Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`Invalidity of U.S. Patent No. 10,084,991
`by
`U.S. Patent No. 7,565,680 to Asmussen (“Asmussen”)
`
`
`The excerpts cited herein are exemplary. For any claim limitation, Defendant may rely on excerpts cited for any other limitation
`and/or additional excerpts not set forth fully herein to the extent necessary to provide a more comprehensive explanation for a
`reference’s disclosure of a limitation. Where an excerpt refers to or discusses a figure or figure items, that figure and any additional
`descriptions of that figure should be understood to be incorporated by reference as if set forth fully therein.
`
`Except where specifically noted otherwise, this chart applies the apparent constructions of claim terms as used by Plaintiff in its
`infringement contentions; such use, however, does not imply that Defendant adopts or agrees with Plaintiff’s constructions in any
`way.
`
`U.S. Patent No. 10,084,991 (“the ’991 Patent”) claims priority to Japanese Application No. 2008-246232, filed September 25, 2008.
`For purposes of these invalidity contentions, Defendant applies the Sep. 25, 2008, priority date for the ’991 Patent. However,
`Defendant reserves the right to contest Plaintiff’s reliance on the Sep. 25, 2008, priority date, should the priority date become an issue
`in this proceeding.
`
`U.S. Patent No. 7,565,680 to Asmussen (“Asmussen”) was filed on June 30, 2000. Asmussen therefore qualifies as prior art with
`regard to the ’991 Patent at least under 35 U.S.C. § 102(e) (pre-AIA).
`
`U.S. Patent No. 7,548,255 to Bear, et al. (“Bear”) was filed on September 30, 2003. Bear therefore qualifies as prior art with regard to
`the ’991 Patent at least under 35 U.S.C. § 102(e) (pre-AIA).
`
`U.S. Patent Application Publication No. 2007/0139514 to Marley (“Marley”) published on June 21, 2007. Marley qualifies as prior art
`with regard to the ’991 Patent at least under 35 U.S.C. §§ 102(a) and (b) (pre-AIA).
`
`U.S. Patent Application Publication No. 2003/0041333 to Allen, et al. (“Allen”) was published on February 27, 2003. Allen therefore
`qualifies as prior art with regard to the ’991 Patent at least under 35 U.S.C. §§ 102(a) and (b) (pre-AIA).
`U.S. Patent No. 7,046,268 to Saburi (“Saburi”) was published on May 16, 2006. Saburi therefore qualifies as prior art with regard to
`the ’991 Patent at least under 35 U.S.C. §§ 102(a) and (b) (pre-AIA).
`
`Asmussen anticipates or otherwise renders obvious claims 1-5 and 8-12 under 35 U.S.C. §§ 102 and 103(a).
`
`
`
`1
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`Apple v. Maxell
`IPR2020-00200
`Maxell Ex. 2013
`
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`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`Alternatively, Asmussen in view of Marley renders claims 1 and 8 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Asmussen in view of Saburi renders claims 1 and 8 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Asmussen in view of Bear renders claims 1 and 8 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Asmussen in view of any of Marley, Saburi, and/or Bear renders claims 1 and 8 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Asmussen in view of Allen renders claims 2-5 and 9-12 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Asmussen in view of Marley and further in view of Allen renders claims 2-5 and 9-12 obvious under 35 U.S.C.
`§ 103(a).
`
`Alternatively, Asmussen in view of Saburi and further in view of Allen renders claims 2-5 and 9-12 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Asmussen in view of Bear and further in view of Allen renders claims 2-5 and 9-12 obvious under 35 U.S.C. § 103(a).
`
`Alternatively, Asmussen in view of any of Marley, Saburi, and/or Bear and further in view of Allen renders claims 2-5 and 9-12
`obvious under 35 U.S.C. § 103(a).
`
`
`Asmussen
`
`To the extent the preamble is limiting, Asmussen discloses a communication apparatus for
`transmitting and receiving digital information to and from another communication apparatus.
