TCL’S INVALIDITY CONTENTIONS FOR U.S. 8,078,767
`Exhibit C5: J.P Pat. App. No. JP2004350160A (“Suda”)
`
`
`
`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 Suda and (b) under 35 U.S.C. § 103(a) as obvious over Suda 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: J.P Pat. App. No. JP2004350160A Suda
`
`Suda discloses a display apparatus.
`See, e.g., elements 1.a – 1.d.
`Suda discloses a display unit.
`For example, Suda discloses:
`¶ 12 (“When the user has selected a specific image from the image indexing information and has
`issued a display command using the operating switches 105, the CPU 107 reads the compressed image
`data for the image from the memory card 120. The retrieved compressed image data is decompressed
`by the image compression/decompression device 106, and the image is displayed on the display
`110.”); see also FIGs. 1, 4.
`To the extent 35 U.S.C. § 112, ¶6 applies, Suda 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.
`Suda discloses a connection unit configured to connect an external device to be able to communicate
`with the external device.
`
`1
`
`Claim Element
`
`’767
`Claim
`1.pre A display apparatus
`characterized by comprising:
`
`1.a
`
`a display unit;
`
`1.b
`
`a connection unit configured
`to connect an external device
`
`
`
`Page 1 of 23
`
`CANON EXHIBIT 2003
`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00341
`
`

`

`’767
`Claim
`
`Claim Element
`
`to be able to communicate
`with the external device; and
`
`Prior Art: J.P Pat. App. No. JP2004350160A Suda
`
`For example, Suda discloses:
`¶ 9 (“The compressed image data is stored temporarily in RAM 108 and recorded on a memory card
`120 for image recording via a memory interface 112 and connector 113. This is recorded on the
`memory card 120 along with a thumbnail of each image, date and time information on when each
`image was captured, date and time information on when each image was recorded, and file names for
`each image, which are used to index images. The memory card 120 is an external recording medium
`consisting of semiconductor memory.”); see also FIGs. 1, 2, 3.
`¶ 11 (“When operating in playback mode, image information in a memory card 120 (thumbnails, date
`and time information, file names, etc.) is read and displayed as image indexing information on the
`display 110 as shown in FIG. 4 (A) if the memory card 120 is connected to the connector 113
`(memory card slot) as indicated in Operation 1 (wired communication mode) in FIG. 3.”)
`¶ 13 (“As indicated in Operation 2 (wireless communication mode) in FIG. 3, power is supplied to the
`memory card 120 via the antenna 116 when the memory card 120 is brought close to or brought into
`contact with the antenna 116. At the same time, communication is established between the antenna
`116 and the memory card 120, and image information on the memory card 120 (thumbnails, date and
`time information, file names, etc.) is read via the modem 115. Because communication speeds via the
`antenna 116 are slower than via the connector 113, the volume of communication, that is, the amount
`of image information that can be read, is limited. The display of image information on the display 110
`is also different compared to when the image information is retrieved via the connector 113.”)
`¶ 15 (“The wired communication mode will be explained first. The wired communication mode is
`entered when connector 211 is connected to connector 113 in the imaging device 100. In the wired
`communication mode, control circuit 213 controls the entire card. Control circuit 213 communicates
`with the imaging device 100 via the communication interface 212, and writes data to and reads data
`from memory circuit 214 and memory circuit 221 in accordance with communication commands from
`the imaging device 100.”)
`¶ 20 (“Data to be sent from the imaging device 100 to the memory card 120 is modulated by the
`modulator 232 in the imaging device 100 and outputted wirelessly from the antenna 234. These
`wireless signals are received by the antenna 217 in the memory card 120, modulated by the
`demodulator 219, and the data from the imaging device 100 is supplied to the control circuit 220.
`Meanwhile, data to be sent from the control circuit 220 to the imaging device 100 is modulated by the
`modulator 218 in the memory card 120 and outputted wirelessly from the antenna 216. These wireless
`
`
`
`2
`
`Page 2 of 23
`
`

