Defendant’s Invalidity Contentions
`Exhibit C4
`
`
`Invalidity of U.S. Patent No. 7,116,438
`by
`Japanese Unexamined Patent Application Publication JP 2003-6110 to Yamazaki (“Yamazaki ’110”)
`
`
`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. 7,116,438 (“the ’438 Patent”) claims priority to Japanese Application No. 2003-144259, filed May 22, 2003. For
`purposes of these invalidity contentions, Defendant applies the May 22, 2003, priority date for the ’438 Patent. However, Defendant
`reserves the right to contest Plaintiff’s reliance on the May 22, 2003, priority date, should the priority date become an issue in this
`proceeding.
`
`Yamazaki ’110 published on Jan 10, 2003. As such, Yamazaki ’110 qualifies as prior art with regard to the ’438 Patent under 35 U.S.C.
`§ 102(a) (pre-AIA). Using Plaintiff’s interpretation of the claims, Yamazaki ’110 anticipates claims 1-7 under 35 U.S.C. § 102(a).
`
`Alternatively, Yamazaki ’110 renders obvious claims 1-7 under 35 U.S.C. § 103(a).
`
`Alternatively, Yamazaki ’110 in view of Japanese Unexamined Patent Application Publication JP 2003-22227 to Nagano (“Nagano
`’227”) renders obvious claims 1-7 under 35 U.S.C. § 103(a). Nagano ’227 published on Jan 24, 2003. As such, Nagano ’227 qualifies
`as prior art with regard to the ’438 Patent under 35 U.S.C. § 102(a) (pre-AIA).
`
`Alternatively, Yamazaki ’110 in view of U.S. Patent No. 7,340,214 to Hamberg (“Hamberg ’214”) renders obvious claims 1-7 under
`35 U.S.C. § 103(a). Hamberg ’214 was filed on Feb 13, 2002. As such, Hamberg ’214 qualifies as prior art with regard to the ’438
`Patent under 35 U.S.C. § 102(e) (pre-AIA).
`
`
`
`
`
`
`1
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`Defendant’s Invalidity Contentions
`Exhibit C4
`
`Alternatively, Yamazaki ’110 in view of U.S. Patent Application No. 2003/0149874 to Balfanz, et al. (“Balfanz ’874”) renders obvious
`claims 1-7 under 35 U.S.C. § 103(a). Balfanz ’874 was filed on Feb. 6, 2002 and, as such, qualifies as prior art with regard to the ’438
`Patent under at least 35 U.S.C. § 102(e) (pre-AIA).
`
`Alternatively, Yamazaki ’110 in view of U.S. Patent No. 7,136,999 to Griffiths (“Griffiths ’999”) renders obvious claims 1-7 under 35
`U.S.C. § 103(a). Griffiths ’999 was filed on June 20, 2000 and, as such, qualifies as prior art with regard to the ’438 Patent under at
`least 35 U.S.C. § 102(e) (pre-AIA).
`
`Alternatively, Yamazaki ’110 in view of U.S. Patent No. 6,351,271 to Mainwaring, et al. (“Mainwaring ’271”) renders obvious claims
`1-7 under 35 U.S.C. § 103(a). Mainwaring ’271 was filed on October 9, 1998 and issued on February 26, 2002, as such, qualifies as
`prior art with regard to the ’438 Patent under at least 35 U.S.C. §§ 102(a), 102 (b), and 102(e) (pre-AIA).
`
`
`Yamazaki ’110
`
`To the extent that the preamble is limiting, Yamazaki ’110 teaches this claim limitation. Specifically,
`Yamazaki ’110 discloses “mobile information terminal[s]” carried by an information poster and an
`information acquirer on a public bulletin board:
`
`
`A mobile information terminal 1 is carried around by an information poster who posts
`information on an electronic bulletin board 5 and is configured having provided on a main body
`2: a display part 3 composed of a liquid crystal display; and an operation part 4 having many
`keys, such as a “power” key, a “settings” key, a “cancel” key, a “scroll” key, and the like
`arranged therein.
`Yamazaki ’110 at ¶ [0015].
