`
`UNITED STATES
`INTERNATIONAL TRADE COMMISSION
`
`------------------------------x
`
`In the Matter of: Investigation No.
`
` 337-TA-1200
`
`CERTAIN ELECTRONIC DEVICES,
`
`INCLUDING STREAMING PLAYERS,
`
`TELEVISIONS, SET TOP BOXES, REMOTE
`
`CONTROLLERS, and COMPONENTS
`
`THEREOF
`
`------------------------------x
`
`
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`
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`Pages:
`
`Place:
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`Date:
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`1 through 210
`Washington, D.C.
`August 19, 2020
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`
`
`
`HERITAGE REPORTING CORPORATION
`Official Reporters
`1220 L Street, N.W., Suite 206
`Washington, D.C. 20005
`(202) 628-4888
`contracts@hrccourtreporters.com
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
`
` 1
`
`
` 1 BEFORE THE UNITED STATES INTERNATIONAL TRADE COMMISSION
`
` 2 Washington, D.C.
`
` 3 ------------------------------x
`
` 4 In the Matter of: Investigation No.
`
` 5 337-TA-1200
`
` 6 CERTAIN ELECTRONIC DEVICES,
`
` 7 INCLUDING STREAMING PLAYERS,
`
` 8 TELEVISIONS, SET TOP BOXES, REMOTE
`
` 9 CONTROLLERS, and COMPONENTS
`
` 10 THEREOF
`
` 11 ------------------------------x
`
` 12
`
` 13 MARKMAN HEARING
`
` 14 (via remote videoconferencing)
`
` 15 Wednesday, August 19, 2020
`
` 16
`
` 17
`
` 18 BEFORE THE HONORABLE CAMERON R. ELLIOT
`
` 19 Administrative Law Judge
`
` 20
`
` 21 The Markman Hearing commenced, pursuant the
`
` 22 to notice of the Administrative Law Judge, at 10:30 a.m.
`
` 23 Eastern Time.
`
` 24
`
` 25
`
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 2
`
`
` 1 APPEARANCES:
`
` 2 (all parties appearing remotely)
`
` 3
`
` 4 For Complainant Universal Electronics Inc.:
`
` 5 ADAM D. SWAIN, ESQ.
`
` 6 Alston & Bird LLP
`
` 7 950 F Street, NW
`
` 8 Washington, DC 20004
`
` 9
`
` 10 -and-
`
` 11
`
` 12 RYAN W. KOPPELMAN, ESQ.
`
` 13 Alston & Bird LLP
`
` 14 950 Page Mill Road
`
` 15 Palo Alto, California 94304
`
` 16
`
` 17 -and-
`
` 18
`
` 19 STEPHEN R. LAREAU, ESQ.
`
` 20 Alston & Bird LLP
`
` 21 101 South Tryon Street
`
` 22 Charlotte, North Carolina 28280
`
` 23
`
` 24
`
` 25 CONTINUED ON FOLLOWING PAGE
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 3
`
`
` 1 APPEARANCES (continued):
`
` 2
`
` 3 For Complainant Universal Electronics Inc. (continued):
`
` 4 NICHOLAS T. TSUI, ESQ.
`
` 5 Alston & Bird LLP
`
` 6 1201 W. Peachtree Street
`
` 7 Atlanta, Georgia 30309
`
` 8
`
` 9
`
` 10 For Respondent Roku, Inc.:
`
` 11 JONATHAN D. BAKER, ESQ.
`
` 12 CRAIG Y. ALLISON, ESQ.
`
` 13 DINO HADZIBEGOVIC, ESQ.
`
` 14 Dickinson Wright PLLC
`
` 15 800 West California Avenue
`
` 16 Sunnyvale, California 95086
`
` 17
`
` 18 -and-
`
` 19 MICHAEL D. SAUNDERS, ESQ.