`

`’767
`Claim
`
`1.c
`
`Claim Element
`
`Prior Art: J.P Pat. App. No. JP2004350160A Suda
`
`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,
`
`signals are received by the antenna 233 in the imaging device 100, demodulated by the demodulator
`231, and the data from the memory card 120 is supplied to the CPU 107.”)
`Suda 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, Suda discloses:
`¶ 7 (“FIG. 1 is a schematic block diagram of an example of the present invention. Each unit in the
`imaging device 100 is connected via a bus 111, and each unit is controlled by a CPU 107.”)
`¶ 12 (“When the user has selected a specific image from the image indexing information and has
`issued a display command using the operating switches 105, the CPU 107 reads the compressed image
`data for the image from the memory card 120. The retrieved compressed image data is decompressed
`by the image compression/decompression device 106, and the image is displayed on the display 110.”)
`¶ 15 (“The wired communication mode will be explained first. The wired communication mode is
`entered when connector 211 is connected to connector 113 in the imaging device 100. In the wired
`communication mode, control circuit 213 controls the entire card. Control circuit 213 communicates
`with the imaging device 100 via the communication interface 212, and writes data to and reads data
`from memory circuit 214 and memory circuit 221 in accordance with communication commands from
`the imaging device 100.”)
`¶ 18 (“The wireless communication mode will now be explained. In wireless communication mode,
`control circuit 220 controls the entire card. In wireless communication mode, the memory card 120 is
`operated without establishing wired communication via the connector 211. Instead, wireless
`communication is established with the imaging device 100 via the antennas 216, 217.”); see also ¶¶
`20, 21, 25.
`¶ 29 (“The following is an explanation of the reading of data from the memory card 120. FIG. 6 shows
`the operational algorithm of the CPU 107 when image information on the memory card is displayed
`by the imaging device 100 on the display 110 in wired communication mode and wireless
`communication mode.”); see also FIG. 6.
`¶ 36 (“The following is an explanation of other operations performed to read data from the memory
`card 120. FIG. 7 shows the operational algorithm of the CPU 107 when image information on the
`
`
`
`3
`
`Page 3 of 23
`
`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: J.P Pat. App. No. JP2004350160A Suda
`
`memory card is displayed by the imaging device 100 on the display 110 in wireless communication
`mode.”); see also FIG. 7.
`¶ 40 (“FIG. 8 shows the operational algorithm of the CPU 107 when image information on the
`memory card 120 is displayed by the imaging device 100 on the display 110 in wired communication
`mode and wireless communication mode.”); see also FIG. 8.
`To the extent 35 U.S.C. § 112, ¶6 applies, Suda 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.
`Suda 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. elements 1.a, 1.c.
`In addition, Suda discloses:
`¶¶ 24-26 (“The startup sequence for the memory card 120 will now be explained with reference to
`FIG. 9. Beginning from S901, it is determined in S902 whether or not power is being supplied via the
`connector 211. If power is being supplied via the connector 211 (Y), the process advances to S903. If
`power is not being supplied (N), the process advances to S907. In S903, power is supplied from power
`supply circuit 215 via the connector 211 to block 202, memory circuit 214, and memory circuit 221.
`Control circuit 213 is started up in S904, and data is read from and written to memory circuit 221 and
`memory circuit 214 and wired communication conducted with external units under the control of
`control circuit 213 in S905. This is the process for transitioning to wired communication mode (S906).
`If the result is N in S902, it is determined in S907 whether or not power is being supplied by
`electromagnetic induction via the antenna 217. If power is being supplied (Y), the process advances to
`S908. If power is not being supplied (N), the process advances to S912. In S908, power is supplied
`from power supply circuit 223 via the antenna 217 to block 223 and memory circuit 221. Control
`circuit 220 is started up in S909, and data is read from and written to memory circuit 221 and wireless
`
`4
`
`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
`
`1.d
`
`
`
`Page 4 of 23
`
`