`
`
`A mobile information terminal 8 is carried around by an information acquirer who acquires
`information from the electronic bulletin board 5, and similar to the mobile information terminal
`1 carried around by an information poster, is configured having disposed on a main body 9: a
`display part 10 (called the information output means in the present invention) composed of a
`liquid crystal display; and an operation part 11 (called the identification number input means
`and keyword input means in the present invention) having many keys arranged therein.
`Yamazaki ’110 at ¶ [0016].
`
`
`2
`
`U.S. Patent No. 7,116,438
`Claim 1
`[1(pre)] An information-
`processing terminal
`comprising:
`
`
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`Exhibit C4
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`
`See also Yamazaki ’110 Fig. 1:
`
`
`
`
`Yamazaki ’110 teaches this claim limitation under Plaintiff’s interpretation. Specifically, Yamazaki
`’110 describes an “operation part” which includes many keys. See [1(pre)] supra. Yamazaki ’110
`further characterizes this operation part as having “input number means” and keyword input means.
`Id.
`
`Yamazaki ’110 further teaches that this input unit receives input entered by a user:
`
`
`3
`
`[1(a)] an input unit for
`receiving an input entered
`by a user;
`
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`Exhibit C4
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`In this case, for example, when an input function of inputting various information such as meet
`up information, information for holding an event, or member recruitment information is
`performed with the operation part 4, the mobile information terminal 1 of the information poster
`displays the inputted information on the display part 3, and when a sending operation for
`sending the inputted information is performed with the operation part 4, a Bluetooth
`communication wireless link is established with the electronic bulletin board 5, and the inputted
`information is sent from the Bluetooth communication part 25 from the electronic bulletin board
`5.
`Yamazaki ’110 at ¶ [0020]; see also id. at ¶ [0022] (characterizing mobile information terminal 8
`similarly).
`
`Yamazaki ’110 also teaches this limitation under Defendant’s interpretation of the claims. To the
`extent that the limitation “an input unit for receiving an input entered by a user” is governed by 35
`U.S.C. § 112(6), the only structure disclosed for this limitation is ’438 Patent’s input/output unit 103,
`which includes a “ten-key board” for receiving data entered by the user.
`
`Yamazaki ’110’s teaching of an “operation part” with “many keys” is equivalent structure to the ’438
`Patent’s “ten-key board.” See supra. Yamazaki ’110’s operation part also performs the claimed
`function of “receiving an input entered by a user.” Id.
`Yamazaki ’110 teaches this claim limitation under Plaintiff’s interpretation. Specifically, Yamazaki
`’110 describes mobile information terminal 1 as including a Bluetooth communication part:
`
`
`The mobile information terminal 1 of the information poster is configured such that a wireless
`communication part 24 for performing wireless communication with a wireless base station (not
`illustrated), a Bluetooth communication part 25 for performing Bluetooth (TM) communication,
`which is one kind of short distance wireless communication, with the bulletin board 5, a memory
`part 26, and the foregoing display part 3 and operation part 4 are connected to a CPU 23
`composed mainly of a microcomputer.
`Yamazaki ’110 at ¶ [0020]; see also id. at FIG. 2 (depicting Bluetooth communication part 25 of
`mobile information terminal 1 in communication with Bluetooth communication part 28 of electronic
`bulletin board 5):
`
`[1(b)] a first short-distance
`communication unit for
`carrying out a short-
`distance communication
`with a display apparatus;
`and
`
`
`
`4
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`Exhibit C4
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`
`
`Thus Yamazaki ’110 teaches that Bluetooth part 25 carries out “short distance communication” with
`the “bulletin board 5.” Id; see also id. at ¶ [0022] (characterizing mobile information terminal 8
`similarly).
`
`This bulletin board is a “display apparatus:”
`
`
`The electronic bulletin board 5 is installed in a public place such as, for example, a railroad
`station, a park, or a shopping center, and is configured having disposed on a main body 6: a
`large display part 7 (called the information posting means in the present invention) composed
`of a liquid crystal display.
`Id. at ¶ [0015].
