Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 1 of 28 PageID: 2022
`
`to Declaration of Katherine Harihar
`in Support of Plaintiff’s Supplemental
`Claim Construction Brief
`
`Roku EX1034
`Roku v. Universal Electronics
`IPR2019-01614
`
`

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`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 2 of 28 PageID: 2023
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`
`
`
`TVnGO LTD. (BVI),
`
`Plaintiff,
`
`v.
`
`LG ELECTRONICS INC. and
`LG ELECTRONICS U.S.A., INC.,
`
`Defendants.
`
`Civil Action No. 1:18-cv-10238-RMB-KMW
`
`
`
`
`SUPPLEMENTAL DECLARATION OF MICHAEL SPRENGER, Ph.D.
`IN SUPPORT OF PLAINTIFF’S SUPPLEMENTAL CLAIM CONSTRUCTION BRIEF
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`

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`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 3 of 28 PageID: 2024
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`1.
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`2.
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`I, Michael Sprenger, Ph.D. hereby declare as follows:
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`I have been retained on behalf of Plaintiff TVnGO. I am being compensated at the
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`rate of $325 per hour. My compensation is in no way dependent on the outcome of this litigation.
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`I understand that this declaration is being submitted with Plaintiff’s Supplemental Claim
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`Construction Brief.
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`3.
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`I have been asked to provide my opinion regarding how a person of ordinary skill
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`in the art (POSA) would have understood certain terms and phrases of U.S. Patent Nos.
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`8,132,220 (“the ’220 patent”); 9,124,945 (“the ’945 patent”); 9,392,339 (“the ’339 patent”);
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`9,407,969 (“the ’969 patent”); 9,794,621 (“the ’621 patent”) (collectively, “the Asserted
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`Patents”).
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`I.
`
`MATERIALS CONSIDERED
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`4.
`
` In reaching the conclusions set forth below, I have considered the materials
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`mentioned in my opening and responsive declarations, as well as both parties’ opening and
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`responsive claim construction briefs, the declarations of W. Leo Hoarty, and the transcript of the
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`Markman hearing held on January 8, 2020.
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`II.
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`ANALYSIS
`
`A.
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`5.
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`“overlay activation criterion” (Term 1)
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`As I set forth in my previous declarations, the Asserted Patents are clear regarding
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`what an overlay activation criterion is and a POSA would understand this term in view of the
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`specification, figures, and claims of the patent.
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`6.
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`A basic overview of the general path of overlay-enabling digital data is described
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`below, using timing and channel information as a simple example of overlay activation criteria
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`for clarity.
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`7.
`
`An IP content provider creates the overlay-enabling digital data. See, e.g., ’220
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`1
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`

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`Patent at 3:57-4:5; FIG. 2. According to the claim language of, e.g., the ’220 Patent, the overlay-
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`enabling digital data includes at least: a Web link indicating a website where content that is
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`associated with said overlay-enabling digital data is stored; an image indicative of the content
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`associated with said overlay-enabling digital data; and an overlay activation criterion. See ’220
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`Patent at Claim 1, 13. A basic representation of the overlay-enabling digital data is shown below
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`with the overlay activation criterion including at least timing and channel information. In this
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`example, timing information relates to specific time slots during which the overlay (or IP
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`content) should be displayed on the user’s TV screen (e.g., between the hours of 19:30-21:30),
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`and channel information relates to the specific channels the overlay is to be displayed on. This is
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`described in the patents at column 7:51-8:5 of the ’220 patent, by way of example. Below, the
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`exemplary overlay-enabling digital data (OEDD) is placed next to the advertiser (as shown on
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`FIG. 1 of the patents). The advertiser is an IP content provider as described in the patents.
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`
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`8.
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`The IP content provider, in FIG. 1, an advertiser, “interfaces with the web server
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`[14] for creating IP content and associating therewith calendar and program data indicating dates,
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`times and channels in respect of which IP content is to be streamed to the customer premises.”
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`2
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`

