TCL’S INVALIDITY CONTENTIONS FOR U.S. 8,078,767
`Exhibit C14: European Patent Application No. EP0989729 (“Takiguchi”)
`
`
`As demonstrated in the claim charts below, the asserted claims of U.S. Patent No. 8,078,767 (“the ’767 patent”) are invalid (a) under
`one or more sections of 35 U.S.C. § 102 as anticipated by Takiguchi and (b) under 35 U.S.C. § 103(a) as obvious over Takiguchi
`standing alone and as set forth herein, and/or combined with the knowledge of a person of ordinary skill in the art, Applicant’s
`Admitted Prior Art (“AAPA”), and/or the additional prior art references discussed in Exhibits C1-C14, and O3, the contents of which
`are hereby incorporated by reference into this chart. One of ordinary skill in the art, as of the alleged priority date of the ’767 patent,
`would have known to combine the prior art elements disclosed by the foregoing references using known methods, and to use these
`elements according to their established functions in order to achieve a known and predictable result.
`
`Except where specifically noted otherwise, this chart may apply the apparent interpretations of claim language as used by Plaintiff in
`its infringement contentions. Such use, however, does not imply that Defendants adopt or agree with Plaintiff’s interpretations in any
`way. Additionally, by providing contentions for claim preamble elements, Defendants do not take a position on whether the preamble
`is a claim limitation.
`
`
`
`Prior Art: EP0989729 (“Takiguchi”)
`
`Takiguchi discloses a display apparatus.
`See, e.g., elements 1.a – 1.d.
`Takiguchi discloses a display unit.
`For example, Takiguchi discloses:
`¶48 (“If images are present, the browser software sends an image transfer request to the camera in step
`S604. The camera checks if the received message is an image transfer request (step S605), and then
`checks if all images have already been transferred (step S606). If images to be transferred still remain,
`the camera sends image data to the browser software in step S608. The browser software receives the
`image data in step S609, and displays that image data on the PC screen in step S610.”);
`¶52 (“A case will be exemplified below wherein the mode dial switch is set at the Rec mode 2b. In
`this case, the on-line image sensing software is started. Fig. 8 shows an example of the on-line image
`sensing software. An image which is being currently seen by the camera is displayed on a preview
`area 802 in a window 801 as a preview image. When the user presses an image sensing button 803 at a
`shutter chance while observing the preview image, the camera senses the image, and sensed image
`
`Claim Element
`
`’767
`Claim
`1.pre A display apparatus
`characterized by comprising:
`
`1.a
`
`a display unit;
`
`
`
`1
`
`Page 1 of 24
`
`CANON EXHIBIT 2006
`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00341
`
`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: EP0989729 (“Takiguchi”)
`
`1.b
`
`a connection unit configured
`to connect an external device
`to be able to communicate
`with the external device; and
`
`data is displayed on a window 804. When the user presses a save button, the sensed image data can be
`saved as an image file.”);
`¶76 (“If it is determined in step S1102 that the camera is in the playback mode, the software is started
`in an image browsing mode in step S1103. The subsequent operation is the same as that described in
`the first embodiment.”);
`see also FIGs. 1-3, 8, Abstract, ¶¶1, 2, 8, 13, 15, 17, 19, 34, 35-37, 55, 56, 77-79, Claims 1-6, 10-16,
`20-22, 25-26.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takiguchi also discloses the corresponding structure(s) and
`function(s) claimed or their equivalents, as shown above, or renders them obvious in view of the
`knowledge of one skilled in the art.
`Takiguchi discloses a connection unit configured to connect an external device to be able to
`communicate with the external device.
`For example, Takiguchi discloses:
`¶¶38-39 (“Fig. 3 shows a state wherein the camera and PC are connected via USB. The camera is
`connected to the PC and can communicate with it in three states shown in Fig. 4.”);
`¶42 (“In the third example, the camera has already been set in a given mode, the corresponding
`application has already been started, and the camera and application are connected and communicate
`with each other. In this state, when the user sets the camera in another mode (step S403), the camera
`sends a disconnection message to the connected application at that timing to disconnect the
`communication with the application (step S405). At this time, whether the application automatically
`ends or is disconnected but kept running depends on the setups of the application. A message
`indicating a new mode in which the camera is set currently is sent to the PC (step S406). After that,
`the camera checks if sensed images are present in the camera (step S407). If no images are present, the
`camera also sends a message indicating that no images are present in the camera (step S408).”);
`¶44 (“The STI starts an associated application in correspondence with the message of each mode. Fig.
