TCL’S INVALIDITY CONTENTIONS FOR U.S. 8,078,767
`Exhibit O3: Prior Art References Under 35 U.S.C. § 103
`
`To the extent that Plaintiff asserts that any reference charted in these Invalidity Contentions does not disclose a given patent claim
`element, it would have been obvious to combine such reference with the knowledge of a person of ordinary skill in the art, any of the
`references identified herein as disclosing the element, Applicant’s Admitted Prior Art, and/or the additional prior art references in
`Exhibits C1-C14, the contents of which are hereby incorporated by reference into this chart. One of ordinary skill in the art would
`have been motivated to, and would have understood how to, combine any of these disclosures based on the background knowledge of
`a person of ordinary skill in the art and the teachings from these references, as well as the exemplary motivations identified in these
`Invalidity Contentions.
`
`To the extent 35 U.S.C. § 112, ¶6 applies to any of the claim limitations of the Asserted Claims, the art cited herein also discloses the
`corresponding structure(s) and function(s) claimed or their equivalents, as shown below, or renders them obvious in view of the
`knowledge of one skilled in the art.
`
`
`Claim Element
`
`’767
`Claim
`1.pre A display apparatus
`characterized by comprising:
`
`Obviousness Combinations1,2
`
`To the extent that the preamble is construed as a limitation, this element was well-known as of the
`priority date of the ’767 patent.
`See, element 1.pre in Exhibits C1-C14.
`See, e.g., elements 1.a – 1.d.
`This element was well-known as of the priority date of the ’767 patent.
`See, element 1.a in Exhibits C1-C14.
`JP 2007206408A (“Ariga”):
`¶[0001] (“The present invention relates to a projector and a notification method for determining
`whether or not a cable is connected and notifying it.”)
`
`1.a
`
`a display unit;
`
`
`1 Defendants incorporate herein any related work performed by or on behalf of an author or an inventor in the United States under 35 U.S.C. § 102(g). Discovery
`in this case is ongoing and, accordingly, this invalidity chart is not to be considered final. Defendants reserve the right to supplement and/or alter this chart based
`on further investigation and ongoing discovery.
`2 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.
`
`
`
`1
`
`Page 1 of 72
`
`CANON EXHIBIT 2007
`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00341
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`¶[0050] (“Further, as the projector 10, for example, various projectors (front projection type
`projection devices) such as a liquid crystal projector, a projector using a DMD, and a CRT
`projector can be adopted.”)
`U.S. Patent No. 7,760,232 (“Takashima”):
`7:36-49 (“Next, FIG. 2 is a block diagram showing the configuration of a digital camera 110 and
`its vicinity according to Embodiment 1 of the present invention. As shown in FIG. 2, in the digital
`camera 110, imaging means 111 is means of imaging an object and thereby acquiring image data.
`Image processing means 112 is means of processing the image data acquired by the imaging means
`111, into data capable of being displayed and stored. A memory card 113 is means of storing the
`image data. A liquid crystal display monitor 114 is means of displaying the contents of the
`acquired image data as well as the operation and function of the digital camera 110. System
`controlling means 115 is means of controlling the image processing means 112, and operates on the
`basis of an input from operating means 116 of receiving a user operation.”)
`8:27-33 (“The operation of the digital camera 110 according to Embodiment 1 of the present invention
`having the above configuration is described below with reference to the flow chart of FIG. 4 as well as
`the schematic operation diagram of FIG. 5 for a liquid crystal display monitor 114. At the same
`time, described is an embodiment of a communication setting method of the present invention.”)