`
` A
`
` set top terminal equipped with a camera and microphone includes the
`capability to send and receive video calls through a cable television delivery
`system or other communications networks. In response to detection of the
`occurrence of a video call event or triggering event, a video program is
`automatically paused. In response to an incoming video phone call, message,
`web page, or other video communications information, the system pauses the
`video program and displays an indication of the occurrence of the
`
`2
`
`U.S. Patent No. 10,084,991
`Claim 1
`[1(P)] A communication
`apparatus for transmitting and
`receiving digital information
`to and from another
`communication apparatus,
`comprising:
`
`
`
`
`Apple v. Maxell
`IPR2020-00200
`Maxell Ex. 2013
`
`Page 2 of 77
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`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`communications event. The system also buffers the video program while paused,
`permitting a user to replay missed portions of it.
`
`
`Asmussen at Abstract.
`
`The present invention is a set top converter box or terminal for a television
`program delivery system. More specifically, the present invention is an
`advanced set top converter box that acts as a terminal in the viewer's home. The
`set top terminal is a key component of a digital cable television delivery system.
`The set top terminal is an upgradeable system that provides for the
`decompression of digital program signals. The preferred set top terminal
`provides both a menu generation capability as well as a number of advanced
`features and functional capabilities.
`
`Asmussen at 3:20-30.
`
`
`Such features include the capability to send and receive video calls through the
`set top terminal equipped with a camera and microphone. The video call can
`be communicated through the cable television delivery system or other
`communications networks.
`
`Asmussen at 4:5-9.
`
`
`Still other such features include caller identification of video calls and dual
`display of video programs and video calls, such as picture in picture. The video
`call functionality can be built into a set top terminal or provided as a hardware
`upgrade to a set top terminal.
`
`
`Asmussen at 4:26-30.
`
`
`Additionally, the set top terminal 220 includes a camera input 666 and a
`microphone jack 667, by which a camera and microphone, respectively, can be
`
`
`
`3
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`IPR2020-00200
`Maxell Ex. 2013
`
`Page 3 of 77
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`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`connected. Alternatively, a camera and microphone can be built into the set top
`terminal 220.
`
`
`Asmussen at 16:34-37.
`
`Asmussen discloses a network interface configured to receive first digital information which is
`received from a contents server which is coupled to the communication apparatus via the network
`interface.
`
`
`In order to achieve the required throughput of video and audio information for
`the system, digital compression techniques for video are employed. As a result,
`the set top terminal 220 typically must decompress any digitally compressed
`program signals that it receives. Methods of decompression are a function of
`the compression technique used in the program delivery system.
`
`
`Asmussen at 23:64-24:3; see also id. at 6:48-7:22, Figs. 1-2.
`
`
`[1(a)] a network interface
`configured to receive first
`digital information which is
`received from a contents
`server which is coupled to the
`communication apparatus via
`the network interface
`
`
`
`
`FIG. 11 shows RF signals, depicted at 330, being received at by a data receiver
`332 and tuner 603 working in unison. Both of these devices are interfaced with
`the microprocessor 602, which receives inputs, depicted at 338, from the
`subscriber, either through the set top terminal's keypad 645 or remote control
`unit 900. All cable signals intended for reception on the subscriber's TV are
`accessed by the tuner 603 and subsequently processed by the processing
`circuitry 340. This processing circuitry 340 typically includes additional
`components for descrambling, demodulation, volume control and remodulation
`on a Channel 3 or 4 TV carrier.
`
`
`Asmussen at 26:1-11.
`
`
`Any received data includes information regarding channels and programs
`available for selection. The subscriber may enter a series of commands using
`the keypad 645 or remote control 900 in order to choose a channel or program.
`Upon receipt of such commands, the set top terminal's microprocessor 602
`
`4
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`IPR2020-00200
`Maxell Ex. 2013
`
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`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`instructs the tuner 603 to tune to the proper frequency of the channel or
`program desired and subsequently instructs the processing circuitry 340 to
`begin descrambling of this channel or program.
`
`
`Asmussen at 26:21-29.
`
`
`The set top terminal's microprocessor coordinates all CATV signal reception
`and also interacts with various upstream data transmission components 604,
`which have been described above.
`
`
`Asmussen at 26:60-63.
