TCL’S INVALIDITY CONTENTIONS FOR U.S. 8,346,986
`Exhibit D3: U.S. Patent Publication No. 2009/0005651 (“Nitta”)
`
`
`
`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 Nitta and (b) under 35 U.S.C. § 103(a) as obvious over Nitta 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. Pub. No. 2009/005651 (“Nitta”)
`
`Nitta discloses a display apparatus.
`See, e.g., elements 1.a – 1.d.
`Nitta discloses a communication unit configured to communicate with an external device.
`For example, Nitta discloses:
`2:62-3:15 (“According to a first embodiment of the present invention, there is provided an
`information processing apparatus including the following elements: a plurality of data-recordable
`recording media; an operation unit operable to receive an operation from a user; a communication
`unit operable to output data stored on the recording media to an external device; and a controller
`operable to display a setting screen for setting a data output mode for outputting data via the
`communication unit on a display unit and to control the information processing apparatus on the
`basis of information input on the setting screen using the operation unit. The controller displays, as
`the setting screen displayed on the display unit, a function selection screen enabling the user to
`simultaneously select a recording medium serving as an output data source from which data is output
`via the communication unit and a function to be executed via the communication unit. On the
`basis of information input on the function selection screen using the operation unit, the controller
`
`’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 34
`
`CANON EXHIBIT 2002
`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00342
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`performs a setting operation to output data recorded on the selected recording medium in accordance
`with a communication mode based on the selected function.”)
`3:42-47 (“The communication unit may output data to the external device via a universal serial
`bus (USB) cable according to the USB standard. When the USB cable is disconnected from the
`communication unit or the external device, the controller may maintain the mode of the information
`processing apparatus set at the time the USB cable was disconnected.”)
`4:4-16 (“According to a third embodiment of the present invention, there is provided an information
`processing apparatus including the following elements: a plurality of data-recordable recording
`media; a USB connector operable to output data stored on the recording media via a USB cable;
`and a controller operable to display a GUI serving as a function selection screen on a display unit. The
`controller performs a display operation to display, on the display unit, a GUI enabling a user to select
`termination of outputting of data via the USB cable or changing of a recording medium serving as an
`output data source from which data is output via the USB cable or a USB function to be executed.”)
`7:50-59 (“The imager (video camera) 100 includes a USB terminal 101 serving as a
`communication unit connecting to USB cables 121 and a display unit 102 displaying recorded data
`and imaging data and presenting a GUI serving as a function selection screen. The imager 100 is
`configured to be connectable to a PC 111 or a printer 112 serving as an external device via the
`USB cable 121 connected to the USB terminal 101. The display unit 102 also functions as an
`operation unit receiving operations from a user.”); see also 3:48-6:23, 16:1-6.
`To the extent 35 U.S.C. § 112, ¶6 applies, Nitta 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.
`Nitta discloses a display unit configured to display an image received from the external device.
`For example, Nitta discloses:
`2:62-3:15 (“According to a first embodiment of the present invention, there is provided an
`information processing apparatus including the following elements: a plurality of data-recordable
`recording media; an operation unit operable to receive an operation from a user; a communication unit
`operable to output data stored on the recording media to an external device; and a controller operable
`to display a setting screen for setting a data output mode for outputting data via the communication
`unit on a display unit and to control the information processing apparatus on the basis of information
`input on the setting screen using the operation unit. The controller displays, as the setting screen
`2
`
`1.b
`
`a display unit configured to
`display an image received
`from the external device;
`
`
`
`Page 2 of 34
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`displayed on the display unit, a function selection screen enabling the user to simultaneously select a
`recording medium serving as an output data source from which data is output via the communication
`unit and a function to be executed via the communication unit. On the basis of information input on
`the function selection screen using the operation unit, the controller performs a setting operation to
`output data recorded on the selected recording medium in accordance with a communication mode
`based on the selected function.”)
`4:4-16 (“According to a third embodiment of the present invention, there is provided an information
`processing apparatus including the following elements: a plurality of data-recordable recording
`media; a USB connector operable to output data stored on the recording media via a USB cable; and a
`controller operable to display a GUI serving as a function selection screen on a display unit. The
`controller performs a display operation to display, on the display unit, a GUI enabling a user to
`select termination of outputting of data via the USB cable or changing of a recording medium serving
`as an output data source from which data is output via the USB cable or a USB function to be
`executed.”)