`
`
`
`
`
`5
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`Exhibit C4
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`
`Additionally, Nagano ’227 teaches this claim limitation. In particular, Nagano ’227 describes mobile
`apparatus 103 as communicating with “public display device 101” via short-range communication
`including “infrared rays or the like”:
`
`
`The public display device 101 is connected to a network at high-speed, and furthermore, is
`configured to enable wireless communication using infrared rays or the like with a mobile
`apparatus 103 at short-range…
`Nagano ’227 at Abst.
`
`This communication is both characterized as “short-range” and limited to line-of-sight:
`
`
`Furthermore, to determine which public display device the information to be sent to the mobile
`telephone will be transmitted to, the public display device and mobile telephone are connected
`using short-range communication between the mobile telephone and the public display device.
`The public display device must be able to be operated from an undefined mobile telephone.
`Furthermore, there is no need to operate from a location in which the public display device
`cannot be seen, so the public display device defines the mobile telephone it is being used by
`via short-range communication.
`Id. at ¶ [0006].
`
`Nagano ’227 discloses a number of potential types of short-range communication technologies, and
`(implicitly) the corresponding types of “short-distance communication unit[s]”:
`
`
`Note that communication between the registration request sending unit 804 and the
`registration request reception unit 801 and between the address notification unit 803 and the
`address reception unit 805 uses a method suitable for short-range communication such as
`communication using infrared rays, communication using Bluetooth, or the like.
`Id. at ¶ [0037]; see also FIG. 8 (depicting “address reception unit 805” in (short-range) communication
`with public display device 101):
`
`
`
`6
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`Defendant’s Invalidity Contentions
`Exhibit C4
`
`
`
`
`
`The motivation to combine Nagano ’227’s short-range communication system with the mobile
`apparatus of Yamazaki ’110 would be to enable authentication via short-range communication,
`described as desirable by Yamazaki ’110. See supra. Doing so would be the simple substitution of one
`known element for another to obtain predictable results.
`
`Additionally, Balfanz ’874 teaches this limitation. In particular, Balfanz ’874 teaches wireless devices
`including a “location limited channel receiver/transmitter”:
`
`
`7
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`Exhibit C4
`
`
`The first wireless device 310 includes a location-limited channel receiver/transmitter 312 and a
`main wireless link receiver/transmitter 314. Likewise, the second wireless device 320 includes a
`location-limited channel receiver/transmitter 322 and a main wireless link receiver/transmitter
`324.
`Balfanz ’874 at ¶ [0033]; see also FIG. 4, rn 432:
`
`
`
`
`
`Balfanz ’874 further discloses that this location-limited channel can be an infrared channel:
`
`
`The first such property is a demonstrative property. A suitable location-limited channel
`receiver/transmitter 442 has physical limitations in its transmissions. For example, Sound,
`whether in the audible and/or in the ultrasonic range, which has a limited transmission range and
`broadcast characteristics, may be used as a location-limited channel for a group of wireless
`devices. For point-to-point communication, such as between two wireless devices, a location-
`limited channel with directionality, such as an infra-red channel may be used.
`Id. at ¶ [0041]. See also, id. at ¶ [0082],
`
`
`8
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`Exhibit C4
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`
`
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`9
`
`The motivation to combine Balfanz ’874’s location-limited channel with the mobile apparatus of
`Yamazaki ’110 would be to enable authentication via short-range communication, described as
`desirable by Yamazaki ’110. See supra. Doing so would be the simple substitution of one known
`element for another to obtain predictable results.
`
`Additionally, Griffiths ’999 teaches this limitation. In particular, Griffiths ’999 teaches wireless
`devices including a “location limited channel receiver/transmitter”:
`
`
`In a preferred embodiment, the first and second electronic devices each have the capability of
`communicating with each other over at least a primary and a secondary communications link.