`
` 20 Dickinson Wright PLLC
`
` 21 8607 W. 3rd Street
`
` 22 Austin, Texas 78701
`
` 23
`
` 24 CONTINUED ON FOLLOWING PAGE
`
` 25
`
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 4
`
`
` 1 APPEARANCES (continued):
`
` 2
`
` 3 For Respondents Hisense Co. Ltd.; Hisense Electronics
`
` 4 Manufacturing Company of America Corporation d/b/a Hisense
`
` 5 USA; Hisense Import & Export Co. Ltd.; Qingdao Hisense
`
` 6 Electric Co., Ltd.; Hisense International (HK) Co., Ltd.;
`
` 7 Funai Electric Co., Ltd.; Funai Corporation Inc.; and Funai
`
` 8 (Thailand) Co., Ltd.:
`
` 9 JORDAN L. COYLE, ESQ.
`
` 10 CHRISTOPHER HIGGINS, ESQ.
`
` 11 Orrick Herrington & Sutcliffe LLP
`
` 12 1152 15th Street, NW
`
` 13 Washington, DC 20005
`
` 14
`
` 15 For Respondents TCL Electronics Holdings Limited, f/k/a TCL
`
` 16 Multimedia Holdings Limited; Shenzhen TCL New Technology
`
` 17 Company; TCL King Electrical Appliances (Huizhou) Company
`
` 18 Limited; TTE Technology Inc. d/b/a TCL USA and TCL North
`
` 19 America; TCL Corp.; TCL Moka, Int'l Ltd.; TCL Overseas
`
` 20 Marketing Ltd.; TCL Industries Holdings Co., Ltd.; TCL
`
` 21 Smart Device (Vietnam) Company, Ltd.:
`
` 22 JOHN P. SCHNURER, ESQ.
`
` 23 Perkins Coie LLP
`
` 24 11452 El Camino Real
`
` 25 San Diego, California 92130
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 5
`
`
` 1 APPEARANCES (continued):
`
` 2
`
` 3
`
` 4 Also Present:
`
` 5 Richard Firehammer, Esq.
`
` 6 General Counsel
`
` 7 Jeremy Black, Esq.
`
` 8 UEI
`
` 9
`
` 10 Joseph Hollinger, Esq.
`
` 11 General Counsel
`
` 12 Roku, Inc.
`
` 13
`
` 14
`
` 15
`
` 16
`
` 17
`
` 18
`
` 19
`
` 20
`
` 21
`
` 22
`
` 23
`
` 24
`
` 25
`
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 6
`
`
` 1 P R O C E E D I N G S
`
` 2 (10:29 a.m.)
`
` 3 JUDGE ELLIOT: We're here in the matter of
`
` 4 Certain Electronic Devices Including Streaming Players,
`
` 5 Televisions, Set-Top Boxes, Remote Controllers and
`
` 6 Components Thereof, United States International Trade
`
` 7 Commission, Investigation No. 337-TA-1200. My name is
`
` 8 Cameron Elliot, presiding Administrative Law Judge.
`
` 9 May I have appearances from counsel, please?
`
` 10 MR. SWAIN: Good morning, Your Honor. This is
`
` 11 Adam Swain with the law firm of Alston & Bird on behalf of
`
` 12 Complainant UEI. I'm joined here today with several of my
`
` 13 colleagues that will be arguing various terms and issues
`
` 14 before you, Nick Tsui, T-S-U-I, Steven Lareau, and Ryan
`
` 15 Koppelman.
`
` 16 I'm also pleased to present Mr. Rick
`
` 17 Firehammer, general counsel of UEI, as well as Jeremy
`
` 18 Black, counsel for UEI, are both on the meeting as well,
`
` 19 Your Honor.
`
` 20 JUDGE ELLIOT: All right. And before we
`
` 21 continue with the Respondents, let me just ask,
`
` 22 Mr. Firehammer, just for bandwidth purposes, it would be
`
` 23 helpful if you were not on video. So could you cut off
`
` 24 your video?
`
` 25 MR. FIREHAMMER: Will do.
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 7
`
`
` 1 JUDGE ELLIOT: Thank you very much. All right.
`
` 2 So Respondents, Mr. Baker?
`
` 3 MR. BAKER: Yes. Good morning, Your Honor.
