TCL’S INVALIDITY CONTENTIONS FOR U.S. 8,346,986
`Exhibit D6: U.S. Patent No. 8,078,766 (“Takenaka”)
`
`
`
`As demonstrated in the claim charts below, the asserted claims of U.S. Patent No. 8,346,986 (“the ’986 patent”) are invalid (a) under
`one or more sections of 35 U.S.C. § 102 as anticipated by Takenaka and (b) under 35 U.S.C. § 103(a) as obvious over Takenaka
`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 D1-D14, and O4, 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 ’986 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: U.S. Pat. No. 8,078,766 (“Takenaka”)
`
`Takenaka discloses a display apparatus.
`See, e.g., elements 1.a – 1.d.
`Takenaka discloses a communication unit configured to communicate with an external device.
`For example, Takenaka discloses:
`4:35-40 (“The image changeover unit 131 is connected to an external input terminal 123, through
`which an external device transmits any image signal VSc such as a composite signal, a component
`signal, high definition multimedia interface (HDMI) signal, digital visual interface (DVI) signal, to
`the image changeover unit 131.”)
`6:20-31 (“A USB interface unit 153 is also connected to the bus 154. The USB interface unit 153 is
`constituted of a USB transceiver for executing any serial communication with connected external
`device, serial interface engine (SIE) for executing communication control processing corresponding to
`USB protocol, and the like. The control unit 151 communicates the USB interface unit 153 and when
`detecting that an external device connects the USB interface unit 153, the control unit 151 executes a
`
`’986
`Claim
`1.pre
`
`Claim Element
`
`A display apparatus
`comprising:
`
`1.a
`
`a communication unit
`configured to communicate
`with an external device;
`
`
`
`1
`
`Page 1 of 17
`
`CANON EXHIBIT 2004
`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00342
`
`

`

`1.b
`
`a display unit configured to
`display an image received
`from the external device;
`
`configuration setting to read out address setting of the connected external device and various kinds of
`pieces of information stored in the connected external device.”); see also 6:42-52.
`To the extent that Plaintiff alleges that Takenaka 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 D1-D14, and
`O4.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takenaka 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.
`Takenaka discloses a display unit configured to display an image received from the external device.
`For example, Takenaka discloses:
`5:20-24 (“The image-output-processing unit 135 is connected to an image display unit 136 which is
`constituted of any display device such as liquid crystal display (LCD), plasma display panel (PDP),
`electro luminescence (EL), and cathode ray tube. The image-output-processing unit 135 generates a
`display drive signal DRv for driving the display device based on the image output signal VSg and
`supplies the display drive signal DRv to the image display unit 136. This enables the image display
`unit 136 to display an image. The image-output-processing unit 135 outputs the image output signal
`VSg as an output signal Vout having any format corresponding to an external device, not shown,
`when the image-output-processing unit 135 supplies an image signal to the external device.”); see
`also FIG. 1, 3:15-33, 4:35-40
`6:26-38 (“The control unit 151 communicates the USB interface unit 153 and when detecting that an
`external device connects the USB interface unit 153, the control unit 151 executes a configuration
`setting to read out address setting of the connected external device and various kinds of pieces of
`information stored in the connected external device. When detecting that an external device is USB
`device that can correspond to the apparatus of displaying the image (the television receiver) based on
`the read information, the control unit 151 communicates this external device to read the image data
`VSusb out of the external device and supply it to the image changeover unit 131, thereby enabling
`image stored in the external device to be displayed on the image display unit 136.”); see also 6:20-25.
`To the extent that Plaintiff alleges that Takenaka 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 D1-D14, and
`O4.
`
`
`
`2
`
`Page 2 of 17
`
`