`The primary communications link is a given short-range wireless link. Preferably, the short-
`range wireless link conforms to a given protocol, namely, Bluetooth. The secondary
`communications link may be any alternative link such as a wide area network (WAN), a local
`area network (LAN), or the like. The devices are first authenticated over the primary link, with
`the user entering the same, given PIN code in both devices. After the devices verify that they share
`the same PIN code, they exchange key information. Later, when the devices are no longer within
`range to authenticate over the primary communications link using Bluetooth, one of the devices
`invites the exchange of key information automatically using the secondary communications link.
`Griffiths ’999 at 2:34-47.
`
`
`According to the invention, each of the devices also includes a transceiver 105 to enable the
`devices to communicate over a communications link 107. Preferably, the communications link
`107 is a short-range wireless link that conforms to a given radio protocol, e.g., Bluetooth. This
`is not a limitation of the present invention, however, as the alternative communications link 107
`may be an infrared link, an acoustic link, or the like.
`Id. at 3:44-48.
`
`The motivation to combine Griffiths ’999’s location-limited channel with the mobile apparatus of
`Yamazaki ’110 would be to enable authentication via short-range communication, described as
`desirable by Yamazaki ’110. See supra. Doing so would be the simple substitution of one known
`element for another to obtain predictable results.
`
`
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`Defendant’s Invalidity Contentions
`Exhibit C4
`
`
`
`
`Yamazaki ’110 also teaches this claim limitation under Defendant’s interpretation. To the extent that
`the limitation “a first short-distance communication unit for carrying out a short-distance
`communication with a display apparatus” is governed by 35 U.S.C. § 112(6), the only structure
`disclosed for this limitation is the ’438 Patent’s short-distance communication unit 102, which is
`described structurally only as a “component for carrying out a short-distance communication with an
`external apparatus.” See also the ’438 Patent at FIG. 2, r.n. 102. To the extent that this is sufficient
`disclosure of structure to perform the claimed function, Yamazaki ’110 discloses “Bluetooth
`communication part 25.” This component carries out the claimed function of “carrying out a short-
`distance communication with a display apparatus.” See supra. To the extent that the ’438 Patent’s
`short-distance communication unit is construed as incorporating “short-distance communication
`means 6,” Yamazaki ’110 discloses that this component “is not limited to a Bluetooth communication
`method, and it may be a configuration using another communication method such as an infrared
`communication method or a PHS transfer communication method.” Yamazaki ’110 at ¶ [0058]; cf. the
`’438 Patent at 3:31-32 (giving the examples of “an infrared ray and a radio LAN” for communication
`means 6).
`
`Nagano ’227 also teaches this claim limitation under Defendant’s interpretation. Nagano ’227
`discloses “registration request sending unit 804” and “address reception unit 805.” These components
`carry out the claimed function of “carrying out a short-distance communication with a display
`apparatus.” See supra. To the extent that the ’438 Patent’s short-distance communication unit is
`construed as incorporating “short-distance communication means 6,” Nagano ’227 discloses that these
`components can use short range communication means such as “infrared rays, communication via
`Bluetooth, or the like.” Supra; cf. the ’438 Patent at 3:31-32 (giving the examples of “an infrared ray
`and a radio LAN” for communication means 6).
`
`Similarly, Balfanz ’874’s teaching of “I/O interface 430” which includes “location limited channel
`interface 432” is equivalent structure to the ’438 Patent’s “short-distance communication unit.” See
`supra. Balfanz ’874’s location limited-channel interface also performs the claimed function of
`“carrying out a short-distance communication with a display apparatus,” at least as required for point-
`to-point communications as described. Id.
`
`The motivation to combine Balfanz ’874’s location-limited channel with the mobile apparatus of
`Yamazaki ’110 would be to enable authentication via short-range communication, described as
`
`10
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`Exhibit C4
`
`
`[1(c)] second
`communication unit for
`carrying out a
`communication with said
`display apparatus through a
`network; wherein
`
`desirable by Yamazaki ’110. See supra. Doing so would be the simple substitution of one known
`element for another to obtain predictable results.
`
`Similarly, Griffiths ’999’s teaching of “transceiver 105” which operates over “short-range wireless
`link” 107 is equivalent structure to the ’438 Patent’s “short-distance communication unit.” See supra.