`
` 4 This is Jonathan Baker from the law firm of Dickinson
`
` 5 Wright on behalf of Respondent Roku. With me are several
`
` 6 of my colleagues: Michael Saunders, Craig Allison, and
`
` 7 Dino Hadzibegovic, all from the law firm of Dickinson
`
` 8 Wright.
`
` 9 I also believe that in-house counsel from Roku
`
` 10 will be joining us, Joseph Hollinger. We also have
`
` 11 co-counsel from Ropes & Gray.
`
` 12 JUDGE ELLIOT: All right. And then, let's see,
`
` 13 who's next? Let's go with the Funai and Hisense attorneys.
`
` 14 I'm sorry. Mr. Coyle, I think you're muted. I
`
` 15 can't hear you. I'm sorry.
`
` 16 Is there anyone else for Funai and Hisense?
`
` 17 Anyone else from Roku can test this?
`
` 18 MR. HIGGINS: Your Honor, can you hear me? This
`
` 19 is Chris Higgins from Orrick.
`
` 20 JUDGE ELLIOT: Yes, I can hear you, Mr. Higgins.
`
` 21 MR. HIGGINS: This is Chris Higgins from Orrick.
`
` 22 With me is Jordan Coyle on behalf of Funai and Hisense
`
` 23 Respondents.
`
` 24 JUDGE ELLIOT: All right. And anyone else for
`
` 25 Funai and Hisense? No? All right.
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 8
`
`
` 1 And so then we have TCL. Let's see. I see
`
` 2 Mr. Schnurer.
`
` 3 Mr. Schnurer?
`
` 4 MR. SCHNURER: Yes. Yes, Your Honor, this is
`
` 5 John Schnurer of Perkins Coie representing the TCL
`
` 6 Respondents.
`
` 7 JUDGE ELLIOT: All right. Very well. So I'm
`
` 8 not sure what the problem is with Mr. Coyle. Right now I
`
` 9 have him as muted. Let's see. Let me ask, if this becomes
`
` 10 an issue, then we may have to do a workaround, but, in any
`
` 11 event, for now I think we can start.
`
` 12 Okay. So let me just get started with the
`
` 13 Markman portion. First of all, this doesn't really affect
`
` 14 us today, but the Commission continues to work on
`
` 15 developing this video platform, and are experimenting with
`
` 16 other ways of holding these hearings.
`
` 17 What we do in the future is not what we're doing
`
` 18 today. Maybe we'll use a different Webex platform and a
`
` 19 rather different system, but, in any event, I just wanted
`
` 20 to give you a heads-up on that, because we're still
`
` 21 developing these things.
`
` 22 Secondly, for today's schedule, although I
`
` 23 mentioned it last week, I want to be a little more specific
`
` 24 about what I anticipate our schedule to be. So what I
`
` 25 expect to do is go about an hour and a half, take a
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 9
`
`
` 1 15-minute break, and then another hour and a half, and then
`
` 2 take a lunch break. And the lunch break would be about an
`
` 3 hour. That's a little bit less than what I usually do, but
`
` 4 I would like to try to get as much done as we can today.
`
` 5 And then after lunch, we would do the same thing
`
` 6 we did in the morning. So an hour and a half, 15-minute
`
` 7 break, and then an hour and a half. And I would like to
`
` 8 end this no later than 6:00. So I think we can get quite a
`
` 9 bit done with that schedule. And, unfortunately, the lunch
`
` 10 break is going to be a little bit odd for everyone -- early
`
` 11 for the West Coast folks and late for the East Coast
`
` 12 folks -- but I don't see any other way to do it.
`
` 13 The third thing, which is the most important
`
` 14 thing before we get started with our substantive work, is I
`
` 15 have reviewed the parties' letters regarding discovery, and
`
` 16 I believe that we would not benefit from any oral argument.
`
` 17 So I'm going to steal the thunder of anyone who was hoping
`
` 18 to make a presentation on that.
