`
`1(h)
`
`
`
`1(i)
`
`
`
`1(j)
`
`
`
`2(a)
`
`2(b)
`
`2(c)
`
`2(d)
`
`3(a)
`
`4(a)
`
`5(a)
`5(b)
`
`5(c)
`
`
`
`
`
`
`
`
`
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`

`

`phone;
`a data capture circuitry;
`said first processor configured to acquire new-media in the digital camera
`device using the data capture circuitry,
`wherein the new-media is acquired after establishing the short-range paired
`wireless connection between the digital camera device and the cellular phone;
`said first processor configured to create a new media file using the acquired
`new media;
`said first processor configured to store the created new-media file in
`the first non-volatile memory device;
`said first processor configured to receive a data transfer request initiated by a
`mobile software application on the cellular phone, over the established short-
`range paired wireless connection,
`[said first processor configured to receive a data transfer request …] wherein
`the data transfer request is for the new-media file, and
`wherein the new-media file was created in the digital camera device before
`receiving the data transfer request; and
`said first processor configured to transfer the new-media file to the cellular
`phone, over the established short-range paired wireless
`connection,
`[said first processor configured to transfer the new-media file to the cellular
`phone…] wherein the cellular phone comprises a mobile software
`application that
`[said first processor configured to transfer the new-media file to the cellular
`phone … wherein the cellular phone comprises a mobile software application
`that] when executed by a processor of the cellular phone is configured to
`control the processor of the cellular phone to receive the new-media file,
`[said first processor configured to transfer the new-media file to the cellular
`phone … wherein the cellular phone comprises a mobile software application
`that when executed by a processor of the cellular phone is configured to]
`store the received new-media file in a non- volatile memory device of the
`cellular phone,
`[said first processor configured to transfer the new-media file to the cellular
`phone … wherein the cellular phone comprises a mobile software application
`that when executed by a processor of the cellular phone is configured to…] use
`HTTP to upload the received new-media file along with user information to a
`user media publishing website, and
`[said first processor configured to transfer the new-media file to the cellular
`phone … wherein the cellular phone comprises a mobile software application
`that when executed by a processor of the cellular
`phone is configured to…] provide a graphical user interface (GUI),
`[said first processor configured to transfer the new-media file to the cellular
`phone … wherein the cellular phone comprises a mobile software application
`that when executed by a processor of the cellular phone is configured to…]
`
`CELLSPIN
`EX. 2009, Page 14
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`
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`
`
`
`
`
`
`5(d)
`
`5(e)
`
`5(f)
`
`5(g)
`
`5(h)
`
`
`
`
`
`
`
`5(i)
`
`
`
`5(j)
`
`
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`

`

`provide a graphical user interface (GUI)] wherein the graphical user interface
`(GUI) is for the received new-
`media file and the graphical user interface (GUI) is configured to receive
`input to delete the created new media file.
`The short-range wireless enabled digital camera device of claim 5, wherein
`the first processor is further configured to: create an associated file, wherein
`the associated file comprises data associated with the new-media
`store the associated file in the first non-volatile memory of the digital camera
`device; and
`transfer the associated file to the cellular phone, over the established short-range
`paired wireless connection, wherein the mobile software application on the
`cellular phone that when executed by the processor of the cellular phone is
`further configured to control the processor of the cellular phone to receive the
`associated file, store the received associated file in the non-volatile memory
`device of the cellular phone, and provide a graphical user interface (GUI) for
`the received
`associated file.
`The short-range wireless enabled digital camera device of claim 5, wherein
`the new-media comprises one or more of video data and image data.
`A system for transferring media, the system comprising:
`a digital camera device, comprising:
`a first non-volatile memory device;
`a first processor coupled to the first memory device;
`a short-range wireless communication device
`configured to establish a short-range paired wireless connection with
`[a short-range wireless communication device configured to establish a
`short-range paired wireless connection with] an internet connected cellular
`phone,
`[a short-range wireless communication device configured to establish a
`short-range paired wireless connection with an internet connected cellular
`phone] wherein establishing the short-range paired wireless connection
`comprises, the digital camera device cryptographically authenticating
`identity of the cellular phone;
`a data capture circuitry;
`said first processor configured to acquire new-media in the digital camera
`device using the data capture circuitry,
`wherein the new-media is acquired after establishing the short-range paired
`wireless connection with the cellular phone, and
`wherein the new-media comprises one or more of video data and image data;
`said first processor configured to create a new-media file using the acquired
`new- media;
`said first processor configured to store the created new-media file in the first
`non-volatile memory device;
`said first processor configured to receive a data transfer request initiated by a
`CELLSPIN
`EX. 2009, Page 15
`
`6(a)
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`6(b)
`
`6(c)
`
`7(a)
`
`8(a)
`
`8(b)
`
`8(c)
`
`
`
`
`
`8(d)
`
`
`
`
`8(e)
`8(f)
`
`8(g)
`
`8(h)
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`