`Griffiths ’999’s transceiver 105 also performs the claimed function of “carrying out a short-distance
`communication with a display apparatus,” at least as required for point-to-point communications as
`described. Id.
`
`The motivation to combine Griffiths ’999’s location-limited channel with the mobile apparatus of
`Yamazaki ’110 would be to enable authentication via short-range communication, described as
`desirable by Yamazaki ’110. See supra. Doing so would be the simple substitution of one known
`element for another to obtain predictable results.
`Yamazaki ’110 teaches this claim limitation under Plaintiff’s interpretation. Specifically, Yamazaki
`’110 further describes mobile information terminal 1 as including “wireless communication part 24”
`and “mobile information terminal 8” as having “wireless communication part 33,” each in
`communication with a wireless base station. See claim element [1(b)] above. This wireless base station
`is a part of mobile phone network 41:
`
`
`That is, in FIG. 21, along with the mobile information terminal 1 of the information poster being
`configured to send information to the electronic bulletin board 5 through a mobile phone
`network 41, the mobile information terminal 8 of the information acquirer is configured to
`receive information from the electronic bulletin board 5 through a mobile phone network 41.
`Yamazaki ’110 at ¶ [0056]. Mobile See also id at FIG. 2:
`
`
`
`11
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`
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`Yamazaki ’110 further discloses an embodiment wherein mobile information terminal 1 communicates
`with electronic bulletin board 5 via mobile phone network 41. See Yamazaki ’110 at FIG. 21:
`
`
`
`
`
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`Defendant’s Invalidity Contentions
`Exhibit C4
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`
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`Yamazaki ’110 confirms that mobile information terminal 1 of FIG. 21 is the same as mobile
`information terminal 1 of FIG. 1 and mobile information terminal 1 of FIG. 2:
`
`
`Next, a second example of the present invention will be described referencing FIG. 21. Note, the
`same numerals will be given to the same portions as the foregoing first example and description
`omitted, and differing portions will be described below.
`Id. at ¶ [0056]. Thus, mobile information terminal of FIG. 21 includes the “wireless communication
`part 24” and “Bluetooth communication part 25” depicted in FIG. 2.
`
`
`13
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`Exhibit C4
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`
`Additionally, Nagano ’227 teaches this limitation. In particular, Nagano ’227 further describes mobile
`apparatus 103 as communicating with “public display device 101” via “mobile apparatus network”
`102 and high-speed “network” 105:
`
`
`The public display device 101 is connected to a network at high-speed, and furthermore, is
`configured to enable wireless communication using infrared rays or the like with a mobile
`apparatus 103 at short-range, and the mobile apparatus 103 acquires a network address of the
`public display device 101 via wireless communication and sends it together with the network
`address of the mobile apparatus 103 to a gateway server 104. The gateway server 104
`transmits the information sent to the mobile apparatus 103 to the public display device 101.
`Nagano ’227 at Abst.
`
`These networks together connect mobile apparatus 103 to public display device 101:
`
`
`The public display device 101 is connected to the network 105, and the mobile apparatus 103
`is connected to the mobile apparatus network 102. The gateway server 104 is connected to the
`mobile apparatus network 102 and the network 105.
`Id at ¶ [0010].
`
`This network connection between mobile apparatus 103 and public display 101 is made at least via
`“address information sending unit 806”:
`
`
`
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`Id. at FIG. 8.
`
`The motivation to incorporate Nagano ’227’s mobile apparatus network interface into the system of
`Yamazaki ’110 would be to allow for higher bandwidth communication of communication such as the
`content of URLs. Doing so would be the use of known technique to improve similar devices in the
`same way.
`
`Additionally, Balfanz ’874 teaches this limitation. In particular, as Balfanz ’874 teaches wireless
`devices including a “main wireless link receiver/transmitter”:
`
`
`15
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`Defendant’s Invalidity Contentions
`Exhibit C4
`
`
`The first wireless device 310 includes a location-limited channel receiver/transmitter 312 and a
`main wireless link receiver/transmitter 314. Likewise, the second wireless device 320 includes a
`location-limited channel receiver/transmitter 322 and a main wireless link receiver/transmitter
`324.
