UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`PANASONIC CORPORATION OF NORTH AMERICA, ET AL.
`Petitioners
`
`v.
`
`CELLSPIN SOFT, INC.
`Patent Owner
`
`______________________
`
`
`Patent No. 9,258,698
`Inter Partes Review No. 2019-00131
`
`______________________
`
`DECLARATION OF DR. MICHAEL FOLEY
`
`
`
`
`CELLSPIN
`EX. 2009, Page 1
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`

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`TABLE OF CONTENTS
`
`EXHIBIT LIST .................................................................................................................... 4
`
`I. INTRODUCTION, BACKGROUND AND QUALIFICATIONS ................................ 6
`
`II. SUMMARY OF OPINIONS ......................................................................................... 7
`
`III. LEGAL UNDERSTANDINGS ..................................................................................... 7
`
`IV. TECHNOLOGY AND THE ’698 PATENT............................................................... 10
`
`A. Background Technology ........................................................................................ 10
`
`1. The ’698 Patent ................................................................................................. 10
`2. ‘698 Claims....................................................................................................... 12
`
`
`V. THE LEVEL OF ORDINARY SKILL IN THE ART ................................................ 19
`
`VI. ASSERTED GROUNDS FOR UNPATENTABILITY ............................................. 20
`
`VII. ANALYSIS ............................................................................................................... 20
`
`A. Claim Construction ................................................................................................ 20
`
`B. Claim Construction Summary ............................................................................... 35
`
`C. Prior Art Relied Upon by Petitioner ...................................................................... 36
`1. Mashita ............................................................................................................... 36
`a. Mashita’s local wireless link termination issue ............................................ 40
`b. Mashita teaches away from a cellular phone using HTTP ........................... 45
`2. Onishi ................................................................................................................. 47
`3. Hiraishi ............................................................................................................... 48
`
`D.Non-obviousness of Claims 1, 3–5, 7, 8, 10–13, and 15–20 over Mashita, Onishi, and
`Hiraishi .................................................................................................................... 48
`1. “Limitation C” – No paired Connection ............................................................ 49
`2. “Limitation C” – No Cryptographic Authentication .......................................... 54
`3. “Limitation D” – No Established Paired Connection ........................................ 55
`4. “Limitation G” – No Data Transfer Request ...................................................... 56
`5. “Limitation H – No Established Paired Connection ........................................... 57
`6. “Limitation J” – No HTTP Upload of New-Media ............................................ 58
`7. “Limitation K” – No GUI Deletion of New-Media File .................................... 60
`7. N73 ..................................................................................................................... 63
`8. Z520A ................................................................................................................ 64
`
`E. Response to Dr. Strawn’s Overview of the State of the Art and the Knowledge of a
`CELLSPIN
`EX. 2009, Page 2
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`
`
`Person of Ordinary Skill in the Art ........................................................................ 64
`
`F. Lack of Motivation to Combine Mashita, Onishi and Hiraishi .............................. 65
`
`G. Claim 5 and Claim 8 – No Single Application Performing Steps ......................... 67
`
`H. Claim 6 – Mobile Application Performing All Steps Lacking .............................. 67
`
`I. Conclusions regarding independent claims 1, 5, 8, and 13 ..................................... 70
`
`J. Dependent Claims 3, 4, 7, 10, 11, 12, 15, 16, 17, 18, 19, and 20 ........................... 70
`
`VIII. SUMMARY AND CONCLUSION ........................................................................ 70
`
`
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`
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`CELLSPIN
`EX. 2009, Page 3
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`

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`EXHIBIT LIST
`
`
`Short Name
`No.
`2001 AIRCable
`2002
`‘891 Patent
`2003 RF4CA
`2004 LR-WPANs
`
`ORDER Invalidating '698 Challenged Claims
`Wireless Communications & Networking, Stallings, 2nd
`Declaration of Michael Foley, Ph.D.
`
`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)
`2005 NIST Glossary Glossary of Key Information Security Terms by NIST
`2006 Bluetooth v.
`Bluetooth Core Specification V2.1 + EDR
`2.1
`2007 101 Order
`2008 Stallings
`2009 Foley
`Declaration
`2010 Foley CV
`2011 Techopedia
`definition for
`encryption
`2012 Science
`Dictionary
`definition of
`cryptographic
`2013 Schneier
`Excerpt
`
`Excerpt from Bruce Schneier, Applied Cryptography:
`Protocols, Algorithms and Source Code in C, 2nd Edition,
`1996, pp. 1-2.
`Excerpt from W. Stallings, "Cryptography And Network
`Security", 2nd, Edition, Chapter 13, IP Security, Jun. 8, 1998,
`pp. 399-440.
`2015 CNSSI Excerpt 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
`
`2014 Stallings
`Excerpt
`
`2016 NISTIR
`Excerpt
`
`2017 ZigBee
`Analysis
`2018 Bluetooth v2.1 Bluetooth v2.1 + EDR Core Specification
`2019 Techopedia
`Definition of “authentication” from the Techopedia dictionary
`definition for
`from
`https://www.techopedia.com/definition/342/Authentication
`authentication
`2020 Techopedia
`Definition of “graphical user interface” from the Techopedia
`definition for
`dictionary from https://www.techopedia.com/
`definition/5435/graphical-user-interface-gui
`GUI
`‘802
`U.S. Patent Application No. No. 11/901,802
`Application
`
`2021
`
`
`
`CELLSPIN
`EX. 2009, Page 4
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`