`

`a storing unit configured to
`store information for
`controlling whether or not to
`continue the display of the
`image being displayed by the
`display unit when the
`communication is
`disconnected,
`wherein said information
`includes at least one of
`information indicating types
`of external devices for which
`display of an image should be
`continued and
`information indicating types
`of external devices for which
`display of an image should
`not be continued;
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Takenaka 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.
`Takenaka discloses a storing unit configured to store information for controlling whether or not to
`continue the display of the image being displayed by the display unit when the communication is
`disconnected, wherein said information includes at least one of information indicating types of
`external devices for which display of an image should be continued and information indicating types
`of external devices for which display of an image should not be continued.
`For example, Takasenaka discloses:
`2:15-21 (“According to an embodiment of the present invention, there is provided an apparatus of
`displaying an image that connects an external device by using USB connection. The apparatus of
`displaying an image contains a display unit and a control unit that reads device information out of the
`connected external device and performs display control on the display unit based on the read device
`information.”); see also FIGs. 1, 2, 4, 6
`6:26-38 (“The control unit 151 communicates the USB interface unit 153 and when detecting that an
`external device connects the USB interface unit 153, the control unit 151 executes a configuration
`setting to read out address setting of the connected external device and various kinds of pieces of
`information stored in the connected external device. When detecting that an external device is USB
`device that can correspond to the apparatus of displaying the image (the television receiver) based on
`the read information, the control unit 151 communicates this external device to read the image data
`VSusb out of the external device and supply it to the image changeover unit 131, thereby enabling
`image stored in the external device to be displayed on the image display unit 136.”)
`6:42-52 (“At step ST1, the control unit 151 determines whether or not the television receiver 100
`connects an external device. When the control unit 151 determines that the television receiver 100
`connects the external device, the operation goes to step ST2. When the control unit 151 determines
`that the television receiver 100 connects no external device, the operation goes back to the step ST1.
`It is to be noted that the control unit 151 may determine whether or not the television receiver 100
`connects an external device based on facts whether or not a D+terminal or a D-terminal of USB
`connector provided in the USB interface unit 153 has a predetermined voltage level.”).
`7:53-62 (“At the step ST5, the television receiver 100 checks a class of the connected external device.
`The control unit 151 checks the class of the connected external device based on the “DEVICE
`DESCRIPTOR” and the “INTERFACE DESCRIPTOR”. The operation then goes to step ST6. FIG. 6
`shows a class specification and class codes. The class specification contains an audio interface class, a
`
`3
`
`1.c
`
`
`
`Page 3 of 17
`
`

`

`communication device class, a human interface device (HID) class, a still image capture device
`(SICD) class, a printer class, and a mass storage class.”)
`8:25-29 (“At the step ST7, the control unit 151 determines whether or not the external device has
`image class. If the class checked at the step ST5 is included in the image class, namely, its device
`class code is “00h” and its interface class code is “06h”, the operation goes to step ST8. (YES)”);
`8:61-9:4 (”At the step ST11, the control unit 151 determines whether or not the connection of the
`external device has been released. If the external device keeps on connecting the television receiver
`100, the operation goes back to the step ST11 where the message PM3 keeps on displaying. If the
`connection of the external device has been released, for example, a USB cable has been released from
`a USB connector in the USB interface unit 153 or a USB connector in the external device, the
`operation goes to step ST15 where the control unit 151 finishes displaying the indication. The
`operation then goes back to the step ST1.”);
`10:6-18 (“At the step ST16, the television receiver 100 displays any noncorresponding notice and
`displays, for example, a message PM5 as shown in FIG. 3F to notice the user that the connected
`external device is not USB device that can correspond to the apparatus of displaying the image (the
`television receiver 100). At the step ST17, the control unit 151 determines whether or not the
`connection of the external device has been released. If the external device keeps on connecting the
`television receiver 100, the operation goes back to the step ST17. If the connection of the external
`device has been released, the operation goes to step ST18. At the step ST18, the control unit 151
`finishes displaying the notice.”)
`10:39-45 (“When the class of the external device is not changeable and a set class of the external
`device is different from the previously specified class of the apparatus of displaying the image (the
`television receiver 100), the television receiver 100 displays on its image display unit 136 a message
`noticing that the television receiver 100 does not correspond to the connected external device.”)
`To the extent that Plaintiff alleges that Takenaka 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 D1-D14 and
`O4.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takenaka 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.
`Takenaka discloses a determination unit configured to determine whether or not to continue the
`display of the image received from the external device by comparing the type of the external device
`
`4
`
`1.d
`
`a determination unit
`configured to determine
`
`
`
`Page 4 of 17
`
`