`Balfanz ’874 at ¶ [0033]; see also FIG. 4, rn 434:
`
`
`
`
`Balfanz ’874 teaches that this main wireless link interface “allows the wireless device to communicate
`over a wireless network”:
`
`
`The wireless application 424 provides computer instructions which, when executed by the
`processor 410, allows the wireless device 400 to communicate with a wireless network through
`the main wireless link receiver/transmitter 444 connected to a main wireless link interface 434 of
`the I/O interface 430. The wireless application 424 may be Bluetooth™, ANSI/IEEE 802.11, or
`any other known or later developed wireless communication media.
`The main wireless link interface 434 and the main wireless link receiver/transmitter 444 can be
`implemented using any known or later developed wireless communication circuit or structure.
`For example, a wireless receiver/transmitter and interface used in a wireless network can be used
`as the main wireless link interface 434 and the main wireless link receiver/transmitter 444. In an
`
`16
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`Exhibit C4
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`alternative embodiment, the wireless device has main wired link interface and main wireless link
`receiver/transmitter such as TCP/IP interface and socket or both the main wireless link interface
`and transmitter, and main wired interface and receiver/transmitter.
`Balfanz ’874 at ¶¶ [0039-0040]. See also, id. at ¶ [0046].
`
`The motivation to combine Balfanz ’874’s main wireless link interface into the system of Yamazaki
`’110 would be to allow for higher bandwidth communication of data such as the content of URLs,
`thereby improving the performance of Yamazaki ’110’s system. Doing so would be the use of known
`technique to improve similar devices in the same way.
`
`Griffiths ’999 also teaches this claim limitation. In particular, Griffiths ’999 teaches that wireless
`devices communicate over a “secondary” link, which may be the “the Internet, an intranet , or some
`other link”:
`
`
`In the preferred embodiment, the alternative communications link 107 is a “primary” link in the
`sense that the devices initially authenticate to each other over the link 107 link and then, later,
`authenticate to each other over a secondary link 109 such as the Internet, an intranet, or some
`other link.
`Griffiths ’999 at 3:51-56.
`
`
`In FIG. 1, such a successive device authentication at different locations is indicated by the
`electronic device 102 having been moved from a network 113 to which the device 102 has
`restrained access, to the unconstrained network 120.
`Id. at 3:61-65; see also FIG. 1 (depicting electronic device 102 communicating over network 120):
`
`
`
`17
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`Exhibit C4
`
`
`
`
`
`The motivation to combine Griffiths ’999’s main wireless link interface into the system of Yamazaki
`’110 would be to allow for higher bandwidth communication of communication such as the content of
`URLs, thereby improving the performance of Yamazaki ’110’s system. Doing so would be the use of
`known technique to improve similar devices in the same way.
`
`Yamazaki ’110 also teaches this claim limitation under Defendant’s interpretation. To the extent that
`the limitation “a second communication unit for carrying out a communication with said display
`apparatus through a network” is governed by 35 U.S.C. § 112(6), the only structure disclosed for this
`limitation is the ’438 Patent’s transmission/reception unit 104, which is described structurally only as
`a “a component for controlling a communication with the network.” See also the ’438 Patent at FIG.
`
`18
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`2, r.n. 104. To the extent that this is sufficient disclosure of structure to perform the claimed function,
`Yamazaki ’110 discloses mobile information terminal 1 as including “wireless communication link
`24.” This component carries out the claimed function of “carrying out a communication with said
`display apparatus through a network.” See supra.
`
`Nagano ’227 also teaches this claim limitation under Defendant’s interpretation. Nagano ’227
`discloses “address information sending unit 806.” This component carries out the claimed function of
`“carrying out a communication with said display apparatus through a network.” See supra.
`
`The motivation to incorporate Nagano ’227’s mobile apparatus network interface into the system of
`Yamazaki ’110 would be to allow for higher bandwidth communication of communication such as the
`content of URLs, thereby improving the performance of Yamazaki ’110’s system. Doing so would be
`the use of known technique to improve similar devices in the same way.