`
`
`The microprocessor 602 initiates and coordinates further decompression of the
`video, graphics and text for each of the program signals. Once these signal
`parts are decompressed within the set top terminal 220, these components are
`passed to a video combiner 316. The video combiner correlates and combine
`the video, graphics and text of the two program signals. The video combiner
`outputs these two signals for display on the subscriber's television.
`
`
`Asmussen at 33:26-33.
`
`
`
`Asmussen at 36:13-15.
`
`
`During this processing, the microprocessor 602 coordinates the demultiplexing
`of the programming signals.
`
`A set top terminal equipped with a camera and microphone includes the
`capability to send and receive video calls through a cable television delivery
`system or other communications networks. In response to detection of the
`occurrence of a video call event or triggering event, a video program is
`automatically paused. In response to an incoming video phone call, message,
`web page, or other video communications information, the system pauses the
`video program and displays an indication of the occurrence of the
`
`5
`
`
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`Apple v. Maxell
`IPR2020-00200
`Maxell Ex. 2013
`
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`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`communications event. The system also buffers the video program while paused,
`permitting a user to replay missed portions of it. Alternatively, the system waits
`for a triggering event, which includes the user's access to the communications
`event, in order to pause the video program. The set top terminal also includes
`features for caller identification of video calls and dual display of video
`programs and video calls, such as picture in picture. A hardware upgrade for
`adding video call functionality to a set top terminal is also disclosed.
`
`
`Asmussen at Abstract.
`
`
`The present invention is a set top converter box or terminal for a television
`program delivery system. More specifically the present invention is an
`advanced set top converter box that acts as a terminal in the viewer's home. The
`set top terminal is a key component of a digital cable television delivery system.
`The set top terminal is an upgradeable system that provides for the
`decompression of digital program signals.
`
`
`Asmussen at 3:20-27.
`
`
`As used herein, "video programs" include live or prerecorded programs from
`any source such as, for example, a broadcast television signal transmission, a
`cable television signal transmission, satellite television, video streaming over
`the Internet or other network, a VCR, a computer memory such as a hard disk
`CD-ROM, or digital versatile disk (DVD).
`
`
`Asmussen at 4:20-25.
`
`
`
`Asmussen at 6:65-7:3.
`
`Although concatenated cable systems 210 are the most prevalent transmission
`media to the home, telephone lines, cellular networks, fiberoptics, Personal
`Communication Networks and similar teleology for transmitting to the home
`can be used interchangeably with this program delivery system 200.
`
`
`
`6
`
`Apple v. Maxell
`IPR2020-00200
`Maxell Ex. 2013
`
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`

`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`
`
`
`
`7
`
`
`Asmussen at 14:14-23.
`
`
`It is preferred that the signal reaches the subscriber's home in a compressed
`format and is decompressed prior to viewing. Included in the delivered program
`signal is information that enables equipment at the subscriber's home to display
`menus for choosing particular programs. Depending on the particular
`embodiment, the television program signal may arrive at the subscriber's home
`through one or more connections such as coaxial cables, fiber cables, twisted
`pairs, cellular telephone connections, or personal communications network
`(PCN) hookups.
`
`The communication paths between the set top terminals 220e-220g are
`preferably wireless links, and in one embodiment the wireless links are RF links
`that utilize an RF transceiver in each of the set top terminals 220e-220g.
`Wireless infrared links are also possible. In alternate embodiments, the
`communication paths can be provided by wired networks, such as an existing
`data or computer network (e.g., LAN), existing television cabling, or existing
`home/building power wiring (as disclosed, for example, in U.S. Pat. No.