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`Short Name
`No.
`2022 Webster
`Definition of
`“along with”
`2023 Bluetooth BIP
`Profile
`
`Exhibit
`Definition of “along with” from the Merriam-Webster
`dictionary: https://www.merriam-
`webster.com/dictionary/along%20with
`Bluetooth Basic Imaging Profile, Interoperability
`Specification, dated July 30, 2003
`
`
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`CELLSPIN
`EX. 2009, Page 5
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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.
`
`Panasonic Corporation and Panasonic Corporation of North America
`
`(collectively “Petitioner” or “Panasonic”) filed a Petition (Paper 1,) to institute an inter partes
`
`review of claims 1, 3–5, 7, 8, 10–13, and 15–20 (“challenged claims”) of U.S. Patent No.
`
`9,258,698 (“’698 patent”). Ex. 1003. The Petition is supported by the Declaration of Dr. John
`
`Strawn (“Strawn Declaration,” Ex. 1001). The Patent Trial & Appeal Board (“PTAB” or
`
`“Board”) 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 issues raised by Petitioner, the Mandisetti Declaration
`
`and/or 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. 2009. 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
`
`Bluetooth Special Interest Group (“SIG”), the WAP Forum, and the Wi-Fi Alliance.
`
`
`
`CELLSPIN
`EX. 2009, Page 6
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`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 in any of
`
`the materials in which I have reviewed:
`
` Paired wireless connection between a camera and a mobile device;
`
` Cyrtographic authentication of the mobile device by the camera;
`
` Mashita teaches away from a cellular phone using HTTP;
`
` Combining Mashita with Hirashi would not work;
`
` 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 burden to prove by a preponderance of the evidence that each challenged
`
`
`
`CELLSPIN
`EX. 2009, Page 7
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`

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`claim of the ‘698 patent 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.
`
`
`
`CELLSPIN
`EX. 2009, Page 8
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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.
`
`I understand
`
`that proving obviousness cannot
`
`involve hindsight
`
`reconstruction.
`
`16.
`
`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 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
`
`
`
`CELLSPIN
`EX. 2009, Page 9
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`unreasonable under general claim construction principles or that are divorced from the
`
`specification and the record evidence.
`
`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 a cable such as a universal serial bus (USB) or a memory stick
`
`and plug the cable into the PC. The 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.
`
`The ’698 Patent
`
`21.
`
`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, Ex. 1001, 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
`
`
`
`CELLSPIN
`EX. 2009, Page 10
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`limitations. Ex. 1001, 1:40–41: 11:54-16:36. Such methods and apparatuses comprise, among
`
`other things, sending or transferring data from an Internet-incapable capture device to an
`
`Internet-capable 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
`
`
`
`CELLSPIN
`EX. 2009, Page 11
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`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.
`
`27.
`
`User information and translation to HTTP are applied in transit and on mobile
`
`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)
`
`
`
`
`
`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,
`CELLSPIN
`EX. 2009, Page 12
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`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
`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
`CELLSPIN
`EX. 2009, Page 13
`
`1(d)
`
`1(e)
`1(f)
`
`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)
`
`
`
`
`

`

`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
`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
`CELLSPIN
`EX. 2009, Page 14
`
`
`
`5(d)
`
`
`
`
`5(e)
`
`5(f)
`
`5(g)
`
`
`
`
`
`5(h)
`
`
`
`
`
`
`
`5(i)
`
`
`
`5(j)
`
`
`
`

`

`that when executed by a processor of the cellular phone is configured to…]
`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
`software application on the cellular phone, over the established short-range
`paired wireless connection,
`
`CELLSPIN
`EX. 2009, Page 15
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`6(a)
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`6(b)
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`6(c)
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`7(a)
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`8(a)
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`8(b)
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`8(c)
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`8(d)
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`8(e)
`8(f)
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`8(g)
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`8(h)
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`8(i)
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`8(j)
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`8(k)
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`8(l)
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`8(m)
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`8(n)
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`8(o)
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`9(a)
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`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
`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;
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`CELLSPIN
`EX. 2009, Page 16
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`9(b)
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`9(c)
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`10
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`11
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`12
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`13(a)
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`13(b)
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`13(c)
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`13(d)
`13(e)
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`13(f)
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`13(g)
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`13(h)
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`13(i)
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`store the associated file in the first non-volatile memory of the digital camera
`device; and
`transfer the