`7:50-59 (“The imager (video camera) 100 includes a USB terminal 101 serving as a communication
`unit connecting to USB cables 121 and a display unit 102 displaying recorded data and imaging
`data and presenting a GUI serving as a function selection screen. The imager 100 is configured to be
`connectable to a PC 111 or a printer 112 serving as an external device via the USB cable 121
`connected to the USB terminal 101. The display unit 102 also functions as an operation unit receiving
`operations from a user.”); see also 3:48-6:23; 16-1:6.
`To the extent 35 U.S.C. § 112, ¶6 applies, Nitta 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.
`Nitta 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, Nitta discloses:
`(“The CPU 531 controls the overall processing of the controller 530 and uses the RAM 533 as a work
`area. The ROM 532 stores a program for controlling the imaging unit 510 and programs for
`
`3
`
`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
`
`1.c
`
`
`
`Page 3 of 34
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`

`

`’986
`Claim
`
`Claim Element
`
`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;
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`controlling the reading/writing of the image signal and the audio signal, selection of the medium
`serving as the output data source from which data is output using the USB cable as described
`above, selection of the USB function, and setting of the mode.”)
`1:49-57 (“The USB connection between the imager and the PC involves a communication
`specification (PC mode) such as the USB mass storage class or picture transfer protocol (PTP).
`In contrast, the USB connection between the imager and the printer involves the communication
`specification “PictBridge” standardizing the interface between PTP defining the transport layer
`and the application layer above the transport layer. Accordingly, different communication
`specifications are applied.”)
`2:27-32 (“The USB cable is disconnected from the information processing apparatus, such as the
`imager, with the USB function upon the ending of the USB function. When the USB cable is
`disconnected, the information processing apparatus such as the imager detects the
`disconnection of the USB cable, ends the USB function mode, and returns to the normal mode.”)
`3:42-47 (“The communication unit may output data to the external device via a universal serial bus
`(USB) cable according to the USB standard. When the USB cable is disconnected from the
`communication unit or the external device, the controller may maintain the mode of the
`information processing apparatus set at the time the USB cable was disconnected.”)
`12:59-65 (“Therefore, the user connects the USB cable 121 to the USB terminal 101 to establish a
`USB connection with the external device (PC 111 or printer 112). With this processing, a connection
`is established with the class driver associated with the connected external device, thereby
`returning to the USB connection state set prior to the disconnection of the USB cable 121.”)
`13:10-34 (“FIG. 6A shows a processing sequence of the information processing apparatus
`(imager 100) according to the embodiment of the present invention. FIG. 6B shows a processing
`sequence of a known general USB connection device (slave). First, a state sequence in the case
`where, from the known general USB connection device (slave) connected via a USB cable to a host
`(PC) (step S421), the USB cable is disconnected and then reconnected will be described.
`Data communication using USB is performed between a host, such as a PC, and a device serving as a
`slave. In this example, the slave is the imager. As has been described above, the slave holds a table
`referred to as a descriptor describing its attributes. The host, such as a PC, which is USB-connected to
`the slave, obtains the descriptor from the USB connection device (slave) to identify a driver
`
`
`
`4
`
`Page 4 of 34
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`compatible with the slave. The host loads the identified driver and performs slave-compatible data
`communication.
`By transferring a right to access a recording medium in the slave (imager) to the host (PC), the PC
`serving as the host can process the recording medium in the slave (imager) in a manner similar to that
`in which the host (PC) processes a storage device, such as a hard disk, in the PC. The standard for
`controlling the connection of the storage device in the USB-compatible device to the PC and the
`data processing is referred to as the USB mass storage class.”)
`14:9-25 (“At time Tb1, the USB cable is disconnected from the imager. At this point, the imager is
`disconnected from the class driver of the host (PC). When the controller of the imager detects that
`the USB connection is broken and the imager is disconnected from the class driver of the host
`(PC), the controller performs an operation to change from the mass storage mode to the normal
`mode. Specifically, after the disconnection from the class driver, medium recognition is performed to
`enable an application to be executed in the imager to access the recording medium (DVD in the
`example shown in FIG. 6B) in the imager, the access right to which has been transferred to the host
`(PC). When the medium recognition is performed, a content file on the medium is read by the
`application executed in the imager, and, for example, an index screen shown in step S422 of FIG.
`6B is presented on the display unit. This is a state where the USB cable is disconnected from the
`USB terminal.”)
`FIG. 6B
`
`
`15:9-27 (“At time Ta1, the USB cable 121 is disconnected from the imager 100. At this point, the
`imager 100 is disconnected from the class driver of the host (PC 111). This is the same as the known
`USB slave device. However, when the controller of the imager 100 according to the embodiment of
`
`
`
`5
`
`Page 5 of 34
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`the present invention detects that the USB connection is broken and the imager 100 is disconnected
`from the class driver of the host (PC 111), the controller maintains the mass storage mode, without
`performing the processing to change from the mass storage mode to the normal mode. Specifically,
`even after the disconnection from the class driver, the imager 100 maintains the mass storage mode
`where the right to access the recording medium (DVD 103 in the example shown in FIG. 6A) in the
`imager 100 is given to the host (PC 111).