`5 shows this process.”);
`¶47 (“It is checked in step S601 if images are present in the camera. This checking step is attained by
`checking if the message issued in step S408 in Fig. 4 has arrived at the PC. If this message has arrived,
`
`
`
`2
`
`Page 2 of 24
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`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: EP0989729 (“Takiguchi”)
`
`the browser software displays a message indicating no image (step S602), and ends itself (step
`S603).”);
`¶48 (“If images are present, the browser software sends an image transfer request to the camera in step
`S604. The camera checks if the received message is an image transfer request (step S605), and then
`checks if all images have already been transferred (step S606). If images to be transferred still remain,
`the camera sends image data to the browser software in step S608. The browser software receives the
`image data in step S609, and displays that image data on the PC screen in step S610.”);
`¶54 (“When the mode dial switch 2 is set at the Rec mode 2b, the on-line image sensing software is
`automatically started. The on-line image sensing software sends a reduced-scale image transmission
`request to the camera (step S701). This reduced-scale image is to be displayed on the preview area
`802. In order to attain preview display that moves as smooth as possible, i.e., to transfer image frames
`as much as possible, a reduced-scale image is requested in place of a full-size image which is equal to
`the sensed image size.”);
`¶76 (“If it is determined in step S1102 that the camera is in the playback mode, the software is started
`in an image browsing mode in step S1103. The subsequent operation is the same as that described in
`the first embodiment.”);
`see also FIGs. 1-11, Abstract, ¶¶1-8, 13, 15, 17, 19, 27, 29, 30, 34-37, 40-41, 52, 55, 56, 61, 62, 73,
`77-79, Claims 1-7, 11-17, 21-22, 25-26.
`To the extent that Plaintiff alleges that Takiguchi does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or the references identified in Exhibits C1-C14, and O3.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takiguchi also discloses the corresponding structure(s) and
`function(s) claimed or their equivalents, as shown above, or renders them obvious in view of the
`knowledge of one skilled in the art.
`Takiguchi discloses a control unit configured to control said display unit to make a display based on
`data received from the external device with which a communication connection is established via said
`connection unit.
`For example, Takiguchi discloses:
`¶42 (“In the third example, the camera has already been set in a given mode, the corresponding
`application has already been started, and the camera and application are connected and communicate
`3
`
`a control unit configured to
`control said display unit to
`make a display based on data
`received from the external
`device with which a
`communication connection is
`
`1.c
`
`
`
`Page 3 of 24
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`

`

`’767
`Claim
`
`Claim Element
`
`established via said
`connection unit,
`
`Prior Art: EP0989729 (“Takiguchi”)
`
`with each other. In this state, when the user sets the camera in another mode (step S403), the camera
`sends a disconnection message to the connected application at that timing to disconnect the
`communication with the application (step S405). At this time, whether the application automatically
`ends or is disconnected but kept running depends on the setups of the application. A message
`indicating a new mode in which the camera is set currently is sent to the PC (step S406). After that,
`the camera checks if sensed images are present in the camera (step S407). If no images are present, the
`camera also sends a message indicating that no images are present in the camera (step S408).”);
`¶44 (“The STI starts an associated application in correspondence with the message of each mode. Fig.