`

`’767
`Claim
`
`Claim Element
`
`with the external device if the
`class of the external device
`indicated by the class
`information is not the
`predetermined class.
`
`Prior Art: J.P Pat. App. No. JP2004350160A Suda
`
`communication conducted with external units under the control of control circuit 220 in S910. This is
`the process for transitioning to wireless communication mode (S911). If the result is N in S907, the
`card is turned OFF in S912.”)
`¶¶ 36-39 (“The following is an explanation of other operations performed to read data from the
`memory card 120. FIG. 7 shows the operational algorithm of the CPU 107 when image information on
`the memory card is displayed by the imaging device 100 on the display 110 in wireless
`communication mode. Beginning from S701, it is determined in S702 whether a connection has been
`established with memory card #1 in wireless communication mode. If the card has not been connected
`in wireless mode (N), the process advances to S702. If the card has been connected wirelessly (Y), the
`process advances to S703. Image information is read from memory circuit 221 in memory card #1 and
`displayed on display 110 in S703. In S704, it is determined whether or not the wireless connection
`with memory card #1 has been interrupted. If the wireless connection has not been interrupted (N), the
`process returns to S703. If the wireless connection has been interrupted (Y), the process advances to
`S705. In S705, it is determined whether a wireless connection has been established with another
`memory card #3. If a wireless connection has been established (Y), the process advances to S707. If
`not (N), the process advances to S706. In S706, the process enters standby for a predetermined period
`of time T1. If predetermined period of time T1 has not been reached, the process returns to S705. If
`predetermined period of time T1 has been reached, the process advances to S707. In S707, the display
`of information recorded in memory circuit 221 of image recording card #1 is ended. In other words,
`when communication has been interrupted and there is more information to display on the display 110
`after communication is re-established, the display of information is ended even while displayed during
`the predetermined period of time (T1). However, when there is no more information to display as
`communication has not been re-established, the information continues to be displayed for
`predetermined period of time (T1).”)
`¶¶ 40-42 (“The following is an explanation of other operations performed to read data from the
`memory card 120. FIG. 8 shows the operational algorithm of the CPU 107 when image information on
`the memory card 120 is displayed by the imaging device 100 on the display 110 in wired
`communication mode and wireless communication mode. Beginning from S801, it is determined in
`S802 whether or not memory card #1 has been connected in wireless communication mode. If the card
`has not been connected in wireless mode (N), the process advances to S803. If the card has been
`connected wirelessly (Y), the process advances to S805. In S803, it is determined whether or not
`memory card #2 has been connected in the card slot in wired communication mode. If the card has
`been connected in wired mode (Y), the process advances to S804. If the card has not been connected
`
`
`
`5
`
`Page 5 of 23
`
`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: J.P Pat. App. No. JP2004350160A Suda
`
`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.
`
`in wired mode (N), the process advances to S802. In S804, image information is retrieved from
`memory circuit 221 and memory circuit 214 in memory card #2 and displayed on the display 110.”)
`To the extent that Plaintiff alleges that Suda 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 in view of the references identified in Exhibits C1-C14 and O3.
`To the extent 35 U.S.C. § 112, ¶6 applies, Suda 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.
`
`Suda discloses a display apparatus characterized in that the predetermined class is a class of a device
`which logically disconnects a communication connection.
`For example, Suda discloses:
`¶ 5 (“In order to achieve this object, the present invention provides an imaging device comprising a
`wired communication means able to conduct wired communication with a memory card, a wireless
`communication means able to conduct wireless communication with a memory card, and a display
`means for displaying an image, wherein the imaging device continues to display image information
`from a first memory card for a first predetermined period of time when wireless communication with
`the first memory card has been interrupted while reading and displaying image information from the
`first memory card using the wireless communication means.”)
`¶ 14 (“FIG. 2 is a schematic block diagram of a memory card 120 and the communication units in the
`imaging device 100. The memory card 120 may be accessed in wired communication mode or
`wireless communication mode.”); see also FIGs. 1, 2, 9 ¶¶ 8, 10, 25.
`To the extent that Plaintiff alleges that Suda 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 in view of the references identified in Exhibits C1-C14 and O3.
`To the extent 35 U.S.C. § 112, ¶6 applies, Suda 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.
`
`
`
`6
`
`Page 6 of 23
`
`

`

`’767
`Claim
`3.pre
`
`3.a
`
`Claim Element
`
`Prior Art: J.P Pat. App. No. JP2004350160A Suda
`
`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.
`
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Suda 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, Suda discloses:
`¶ 5 (“In order to achieve this object, the present invention provides an imaging device comprising a
`wired communication means able to conduct wired communication with a memory card, a wireless
`communication means able to conduct wireless communication with a memory card, and a display
`means for displaying an image, wherein the imaging device continues to display image information
`from a first memory card for a first predetermined period of time when wireless communication with
`the first memory card has been interrupted while reading and displaying image information from the
`first memory card using the wireless communication means.”)
`¶ 14 (“FIG. 2 is a schematic block diagram of a memory card 120 and the communication units in the
`imaging device 100. The memory card 120 may be accessed in wired communication mode or
`wireless communication mode.”); see also FIGs. 1, 2, 9 ¶ 25.
`¶¶ 40-42 (“The following is an explanation of other operations performed to read data from the
`memory card 120. FIG. 8 shows the operational algorithm of the CPU 107 when image information on
`the memory card 120 is displayed by the imaging device 100 on the display 110 in wired
`communication mode and wireless communication mode. Beginning from S801, it is determined in
`S802 whether or not memory card #1 has been connected in wireless communication mode. If the card
`has not been connected in wireless mode (N), the process advances to S803. If the card has been
`connected wirelessly (Y), the process advances to S805. In S803, it is determined whether or not
`memory card #2 has been connected in the card slot in wired communication mode. If the card has
`been connected in wired mode (Y), the process advances to S804. If the card has not been connected
`in wired mode (N), the process advances to S802. In S804, image information is retrieved from
`memory circuit 221 and memory circuit 214 in memory card #2 and displayed on the display 110.”)
`To the extent that Plaintiff alleges that Suda 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 in view of the references identified in Exhibits C1-C14 and O3.
`
`
`
`7
`
`Page 7 of 23
`
`