`U.S. Patent Pub. No. 2006/0248192 (“Morris”):
`¶[0011] (“Referring to the drawings, FIG. 1 shows a digital display 1 having a local storage,
`whereby the display is capable of storing a plurality of digital images and associated information
`so that the images can be sequentially displayed in a predetermined order. The digital display 1
`may be any suitable device with storage and internet compatibility such as that sold commercially as
`MEMORY FRAME by Pacific Digital Corporation of Irvine, Calif. By way of example, digital
`images, such as photographs, may be prepared and uploaded to display 1 from a workstation 10 by
`way of a USB or ethernet link 12. The digital display 1 may be conveniently located on a desk, table,
`or similar stand, in a home or office to display the stored digital images one at a time at a
`preprogrammed rate. In this case, the digital images are displayed as slides 3, 5, 7 and 9 in a
`continuously running slide show.”); see also ¶[0012]
`U.S. Patent No. 7,134,077 (“Sellen”):
`2:31-63 (“Referring now to FIG. 1, a text processing system includes first and second text-editing
`units, in this example provided by a personal-type computer unit 10 and an auxiliary screen unit
`2
`
`
`
`Page 2 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`20….[¶] The auxiliary screen unit 20 essentially functions, from the user's point of view, as an
`independent word processor having limited user-interaction. The auxiliary screen unit 20 has
`limited memory and processing capability (which will be described in more detail subsequently)
`sufficient to enable the running of a text-processing program, typically a cut-down version of the word
`processing package running on the computer unit 10 (i.e. uses the same or similar commands, and the
`same or similar text format control characters), although this is not essential provided that the cut-
`down word processing package is not incompatible with the word processing package on the computer
`unit 10. Interaction with the screen 22 of the auxiliary screen unit (e.g. inputting and editing of
`text) is achieved by means of a touch-sensitive screen 22 and stylus 24; the latter being a tool
`held by a user to touch the screen.”)
`U.S. Patent Pub. No. 2006/0242362 (“Hanes”):
`¶[0017] (“The chipset 14 is coupled to the I/O bus 24. The I/O bus 24 serves as a communication
`pathway for signals from the chipset 14 to I/O devices 26, 27, 28, 30, 32, and 34. The I/O devices 26,
`27, 28, 30, 32, and 34 include external data storage devices, such as an external hard disk drive 26, an
`external data storage device 27, or a flash memory drive 28, as well as user interface devices, such as
`a mouse 30, a video display 32, or a keyboard 34. The external data storage device 27 may comprise
`any suitable type of external data storage device, such as a camera, a phone, or a memory card reader,
`that can be coupled to the computer system 10.”); see also FIG. 1.
`High-Definition Multimedia Interface Specification Version 1.3a (“HDMI Specification”):
`1 (This document constitutes the specification for the High-Definition Multimedia Interface (HDMI),
`version 1.3a. The High-Definition Multimedia Interface is provided for transmitting digital
`television audiovisual signals from DVD players, set-top boxes and other audiovisual sources to
`television sets, projectors and other video displays. HDMI can carry high quality multi-channel
`audio data and can carry all standard and highdefinition consumer electronics video formats. Content
`protection technology is available. HDMI can also carry control and status information in both
`directions.); see also 84.
`U.S. Patent No. 9,110,624 (“Herz ’624”):
`2:40-48 (“In one embodiment, the present invention is implemented as a method for restoring
`display output to a display device (e.g., LCD display, projection TV display, plasma display, and
`the like). The method includes detecting a display device connection change (e.g., connection or
`disconnection) on an output connector (e.g., HDMI, DVI, and the like) and in response output settings
`
`
`
`3
`
`Page 3 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`(e.g., resolution and/or refresh rate) are changed to a compatible output mode (e.g., NTSC standard
`480i, etc.) on the connected output connector.”); see also 12:43-46.
`U.S. Patent No. 6,442573 (“Schiller”):
`8:30-37 (“The present invention comprises one or more interconnected frame devices. A frame device
`is a self-configuring digital picture frame that obtains images for display and/or software from a data
`repository via an interconnection fabric (e.g. a computer network). Each frame device is configured to
`automatically interface with the data repository to obtain image data and to then display that data
`according to a set preference.”); see also 10:37-54, 10:64-11:17, Fig. 3.