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`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 5 of 28 PageID: 2026
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`See ’220 Patent at 4:6-18. Below, I depict how the overlay-enabling digital data is provided to
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`the web server 14 (also referred to as the “provider server”) via the Internet.
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`
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`9.
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`The web server 14 also communicates with the database 19, and database 19 can
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`receive and store overlay-enabling digital data. The database 19 includes an event timetable
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`(shown below on the next figure), as well as associated TV channels that can be updated from
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`time to time. See ’220 Patent at 4:6-18; FIGS. 1, 2.
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`10.
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`As depicted below, I show an example where the database 19 has received
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`overlay-enabling digital data from three different IP content providers with different overlay
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`activation criteria comprising timing and channel information for each particular overlay from
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`the three IP content providers. The event timetable stored in the database 19 indicates on what
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`channels and at what times the overlay-enabling digital data are to be streamed to a user based on
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`each respective overlay activation criterion. For instance, OEDD 1 is to be streamed on all
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`channels at all times, OEDD 2 is only to be streamed on Channel 3 beginning at 7:00 and 8:00
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`PM, and OEDD 3 is only to be streamed on Channel 4 beginning at 7:00 and 9:00 PM.
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`3
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`

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`
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`11.
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`The web server 14 then monitors events, such as time and channel information,
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`and when appropriate, the web server extracts from the database 19 the stored overlay-enabling
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`digital data “for streaming over the Internet 15 to the TV-Internet Integration Box 16.” See ’220
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`Patent at 4:6-18; FIGS. 1, 2. This is depicted below. For instance, the web server might send
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`OEDD 1 to all users on all channels and OEDD 2 only to users viewing Channel 3 at 7:00 and
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`8:00 PM.
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`4
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`

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`12.
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`As depicted below, overlay-enabling digital data is received by the TV-Internet
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`Integration Box. In the most basic situation where there is no other information from the user
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`regarding preferences for IP content, or specific times or channels to view content (e.g., all times
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`
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`5
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`

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`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 8 of 28 PageID: 2029
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`and all channels are available), the TV-Internet Integration Box checks its own timetable stored
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`in memory (see, e.g., ’220 Patent at 4:28-32), determines whether the overlay activation criteria
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`is met (e.g., confirming that the user is watching Channel 3 at 7:00 PM which would match the
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`overlay activation criteria embedded in OEDD 2), and the TV-Internet Integration Box combines
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`the overlay-enabling digital data with the TV video signal received at the first input, outputting
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`the combined video signal to the TV set. See ’220 Patent at 4:19-49; FIG. 3; FIG. 5. As shown
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`below, the overlay-enabling digital data (OEDD 2) is received at the second input of the
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`combiner circuit from the Internet, and the image included with the overlay-enabling digital data
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`is overlaid, or visually combined, with the first data, e.g., a TV video signal. A new output video
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`signal combining the TV video signal and the image overlaid over the TV video signal is output
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`to the TV screen. The image displayed on the screen is directly associated with the other overlay-
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`enabling digital data, namely the web link and overlay activation criteria.
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`13.
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`Once the image is overlaid over the TV video signal, the user can interact with the
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`image and its associated overlay-enabling digital data to cause the system to retrieve the content
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`
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`6
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`

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`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 9 of 28 PageID: 2030
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`associated with the image from the web link. For example, the user can use a remote control to
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`send a signal (i.e., an overlay activation signal) to the TV-Internet Integration Box instructing it
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`to follow the web link (Web Link 2) associated with the displayed image (Image 2) to display the
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`IP material associated with the displayed image.
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`14.
`
`As shown below, a POSA would understand the following steps to occur in
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`combining the TV video signal and overlay-enabling digital data to result in the new combined
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`video signal.
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`15.
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`For simplicity, in this example I show the overlay-enabling digital data as just an
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`image, i.e., the Best Buy® logo. In practice, and as described in the Asserted Patents, the image
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`would also include the other overlay-enabling digital data (e.g., web link and overlay activation
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`criterion) as described earlier. The figures below are based on Figure 5 of the patents, with only
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`relevant portions included for simplicity and clarity. In a first step, the overlay gets retrieved
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`from the Internet:
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`
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`7
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`

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`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 10 of 28 PageID: 2031
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`16.
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`The overlay gets stored in memory for later use:
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`17. When the time comes to generate (or display) the overlay as part of the combined
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`video to the TV screen, the overlay gets retrieved from memory:
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`8
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`