`

`’767
`Claim
`
`4.pre
`
`4.a
`
`Claim Element
`
`Prior Art: J.P Pat. App. No. JP2004350160A Suda
`
`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 35 U.S.C. § 112, ¶6 applies, Suda 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.
`
`Suda 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, Suda discloses:
`¶¶ 36-39 (“The following is an explanation of other operations performed to read data from the
`memory card 120. FIG. 7 shows the operational algorithm of the CPU 107 when image information on
`the memory card is displayed by the imaging device 100 on the display 110 in wireless
`communication mode. Beginning from S701, it is determined in S702 whether a connection has been
`established with memory card #1 in wireless communication mode. If the card has not been connected
`in wireless mode (N), the process advances to S702. If the card has been connected wirelessly (Y), the
`process advances to S703. Image information is read from memory circuit 221 in memory card #1 and
`displayed on display 110 in S703. In S704, it is determined whether or not the wireless connection
`with memory card #1 has been interrupted. If the wireless connection has not been interrupted (N), the
`process returns to S703. If the wireless connection has been interrupted (Y), the process advances to
`S705. In S705, it is determined whether a wireless connection has been established with another
`memory card #3. If a wireless connection has been established (Y), the process advances to S707. If
`not (N), the process advances to S706. In S706, the process enters standby for a predetermined period
`of time T1. If predetermined period of time T1 has not been reached, the process returns to S705. If
`predetermined period of time T1 has been reached, the process advances to S707. In S707, the display
`of information recorded in memory circuit 221 of image recording card #1 is ended. In other words,
`when communication has been interrupted and there is more information to display on the display 110
`after communication is re-established, the display of information is ended even while displayed during
`the predetermined period of time (T1). However, when there is no more information to display as
`communication has not been re-established, the information continues to be displayed for
`predetermined period of time (T1).”)
`
`
`
`8
`
`Page 8 of 23
`
`

`

`’767
`Claim
`
`5.pre
`
`5.a
`
`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.
`
`6.pre
`
`The display apparatus
`according to claim 1,
`
`
`
`Claim Element
`
`Prior Art: J.P Pat. App. No. JP2004350160A Suda
`
`To the extent that Plaintiff alleges that Suda 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 in view of the references identified in Exhibits C1-C14 and O3.
`Defendants incorporate by reference their contentions relating to claim 4, as if fully set forth herein.
`
`Suda 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, Suda discloses:
`¶¶ 48-49 (“In S815, standby is entered for a predetermined period of time T3. If standby in
`predetermined period of time T3 has not ended (N), the process returns to S812. If standby in
`predetermined period of time T3 has ended (Y), the process returns to S816. In S816, the display of
`information recorded in memory circuit 221 in image recording card #1 is ended. In other words, this
`takes priority when the main unit is operated during a wireless communication, and information
`manipulated by the operation is displayed for a predetermined period of time (T4). When there is more
`information to be displayed after wireless communication has been interrupted, the previous display of
`information ends immediately. When there is no more information to be displayed after wireless
`communication has been interrupted, the display of information continues for a predetermined period
`of time (T3). When the main unit is operated while this information is being displayed, the display of
`information during the predetermined period of time (T3) is cancelled.”); see also 5, 14, 40-47.
`To the extent that Plaintiff alleges that Suda 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 in view of the references identified in Exhibits C1-C14 and O3.
`To the extent 35 U.S.C. § 112, ¶6 applies, Suda 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.
`
`9
`
`Page 9 of 23
`
`