`5 shows this process.”);
`¶47 (“It is checked in step S601 if images are present in the camera. This checking step is attained by
`checking if the message issued in step S408 in Fig. 4 has arrived at the PC. If this message has arrived,
`the browser software displays a message indicating no image (step S602), and ends itself (step
`S603).”);
`¶48 (“If images are present, the browser software sends an image transfer request to the camera in step
`S604. The camera checks if the received message is an image transfer request (step S605), and then
`checks if all images have already been transferred (step S606). If images to be transferred still remain,
`the camera sends image data to the browser software in step S608. The browser software receives the
`image data in step S609, and displays that image data on the PC screen in step S610.”);
`¶54 (“When the mode dial switch 2 is set at the Rec mode 2b, the on-line image sensing software is
`automatically started. The on-line image sensing software sends a reduced-scale image transmission
`request to the camera (step S701). This reduced-scale image is to be displayed on the preview area
`802. In order to attain preview display that moves as smooth as possible, i.e., to transfer image frames
`as much as possible, a reduced-scale image is requested in place of a full-size image which is equal to
`the sensed image size.”);
`¶76 (“If it is determined in step S1102 that the camera is in the playback mode, the software is started
`in an image browsing mode in step S1103. The subsequent operation is the same as that described in
`the first embodiment.”);
`¶80 (“The objects of the present invention are also achieved by supplying a storage medium, which
`records a program code of a software program that can implement the functions of the above-
`mentioned embodiments to the system or apparatus, and reading out and executing the program code
`stored in the storage medium by a computer (or a CPU or MPU) of the system or apparatus”);
`
`
`
`4
`
`Page 4 of 24
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`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: EP0989729 (“Takiguchi”)
`
`¶81 (“In this case, the program code itself read out from the storage medium implements the functions
`of the above-mentioned embodiments, and the storage medium which stores the program code
`constitutes the present invention.”);
`see also FIGs. 1-11, Abstract, ¶¶1-8, 13, 15, 17, 19, 21, 23, 27, 29, 30, 34, 35-37, 39-41, 49, 53, 55,
`56, 61, 62, 73, 77-79, Claims 1-7, 11-17, 21-26.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takiguchi also discloses the corresponding structure(s) and
`function(s) claimed or their equivalents, as shown above, or renders them obvious in view of the
`knowledge of one skilled in the art.
`Takiguchi discloses a control unit that acquires class information indicating a class of the external
`device from the external device via said connection unit, controls said display unit to continue the
`display based on the data received from the external device at the time of disconnection of the
`communication connection with the external device if the class of the external device indicated by the
`class information is a predetermined class, and controls said display unit to end the display based on
`the data received from the external device at the time of disconnection of the communication
`connection with the external device if the class of the external device indicated by the class
`information is not the predetermined class.
`See, e.g. element 1.c.
`In addition, Takiguchi discloses:
`¶42 (“In the third example, the camera has already been set in a given mode, the corresponding
`application has already been started, and the camera and application are connected and communicate
`with each other. In this state, when the user sets the camera in another mode (step S403), the camera
`sends a disconnection message to the connected application at that timing to disconnect the
`communication with the application (step S405). At this time, whether the application automatically
`ends or is disconnected but kept running depends on the setups of the application. A message
`indicating a new mode in which the camera is set currently is sent to the PC (step S406). After that,
`the camera checks if sensed images are present in the camera (step S407). If no images are present, the
`camera also sends a message indicating that no images are present in the camera (step S408).”);
`¶50 (“When another mode is selected at the camera while the browser software is connected to the
`camera, or when the power switch of the camera is turned off, the camera sends a corresponding
`message to the browser software. At this time, the browser software executes a process for
`
`5
`
`characterized in that said
`control unit acquires class
`information indicating a class
`of the external device from
`the external device via said
`connection unit, controls said
`display unit to continue the
`display based on the data
`received from the external
`device at the time of
`disconnection of the
`communication connection
`with the external device if the
`class of the external device
`indicated by the class
`information is a
`predetermined class, and
`controls said display unit to
`end the display based on the
`data received from the
`external device at the time of
`disconnection of the
`communication connection
`with the external device if the
`
`1.d
`
`
`
`Page 5 of 24
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`

`

`’767
`Claim
`
`Claim Element
`
`class of the external device
`indicated by the class
`information is not the
`predetermined class.