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`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 11 of 28 PageID: 2032
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`18.
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`The combiner circuit combines the TV video signal with the overlay to generate a
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`new video signal:
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`19.
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`The new combined video signal gets sent to the display:
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`20.
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`The above examples involved two overlay activation criteria: time and channel.
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`However, the overlay-enabling digital data can include various embedded data as overlay
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`activation criteria, including for instance, data corresponding to user command information. A
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`user command information is information generated or input into the system by the user. For
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`9
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`instance, if we refer back to the advertiser example above, a user command information might be
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`a user setting for particular content, e.g., electronics advertisements. While the time and channel
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`overlay activation criteria of the overlay-enabling digital data may be met automatically by
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`matching the user’s time and channel conditions (which are known by the system), the user
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`might also provide settings for content (e.g., show me electronics advertisements, but not food
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`advertisements). The user can enter these settings via the user interface 27 of the TV-Internet
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`Integration Box, or via the user interface 32 on the remote control. See ’220 patent at FIG. 5, 6. If
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`such information is provided by the user, it can be matched against overlay activation criteria
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`embedded in the overlay-enabling digital data, if they exist, corresponding to such settings as
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`described above with respect to channel and timing information. For instance, separate from time
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`and channel information, the overlay-enabling digital data provided by IP data provider, the
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`advertiser, might also include information indicating that it is an advertisement for a particular
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`consumer electronics company. If the user has indicated a setting to receive advertisements from
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`electronics companies, or advertisements from particular electronics companies, then such user-
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`generated information can be matched against the overlay activation criteria within the overlay-
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`enabling digital data.
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`21.
`
`This is depicted, by way of example, in the figure below. In this example, the IP
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`data provider (Best Buy®) has provided overlay-enabling digital data including a web link, an
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`image, and overlay activation criteria concerning: timing information (the overlay is to be
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`streamed beginning 5PM until 9PM); channel information (the overlay is to be streamed on all
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`channels); type of content (the overlay is an advertisement); substance of content (the overlay is
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`regarding electronics); who the IP data provider is (the overlay is from Best Buy®); and
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`language (the overlay is in English). Similarly, the user has provided the system, via the remote
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`10
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`

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`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 13 of 28 PageID: 2034
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`control, information and settings concerning, for example, user name and location (Jane Smith in
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`Atlanta, GA), as well as user settings for overlays regarding advertisements or other IP content,
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`including: whether to show overlays directed to advertisements (show ads); when to show
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`advertisement overlays (show ads after 5PM); on what channels to show advertisement overlays
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`(show ads all channels); types of advertisement overlays to show (for food, sports, and
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`electronics); and other types of overlays that can be shown (show game overlays or sign
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`language overlays). The system determines whether overlay activation criteria from the overlay-
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`enabling digital data match settings within the user-provided information, and if the information
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`matches, the overlay is generated. For example, in the below, four overlay activation criteria with
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`thicker borders were found to match specific user settings: overlay activation criterion
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`“advertisement” matches user setting “show ads”; overlay activation criterion “5PM-9PM”
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`matches user setting “show ads after 5PM”; overlay activation criterion “all channels” matches
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`user setting “show ads all channels”; and overlay activation criterion “electronics” matches user
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`setting “show ads for electronics.” See ’220 patent at 4:19-49; FIG. 3, 5, 6. Because conditions
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`match, the overlay is sent to this particular user.
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`11
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`

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`22.
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`All of this is done by the components of FIG. 5. The overlay-enabling digital data
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`is provided to the system via the second input, and information from the user is provided to the
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`system through the user interface or remote control, and stored in memory. See ’220 patent at
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`FIG. 5, 6.
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`23.
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`A POSA would understand that when the Asserted Patents refer to overlays being
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`stored in memory, the overlays are stored in memory and rendered on the TV screen as images or
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`other IP material.
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`24.
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`A POSA would understand an overlay, as used in the Asserted Patents and as I
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`described in my previous declarations, to refer to second data (IP data or material) superimposed
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`over first data (TV video).
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`B.
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` “overlay activation signal” (Term 5a), and “special overlay activation
`signal” (Term 5b)
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`25.
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`Based on the context of the patents, a POSA would understand that an overlay
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`activation signal can be used to generate an overlay. A POSA would also understand that an
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`overlay activation signal can be used to select an overlay to generate an overlay of IP material
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`associated with the selected overlay.
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`26.
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`A POSA would understand the ways that an overlay activation criterion can be
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`satisfied or used. For instance, as shown below, the overlay activation criterion can be used to
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`generate a signal (e.g., once the overlay activation criterion is met, a signal gets generated).
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`12
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`27.
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`A signal can also be used to satisfy an overlay activation criterion (e.g., an
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`overlay activation criterion can be met when a signal is received).
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`28.
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`A signal can be generated by hardware, or a combination of both hardware and
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`software. Some examples of signals include: a signal from a remote control; a signal from a
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`13
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`