`

`software application on the cellular phone, over the established short-range
`paired wireless connection,
`wherein the data transfer request is for the new-media file, and
`wherein the new-media file was created in the digital camera device before
`receiving the data transfer request; and
`said first processor configured to transfer the new-media file to the cellular
`phone, over the established short-range paired wireless connection;
`[said first processor configured to receive a data transfer request initiated by
`a software application on the cellular phone…] said software application for
`the cellular phone, wherein the software application is embodied as
`executable program instructions that when executed by a processor of the
`cellular phone, is configured to control the processor of the cellular phone to:
`[said first processor configured to receive a data transfer request
`initiated by a software application … wherein the software application is
`embodied as executable program instructions that … is configured to control
`the processor of the cellular phone to] send the data transfer request to the
`digital camera device, over the established short-range paired wireless
`connection,
`wherein the data transfer request corresponds to transfer of the new- media
`file;
`[said first processor configured to receive a data transfer request initiated by
`a software application … wherein the software application is embodied as
`executable program instructions that … is configured to control the processor
`of the cellular phone to] receive the new-media file from the digital camera
`device, over the established short-range paired wireless connection,
`[said first processor configured to receive a data transfer request initiated by a
`software application … wherein the software application is embodied as
`executable program instructions that … is configured to control the processor
`of the cellular phone to] store the received new-media file in a non-volatile
`memory device of the
`cellular phone;
`[said first processor configured to receive a data transfer request initiated by
`a software application … wherein the software application is embodied as
`executable program instructions that … is configured to control the processor
`of the cellular phone to] provide a graphical user interface (GUI) for the
`received new-media file and
`[said first processor configured to receive a data transfer request initiated by a
`software application … wherein the software application is embodied as
`executable program instructions that … is configured to control the processor
`of the cellular phone to] to delete the created new-media file based on input
`received through the graphical user interface (GUI); and
`[said first processor configured to receive a data transfer request initiated by
`a software application … wherein the software application is embodied as
`executable program instructions that … is configured to control the processor
`
`CELLSPIN
`EX. 2009, Page 16
`
`
`
`
`8(i)
`
`8(j)
`
`8(k)
`
`
`
`8(l)
`
`8(m)
`
`8(n)
`
`
`
`8(o)
`
`
`
`

`

`of the cellular phone to] use HTTP to upload the received new media file
`along with user information to a user media publishing website.
`The system of claim 8, wherein the first processor is further configured to:
`create an associated file, wherein the associated file comprises data
`associated with the new-media;
`store the associated file in the first non-volatile memory of the digital camera
`device; and
`transfer the associated file to the cellular phone, over the established short-
`range paired wireless connection, wherein the software application on the
`cellular phone that when executed by the processor of the cellular phone
`is further configured to control the processor of the cellular phone to receive
`the associated file, store the received associated file in the non-volatile
`memory device of the cellular phone, and provide a graphical user interface
`(GUI) for the received associated file.
`The system of claim 8, wher