`
`Prior Art: EP0989729 (“Takiguchi”)
`
`disconnecting the communication with the camera, and then executes one of the following three
`options.”);
`¶51 (“The first option automatically ends the browser software, the second option displays a message
`indicating that the connection with the camera is disconnected by user operation to the user, and
`prompts the user to select whether the browser software is to end or continue, and the third option
`continues to run the browser software. These options can be selected from a setup menu of the
`browser software. As a default, the second option that prompts the user to select whether the browser
`software is to end or continue is preferably set.”);
`¶58 (“When another mode is selected at the camera while the on-line image sensing software is
`connected to the camera, or when the power switch of the camera is turned off, the camera sends a
`corresponding message to the on-line image sensing software. At this time, the on-line image sensing
`software executes a process for disconnecting the communication with the camera, and then
`automatically ends itself. The aforementioned browser software has options for selecting, e.g.,
`whether or not the software continues to run, but such options are not available for this software. This
`is because the on-line image sensing software does not function at all unless it is connected to the
`camera.);
`¶60 (“It is checked in step S901 if images are present in the camera. This checking step is attained by
`checking if the message issued in step S408 in Fig. 4 has arrived at the PC. If this message has arrived,
`the stitch synthesis software displays a message indicating that no images are stored in the camera
`(step S902), and ends (step S903).”);
`¶64 (“When another mode is selected at the camera while the stitch synthesis software is connected to
`the camera, or when the power switch of the camera is turned off, the camera sends a corresponding
`message to the stitch synthesis software. At this time, the stitch synthesis software disconnects the
`connection with the camera. In this case, if all the stitch assist images in the camera have already been
`loaded, the stitch synthesis software continues a synthesis process. However, if all the images have not
`been loaded yet, the stitch synthesis software automatically ends itself since it cannot execute a
`synthesis process.”);
`¶66 (“It is checked in step S1001 if images are present in the camera. This checking step is attained by
`checking if the message issued in step S408 in Fig. 4 has arrived at the PC. If this message has arrived,
`the slideshow playback software displays a message indicating that no images are stored in the camera
`(step S1002), and ends itself (step S1003).”);
`
`
`
`6
`
`Page 6 of 24
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`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: EP0989729 (“Takiguchi”)
`
`2.pre
`
`2.a
`
`The display apparatus
`according to claim 1,
`characterized in that the
`predetermined class is a class
`of a device which logically
`disconnects a communication
`connection.
`
`see also FIGs. 4-7, 9-11, ¶¶27, 29, 30, 72, Claims 7-9, 17-19.
`To the extent that Plaintiff alleges that Takiguchi does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or the references identified in Exhibits C1-C14, and O3.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takiguchi also discloses the corresponding structure(s) and
`function(s) claimed or their equivalents, as shown above, or renders them obvious in view of the
`knowledge of one skilled in the art.
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Takiguchi discloses a display apparatus characterized in that the predetermined class is a class of a
`device which logically disconnects a communication connection.
`For example, Takiguchi discloses:
`¶50 (“When another mode is selected at the camera while the browser software is connected to the
`camera, or when the power switch of the camera is turned off, the camera sends a corresponding
`message to the browser software. At this time, the browser software executes a process for
`disconnecting the communication with the camera, and then executes one of the following three
`options.”);
`¶51 (“The first option automatically ends the browser software, the second option displays a message
`indicating that the connection with the camera is disconnected by user operation to the user, and
`prompts the user to select whether the browser software is to end or continue, and the third option
`continues to run the browser software. These options can be selected from a setup menu of the
`browser software. As a default, the second option that prompts the user to select whether the browser
`software is to end or continue is preferably set.”);
`¶58 (“When another mode is selected at the camera while the on-line image sensing software is
`connected to the camera, or when the power switch of the camera is turned off, the camera sends a
`corresponding message to the on-line image sensing software. At this time, the on-line image sensing
`software executes a process for disconnecting the communication with the camera, and then
`automatically ends itself. The aforementioned browser software has options for selecting, e.g.,
`whether or not the software continues to run, but such options are not available for this software. This
`
`
`
`7
`
`Page 7 of 24
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`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: EP0989729 (“Takiguchi”)
`
`is because the on-line image sensing software does not function at all unless it is connected to the
`camera.);
`¶72 (“When another mode is selected at the camera while the slideshow playback software is
`connected to the camera, or when the power switch of the camera is turned off, the camera sends a
`corresponding message to the slideshow playback software. At this time, the slideshow playback
`software disconnects the connection with the camera. In this case, if all the images in the camera have
`already been loaded, the slideshow playback software continues slideshow playback. However, if all
`the images have not been loaded yet, the slideshow playback software automatically ends itself since
`it cannot execute slideshow playback”);
`see also FIGs. 4-7, 9-11, ¶64, Claim 9, 19.
`To the extent that Plaintiff alleges that Takiguchi does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or the references identified in Exhibits C1-C14, and O3.