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`video output circuit to a TV; or a signal that tells hardware and/or a combination of both
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`hardware and software to generate an overlay.
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`C.
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`29.
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`“combiner unit” (Term 6), “combiner circuit” (Term 7)
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`As I mentioned in my Opening Declaration, I understand from counsel that courts,
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`specifically the Federal Circuit, have relied on certain technical dictionaries to determine the
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`structure of the term “circuit,” including The Dictionary of Computing 75 (4th ed. 1996), which
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`defines “circuit” as “the combination of a number of electrical devices and conductors that, when
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`interconnected to form a conducting path, fulfill some desired function.” I continue to agree with
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`this definition and it is consistent with and supports my opinion.
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`30.
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`A chip (also called microchip or integrated circuit) is a term used by a POSA in
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`describing a circuit that integrates many components into a single device, also referred to as
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`integrated circuit.
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`31.
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`The combiner unit/circuit of the TVnGO patents is a combiner that merges a TV
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`signal and Internet content and creates a new video signal, in which Internet content is
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`superimposed, or overlaid, on top of TV content.
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`32.
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`By the time these signals reach the combiner unit, they have undergone any
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`processing that needs to occur in order for the combiner unit to combine the signals. Such
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`processing could include, but is not limited to, e.g., analog to digital video conversion. Any such
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`processing needed before the combination would be readily understood by a POSA.
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`33.
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`As I indicated in my previous declarations, the terms “unit” and “circuit” (as in
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`“combiner unit” and “combiner circuit”) are interchangeable in this context – they are one and
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`the same. I have personally used the terms interchangeably and a POSA would do the same.
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`34.
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`As I described at the hearing, I have inspected certain of the TVnGO set-top
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`boxes. I understand that the TVnGO set-top boxes that I inspected were manufactured and used
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`14
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`by customers as part of the pilot program TVnGO undertook in Israel as discussed at the hearing.
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`I have also extensively reviewed the datasheets and additional technical information associated
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`with the key components used in the TVnGO set-top box hardware made available to me. Based
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`on my research and analysis, I have concluded that all of the components were:
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`a. Standard components used throughout the industry.
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`b. Widely used in similar kinds of devices (e.g., set-top boxes for cable, satellite, and
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`telecom)
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`c. Widely used in other kinds of devices (e.g., computers, media players, interactive
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`displays)
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`d. Readily available in large quantities at the time the first patents were being filed
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`(2005), with some parts available as far back as 1997.
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`e. Extensively documented with comprehensive datasheets and application notes.
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`f. No “magic components” that may have been hard to source.
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`35.
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`Additional information regarding the components used in the TVnGO products is
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`attached as an Appendix to this declaration.
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`36.
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`The combiner circuits chosen by TVnGO’s designers are able to combine video
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`signals with content obtained from the Internet (e.g., graphics, text, video), as detailed in
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`datasheets that are provided by the manufacturer of the circuits.
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`37.
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`The TVnGO designers had a choice of components to implement the inventions
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`described in the TVnGO patents. These were not unique or special electronic components. In all
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`cases, a range of components was available for the designers to choose from.
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`38.
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`All components required to practice the patent were readily available prior to
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`2005.
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`15
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`39.
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`Based on my analysis, the chips used in the TVnGO set-top boxes were very
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`logical and natural choices.
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`40.
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`The specification and figures provided in the patents are sufficient for a POSA to
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`implement TVnGO’s invention to create a product based on the patents.
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`41.
`
`In my 30 years of working as an engineer, in both research as well as industry
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`environments, block diagrams (such as those used in the TVnGO patents) have always been a
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`very natural way of conveying the basic principles of a design.
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`42.
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`The specification and figures provided in the patents all make sense to someone
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`skilled in the art. In my opinion, a POSA would readily understand:
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`a. What kind of components would be needed to implement the patented inventions;
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`b. What role and purpose the components would have; and
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`c. How the components would be connected together.
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`43.
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`For example, one aspect of the patents I find particularly noteworthy is the
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`double-wide arrow shown in Figure 5. This is very meaningful to someone skilled in the art and
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`provides essential information. For example:
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`a. It indicates a symbiotic relationship between the combiner unit and processing
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`unit;
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`b. It is clear to someone skilled in the art that the combiner unit and processing unit
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`are very closely coupled in terms of how they work together; and
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`c. It indicates a very high bandwidth connection where a lot of information and
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`signals are being exchanged between the combiner unit and processing unit.
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`16
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`44.
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`I confirm my understanding that a person skilled in the art would know what kind
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`of components are needed to implement the architecture and know how to build a set-top box,
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`based on the information available in the TVnGO patents.
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`45.
`
`To build a set-top box based on the TVnGO patents does not require extensive
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`experimentation, but rather routine development efforts. Reading the patent, it is straightforward
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`what the basic building blocks are and how to build a device like this.
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`46.
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`In my opinion, a POSA would have the same level of knowledge and familiarity
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`with these building blocks. In my career as an electrical engineer, I have worked on designs
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`using some of the same and/or similar chips as are in the TVnGO set-top boxes (e.g., Intel
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`processors, Ethernet network chips, memory). While working in the telecom industry, myself
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`and my colleagues have also worked on design specifications for our own suppliers, using very
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`similar chips (e.g., processor, memory, network interfaces).
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`17
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`I declare under the penalty of perjury under the laws of the United States that
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`the
`
`foregoing is true and correct.
`
`4
`
`, 2020
`
`Dated: February
`
`L (ee @)
`
`
`Michael Sprenger, Ph.D.
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`