`

`whether or not to continue the
`display of the image received
`from the external device by
`comparing the type of the
`external device involving the
`communication by the
`communication unit with said
`information stored in the
`storing unit; and
`
`1.e
`
`a control unit configured to
`control whether or not to
`continue the display of the
`image being displayed by the
`display unit when the
`communication is
`disconnected, in accordance
`with the determination result
`by the determination unit.
`
`involving the communication by the communication unit with said information stored in the storing
`unit.
`See, e.g., element 1.c.
`In addition, Takenaka discloses:
`8:61-9:4 (”At the step ST11, the control unit 151 determines whether or not the connection of the
`external device has been released. If the external device keeps on connecting the television receiver
`100, the operation goes back to the step ST11 where the message PM3 keeps on displaying. If the
`connection of the external device has been released, for example, a USB cable has been released from
`a USB connector in the USB interface unit 153 or a USB connector in the external device, the
`operation goes to step ST15 where the control unit 151 finishes displaying the indication. The
`operation then goes back to the step ST1.”);
`To the extent that Plaintiff alleges that Takenaka 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 D1-D14 and
`O4.
`Takenaka discloses a control unit configured to control whether or not to continue the display of the
`image being displayed by the display unit when the communication is disconnected, in accordance
`with the determination result by the determination unit.
`See, e.g., element 1.c, 1.d.
`In addition, Takenaka discloses:
`8:61-9:4 (”At the step ST11, the control unit 151 determines whether or not the connection of the
`external device has been released. If the external device keeps on connecting the television receiver
`100, the operation goes back to the step ST11 where the message PM3 keeps on displaying. If the
`connection of the external device has been released, for example, a USB cable has been released from
`a USB connector in the USB interface unit 153 or a USB connector in the external device, the
`operation goes to step ST15 where the control unit 151 finishes displaying the indication. The
`operation then goes back to the step ST1.”); see also FIG. 1.
`To the extent that Plaintiff alleges that Takenaka 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 D1-D14 and
`O4.
`
`
`
`5
`
`Page 5 of 17
`
`

`

`2.pre
`
`2.a
`
`The display apparatus
`according to claim 1,
`wherein said information
`stored in the storing unit
`includes information
`indicating types of external
`devices which logically
`disconnect the
`communication with the
`communication unit.
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Takenaka 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.
`
`Takenaka discloses a display apparatus wherein said information stored in the storing unit includes
`information indicating types of external devices which logically disconnect the communication with
`the communication unit.
`See, e.g., element 1.c.
`In addition, Takenaka discloses:
`6:20-31 (“A USB interface unit 153 is also connected to the bus 154. The USB interface unit 153 is
`constituted of a USB transceiver for executing any serial communication with connected external
`device, serial interface engine (SIE) for executing communication control processing corresponding to
`USB protocol, and the like. The control unit 151 communicates the USB interface unit 153 and when
`detecting that an external device connects the USB interface unit 153, the control unit 151 executes a
`configuration setting to read out address setting of the connected external device and various kinds of
`pieces of information stored in the connected external device.”)
`6:42-52 (“At step ST1, the control unit 151 determines whether or not the television receiver 100
`connects an external device. When the control unit 151 determines that the television receiver 100
`connects the external device, the operation goes to step ST2. When the control unit 151 determines
`that the television receiver 100 connects no external device, the operation goes back to the step ST1.
`It is to be noted that the control unit 151 may determine whether or not the television receiver 100
`connects an external device based on facts whether or not a D+terminal or a D-terminal of USB
`connector provided in the USB interface unit 153 has a predetermined voltage level.”); see also FIG.
`2.
`7:40-62 (“FIG. 4 shows the device information of “DEVICE DESCRIPTOR”. The “DEVICE
`DESCRIPTOR” is constituted of various kinds of pieces of information relative to a version of the
`corresponding USB specification, a device class, a device subclass, a protocol, a vender identification
`(ID), a product ID, a device release number, an index of manufacturer, an index of product, an index
`of serial number, and the like. FIG. 5 shows the device information of “INTERFACE
`DESCRIPTOR”. The “INTERFACE DESCRIPTOR” is constituted of various kinds of pieces of
`information relative to a number of an interface, an interface class, an interface subclass, an interface
`protocol, and the like, which are used for selecting the interface. At the step ST5, the television
`
`
`
`6
`
`Page 6 of 17
`
`