`At this point, as shown in step S402, a warning message indicating that the USB cable 121 is
`disconnected is presented on the screen on the display unit 102. This is a state where the USB
`cable 121 is disconnected from the USB terminal 101.”)
`FIG. 6A
`
`
`11:64-12:28 (“Further, even when the USB cable 121 is disconnected from the USB terminal 101
`of the imager 100 to disconnect the imager 100 from the external device such as the PC 111 or the
`printer 112, the imager 100 according to the embodiment of the present invention can maintain
`the same mode as that in which the USB cable 121 is connected.
`Known general USB-connectable slave devices are such that, when a USB cable is disconnected
`from a USB terminal of a slave device to disconnect the slave device from an external device
`such as a PC or a printer, the slave device cancels the so-called PC mode which has been
`maintained by the USB connection and enters the normal mode where only the normal function
`of the imager is executed. However, when the imager 100 according to the embodiment of the
`present invention is in the USB-connected mode, namely, in the PC mode or the PictBridge
`mode, the imager 100 maintains the same mode even when the USB cable 121 is disconnected
`from the USB terminal 101.
`
`
`
`6
`
`Page 6 of 34
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`A specific example will be described with reference to FIG. 5. Portions (a) to (d) of step S301 of FIG.
`5 correspond to portions (a) to (d) of step S104 of FIG. 3, namely:
`(a) PC mode where the data recorded on the DVD 103 can be output to the external device such as the
`PC 111;
`(b) PC mode where the data recorded on the flash memory 104 can be output to the external device
`such as the PC 111;
`(c) PictBridge mode where the data recorded on the DVD 103 can be output to the external
`device such as the printer 112; and
`(d) PictBridge mode where the data recorded on the flash memory 104 can be output to the
`external device such as the printer 112.”)
`FIG. 5
`
`
`
`7
`
`
`
`Page 7 of 34
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`See also 3:48-6:23; 11:16-28; FIG.4; FIG 5.
`To the extent that Plaintiff alleges that Nitta does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or the references identified in Exhibits D1-D14, and O4.
`To the extent 35 U.S.C. § 112, ¶6 applies, Nitta 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.
`Nitta 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 involving
`the communication by the communication unit with said information stored in the storing unit.
`For example, Nitta discloses:
`2:62-3:15 (“According to a first embodiment of the present invention, there is provided an
`information processing apparatus including the following elements: a plurality of data-recordable
`recording media; an operation unit operable to receive an operation from a user; a communication unit
`operable to output data stored on the recording media to an external device; and a controller
`operable to display a setting screen for setting a data output mode for outputting data via the
`communication unit on a display unit and to control the information processing apparatus on
`the basis of information input on the setting screen using the operation unit. The controller
`displays, as the setting screen displayed on the display unit, a function selection screen enabling the
`user to simultaneously select a recording medium serving as an output data source from which data is
`output via the communication unit and a function to be executed via the communication unit. On the
`basis of information input on the function selection screen using the operation unit, the controller
`performs a setting operation to output data recorded on the selected recording medium in accordance
`with a communication mode based on the selected function.”)
`3:42-47 (“The communication unit may output data to the external device via a universal serial bus
`(USB) cable according to the USB standard. When the USB cable is disconnected from the
`communication unit or the external device, the controller may maintain the mode of the
`information processing apparatus set at the time the USB cable was disconnected.”)
`4:17-25 (“According to a fourth embodiment of the present invention, there is provided an
`information processing apparatus including the following elements: a plurality of data-recordable
`recording media; a USB connector operable to output data stored on the recording media via a
`8
`
`1.d
`
`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 involving the
`communication by the
`communication unit with said
`information stored in the
`storing unit; and
`
`
`
`Page 8 of 34
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`USB cable; and a controller operable to maintain, when the USB cable is disconnected from the USB
`connector, a mode of the information processing apparatus set at the time the USB cable was
`disconnected.”)
`7:50-59 (“The imager (video camera) 100 includes a USB terminal 101 serving as a communication
`unit connecting to USB cables 121 and a display unit 102 displaying recorded data and imaging
`data and presenting a GUI serving as a function selection screen. The imager 100 is configured to be
`connectable to a PC 111 or a printer 112 serving as an external device via the USB cable 121
`connected to the USB terminal 101. The display unit 102 also functions as an operation unit receiving
`operations from a user.”).