`5,319,634, which is hereby incorporated by reference). In any case, the channel
`linking the set top terminals 220e-220g is multiplexed to accommodate six
`unidirectional links that connect the three set top terminals 220e-220g in a fully
`meshed network. Although one skilled in the art will readily appreciate that
`many multiplexing schemes are possible, including TDMA (time division
`multiple access) and FDMA (frequency division multiple access), the
`multiplexing scheme preferably utilizes CDMA (code division multiple access),
`also termed SSMA (spread spectrum multiple access), techniques. Advantages
`of CDMA in this instance include security of transmissions and the fact that
`FCC (Federal Communication Commission) regulations might not apply to
`these transmissions. In one embodiment, an asynchronous direct sequence
`CDMA system with a common spreading code is utilized. Similar CDMA
`systems are well known and discussed, for example, in U.S. Pat. No. 5,103,459
`
`Apple v. Maxell
`IPR2020-00200
`Maxell Ex. 2013
`
`Page 7 of 77
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`

`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`and U.S. Pat. No. 5,546,381, both of which are hereby incorporated by
`reference.
`
`
`Asmussen at 51:37-64.
`
`
`FIG. 4 shows the basic hardware components of the set top terminal 220. The
`set top terminal 220 has a tuner 603, digital demodulator 606, decryptor 600,
`and demultiplexers 609, 616 as well as audio equipment 612 and a remote
`control interface 626 for receiving and processing signals from the remote
`control unit 900. An optional modem 627 allows communication between a
`microprocessor 602 and the cable headend 208. An NTSC encoder 625 provides
`a standard NTSC video output.
`
`
`Asmussen at 15:15-23.
`
`
`
`
`8
`
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`IPR2020-00200
`Maxell Ex. 2013
`
`Page 8 of 77
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`

`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`Asmussen at Fig. 4.
`
`Asmussen discloses receiving second digital information from the another communication
`apparatus, e.g., video of a called party.
`
`
`Such features include the capability to send and receive video calls through the
`set top terminal equipped with a camera and microphone. The video call can
`be communicated through the cable television delivery system or other
`communications networks.
`
`
`
`[1(b)] and second digital
`information from the another
`communication apparatus;
`
`
`
`
`
`9
`
`Apple v. Maxell
`IPR2020-00200
`Maxell Ex. 2013
`
`Page 9 of 77
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`

`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`Asmussen at 4:5-9.
`
`
`To support video calling, the instructions also enable the microprocessor 602
`to process video signals from a camera, to process audio signals from a
`microphone and to control a camera and microphone. The microprocessor 602
`may be a single microprocessor, as shown, or may be several microprocessors,
`such as a general microprocessor, a camera microprocessor and a microphone
`processor.
`
`
`Asmussen at 15:27-33.
`
`
`Additionally, the set top terminal 220 includes a camera input 666 and a
`microphone jack 667, by which a camera and microphone, respectively, can be
`connected. Alternatively, a camera and microphone can be built into the set top
`terminal 220.
`
`
`Asmussen at 16:34-38.
`
`
`FIG. 10 further depicts an optional camera interface 326 and an optional
`microphone interface 328 for connection with a camera 2000 and a microphone
`2002, respectively.
`
`
`Asmussen at 25:43-46.
`
`
`
`
`10
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`IPR2020-00200
`Maxell Ex. 2013
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`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`
`
`Asmussen at Fig. 10.
`
`
`11
`
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`IPR2020-00200
`Maxell Ex. 2013
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`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`
`
`12
`
`To support video calling capabilities, the remote control unit 900 preferably
`includes a call answer button (not shown) and a call hang up button (not
`shown). The call answer button and the call hang up button may be separate
`buttons or the same button. To support video calling with outgoing video, the
`remote control unit 900 preferably includes a camera activation button (not
`shown) and buttons or other controls for pointing the camera 2000. The cursor
`movement buttons 370 a joystick, a trackball or something similar can be used
`for camera pointing in a camera control mode.
`
`
`Asmussen at 31:39-46.
`
`
`Automatic Program Pause Feature
`An apparatus and method consistent with the present invention provides for
`automatically pausing of a video program in response to detection of an
`occurrence of a communications event or related triggering event. The term
`"communications event" includes any communication of information through
`any wireline or wireless medium, examples of which are provided below. The
`term "triggering event" includes a user's access to a communications event,
`examples of which are provided below. During the pausing, the video program
`is buffered such that a user may replay portions of it and perform other VCR-
`type functions of the program. In addition, the apparatus and method provide
`an indication of the communications event to the user by displaying, for
`example, text or graphics on a video display for the video program. For
`example, based upon detection of an incoming telephone call, the apparatus
`pauses the video program and displays an indication of the call overlayed on
`the paused video program or inset within it. This feature thus permits a user to
`automatically obtain an indication of a particular event while, at the same time,
`having the video program buffered such that portions of it are not missed, which
`is particularly useful for "live" video programs.