`U.S. Patent Pub. No. 2006/0132437 (“Kim”):
`¶[0033] (“FIG. 1 is a control block diagram of a display apparatus according to a first embodiment of
`the present invention. As shown therein, a display apparatus according to the first embodiment of the
`present invention comprises a display part 20, a frame buffer 36 to store frame information
`corresponding to a video signal, and a video signal processor 30 that is controlled by a controller 60 to
`process the video signal transmitted from a computer main body (not shown) on the basis of the
`frame information stored in the frame buffer 36 so as to be displayed on the display part 20.”); see
`also ¶¶[0049]; [0062].
`Photographic and Imaging Manufacturers Association, Inc. – PIMA 15740:2000 (“PIMA”):
`p.24 (“This standard specifies how image and data objects are transferred between a digital still
`photography device (DSPD) and other devices, but it does not specify how they are stored within such
`devices. … In addition, if the receiving device displays images, it shall be capable of decoding and
`displaying both of the thumbnail image file formats defined in this clause.”).
`U.S. Patent No. 7,519,760 (“Morozumi”):
`1:6-15 (“The present invention also relates to a data input method and an image output system using
`such a data input device. A digital camera device photographs a subject and stores image data
`pertaining to the subject in a built-in recording medium as a data file. When the data file of the image
`data is fetched, terminal equipment, such as a personal computer, is connected to a digital camera
`device.”); see also 2:17-23.
`Universal Serial Bus Specification, Revision 2.0 (USB 2.0 Specification):
`Figure 4.4
`
`
`
`4
`
`Page 4 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`
`24 (“Each function contains configuration information that describes its capabilities and resource
`requirements. Before a function can be used, it must be configured by the host. This configuration
`includes allocating USB bandwidth and selecting function-specific configuration options.
`Examples of functions include the following:
`• A human interface device such as a mouse, keyboard, tablet, or game controller
`• An imaging device such as a scanner, printer, or camera
`• A mass storage device such as a CD-ROM drive, floppy drive, or DVD drive”)
`
`
`
`5
`
`Page 5 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`1.b
`
`a connection unit configured
`to connect an external device
`to be able to communicate
`with the external device; and
`
`’767 Patent, Applicant Admitted Prior Art (“AAPA”)
`’767 at 1:14-21 (“Conventionally, a display apparatus such as a projector . . .”), 1:26-28 (“FIG. 11A is
`a schematic view showing an overview when a flash memory 93 is connected to a conventional
`projector 91 to display an image.”), 1:34-2:51 (identifying projectors when describing background
`art), 3:9-12 (in describing background art: “The digital camera 94 has a liquid crystal panel screen
`9401. . . . The liquid crystal panel screen 9401 displays a preview of an image or the like transferred
`via the PictBridge.”), 5:15-17 (“As described above, the conventional display apparatus can be
`connected to various devices, and can display image data stored in a connected device.”).
`This element was well-known as of the priority date of the ’767 patent.
`See, element 1.b in Exhibits C1-C14.
`U.S. Patent No. 7,577,766 (“Ono”):
`3:33-37 (“FIG. 1 shows a configuration of an essential part of the inkjet recording apparatus according
`to the embodiment of the present invention. In FIG. 1, the inkjet recording apparatus includes a main
`body 101 and a CPU (central processing unit) 102 controlling the inkjet recording apparatus.”)
`3:58-67 (“The USB host controller 105 operates as a USB host and communicates with a USB
`device connected to a USB connector (type-A) 108 so as to transmit/receive data.
`In FIG. 1, the digital camera 301 and the USB memory 401 are shown as examples of the USB
`device connected to the USB connector 108.
`Typically, in a printer capable of performing direct printing from this type of digital camera 301, a
`driver of only a still image class may be provided for a path between the USB connector 108 and the
`USB host controller 105.”)
`
`
`
`6
`
`Page 6 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`
`
`Ariga:
`¶[0021] (“The projector 10 receives an image signal or the like from a notebook PC 20 which is a
`kind of external device via a cable 30 and projects an image based on the image signal.”)