`16:1-23 (“As shown in FIG. 7, the information processing apparatus according to the
`embodiment of the present invention includes a plurality of data-recordable recording media 301
`and 302, a USB connector 303 with a USB terminal for outputting data stored on the recording media
`301 and 302 via a USB cable, a display unit 304, and a controller 305.
`The controller 305 displays a setting screen serving as a GUI for setting the data output mode
`for outputting data via the USB connector 303 on the display unit 304 and controls the
`information processing apparatus on the basis of information input to the GUI. That is, the
`display unit 304 serves also as an operation unit for receiving user operations.
`The controller 305 displays, as a GUI to be displayed on the display unit 304, a function selection
`screen enabling the user to select both the recording medium serving as an output data source from
`which data is output via the USB cable and the USB function (PC mode or PictBridge mode) to be
`executed, namely, the GUI screen 105 described with reference to FIG. 2. On the basis of selection
`information input on the function selection screen, the controller 305 performs the setting processing
`to output data recorded on the selected recording medium in accordance with the selected USB
`function (PC mode or PictBridge mode).”) ; see also 3:48-6:23; 18:8-23.
`1:49-57 (“The USB connection between the imager and the PC involves a communication
`specification (PC mode) such as the USB mass storage class or picture transfer protocol (PTP).
`In contrast, the USB connection between the imager and the printer involves the communication
`specification “PictBridge” standardizing the interface between PTP defining the transport layer
`and the application layer above the transport layer. Accordingly, different communication
`specifications are applied.”)
`
`
`
`9
`
`Page 9 of 34
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`2:27-32 (“The USB cable is disconnected from the information processing apparatus, such as the
`imager, with the USB function upon the ending of the USB function. When the USB cable is
`disconnected, the information processing apparatus such as the imager detects the
`disconnection of the USB cable, ends the USB function mode, and returns to the normal mode.”)
`3:42-47 (“The communication unit may output data to the external device via a universal serial bus
`(USB) cable according to the USB standard. When the USB cable is disconnected from the
`communication unit or the external device, the controller may maintain the mode of the
`information processing apparatus set at the time the USB cable was disconnected.”)
`12:59-65 (“Therefore, the user connects the USB cable 121 to the USB terminal 101 to establish a
`USB connection with the external device (PC 111 or printer 112). With this processing, a connection
`is established with the class driver associated with the connected external device, thereby
`returning to the USB connection state set prior to the disconnection of the USB cable 121.”)
`13:10-34 (“FIG. 6A shows a processing sequence of the information processing apparatus
`(imager 100) according to the embodiment of the present invention. FIG. 6B shows a processing
`sequence of a known general USB connection device (slave). First, a state sequence in the case
`where, from the known general USB connection device (slave) connected via a USB cable to a host
`(PC) (step S421), the USB cable is disconnected and then reconnected will be described.
`Data communication using USB is performed between a host, such as a PC, and a device serving as a
`slave. In this example, the slave is the imager. As has been described above, the slave holds a table
`referred to as a descriptor describing its attributes. The host, such as a PC, which is USB-connected to
`the slave, obtains the descriptor from the USB connection device (slave) to identify a driver
`compatible with the slave. The host loads the identified driver and performs slave-compatible data
`communication.
`By transferring a right to access a recording medium in the slave (imager) to the host (PC), the PC
`serving as the host can process the recording medium in the slave (imager) in a manner similar to that
`in which the host (PC) processes a storage device, such as a hard disk, in the PC. The standard for
`controlling the connection of the storage device in the USB-compatible device to the PC and the
`data processing is referred to as the USB mass storage class.”)
`14:9-25 (“At time Tb1, the USB cable is disconnected from the imager. At this point, the imager is
`disconnected from the class driver of the host (PC). When the controller of the imager detects that
`the USB connection is broken and the imager is disconnected from the class driver of the host
`
`
`
`10
`
`Page 10 of 34
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`(PC), the controller performs an operation to change from the mass storage mode to the normal
`mode. Specifically, after the disconnection from the class driver, medium recognition is performed to
`enable an application to be executed in the imager to access the recording medium (DVD in the
`example shown in FIG. 6B) in the imager, the access right to which has been transferred to the host
`(PC). When the medium recognition is performed, a content file on the medium is read by the
`application executed in the imager, and, for example, an index screen shown in step S422 of FIG.
`6B is presented on the display unit. This is a state where the USB cable is disconnected from the
`USB terminal.”)