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Takiguchi discloses a display apparatus characterized in that if the class information indicates a USB
`mass storage class, said control unit controls to end the display.
`For example, Takiguchi discloses:
`¶5 (“USB can implement hot plugin (a USB device can be plugged or unplugged while a PC is
`running, and the OS can recognize the plugged or unplugged state), and a mechanism for
`automatically recognizing the connected camera, and automatically starting a predetermined
`application associated with the camera by the STI can be provided. …”);
`¶33 (“Referring to Fig. 1, reference numeral 1 denotes a USB I/F which is connected to the PC.
`Reference numeral 2 denotes a mode dial switch which has a playback (Play) mode 2a, image sensing
`(Rec) mode 2b, stitch assist (Stitch) mode 2c, slideshow playback (Slide) mode 2d, and power OFF
`2e. Reference numeral 3 denotes a CF (Compact Flash™) card slot.”);
`see also FIGs. 1, 3, ¶38.
`
`3.pre
`
`3.a
`
`The display apparatus
`according to claim 1,
`characterized in that if the
`class information indicates a
`USB mass storage class, said
`control unit controls to end
`the display.
`
`
`
`8
`
`Page 8 of 24
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`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: EP0989729 (“Takiguchi”)
`
`4.pre
`
`4.a
`
`The display apparatus
`according to claim 1,
`characterized in that if the
`class information is class
`information indicating a USB
`imaging class, said control
`unit controls to continue the
`display.
`
`
`To the extent that Plaintiff alleges that Takiguchi does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or the references identified in Exhibits C1-C14, and O3.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takiguchi also discloses the corresponding structure(s) and
`function(s) claimed or their equivalents, as shown above, or renders them obvious in view of the
`knowledge of one skilled in the art.
`
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Takiguchi discloses a display apparatus characterized in that if the class information is class
`information indicating a USB imaging class, said control unit controls to continue the display.
`For example, Takiguchi discloses:
`¶5 (“USB can implement hot plugin (a USB device can be plugged or unplugged while a PC is
`running, and the OS can recognize the plugged or unplugged state), and a mechanism for
`automatically recognizing the connected camera, and automatically starting a predetermined
`application associated with the camera by the STI can be provided. …”);
`¶33 (“Referring to Fig. 1, reference numeral 1 denotes a USB I/F which is connected to the PC.
`Reference numeral 2 denotes a mode dial switch which has a playback (Play) mode 2a, image sensing
`(Rec) mode 2b, stitch assist (Stitch) mode 2c, slideshow playback (Slide) mode 2d, and power OFF
`2e. Reference numeral 3 denotes a CF (Compact Flash™) card slot.”);
`see also FIGs. 1, 3, ¶38.
`To the extent that Plaintiff alleges that Takiguchi does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or the references identified in Exhibits C1-C14, and O3.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takiguchi also discloses the corresponding structure(s) and
`function(s) claimed or their equivalents, as shown above, or renders them obvious in view of the
`knowledge of one skilled in the art.
`
`
`
`9
`
`Page 9 of 24
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`

`

`’767
`Claim
`5.pre
`
`5.a
`
`Claim Element
`
`The display apparatus
`according to claim 4,
`characterized in that even if
`the class information is the
`class information indicating
`the USB imaging class, when
`the communication
`connection with the external
`device is disconnected during
`a communication with the
`external device, said control
`unit controls to end the
`display.
`
`Prior Art: EP0989729 (“Takiguchi”)
`
`Defendants incorporate by reference their contentions relating to claim 4, as if fully set forth herein.
`
`Takiguchi discloses a display apparatus characterized in that even if the class information is the class
`information indicating the USB imaging class, when the communication connection with the external
`device is disconnected during a communication with the external device, said control unit controls to
`end the display.
