TCL’S INVALIDITY CONTENTIONS FOR U.S. 8,346,986
`Exhibit D7: U.S. Patent No. U.S. Patent No. 7,877,696 (“Telek”)
`
`
`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 Telek and (b) under 35 U.S.C. § 103(a) as obvious over Telek 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. 7,877,696 (“Telek”)
`
`Telek discloses a display apparatus.
`See, e.g., elements 1.a – 1.d.
`Telek discloses a communication unit configured to communicate with an external device.
`For example, Telek discloses:
`4:31-5:6: (“A digital media frame (DMF) has a display unit and control system that allows a user to
`display at least one digital image with minimal user intervention. The DMF is capable of receiving
`digital images from various external input devices, such as, digital cameras, video cameras,
`computers, telephone lines, television cables, and Internet servers or other types of networks and
`in certain embodiments the DMF optionally can be made to capture digital images….
`FIG. 1 illustrates an embodiment of a connection between external devices 100 and a DMF 102. In
`FIG. 1, DMF 102 is illustrated as being connected to a camera 110, a personal computer (“PC”) 112, a
`cable connector 114, and an Internet connector 116.”
`DMF 102 further contains an interface unit 104 and a user input component 105. The user input
`component 105 also contains user-input buttons 106, which are the input devices. The interface unit
`104 includes at least one I/O (“input and output”) port capable of connecting to the camera 110,
`
`’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 25
`
`CANON EXHIBIT 2005
`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00342
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`PC 112, the cable connectors 114, and the Internet connector 116 using connecting cables 120,
`122, 124, and 126, respectively. The interface unit 104 is further capable of receiving and processing
`both digital and analog image data. It will be apparent to one of ordinary skill in the art that one or
`more of these external devices 100 can be connected to a particular DMF 102. It will also be apparent
`that the equivalent conventional input devices 100 can be similarly connected.
`A camera 110 can be connected to interface unit 104. Camera 110 can be a digital still camera or a
`digital video camera that provides captured images in digital form. Camera 110 can also be an analog
`video camera that provides analog image signals that can be converted by interface unit 104 or other
`portions of DMF 102 into a digital image. In one embodiment, the camera 110 can directly transfer
`the captured image to the DMF using conventional transmission media, such as, for example,
`wireless, cable, or removable media.)
`
`
`
`2
`
`
`
`Page 2 of 25
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`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`5:41-6:15 (“FIG. 2 illustrates a block diagram of one embodiment of a digital media frame 200. In
`the illustrated embodiment, digital media frame 120 has an interface circuit 204, a processing
`circuit 206, memory 208, a display controller 210 and a display device 212, a user input system 214
`and optional sensors 216.
`Interface circuit 204 enables digital media frame 20 to receive input data from external devices
`202 and can optionally be used to send data to external devices 202. External devices 202 can
`comprise but are not limited to digital still cameras, digital video cameras, scanners, computers, local
`servers, remote servers, memory devices, the internet, printers, internet appliances, a remote control
`(as will be described in greater detail below), personal digital assistants, personal video players,
`telephones, telecommunication networks, cellular telephones, analog televisions or digital televisions
`or television signal distribution systems such as cable, satellite or other television systems and/or
`television storage systems such as recorders or players of television systems such as solid state,
`optical, or magnetic television signal recording and/or playback systems. As will be discussed in
`greater detail below, interface unit 204 can also be adapted to communicate with one or more
`other types of external devices including other DMFs and/or a remote control.
`Interface circuit 204 can take many known forms. Where interface circuit 204 is connected to an
`external device 202 that provides data signals that are already in proper form for use by DMF
`102, interface circuit 204 can simply provide appropriate structures to receive and make use of
`the properly formatted digital data. Interface circuit 204 can also be adapted to enable exchange
`data with a connected external device 202 using optical signals, radio frequency signals or other forms
`of signals that are specially adapted for data exchange using particular wireless or wired
`communication systems or standards. In this regard, interface circuit 204 can provide optical, radio
`frequency or other receiving and optionally transmitting circuits appropriate to enable such an
`exchange of data and interface circuit 204 can be adapted for communication with external devices
`202 using a direct electrical or optical path and can comprise, for example, a serial or parallel port, or
`a networked interface to a computer network or the Internet.”)
`
`
`
`3
`
`Page 3 of 25
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`
`9:6-20 (“FIG. 3 illustrates a detailed architecture of one embodiment of a DMF 300 with an
`interface block 301, a processing block 310 and a displaying block 340. In this embodiment,
`interface block 301 receives signals from external devices (not shown) or captures image, video
`or audio signals and in turn provides signals to processing unit 320 based upon such signals.
`Processing block 310 receives digital images from interface block 301 and causes the received digital
`images to be presented by displaying block 340 based upon the signals received from interface block
`301 or takes such other action as may be indicated by the received signals from interface block 301 or
`by signals received from a user input unit 322.
`In this embodiment, interface block 301 is illustrated as having an analog input circuit 302, a
`digital input circuit 304, and wireless input circuit 305.”)
`
`
`
`4
`
`Page 4 of 25
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`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`See also 15:41-53; FIG. 7; 15:64-16:6.
`To the extent 35 U.S.C. § 112, ¶6 applies, Telek 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.
`
`
`
`
`
`5
`
`Page 5 of 25
`
`