`
` 19 Let me just say this. I think, bottom line, I
`
` 20 think that I don't want any motions to compel until next
`
` 21 Friday, Friday, the 28th, and here's my rationale. I'm
`
` 22 going to explain this using the framework that Roku ... for
`
` 23 the general dispute that the parties have over what has
`
` 24 been produced or not produced. I'm going to accept Roku's
`
` 25 representation that there's still some discussion going on
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 10
`
`
` 1 about narrowing down the number of products at issue, that
`
` 2 is, identifying representative products. Very good. I
`
` 3 encourage you to do that. It will help everybody. It will
`
` 4 help me and make things much simpler. I want you to
`
` 5 continue doing that.
`
` 6 If, of course, you can't reach an agreement or
`
` 7 you feel like you really need to -- that is, if UEI feels
`
` 8 like it really needs to file a motion, again, we'll do that
`
` 9 no later, I'm sorry, no earlier than Friday the 28th.
`
` 10 The second issue has to do with the documents in
`
` 11 Roku's possession, which are from third parties. This is
`
` 12 not really a basis to withhold the documents. If Roku
`
` 13 feels like it needs to turn over or if it needs to inform
`
` 14 the third parties that it's turned over discovery, well,
`
` 15 that's fine, the third parties can object, but if it's in
`
` 16 Roku's possession and it's responsive, and the requests for
`
` 17 discovery are of the sort that are reasonably calculated to
`
` 18 lead to the discovery of admissible evidence, then ...
`
` 19 over.
`
` 20 And it seems to me, based on the descriptions
`
` 21 from both sides, that what is being sought that happens to
`
` 22 be third-party information is within the regular scope of
`
` 23 discovery. If Roku contends that there's an undue burden
`
` 24 in producing it, well, that would be a separate issue and I
`
` 25 would resolve that in connection with motions practice.
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 11
`
`
` 1 Similarly, the fact that Roku is of the view
`
` 2 that these documents are not relevant, that's ... if you
`
` 3 think there's an undue burden or if you think they are not
`
` 4 reasonably calculated to lead to the discovery of
`
` 5 admissible evidence, then I'll hear you on that, but that's
`
` 6 not -- that's something that has yet to be determined.
`
` 7 And then the third issue has to do with requests
`
` 8 for admission. I am somewhat sympathetic with Roku's
`
` 9 position. It does not appear to be in dispute that Roku
`
` 10 was late in getting its RFA responses out, and, of course,
`
` 11 I don't look favorably on that.
`
` 12 On the other hand, it's always been my view that
`
` 13 RFAs, because of the difficulty in amending them, are
`
` 14 something that really ought to be propounded later in the
`
` 15 case, especially when they are on topics that can benefit
`
` 16 from evidentiary development in the course of discovery,
`
` 17 like infringement issues or invalidity.
`
` 18 So I'm going to give Roku a break on this, that
`
` 19 Roku says that it will get them out Wednesday, I will
`
` 20 accept that representation, and, on that basis, I'm going
`
` 21 to give UEI two days to look them over. And then if UEI is
`
` 22 still unsatisfied, still dissatisfied with them, then that
`
` 23 can be part of the motions practice on Friday, the 28th.
`
` 24 So, bottom line, keep working on reaching an
`
` 25 agreement, particularly over representative products. If
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 12
`
`
` 1 it's coming from a third party, we have a protective order
`
` 2 in place, you need to produce it if you have it. Requests
`
` 3 for admission, assuming that they get served on ... then
`
` 4 I'll be fine with that, and, otherwise, motions practice,
`
` 5 no earlier than Friday the 28th.
`
` 6 Okay. So that resolves, as far as I'm
`
` 7 concerned, the -- or satisfies, I should say -- my normal
`
` 8 requirement that there be a discovery conference when
`
` 9 there's a discovery dispute. So we don't need to get into
`
` 10 that.
`
` 11 So now all we have left is the Markman and the
`
` 12 101 argument. So let me just ask the parties. Any
`
` 13 questions or anything else we need to take up before we
`
` 14 start with the Markman argument? I'll start with
`
` 15 Mr. Swain.