`¶[0025] (“The projector 10 includes an interface unit 140 including a terminal to which the cable
`30 is connected, a connection determination unit 110 that determines whether the cable 30 is
`connected to the terminal, and whether an image signal or the like is input via the cable 30. When the
`determination result of the input determination unit 120 and the connection determination unit 110 for
`determining whether or not, and when the determination result of the connection determination unit
`110 is true and the determination result of the input determination unit 120 is false And a notification
`unit 130 that performs different notifications.”)
`
`
`
`7
`
`Page 7 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`¶[0042] (“As such a cable 30, for example, a cable having a D-SUB connector, a cable having a DVI-
`D connector, a USB cable, an IEEE 1394 cable, or the like can be adopted.”)
`Takashima:
`7:50-55 (“A communication connector 117 is a connector of connecting a USB cable 200. A USB
`control section 118 is means of controlling the connection state and the communication through
`the USB cable, and is controlled by the system controlling means 115. In practice, the USB control
`section 118 is embodied in a dedicated semiconductor chip or the like.”)
`Morris:
`¶[0011] (“Referring to the drawings, FIG. 1 shows a digital display 1 having a local storage,
`whereby the display is capable of storing a plurality of digital images and associated information
`so that the images can be sequentially displayed in a predetermined order. The digital display 1
`may be any suitable device with storage and internet compatibility such as that sold commercially as
`MEMORY FRAME by Pacific Digital Corporation of Irvine, Calif. By way of example, digital
`images, such as photographs, may be prepared and uploaded to display 1 from a workstation 10
`by way of a USB or ethernet link 12. The digital display 1 may be conveniently located on a desk,
`table, or similar stand, in a home or office to display the stored digital images one at a time at a
`preprogrammed rate. In this case, the digital images are displayed as slides 3, 5, 7 and 9 in a
`continuously running slide show.”)
`¶[0015] (“The foregoing dynamic method is accomplished by the digital display 1 connecting to at
`least one remote web server 14 at an internet connection so that the digital display 1 is adapted
`to retrieve digital images from across the internet. That is, more than the single web server 14 as
`shown in FIG. 1 may be utilized herein.”)
`Sellen:
`3:10-14 (“Both the computing and auxiliary screen unit 10, 20 include input/output ports 40, 42 to
`enable operable interconnection between. This interconnection may be by means of a tethered
`USB, by wireless connection such as “Bluetooth”, or IEEE802.11 Wireless Ethernet.”)
`Hanes:
`¶[0017] (“The chipset 14 is coupled to the I/O bus 24. The I/O bus 24 serves as a communication
`pathway for signals from the chipset 14 to I/O devices 26, 27, 28, 30, 32, and 34. The I/O devices
`26, 27, 28, 30, 32, and 34 include external data storage devices, such as an external hard disk
`8
`
`
`
`Page 8 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`drive 26, an external data storage device 27, or a flash memory drive 28, as well as user interface
`devices, such as a mouse 30, a video display 32, or a keyboard 34. The external data storage device
`27 may comprise any suitable type of external data storage device, such as a camera, a phone, or a
`memory card reader, that can be coupled to the computer system 10.”); see also FIG. 1.
`¶[0018] (“In one embodiment, the I/O bus 24 employs any one of a number of communications
`protocols to communicate with the I/O devices 26, 27, 28, 30, 32, and 34. External data storage
`devices communicate with the computer using an interface protocol. These interface protocols
`permit the computer to exchange information with the external data storage device. Acceptable
`communication protocols include, but are not limited to, universal serial bus (“USB”), USB-2,
`serial advanced technology attachment (“S-ATA”), IEEE-1394, small computer system interface
`(“SCSI”), integrated drive electronics (“IDE”), fiber channel, gigabit Ethernet, or Bluetooth.
`Various types of communication protocols can be implemented in the computer system 10. In one
`alternate embodiment, the I/O bus 24 is integrated into the chipset 14.”); see also ¶¶[0020]-[0021],
`[0023].