`

`’767
`Claim
`
`6.a
`
`Claim Element
`
`Prior Art: J.P Pat. App. No. JP2004350160A Suda
`
`characterized by further
`comprising:
`a detection unit configured to
`detect whether or not the
`external device is physically
`connected to said connection
`unit,
`
`Suda discloses a detection unit configured to detect whether or not the external device is physically
`connected to said connection unit.
`For example, Suda discloses:
`¶ 9 (“The compressed image data is stored temporarily in RAM 108 and recorded on a memory card
`120 for image recording via a memory interface 112 and connector 113. This is recorded on the
`memory card 120 along with a thumbnail of each image, date and time information on when each
`image was captured, date and time information on when each image was recorded, and file names for
`each image, which are used to index images. The memory card 120 is an external recording medium
`consisting of semiconductor memory.”); see also FIGs. 1, 2, 3.
`¶ 11 (“When operating in playback mode, image information in a memory card 120 (thumbnails, date
`and time information, file names, etc.) is read and displayed as image indexing information on the
`display 110 as shown in FIG. 4 (A) if the memory card 120 is connected to the connector 113
`(memory card slot) as indicated in Operation 1 (wired communication mode) in FIG. 3.”)
`¶ 15 (“The wired communication mode will be explained first. The wired communication mode is
`entered when connector 211 is connected to connector 113 in the imaging device 100. In the wired
`communication mode, control circuit 213 controls the entire card. Control circuit 213 communicates
`with the imaging device 100 via the communication interface 212, and writes data to and reads data
`from memory circuit 214 and memory circuit 221 in accordance with communication commands from
`the imaging device 100.”); see also FIG. 9, ¶ 24.
`¶ 33 (“In S607, it is determined whether or not memory card #2 has been inserted into the card slot
`and a connection established in wired communication mode. If a wired connection has been
`established (Y), the process advances to S608. If a wired connection has not been established (N), the
`process advances to S610.”)
`To the extent 35 U.S.C. § 112, ¶6 applies, Suda 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.
`
`
`
`10
`
`Page 10 of 23
`
`

`

`’767
`Claim
`
`6.b
`
`Claim Element
`
`Prior Art: J.P Pat. App. No. JP2004350160A Suda
`
`characterized in that if said
`detection unit 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.
`
`To the extent that Plaintiff alleges that Suda 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 in view of the references identified in Exhibits C1-C14 and O3.
`Suda 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.
`For example, Suda discloses:
`¶¶ 30-31 (“Beginning from S601, it is determined in S602 whether or not a memory card #1 has been
`connected in wireless communication mode. (In order to differentiate between multiple memory cards,
`the cards are numbered #1, #2 and #3 below.) If a card has not been connected in wireless mode (N),
`the process advances to S603. If a card has been connected wirelessly (Y), the process advances to
`S605. In S603, it is determined whether or not another memory card #2 has been connected in the
`card slot in wired communication mode. If a card has been connected in wired mode (Y), the process
`advances to S604. If a card has not been connected in wired mode (N), the process advances to S602.
`In S604, image information is retrieved from memory circuit 221 and memory circuit 214 in memory
`card #2 and displayed on the display 110.”)
`¶¶ 40-42 (“The following is an explanation of other operations performed to read data from the
`memory card 120. FIG. 8 shows the operational algorithm of the CPU 107 when image information on
`the memory card 120 is displayed by the imaging device 100 on the display 110 in wired
`communication mode and wireless communication mode. Beginning from S801, it is determined in
`S802 whether or not memory card #1 has been connected in wireless communication mode. If the card
`has not been connected in wireless mode (N), the process advances to S803. If the card has been
`connected wirelessly (Y), the process advances to S805. In S803, it is determined whether or not
`memory card #2 has been connected in the card slot in wired communication mode. If the card has
`been connected in wired mode (Y), the process advances to S804. If the card has not been connected
`in wired mode (N), the process advances to S802. In S804, image information is retrieved from
`memory circuit 221 and memory circuit 214 in memory card #2 and displayed on the display 110.”)
`To the extent 35 U.S.C. § 112, ¶6 applies, Suda 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.
`
`
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`11
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`Page 11 of 23
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`

`

`’767
`Claim
`
`7.pre
`
`7.a
`
`Claim Element
`
`Prior Art: J.P Pat. App. No. JP2004350160A Suda
`
`The display apparatus
`according to claim 6,
`characterized in that said
`control unit controls to end
`the display after a
`predete