`
`Similarly, Balfanz ’874’s teaching of “I/O Interface 430” which includes “main wireless link interface
`434” is equivalent structure to the ’438 Patent’s “second communication unit.” See supra. Balfanz
`’874’s main wireless link interface 434 also performs the claimed function of “carrying out a
`communication with said display apparatus through a network,” at least as described. Id.
`
`The motivation to combine Balfanz ’874’s main wireless link interface into the system of Yamazaki
`’110 would be to allow for higher bandwidth communication of communication such as the content of
`URLs, thereby improving the performance of Yamazaki ’110’s system. Doing so would be the use of
`known technique to improve similar devices in the same way.
`
`Similarly, Griffiths ’999’s teaching of “transceiver 105” which communicates over network 120 is
`equivalent structure to the ’438 Patent’s “second communication unit.” See supra. Transceiver 105
`also performs the claimed function of “carrying out a communication with said display apparatus
`through a network,” at least as described. Id.
`
`The motivation to combine Griffiths ’999’s main wireless link interface into the system of Yamazaki
`’110 would be to allow for higher bandwidth communication of data such as the content of URLs,
`thereby improving the performance of Yamazaki ’110’s system. Doing so would be the use of known
`technique to improve similar devices in the same way.
`
`19
`
`Apple v. Maxell
`IPR2020-00201
`Maxell Ex. 2018
`
`Page 19 of 57
`
`

`

`Defendant’s Invalidity Contentions
`Exhibit C4
`
`
`[1(d)] said first short-
`distance communication
`unit using said input,
`carries out an
`authentication process for
`allowance to use said
`display apparatus;
`
`Yamazaki ’110 teaches that the mobile information terminal 1 must authenticate prior to posting
`information on the electronic bulletin board and the mobile information terminal 8 must authenticate
`prior to retrieving information from the bulletin board:
`
`
`The authentication server 15 authenticates the mobile information terminal 1 of the information
`poster and the mobile information terminal 8 of the information acquirer based on
`authentication information stored in an authentication database 19, it is possible for the mobile
`information terminal 1 of the information poster to post information on the electronic bulletin
`board 5 with authentication by the authentication server 15 being determined as being true as
`
`a condition thereof and furthermore, it is possible for the mobile information terminal 8 of the
`
`information acquirer to acquire information from the electronic bulletin board 5 with
`authentication by the authentication server 15 being determined as being true as a condition
`thereof.
`Yamazaki ’110 at ¶ [0018].
`
`This authentication process uses input received from the user via the operation part and carried out
`over Bluetooth communication part 34:
`
`
`Subsequently, after the keyword in inputted, when the CPU 32 detects that an operation of
`sending a request to the electronic bulletin board 5 is performed (“YES” in step B9), it causes
`the Bluetooth communication part 34 to establish a Bluetooth communication wireless link with
`the electronic bulletin board 5 and to send a request including the inputted keyword along with
`the terminal ID uniquely assigned to the mobile information terminal 8 of the information
`acquirer from the Bluetooth communication part 34 to the electronic bulletin board 5 (step B10).
`Id. at ¶ [0045].
`
`This transmission is the first step in the process of authenticating the user of mobile information
`terminal 1. See, e.g., FIG. 14 (showing the input, authentication, and communication steps):
`
`
`
`20
`
`Apple v. Maxell
`IPR2020-00201
`Maxell Ex. 2018
`
`Page 20 of 57
`
`

`

`Defendant’s Invalidity Contentions
`Exhibit C4
`
`
`
`
`
`This transmitted terminal ID is used to authenticate the mobile information terminal:
`
`
`In the electronic bulletin board 5, when the CPU 27 detects that the Bluetooth communication
`terminal 28 has received the request and terminal ID from the mobile information terminal 8
`of the information acquirer (“YES” in step C8), from then on, it performs authentication with
`the host server 13 such as described above…
`Id. at ¶ [0046]; see also id. at ¶ [0029] (describing using the received terminal ID to authenticate).
`
`Additionally, Balfanz ’874 teache