`

`’986
`Claim
`1.b
`
`Claim Element
`
`a display unit configured to
`display an image received
`from the external device;
`
`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
`
`1.c
`
`
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`Telek discloses a display unit configured to display an image received from the external device.
`For example, Telek discloses:
`4:31-34 (“A digital media frame (DMF) has a display unit and control system that allows a user to
`display at least one digital image with minimal user intervention.”)
`5:41-46 (“FIG. 2 illustrates a block diagram of one embodiment of a digital media frame 200. In the
`illustrated embodiment, digital media frame 120 has an interface circuit 204, a processing circuit
`206, memory 208, a display controller 210 and a display device 212, a user input system 214 and
`optional sensors 216.”)
`12:34-39 (“Image display block 340 contains display controller 342, display unit 350, an optional
`display memory buffer 344 and an optional audio circuit 370. In one embodiment, the display unit
`350 is a LCD. However, display unit 350 can take any other known form of device that is
`capable of providing image modulated light.”)
`See also FIG.4; 12:59-65; 15:41-53; FIG. 7.
`To the extent 35 U.S.C. § 112, ¶6 applies, Telek 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.
`Telek 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, Telek discloses:
`6:48-7:21 (“A digital image can be associated with metadata. Such metadata generally comprises
`any form of data that is associated with the digital image but that is not necessarily presented as
`a part of the visually perceptible output. For example, such metadata can include but is not
`necessarily limited to data reflecting a time and/or date upon which the visual content used to form
`the digital image was captured or generated, a location of such capture or generation, conditions of
`capture or generation, the identification of a capture or generation device, an identification of a
`photographer, creator or editor of the visual content used to form the visual content data record,
`information characterizing the nature of the visual content, information that can be used in
`6
`
`Page 6 of 25
`
`