`

`receiver 100 checks a class of the connected external device. The control unit 151 checks the class of
`the connected external device based on the “DEVICE DESCRIPTOR” and the “INTERFACE
`DESCRIPTOR”. The operation then goes to step ST6. FIG. 6 shows a class specification and class
`codes. The class specification contains an audio interface class, a communication device class, a
`human interface device (HID) class, a still image capture device (SICD) class, a printer class, and a
`mass storage class.”).
`To the extent that Plaintiff alleges that Takenaka 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 D1-D14 and
`O4.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takenaka 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 2, as if fully set forth herein.
`
`Takenaka discloses a display apparatus wherein the control unit controls to continue the display of the
`image being displayed by the display unit when the communication is disconnected, if the type of the
`external device is one of the types of external devices which logically disconnect the communication
`with the communication unit.
`See, e.g., elements 1.c, 2.a.
`In addition, Takenaka discloses:
`6:42-52 (“At step ST1, the control unit 151 determines whether or not the television receiver 100
`connects an external device. When the control unit 151 determines that the television receiver 100
`connects the external device, the operation goes to step ST2. When the control unit 151 determines
`that the television receiver 100 connects no external device, the operation goes back to the step ST1.
`It is to be noted that the control unit 151 may determine whether or not the television receiver 100
`connects an external device based on facts whether or not a D+terminal or a D-terminal of USB
`connector provided in the USB interface unit 153 has a predetermined voltage level.”); see also FIG.
`2.
`8:25-29 (“At the step ST7, the control unit 151 determines whether or not the external device has
`image class. If the class checked at the step ST5 is included in the image class, namely, its device
`class code is “00h” and its interface class code is “06h”, the operation goes to step ST8. (YES)”)
`
`3.pre
`
`3.a
`
`The display apparatus
`according to claim 2,
`wherein the control unit
`controls to continue the
`display of the image being
`displayed by the display unit
`when the communication is
`disconnected, if the type of
`the external device is one of
`the types of external devices
`which logically disconnect
`the communication with the
`communication unit.
`
`
`
`7
`
`Page 7 of 17
`
`

`

`4.pre
`
`4.a
`
`The display apparatus
`according to claim 1,
`wherein the control unit
`controls to end the display of
`the image being displayed by
`the display unit when the
`communication is
`disconnected, if the type of
`the external device is in a
`USB Mass Storage Class.
`
`8:61-65 (”At the step ST11, the control unit 151 determines whether or not the connection of the
`external device has been released. If the external device keeps on connecting the television receiver
`100, the operation goes back to the step ST11 where the message PM3 keeps on displaying.”)
`To the extent that Plaintiff alleges that Takenaka 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 D1-D14 and
`O4.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takenaka 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.
`
`Takenaka discloses a display apparatus wherein the control unit controls to end the display of the
`image being displayed by the display unit when the communication is disconnected, if the type of the
`external device is in a USB Mass Storage Class.
`See, e.g., element 1.c
`In addition, Takenaka discloses:
`8:8-14 (“At the step ST6, the control unit 151 determines whether or not the external device has mass
`storage class. If the class checked at the step ST5 is included in the mass storage class, namely, its
`device class code is “00h” and its interface class code is “08h”, the operation goes to step ST9. If the
`class checked at the step ST5 is not included in the mass storage class, the operation goes back to step
`ST7.”)
`10:6-11 (“At the step ST16, the television receiver 100 displays any noncorresponding notice and
`displays, for example, a message PM5 as shown in FIG. 3F to notice the user that the connected
`external device is not USB device that can correspond to the apparatus of displaying the image (the
`television receiver 100).”)
`To the extent that Plaintiff alleges that Takenaka 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 D1-D14 and
`O4.
`
`
`
`8
`
`Page 8 of 17
`
`

`

`5.pre
`
`
`
`The display apparatus
`according to claim 1,
`wherein the control unit
`controls to continue the
`display of the image being
`displayed by the display unit
`when the communication is
`disconnected, if the type of
`the external device is in a
`USB Imaging Class.
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Takenaka 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.
`
`Takenaka discloses a display apparatus wherein the control unit controls to continue the display of the
`image being displayed by the display unit when the communication is disconnected, if the type of the
`external device is in a USB Imaging Class.
`For example, Takenaka discloses:
`1:21-25 (“As the external device which may be connected by using the USB connection, various
`kinds of device such as image device, audio device, memory device, input/output device, and
`communication device have been presented.”)
`7:58-8-31 (“FIG. 6 shows a class specification and class codes. The class specification contains an
`audio interface class, a communication device class, a human interface device (HID) class, a still
`image capture device (SICD) class, a printer class, and a mass storage class...On the SICD class, the
`device class code is set to “00h” and the interface class code is set to “06h”....At the step ST7, the
`control unit 151 determines whether or not the external device has image class. If the class checked at
`the step ST5 is included in the image class, namely, its device class code is “00h” and its interface
`class code is “06h”, the operation goes to step ST8. If the class checked at the step ST5 is not included
`in the image class, the operation goes back to step ST12.”)
`6:26-38 (“The control unit 151 communicates the USB interface unit 153 and when detecting that an
`external device connects the USB interface unit 153, the control unit 151 executes a configuration
`setting to read out address setting of the connected external device and various kinds of pieces of
`information stored in the connected external device. When detecting that an external device is USB
`device that can correspond to the apparatus of displaying the image (the television receiver) based on
`the read information, the control unit 151 communicates this external device to read the image data
`VSusb out of the external device and supply it to the image changeover unit 131, thereby enabling
`image stored in the external device to be displayed on the image display unit 136.”)
`8:25-31 (“At the step ST7, the control unit 151 determines whether or not the external device has
`image class. If the class checked at the step ST5 is included in the image class, namely, its device
`class code is “00h” and its interface class code is “06h”, the operation goes to step ST8. If the class
`checked at the step ST5 is not included in the image class, the operation goes back to step ST12.”).
`
`
`
`9
`
`Page 9 of 17
`
`