`HDMI Specification:
`1 (“This document constitutes the specification for the High-Definition Multimedia Interface (HDMI),
`version 1.3a. The High-Definition Multimedia Interface is provided for transmitting digital
`television audiovisual signals from DVD players, set-top boxes and other audiovisual sources to
`television sets, projectors and other video displays. HDMI can carry high quality multi-channel
`audio data and can carry all standard and highdefinition consumer electronics video formats. Content
`protection technology is available. HDMI can also carry control and status information in both
`directions.”)
`8 (“HDMI carries a VESA DDC channel. The DDC is used for configuration and status exchange
`between a single Source and a single Sink. The optional CEC protocol provides high-level control
`functions between all of the various audiovisual products in a user’s environment.”)
`10 (“A device’s external HDMI connection shall be presented via one of the three specified HDMI
`connectors, Type A, Type B or Type C. This connector can be attached directly to the device or can be
`attached via a cable adapter that is shipped with the device.”)
`Herz ’624:
`
`
`
`9
`
`Page 9 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`2:40-48 (“In one embodiment, the present invention is implemented as a method for restoring display
`output to a display device (e.g., LCD display, projection TV display, plasma display, and the like).
`The method includes detecting a display device connection change (e.g., connection or
`disconnection) on an output connector (e.g., HDMI, DVI, and the like) and in response output
`settings (e.g., resolution and/or refresh rate) are changed to a compatible output mode (e.g.,
`NTSC standard 480i, etc.) on the connected output connector.”); see also 7:4-8; 7:41-45; 12:52-
`59.
`U.S. Patent No. 5,027,269 (“Grant”):
`4:35-42 (“In the communication services component 30, a session control block (SCB) 32 and
`memory 34 for recording the session state information are maintained. Address space 20 depicts a
`recovery (alternate) instance for Lux. The connection labeled 22 in FIG. 1A depicts the session
`appearance in address space 10 when processing is proceeding normally.”); see also 4:42-51; Figs.
`1A, 1B.
`4:52-59 (“Depending on the type of recovery, address space 20 can be viewed as a restarted version of
`Lux in address space 10, as another address space that contains a local alternate, or as an alternate in
`another host system. In the latter case, the connection between the communication services 30 and the
`address space that contained the active logical unit requires a communication access via a channel,
`bus, or high speed link.”).
`Schiller:
`8:45-50 (“For example, each frame device is programmed to automatically configure itself with out
`obtaining input form the user. So long as the frame device is connected to a power source and a
`communication source it may remain operational without obtaining input from the user.”); see also
`9:13-29.
`12:41-50 (“Communication interface 340 provides a two-way data communication coupling via a
`network link 341 to interconnection fabric 342. Communication interface 340 may be implemented in
`software or hardware form. In one or more embodiments of the invention, data communication
`interface provides a codec for optimizing data throughput to network link 341. Interconnection fabric
`342 represents any type of network configured to transmit data. For example, interconnection fabric
`342 may represent the Internet or any other type of easily accessible computer network.”); see also
`12:51-67; 13:51-64.
`
`
`
`10
`
`Page 10 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`Kim:
`¶[0034] (“Here, the computer main body communicates with the display apparatus through a digital
`connection port (not shown).”); see also ¶[0064].
`PIMA:
`p. iv (“For the purposes of this standard, digital still photography devices (DSPDs) are defined as
`devices with persistent storage that capture a digital two-dimensional image at a discrete point in time.
`Most DSPDs include interfaces that can be used to connect to a host computer or other imaging
`devices, such as a printer.”).
`Morozumi:
`2:20-23 (“providing a first device comprising a communicator having a first interface function and a
`second interface function defined in an asymmetric interface standard; connecting a second device to
`the first device; detecting whether the second device has at least one of the first interface function and
`the second interface function; and transmitting a signal for processing the data, from the first device to
`the second device, through use of the second interface function, in a case where it is detected that the
`second device has the first interface function.”); see also 3:18-31; 4:35-54; 20:40-45; 23:7-21.