`
`Asmussen at 43:18-40.
`
`
`Apple v. Maxell
`IPR2020-00200
`Maxell Ex. 2013
`
`Page 12 of 77
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`

`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`As shown in FIG. 24d, detection of an incoming web page may result in display
`of a web page 1405. Web pages includes pages formatted, for example, in
`HyperText Markup Language (HTML) for transmission over the Internet using
`web browsers. Also, a user's access to the web page may constitute a triggering
`event, resulting in pausing and buffering of the video program. Many other
`types of triggering events are possible, involving a user's access to other types
`of communications events. Examples of other communications events include,
`but are not limited to, the following: a page to a pager number; an incoming
`cell phone call; an incoming facsimile transmission; an indication of a voice
`mail; or an incoming video call. Likewise, examples of other triggering events
`include, but are not limited to, the following: a user's access to a page to pager
`number; a user answering an incoming cell phone call; a user accessing or
`otherwise requesting to view an incoming facsimile transmission; a user's
`access to a pending voice mail message; a user's access to his or her personal
`web page; or a user's initiation of a video call.
`
`
`Asmussen at 44:1-19.
`
`
`Basic Video Call Functionality
`A preferred form of the present invention provides video calling capability in
`the set top terminal 220. To support video calling, the set top terminal 220 is
`augmented with additional features, as shown in FIG. 30. The additional
`features can be integrated into an enhanced set top terminal 220 or provided
`as one or more upgrades to a more basic set top terminal 220. In FIG. 30, a
`camera 2000 and an input device 704 are included in the set top terminal 220.
`The camera 2000 is preferably a small video camera located and oriented on
`the set top terminal 220 so that it is typically directed at the face, torso, or entire
`body of one viewing the display 602. The direction of pointing is preferably
`manually adjustable by the user. Alternatively or additionally, the camera 2000
`can be pointed, focused and otherwise controlled electronically.
`
`
`
`
`Asmussen at 49:41-56.
`
`
`13
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`IPR2020-00200
`Maxell Ex. 2013
`
`Page 13 of 77
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`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`In regards to reception, an incoming (i.e., downstream) video conferencing
`signal is received by a receiver 750, decoded by a channel decoder 755,
`decrypted by a decryptor 760, and demutliplexed with proper relative timing
`among video, audio and other data components by a demultiplexer
`synchronizer 765. Video signals are decompressed by a video source decoder
`770 and output for display on a display device 602, which is typically the
`television 222. Audio signals are decompressed by an audio source decoder 775
`and output for playing on the speaker/microphone 2002, the speaker portion of
`which may be the speaker(s) of the television 222 Data files, such as electronic
`books, are stored in one or more files 777. Again, the order of processing can
`be different from that illustrated.
`
`
`Asmussen at 50:44-57.
`
`
`Each of the set top terminals 220 participating in a video conference call
`broadcasts its audio/video signal(s), and any set top terminals 220 that receives
`the signal(s) performs the necessary processing to output the audio and video
`components in combination with those of other received signal(s).
`
`
`
`
`Asmussen at 52:20-25.
`
`Asmussen discloses a camera configured to generate video information which is included in third
`digital information. For example, Asmussen’s video and audio source encoders 705 and 710
`respectively perform the encoding/decoding of the video and audio. Asmussen at 50:18-31.
`
`
`
`[1(c)] a camera configured to
`generate video information
`which is included in third
`digital information;
`
`
`
`
`14
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`IPR2020-00200
`Maxell Ex. 2013
`
`Page 14 of 77
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`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`Asmussen at Fig. 30.