`For example, Takiguchi discloses:
`¶50 (“When another mode is selected at the camera while the browser software is connected to the
`camera, or when the power switch of the camera is turned off, the camera sends a corresponding
`message to the browser software. At this time, the browser software executes a process for
`disconnecting the communication with the camera, and then executes one of the following three
`options.”);
`¶51 (“The first option automatically ends the browser software, the second option displays a message
`indicating that the connection with the camera is disconnected by user operation to the user, and
`prompts the user to select whether the browser software is to end or continue, and the third option
`continues to run the browser software. These options can be selected from a setup menu of the
`browser software. As a default, the second option that prompts the user to select whether the browser
`software is to end or continue is preferably set.”);
`¶58 (“When another mode is selected at the camera while the on-line image sensing software is
`connected to the camera, or when the power switch of the camera is turned off, the camera sends a
`corresponding message to the on-line image sensing software. At this time, the on-line image sensing
`software executes a process for disconnecting the communication with the camera, and then
`automatically ends itself. The aforementioned browser software has options for selecting, e.g.,
`whether or not the software continues to run, but such options are not available for this software. This
`is because the on-line image sensing software does not function at all unless it is connected to the
`camera.);
`¶64 (“When another mode is selected at the camera while the stitch synthesis software is connected to
`the camera, or when the power switch of the camera is turned off, the camera sends a corresponding
`message to the stitch synthesis software. At this time, the stitch synthesis software disconnects the
`connection with the camera. In this case, if all the stitch assist images in the camera have already been
`loaded, the stitch synthesis software continues a synthesis process. However, if all the images have not
`
`
`
`10
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`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: EP0989729 (“Takiguchi”)
`
`6.pre
`
`6.a
`
`The display apparatus
`according to claim 1,
`characterized by further
`comprising:
`a detection unit configured to
`detect whether or not the
`external device is physically
`connected to said connection
`unit,
`
`been loaded yet, the stitch synthesis software automatically ends itself since it cannot execute a
`synthesis process.”)
`see also Claim 9, 19.
`To the extent that Plaintiff alleges that Takiguchi does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or the references identified in Exhibits C1-C14, and O3.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takiguchi also discloses the corresponding structure(s) and
`function(s) claimed or their equivalents, as shown above, or renders them obvious in view of the
`knowledge of one skilled in the art.
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Takiguchi discloses a detection unit configured to detect whether or not the external device is
`physically connected to said connection unit.
`¶50 (“When another mode is selected at the camera while the browser software is connected to the
`camera, or when the power switch of the camera is turned off, the camera sends a corresponding
`message to the browser software. At this time, the browser software executes a process for
`disconnecting the communication with the camera, and then executes one of the following three
`options.”);
`¶51 (“The first option automatically ends the browser software, the second option displays a message
`indicating that the connection with the camera is disconnected by user operation to the user, and
`prompts the user to select whether the browser software is to end or continue, and the third option
`continues to run the browser software. These options can be selected from a setup menu of the
`browser software. As a default, the second option that prompts the user to select whether the browser
`software is to end or continue is preferably set.”);
`¶58 (“When another mode is selected at the camera while the on-line image sensing software is
`connected to the camera, or when the power switch of the camera is turned off, the camera sends a
`corresponding message to the on-line image sensing software. At this time, the on-line image sensing
`software executes a process for disconnecting the communication with the camera, and then
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`’767
`Claim
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`Claim Element
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`Prior Art: EP0989729 (“Takiguchi”)
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`automatically ends itself. The aforementioned browser software has options for selecting, e.g.,
`whether or not the software continues to run, but such options are not available for this software. This
`is because the on-line image sensing software does not function at all unless it is connected to the
`camera.);
`¶64 (“When another mode is selected at the camera while the stitch synthesis software is connected to
`the camera, or when the power switch of the camera is turned off, the camera sends a corresponding
`message to the stitch synthesis software. At this time, the stitch synthesis software disconnects the
`connection with the camera. In this case, if all the stitch assist images in the camera have already been
`loaded, the stitch synthesis software continues a synthesis process. However, if all the images have not
`been loaded yet, the stitch synthesis software automatically ends itself since it cannot execute a
`synthesis process.”);
`see also Claim 9, 19.
`To the extent that Plaintiff alleges that Takiguchi does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or the references identified in Exhibits C1-C14, and O3.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takiguchi also discloses the corresponding structure(s) and
`function(s) claimed or their equivalents, as shown above, or renders them obvious in view of the
`knowledge of one skilled in the art.
`Takiguchi discloses a detection unit that detects that a physical connection with the external device is
`disconnected at the time of disconnection of the communication connection with the external device,
`said control unit controls to end the display irrespective of the class information.
`¶50 (“When another mode is selected at the camera while the browser software is connected to the
`camera, or when the power switch of the camera is turned o