`8:64-9:5 (“Fig. 1 shows a digital camera device serving as a data input device according to a first
`embodiment of the invention. In this digital camera device 1, an image capturer 11 is constituted of an
`optical system, such as a lens, and an image capturing element; e.g., a CCD (Charge-Couple Device).
`A display 12 is such as a liquid crystal display used for displaying a menu and a finder and for
`browsing a captured image. A control panel 13 is constituted of button switches, used for selecting
`menu items, for executing the image caption or the like.”).
`10:45-48 (“The descriptors of the USB correspond to data including information about pieces of
`equipment of respective USB devices and are transmitted to the USB host when the USB equipment is
`connected to the digital camera device 1.”); see also 10:48-53; 10:59-11:16.
`USB 2.0 Specification:
`Figure 4.4
`
`
`
`11
`
`Page 11 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`
`24 (“A function is a USB device that is able to transmit or receive data or control information over the
`bus. A function is typically implemented as a separate peripheral device with a cable that plugs into a
`port on a hub. However, a physical package may implement multiple functions and an embedded hub
`with a single USB cable. This is known as a compound device. A compound device appears to the
`host as a hub with one or more non-removable USB devices.
`Each function contains configuration information that describes its capabilities and resource
`requirements. Before a function can be used, it must be configured by the host. This configuration
`includes allocating USB bandwidth and selecting function-specific configuration options.
`Examples of functions include the following:
`
`
`
`12
`
`Page 12 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`• A human interface device such as a mouse, keyboard, tablet, or game controller
`• An imaging device such as a scanner, printer, or camera
`• A mass storage device such as a CD-ROM drive, floppy drive, or DVD drive”)
`Apple TV Setup Guide
`Pgs. 9-11
`
`
`“Ethernet port - If you connect to your network using Ethernet, connect an Ethernet cable…Built-in
`Wi-Fi/AirPort wireless - Connect Apple TV to your wireless network.”
`AAPA
`’767 at 1:14-21 (“Conventionally, a display apparatus such as a projector is connected to various
`devices via, for example, USB (Universal Serial Bus), and displays image data transmitted from these
`connected devices. Various devices connected to the display apparatus include a semiconductor
`memory device such as a flash memory device, a PC (Personal Computer), a digital still camera (to be
`referred to as a “digital camera” hereinafter), and the like.”), 1:26-28 (in describing the prior art,
`disclosing that: “FIG. 11A is a schematic view showing an overview when a flash memory 93 is
`connected to a conventional projector 91 to display an image.”), 1:34-47 (“As shown in FIG. 11A, the
`projector 91 has the control panel 9101 and a USB connector 9102. . . . The USB connector 9102
`receives the flash memory 93 having a USB connection terminal. This flash memory 93 stores image
`data to be displayed by the projector 91. By the user plugging the flash memory 93 into the USB
`
`
`
`13
`
`Page 13 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`connector 9102 and operating the control panel 9101, he or she can browse image data stored in the
`flash memory 93 as an image 921 on the screen 92.”), 1:61-65 (in describing the prior art, disclosing
`that “the user connects the flash memory 93 to the USB connector 9102. In step S202, a USB
`communication is established based on the USB standard between the projector 91 and flash memory
`93 which are physically connected via the USB connector 9102.”), 3:7-9 (in describing the prior art,
`disclosing that: “To the USB connector 9602, the digital camera 94 is connected via a USB cable.”),
`3:26-30 (“In step S500, the user connects the digital camera 94 and printer 96 via the USB cable 95. In
`step S501, a USB communication is established based on the USB standard between the digital
`camera 94 and printer 96 which are physically connected via the USB cable 95.”), 3:33-39 (“In step
`S502, a PictBridge connection is established between the digital camera 94 and printer 96. More
`specifically, a connection is established in a PTP (Picture Transfer Protocol) layer, device information
`is exchanged, and so forth. Then, a communication state as a PictBridge sequence transits to an idle
`state, and the printer 96 waits for issuance of a print job by the digital camera 94.”), 5:15-17 (“As
`described above, the conventional display apparatus can be connected to various devices, and can
`display image data stored in a connected device.”).