`
`
`FIG. 30 is a block diagram of video call transmission and reception functions
`of the set top terminal 220. In regards to transmission, a video signal from the
`camera 2000 is subjected to source encoding (i.e., conversion to spectrally
`efficient or compressed digital form) by a video source encoder 705, and an
`audio signal from the speaker/microphone 2002 is subjected to source encoding
`
`15
`
`
`
`
`
`Apple v. Maxell
`IPR2020-00200
`Maxell Ex. 2013
`
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`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`by an audio source encoder 710. The source encoded video and audio signal
`are synchronized and multiplexed together by a synchronizer multiplexer 715.
`The video source encoder 705, audio source encoder 710 and the synchronizer
`multiplexer 715 together can function to perform standard audio/visual
`encoding algorithms such as MPEG (motion picture expert group) or ITU
`standard H.261 or H.263, which are well known in the art.
`
`
`Asmussen at 50:18-31.
`
`
`
`
`A preferred form of the present invention provides video calling capability in
`the set top terminal 220. To support video calling, the set top terminal 220 is
`augmented with additional features, as shown in FIG. 30. The additional
`features can be integrated into an enhanced set top terminal 220 or provided
`as one or more upgrades to a more basic set top terminal 220. In FIG. 30, a
`camera 2000 and an input device 704 are included in the set top terminal 220.
`The camera 2000 is preferably a small video camera located and oriented on
`the set top terminal 220 so that it is typically directed at the face, torso, or entire
`body of one viewing the display 602. The direction of pointing is preferably
`manually adjustable by the user. Alternatively or additionally, the camera 2000
`can be pointed, focused and otherwise controlled electronically.
`
`
`Asmussen at 49:43-56.
`
`
`A set top terminal 220 performs signal processing associated with the
`transmission and reception of call content. In regards to transmission, the audio
`signal sensed by the speaker/microphone 2002 is converted to digital form and
`compressed. For Voice or speech audio, the following families of algorithms
`are particularly Suitable: pulse code modulation (PCM), delta modulation
`(DM) and linear predictive coding (LPC). Each of the above families of
`algorithms includes variations, such as differential and adaptive variations.
`Similarly, the video signal sensed by the camera 2000 is converted to digital
`form and compressed. The fundamental techniques for image compression
`include vector quantization, discrete cosine transforms, and run-length
`
`16
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`IPR2020-00200
`Maxell Ex. 2013
`
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`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`encoding. Combinations of these techniques are also possible. For video
`sequences of images, interframe encoding based on motion prediction can be
`applied to provide further compression gains. These techniques as well as
`others are utilized in standard video compression algorithms, including low-
`rate MPEG and ITU Standard H.261 and H.263 for video conferencing, which
`are well known in the art. Any compression algorithm that produces acceptably
`low bit rates for video and/or audio transmission through the network and can
`be implemented in real time with acceptably Small delay is Suit able for use
`with the present invention. Encoding of video and audio may be distinct or
`interrelated. By way of example, MPEG is a combined standard for both video
`and audio. These and other features are disclosed in additional detail in the 128
`patent.
`
`
`Asmussen 55:56-56:16.
`
`Alternatively, Bear discloses a camera.
`
`
`A system and method for improved video capture on a personal computer is
`provided. The personal computer is equipped with video controls and a camera
`with a privacy lens cover. A sensor for sensing when the lens cover is closed
`may be used along with an actuator for mechanically opening the lens cover,
`so that the system may optionally open the lens cover automatically for video
`capture applications. A user may easily capture a video stream or still images
`using the video controls provided. A user may also answer an incoming phone
`call that supports video by pressing the camera button or, optionally, the user
`can set a preference so that the camera is automatically enabled whenever
`answering a call that supports video. Additionally, the system may
`automatically transition to or from video anytime during a call.
`
`
`Bear at Abstract.
`
`
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`17
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`Apple v. Maxell
`IPR2020-00200
`Maxell Ex. 2013
`
`Page 17 of 77
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`

`

`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`
`Bear at Fig. 3.