`

`8:61-9:4 (”At the step ST11, the control unit 151 determines whether or not the connection of the
`external device has been released. If the external device keeps on connecting the television receiver
`100, the operation goes back to the step ST11 where the message PM3 keeps on displaying. If the
`connection of the external device has been released, for example, a USB cable has been released from
`a USB connector in the USB interface unit 153 or a USB connector in the external device, the
`operation goes to step ST15 where the control unit 151 finishes displaying the indication. The
`operation then goes back to the step ST1.”); see also FIG. 2.
`To the extent that Plaintiff alleges that Takenaka 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 D1-D14 and
`O4.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takenaka 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.
`Takenaka discloses a display apparatus.
`See, e.g., elements 6.a – 6.d.
`Takenaka discloses a communication unit configured to communicate with an external device.
`See, e.g., element 1.a.
`To the extent that Plaintiff alleges that Takenaka 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 D1-D14 and
`O4.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takenaka 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.
`Takenaka discloses a display unit configured to display an image received from the external device.
`See, e.g., element 1.b.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takenaka 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.pre
`
`6.a
`
`A display apparatus
`comprising:
`
`a communication unit
`configured to communicate
`with an external device;
`
`6.b
`
`a display unit configured to
`display an image received
`from the external device;
`
`
`
`10
`
`Page 10 of 17
`
`

`

`6.c
`
`a determination unit
`configured to determine
`whether or not to continue the
`display of the image received
`from the external device by
`detecting whether the
`communication is physically
`disconnected or whether the
`communication is logically
`disconnected when the
`communication with the
`external device is
`disconnected; and
`
`a control unit configured to
`control whether or not to
`continue the display of the
`image being displayed by the
`display unit when the
`communication is
`disconnected, in accordance
`with the determination result
`by the determination unit.
`
`6.d
`
`
`
`Takenaka discloses a determination unit configured to determine whether or not to continue the
`display of the image received from the external device by detecting whether the communication is
`physically disconnected or whether the communication is logically disconnected when the
`communication with the external device is disconnected.
`See, e.g., elements 1.c, 1.d.
`In addition, Takenaka discloses:
`6:42-52 (“At step ST1, the control unit 151 determines whether or not the television receiver 100
`connects an external device. When the control unit 151 determines that the television receiver 100
`connects the external device, the operation goes to step ST2. When the control unit 151 determines
`that the television receiver 100 connects no external device, the operation goes back to the step ST1.
`It is to be noted that the control unit 151 may determine whether or not the television receiver 100
`connects an external device based on facts whether or not a D+terminal or a D-terminal of USB
`connector provided in the USB interface unit 153 has a predetermined voltage level.”)
`6:20-25 (“A USB interface unit 153 is also connected to the bus 154. The USB interface unit 153 is
`constituted of a USB transceiver for executing any serial communication with connected external
`device, serial interface engine (SIE) for executing communication control processing corresponding to
`USB protocol, and the like.”); see also FIG. 2, 7:40-62
`To the extent that Plaintiff alleges that Takenaka 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 D1-D14 and
`O4.
`To the extent 35 U.S.C. § 112, ¶6 applies, Takenaka 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.
`Takenaka discloses a control unit configured to control whether or not to continue the display of the
`image being displayed by the display unit when the communication is disconnected, in accordance
`with the determination result by the determination unit.
`See, e.g., element 1.c, 1.e.
`To the extent that Plaintiff alleges that Takenaka 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, an