`This element was well-known as of the priority date of the ’767 patent.
`See, element 1.c in Exhibits C1-C14.
`Ono:
`3:33-37 (“FIG. 1 shows a configuration of an essential part of the inkjet recording apparatus according
`to the embodiment of the present invention. In FIG. 1, the inkjet recording apparatus includes a main
`body 101 and a CPU (central processing unit) 102 controlling the inkjet recording apparatus.”)
`3:50-57 (“The CPU 102 controls the entire inkjet recording apparatus in accordance with a
`control program of a user mode stored in the ROM 104 (or a control program of a factory mode stored
`in a USB memory 401 described below). Accordingly, the CPU 102 controls a recording operation
`of allowing a recording unit (not shown) to record image data transmitted from a PC (personal
`computer) 201 connected to the inkjet recording apparatus or from a digital camera 301.”)
`
`1.c
`
`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,
`
`
`
`14
`
`Page 14 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`
`
`Ariga:
`¶[0021] (“The projector 10 receives an image signal or the like from a notebook PC 20 which is a
`kind of external device via a cable 30 and projects an image based on the image signal.”)
`¶[0027] (“For example, the following can be used as hardware for implementing the functions of the
`above described units. For example, the interface unit 140 is an input / output unit such as a terminal,
`a sensor that detects the pressure sensitivity of the terminal, the connection determination unit 110, the
`input determination unit 120 is a CPU, the image processing unit 132 is an image processing
`circuit, or the like. As the unit 134, a liquid crystal panel, a lamp, a driver, or the like can be used.”)
`Takashima:
`
`
`
`15
`
`Page 15 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`7:50-55 (“A communication connector 117 is a connector of connecting a USB cable 200. A USB
`control section 118 is means of controlling the connection state and the communication through the
`USB cable, and is controlled by the system controlling means 115. In practice, the USB control
`section 118 is embodied in a dedicated semiconductor chip or the like.”)
`8:59-9:4 (“In response to the notification code, the external device 300 transmits a command of mass
`storage class. The digital camera 110 receives this command (Yes in S4), and then continues the
`communication in the mass storage class (S10). At that time, on the basis of the control of the USB
`control section 118, the system controlling means 115 displays a screen shown in FIG. 5( c) onto
`the liquid crystal display monitor 114, and thereby notifies the user of the communication state
`of the digital camera 110. After that, once the communication is established between the digital
`camera 110 and the personal computer 720 or the printer A 730, the personal computer 720 or the
`printer A 730 can process image data in the memory card 113 in the digital camera 110.”)
`
`
`10:15-25 (“Then, in response to this new communication code, the printer B 740 transmits a command
`of imaging class. The digital camera 110 receives this command (Yes in S8), and then continues the
`communication in the imaging class (S9). At that time, the digital camera displays a screen shown
`in FIG. 5(d) onto the liquid crystal display monitor 114, and thereby notifies the user of the
`communication state of the digital camera 110. After that, once the communication is established
`
`
`
`16
`
`Page 16 of 72
`
`

`

`’767
`Claim
`
`Claim Element
`
`Obviousness Combinations1,2
`
`between the digital camera 110 and the printer B 740, the printer B 740 can process image data in the
`memory card 113 in the digital camera 110.”)
`
`
`
`Morris:
`¶[0011] (“Referring to the drawings, FIG. 1 shows a digital display 1 having a local storage,
`whereby the display is capable of storing a plurality of digital images and associated information
`so that the images can be sequentially displayed in a predetermined order. The digital display 1
`may be any suitable device with storage and internet compatibility such as that sold commercially as
`MEMORY FRAME by Pacific Digital Corporation of Irvine, Calif. By way of example, digital
`images, such as photographs, may be prepared and uploaded to display 1 from a workstation 10
`by way of a USB or ethernet link 12. The digital display 1 may be conveniently located on a desk,
`table, or similar stand, in a home or office to display the stored digital images one at a time at a
`preprogrammed rate. In this case, the digit