`
`
`
`
`As generally represented in FIG. 3, the camera 202 coupled to the computer
`system 110 may include a microphone 302, a lens 304, a camera indicator light
`306, a video capture button 308, a lens cover 310, a sensor 312, and an actuator
`314. The capture button 308 may be located on the body of the camera where
`the right index finger normally rests while manually aiming the lens. Its
`behavior may vary and depends on the controlling software that is running
`when it is pressed. While an audio/video (A/V) capture application is executing,
`pressing the capture button 308 usually triggers an image or video stream
`capture, depending on the mode setting.
`
`Because the state of the capture button 308 may not be readily apparent to a
`user, a camera indicator light 306 such as an LED may be used in conjunction
`
`18
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`
`Apple v. Maxell
`IPR2020-00200
`Maxell Ex. 2013
`
`Page 18 of 77
`
`

`

`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`with the capture button 308. The camera indicator light 306 may be adjacent
`the camera lens 304 or integrated into the capture button 308. The camera
`indicator light 306 may indicate state via various colors and flash patterns, e.g.,
`steady state unlit when the camera is off, steady state red when video capture is
`taking place, a slowly blinking red indicator light when there is an incoming
`video call, or steady state green when the camera is used for proximity
`detection. Note that although video-capable applications can set this indicator
`to a particular color such as red when recording, the firmware may additionally
`ensure the indicator is set to red if the camera is actively streaming video.
`
`
`Bear at 7:35-60.
`
`Bear teaches the camera generates video information.
`
`
`
`
`
`
`Briefly, the present invention provides a system and method for capturing and
`otherwise working with video on a personal computer. In one implementation,
`the present invention provides a camera that may include a microphone, a lens,
`a camera indicator light, a video capture button, and a lens cover that acts as
`a safeguard against inadvertent video recording or damage to the lens. In
`another implementation, a sensor for determining when the lens cover is closed
`may be used, along with an actuator for mechanically opening the lens cover,
`so that the system may optionally open the lens cover automatically for video
`capture applications. The actuator may be controlled by a button such as a
`shutter button or may be controlled by system software. Closing the lens cover
`secures active capture operations and, for example, may close an audio/video
`capture application. Opening the lens cover prepares the camera for capture,
`and may stream preview video to the audio/video capture application.
`
`
`Bear at 2:14-30.
`
`
`The present invention allows different types of video to be captured. For
`example, an audio/video application may capture a video stream or still images.
`If a user has selected still images to be captured, the audio/video application
`
`19
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`Apple v. Maxell
`IPR2020-00200
`Maxell Ex. 2013
`
`Page 19 of 77
`
`

`

`Defendant’s Invalidity Contentions
`Exhibit E2
`
`
`may set the camera capture indicator light to green to indicate that the
`application is in preview mode. A user may conveniently snap a still image by
`pressing the capture button. The application may then set the camera capture
`indicator light to blink red for a few moments while the image is captured. After
`the image has been captured, the application may display a confirmation dialog
`box to the user to allow for saving the image.
`
`
`Bear at 2:47-57.
`
`
`A user who wishes to capture a video stream opens the lens cover 310, whether
`manually or by pressing an actuator button that opens the lens cover 310.
`Before capture of a video stream occurs, the system is in the Stopped 902 state.
`Whenever a capture event is received and the shutter 310 is open, the system
`transitions to the Capturing 904 state and the camera begins capturing a video
`stream. In one embodiment, the shutter may only be opened by the user for
`privacy reasons. In this case, the user may press the shutter button 404 to open
`the lens cover or manually move the lens cover to expose the lens. In another
`embodiment, the lens cover may be automatically opened whenever a capture
`event occurs. A capture event occurs whenever the user presses the capture
`button 308 while in the Stopped state 902. It will be appreciated by those skilled
`in the art that there are other ways of generating a capture event, such as
`opening the shutter 310, pressing the record button within the transport
`controls of FIG. 7, selecting a menu item using a graphical user interface, and
`so forth. In yet a third embodiment, image analysis software may sense when
`the lens is uncovered or covered by any way known to those skilled in the art,
`including detecting the amount of light received through the camera lens. When
`the images analysis software senses that the lens is uncovered, a capture event
`is generated. For example, the image analysis software may determine that
`sufficient light is being received through the camera lens, a