`
` 16 MR. SWAIN: Thank you, Your Honor. And I
`
` 17 appreciate your ruling.
`
` 18 One additional piece of guidance I think UEI
`
` 19 would appreciate is one of the types of documents that were
`
` 20 at issue are the agreements, the supply agreements between
`
` 21 these third parties and Roku. I wanted to make sure that
`
` 22 was part of your statement that these documents are ...
`
` 23 discovery. I just wanted to make sure that that was part
`
` 24 of the boundaries Your Honor just set forth
`
` 25 JUDGE ELLIOT: Yes. So let's do this...just a
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 13
`
`
` 1 moment ago at the end. We have a protective order, and we
`
` 2 do it in every case, it's robust, and we take it very
`
` 3 seriously. So it really isn't an issue that something is
`
` 4 coming from a third party, and that includes supply
`
` 5 agreements.
`
` 6 And on the question of relevance, it would seem
`
` 7 to me that supply agreements are at least facially within
`
` 8 the scope of discovery. I could be wrong about that, and
`
` 9 I'm willing to hear from Roku on that. But when I saw the
`
` 10 description of these documents, I thought, well, this very
`
` 11 clearly is the kind of thing that you would normally see in
`
` 12 discovery requests. So the answer is yes.
`
` 13 MR. SWAIN: Thank you, Your Honor. Nothing
`
` 14 further from Complainant.
`
` 15 JUDGE ELLIOT: All right. Mr. Baker, anything?
`
` 16 MR. BAKER: No, nothing further from Respondent
`
` 17 Roku. Thank you.
`
` 18 JUDGE ELLIOT: All right. Very good. So I
`
` 19 think we can get started, then.
`
` 20 I see that Ms. Boswell is the host and
`
` 21 Ms. Jackson is the presenter. Let's see. I think I can
`
` 22 move the presenter ball to Mr. Swain -- well, maybe not.
`
` 23 All right.
`
` 24 Ms. Jackson, would you please move the presenter
`
` 25 ball to Mr. Swain. Or Ms. Boswell. I think Ms. Boswell
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 14
`
`
` 1 might be able to do it actually.
`
` 2 All right. We seem to have lost our host. Give
`
` 3 me a moment here.
`
` 4 Here we go. Okay. Good. Okay. Mr. Swain. Go
`
` 5 ahead.
`
` 6 MR. SWAIN: I'm happy to report I will not have
`
` 7 the ball too long, Your Honor. I'm going to pass the ball
`
` 8 now to my colleague, Nick Tsui, who will be dealing with
`
` 9 the patent -- or the terms related to the Mui Patents.
`
` 10 So starting with key code signal, I will pass
`
` 11 the ball to Mr. Tsui now.
`
` 12 MR. TSUI: While I'm waiting for the ball, good
`
` 13 morning, Your Honor. This is Nick Tsui here from Alston &
`
` 14 Bird on behalf of Complainant UEI. I hope you can hear me
`
` 15 all right.
`
` 16 JUDGE ELLIOT: Yes, I can hear you.
`
` 17 MR. TSUI: I have some slides as well that I'll
`
` 18 go ahead and post up. Actually can people see that?
`
` 19 JUDGE ELLIOT: Yes, I can see that.
`
` 20 MR. TSUI: Okay. So if the slides are coming
`
` 21 through and everyone can hear me, I'll go ahead and start.
`
` 22 There are five terms that the parties dispute
`
` 23 that we're going to be talking about today and they relate
`
` 24 to four patents in total, but there are really only two
`
` 25 patent families at issue here.
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 15
`
`
` 1 So I'm going to be discussing the first patent
`
` 2 family, which has three of the disputed terms and then my
`
` 3 colleague, Steven Lareau, will take over for the other
`
` 4 patent family which has the last two terms.
`
` 5 So for my part the agenda, if you will, is that
`
` 6 I'll give a very quick introduction to the first family of
`
` 7 patents and then go to the disputed terms where the parties
`
` 8 will proceed [network interruption], and, when we're done
`
` 9 with those, I'll hand off to Mr. Lareau for our side.