`FIG. 6B
`
`
`15:9-27 (“At time Ta1, the USB cable 121 is disconnected from the imager 100. At this point, the
`imager 100 is disconnected from the class driver of the host (PC 111). This is the same as the known
`USB slave device. However, when the controller of the imager 100 according to the embodiment of
`the present invention detects that the USB connection is broken and the imager 100 is disconnected
`from the class driver of the host (PC 111), the controller maintains the mass storage mode, without
`performing the processing to change from the mass storage mode to the normal mode. Specifically,
`even after the disconnection from the class driver, the imager 100 maintains the mass storage mode
`where the right to access the recording medium (DVD 103 in the example shown in FIG. 6A) in the
`imager 100 is given to the host (PC 111).
`At this point, as shown in step S402, a warning message indicating that the USB cable 121 is
`disconnected is presented on the screen on the display unit 102. This is a state where the USB
`cable 121 is disconnected from the USB terminal 101.”)
`FIG. 6A
`
`
`
`11
`
`Page 11 of 34
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`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`
`11:64-12:28 (“Further, even when the USB cable 121 is disconnected from the USB terminal 101
`of the imager 100 to disconnect the imager 100 from the external device such as the PC 111 or the
`printer 112, the imager 100 according to the embodiment of the present invention can maintain
`the same mode as that in which the USB cable 121 is connected.
`Known general USB-connectable slave devices are such that, when a USB cable is disconnected
`from a USB terminal of a slave device to disconnect the slave device from an external device
`such as a PC or a printer, the slave device cancels the so-called PC mode which has been
`maintained by the USB connection and enters the normal mode where only the normal function
`of the imager is executed. However, when the imager 100 according to the embodiment of the
`present invention is in the USB-connected mode, namely, in the PC mode or the PictBridge
`mode, the imager 100 maintains the same mode even when the USB cable 121 is disconnected
`from the USB terminal 101.
`A specific example will be described with reference to FIG. 5. Portions (a) to (d) of step S301 of FIG.
`5 correspond to portions (a) to (d) of step S104 of FIG. 3, namely:
`(a) PC mode where the data recorded on the DVD 103 can be output to the external device such as the
`PC 111;
`(b) PC mode where the data recorded on the flash memory 104 can be output to the external device
`such as the PC 111;
`(c) PictBridge mode where the data recorded on the DVD 103 can be output to the external
`device such as the printer 112; and
`(d) PictBridge mode where the data recorded on the flash memory 104 can be output to the
`external device such as the printer 112.”)
`
`
`
`12
`
`Page 12 of 34
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`

`

`’986
`Claim
`
`Claim Element
`
`FIG. 5
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`
`
`See also 3:48-6:23; 11:16-28; FIG.4; FIG 5.
`To the extent that Plaintiff alleges that Nitta does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or the references identified in Exhibits D1-D14, and O4.
`To the extent 35 U.S.C. § 112, ¶6 applies, Nitta 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.
`Nitta 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.
`
`13
`
`a control unit configured to
`control whether or not to
`continue the display of the
`image being displayed by the
`
`1.e
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`
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`Page 13 of 34
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`

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`’986
`Claim
`
`Claim Element
`
`display unit when the
`communication is
`disconnected, in accordance
`with the determination result
`by the determination unit.
`
`
`
`Prior Art: U.S. Pat. Pub. No. 2009/005651 (“Nitta”)
`
`For example, Nitta discloses:
`2:62-3:15 (“According to a first embodiment of the present invention, there is provided an
`information processing apparatus including the following elements: a plurality of data-recordable
`recording media; an operation unit operable to receive an operation from a user; a communication unit
`operable to output data stored on the recording media to an external device; and a controller
`operable to display a setting screen for setting a data output mode for outputting data via the
`communication unit on a display unit and to control the information processing apparatus on
`the basis of information input on the setting screen using the operation unit. The controller
`displays, as the setting screen displayed on the display unit, a function selection screen enabling the
`user to simultaneously select a recording medium serving as an output data source from which data is
`output via the communication unit and a function to be executed via the communication unit. On the
`basis of information input on the function selection screen using the operation unit, the controller
`performs a setting operation to output data recorded on the selected recording medium in accordance
`with a communication mode based on the selected function.”)
`3:42-47 (“The communication unit may output data to the external device via a universal serial bus
`(USB) cable according to the USB standard. When the USB cable is disconnected from the
`communication unit or the external device, the controller may maintain the mode of the
`information processing apparatus set at the time the USB cable was disconnected.”)
`4:17-25 (“According to a fourth embodiment of the present invention, there is provided an
`information processing apparatus including the following elements: a plurality of data-recordable
`recording media; a USB connector operable to output data stored on the recording media via a
`USB cable; and