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`APPENDIX
`PP D
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`

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`TVnGOSet-Top Box Hardware and
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`Circuit Analysis
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`

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`2
`
`2nd
`
`1st
`
`2005
`
`2002
`
`82854 GMCH
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`CLE266
`
`Intel
`
`VIA
`
`Combiner Unit/Circuit
`
`Combiner Unit/Circuit
`
`Box Generation
`Used in Set-Top
`
`Year available
`
`Model
`
`Manufacturer
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`Component
`
`Chip overview
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`

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`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 24 of 28 PageID: 2045
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`motherboard of TVnGO
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`VIA CLE266 chip on
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`(heatsink removed)
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`set-top box
`
`Figure 5 in ‘220 patent
`
`•Chip model: CLE266
`•Manufacturer: VIA Technologies
`
`3
`
`•Small, low-cost computers
`•Video conferencing
`•Video streaming
`•Set-top boxes, media players, DVD players
`•Digital video playback
`
`•Numerous and broad applications:
`•Many companies used this chip
`•Industry standard interfaces
`
`•Implemented using a widely available, well
`•Available in 2002
`Combiner Unit in 1stGeneration TVnGO Set Top Box
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`documented chip (integrated circuit)
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`

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`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 25 of 28 PageID: 2046
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`4
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`•Video outputs
`•Extensive graphics blending capabilities
`•Overlay support
`•Multiple video inputs
`
`•Combining graphics
`•Access to Internet (via companion chip)
`•Access to memory
`
`•This chip can handle all of the functionality outlined in the patent:
`features
`Combiner Unit in 1stGeneration TVnGO Set Top Box: chip
`
`

`

`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 26 of 28 PageID: 2047
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`Second Input (22)
`
`First Input (21)
`
`Video Output (24)
`
`(FSB = Front Side Bus)
`in Fig. 5: 
`Double-wide arrow
`
`[source: VIA technical documentation]
`(auxiliary circuitry omitted for simplicity)
`VIA CLE266 chip diagram
`
`5
`
`Figure 5 in ‘220 patent
`
`Memory (26)
`
`Combiner Unit (23)
`
`Processing Unit (25)
`
`diagram
`Combiner Unit in 1stGeneration TVnGO Set Top Box: block
`
`

`

`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 27 of 28 PageID: 2048
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`top box (heatsink removed)
`motherboard of TVnGOset-
`
`Intel 82854 chip on
`
`Figure 5 in ‘220 patent
`
`6
`
`•Chip model: Intel 82854
`•Manufacturer: Intel
`•Fast memory access
`•Interface to matched CPU (Celeron M)
`
`•Extensive support for blended graphics and video
`
`•Integrated graphics engine
`
`•Video game consoles
`•Digital Media Recorder devices (DMR)
`•IP-Digital Set Top Boxes
`
`•Designed as a building block for consumer electronics platforms:
`•Available in 2005
`Combiner Unit in 2ndGeneration TVnGO Set Top Box
`
`

`

`Case 1:18-cv-10238-RMB-KMW Document 75-2 Filed 02/03/20 Page 28 of 28 PageID: 2049
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`7
`
`•Video outputs
`•Extensive graphics blending capabilities
`•Overlay support
`•Multiple video inputs (via shared memory)
`
`•Combining graphics
`•Access to Internet (via companion chip)
`•Access to memory
`
`•This chip can handle all of the functionality outlined in the patent:
`features
`Combiner Unit in 2ndGeneration TVnGO Set Top Box: chip
`
`