`
` 10 Now the first three terms that we will discuss
`
` 11 all come from what we're calling the Mui Patent family,
`
` 12 that is, the '642 patent and the '325 patent. They're the
`
` 13 same patent family and the same single inventor, Daniel
`
` 14 Mui, and they have the identical specification.
`
` 15 The three terms that are in dispute are
`
` 16 highlighted on the slide. The first term is "key code
`
` 17 signal" in yellow, the second term is "key code generator
`
` 18 device," which is highlighted in green, and the third term
`
` 19 is a "means for" term that I have highlighted in red.
`
` 20 Now slide 4 here is just to try to put a little
`
` 21 context to how these claim terms generally fit together
`
` 22 just to help give Your Honor a little bit visually as to
`
` 23 what we're talking about here.
`
` 24 As shown in the figures on the slide, a user has
`
` 25 a device, a consumer electronic device such as a TV, that
`
`
`
`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 16
`
`
` 1 the user would like to control with a remote control. But
`
` 2 the remote control is not the remote control that came with
`
` 3 the TV. It may be a remote control that came with a
`
` 4 different device or even a universal remote control that
`
` 5 does not have the key codes to control the TV yet.
`
` 6 So when a user ... a remote, the remote control
`
` 7 sends a keystroke indicator signal to a key code generator
`
` 8 device, which is highlighted here in green. A key code
`
` 9 generator device then generates the key code using the key
`
` 10 code -- keystroke indicator signal that the remote control
`
` 11 sent.
`
` 12 Now key code and keystroke indicator signal are
`
` 13 both terms that the parties have already construed by
`
` 14 agreement. And that's in the briefing so I won't be
`
` 15 discussing very much about that.
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` 16 And so the key code generator device generates
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` 17 the key code by a two-step procedure. First it identifies
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` 18 the set of keys that work to control the TV in this case,
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` 19 which is called a codeset, and then, second, it identifies
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` 20 a key code from that codeset that corresponds to the key
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` 21 that was pressed on the remote.
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` 22 The key code is then sent back to the remote
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` 23 control and a key code signal, which is highlighted here in
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` 24 yellow.
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` 25 Now as shown in slide 5, the remote control has
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`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 17
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` 1 a "means for" receiving the key code that is in the key
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` 2 code ... and then the remote control has a means to send
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` 3 that key code to the TV to cause the TV to perform the
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` 4 function of the very first button that was pressed on the
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` 5 remote control.
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` 6 And that, at a high level, sums up one of the
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` 7 main embodiments of the Mui Patents and shows how these
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` 8 terms relate to one another. And it's important to note
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` 9 that the TV and what's shown here on the slide as a set-top
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` 10 box are just examples in this particular illustration. The
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` 11 key code generator device could be the TV, and then the
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` 12 consumer electronic device to be controlled could be a
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` 13 sound bar or a Blu-ray player or something like that. So
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` 14 there are variations here.
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` 15 And then one final point for this introduction
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` 16 is that the Mui Patents also have another main embodiment
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` 17 shown here on slide 6, where instead of sending the key
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` 18 code back to the remote control, the key code generator
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` 19 device just sends the key code directly to the consumer
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` 20 electronic device to control it that way.
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` 21 So the terms in dispute today are not
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` 22 necessarily limited to only one embodiment or one claim.
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` 23 Some of them appear in multiple claims, in multiple
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` 24 embodiments, and I'll point that out as we go along.
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` 25 Turning to the first term that is disputed, the
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`
`
`
`Heritage Reporting Corporation
`(202) 628-4888
`
`Universal Electronics Inc., Exhibit 2012
`Roku, Inc. v. Universal Electronics Inc., IPR2019-01612
`
`

`

`
`
` 18
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` 1 parties dispute the meaning of the term "key code signal,"
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` 2 which appears in both of the Mui Patents, the '642 patent
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` 3 as well as the '325 patent, and it's present in a number of
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` 4 the claims in those patents.
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` 5 For example, independent