`

`’986
`Claim
`
`Claim Element
`
`display of an image should
`not be continued;
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`determining parameters for presenting the visual content depicted in the visual content data record,
`audio data or text data for presentation with the visual content data record, and/or keywords and or
`other indexing information.
`Where processing circuit 206 determines that data received from interface circuit 204 comprises
`a digital image, processing circuit 206 can determine a location in memory 26 for the storage of
`the digital image so that, as required, processing circuit 206 can recall this digital image.
`Processing circuit 206 can also generate and/or store auxiliary information for each digital image.
`Such auxiliary information can include a color assignment. The color assignment maps out image
`color distribution from an available color grid according to the color distribution of the image data.
`The auxiliary information can also include date and time that the digital image was received by DMF
`102, an Internet address that indicates which Internet node was used for sending the digital image to
`the DMF 102 or other source identifier information. The auxiliary information can also include
`Internet address links to other web sites that are related to the image. For example, if an image
`describes a child, the linked web sites that describe child's family or that are known to or that are
`likely to contain visual content data records related to the family or child such as web sites of other
`family members, schools, churches etc associated with the family or child. Image orientations,
`transitions, or other presentation related information determined by DMF 102 can also be stored as
`auxiliary information with the digital image by processing circuit 206.”)
`8:8-18 (“Memory 208 is provided to allow processor 34 (or set of memory blocks) which may
`include, for example, one or more of the following: dynamic random access memory (“DRAM”),
`static random access memory (“SRAM”), read-only memory, (“ROM”), non-volatile memory,
`magnetic disk storage, magnetic tape storage, CD-ROM, DVD-ROM, and so on. In one embodiment,
`processor 206 controls the access to data stored in memory 208. It should be noted that memory 208
`can also receive data from other circuits and systems, such as from interface circuit 204 and/or
`display controller 210.”)
`14:54-15:14 (“After attaching the auxiliary information, the process proceeds from block 618 to block
`616, where the image data together with the attached auxiliary information are stored in a
`memory buffer. The memory buffer is a small and fast memory device that provides fast
`memory access for displaying images. In one embodiment, the memory buffer is non-volatile
`memory device to prevent memory loss upon power disconnection. In another embodiment, the
`memory buffer is regular random access memory having a backup portable power supply to prevent
`
`
`
`7
`
`Page 7 of 25
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`memory loss. After block 616, the process moves to block 620, where the output from the
`memory buffer can be selected for displaying.
`At block 620, the process further receives signals from block 624 and block 622. The block 624
`contains input control signals from the user, while the block 622 contains the image data for the
`last displayed images. The process at block 624 receives a user input, which may indicate to pause
`the current image. In another embodiment, the user input is used as one of many combinational logic
`inputs for selecting the next image.
`Upon selecting the image data, the process proceeds from block 620 to block 630, where the
`image is displayed. When the current image is displayed, the process proceeds from block 630 to
`block 622, where the current image is stored. In one embodiment, block 622 stores the image
`data only for one image, which is the last displayed image. In another embodiment, block 622
`stores the image data for a set of recently displayed images.”)
`18:9-32 (“FIG. 11 is a flowchart 1100 illustrating an embodiment of receiving data from various
`devices. The process begins at the start block and proceeds to block 1002 where the process receives
`data. At block 1004, the process examines whether the data comes from a camera. If block 1004 is
`false, the process proceeds to block 1008. However, if the block 1004 is true, which indicates that
`the data comes from the camera, the process receives the data using camera interface program
`at block 1006. Camera interface program includes, but not limited to, identifying types of protocol
`used to transmit the code from the camera and translating the code to native language if it is needed.
`At block 1008, the process examines whether the data comes from a PC. If block 1008 is false, the
`process moves to the block 1002. On the other hand, if block 1008 is true, which indicates that the
`data comes from the PC, the process moves from block 1008 to block 1010 where the data is
`received. At block 1012, the process examines whether the data comes from Internet connector.
`If block 1012 is false, the process loops to the end block where the process ends.
`However, if block 1012 is true, which indicates that the data comes from Internet connector, the
`process proceeds to block 1014 where the process examines whether the communication is a
`two-way communication.”)
`
`
`
`8
`
`Page 8 of 25
`
`

`

`1100
`
`RECEIVE DATA
`
`IS
`DATA FROM
`CAMERA?
`1004
`
`1002
` RECEIVE DATA
`
`FROM CAMERA
`
`1006
` YES
`
`
`
`
`RECEIVE DATA
`FROM PG
`1010
`
`IS
`
`YES
`DATA FROM THE
`INTERNET CONNECTOR?
`
`
`1012
` 1S IT
`
`
`MORE THAN ONE-
`
`WAY COMMUNICATION?
`
`1014
`
`
`INVOKE DMF
`INVOKE DMF ONE-WAY
`INTERACTIVE
`INTERFACE PROGRAM
`i 3e
`
`
`
`
`
`FIG. 11
`
`9
`
`
`
`
`
`
`
`
`
`Page 9 of 25
`
`Page 9 of 25
`
`

`

`’986
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`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
`
`To the extent that Plaintiff alleges that Telek 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, Telek 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.
`Telek 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, Telek discloses:
`6:40-47 (“Among other things, processing circuit 206 is adapted to analyze data received from
`interface circuit 204 to determine whether the data comprises instructions, a digital image or
`other data and to determine appropriate steps for processing such data. Processing circuit 206
`can be adapted to edit, compress, modify or otherwise process and in this regard can be programmed
`for such use or can incorporate specific circuits such as signal processing circuits for this purpose.”)
`11:5-16 (“Processing circuit 206 is configured to determine a manner for presenting images, a
`sequence of sequence of images, video streams and other visual content on display unit 350. This
`can involve, for example, determining time intervals for presenting the visual content, time transition
`types between images. The interval transition time indicates the time interval between the current
`image and the next image to be displayed. The image transition is a mechanism of retiring the
`presentation of a current image while phasing in the next image. In one embodiment, the image
`transition moves current and next images in one direction as the current image move out while the
`next image moves.”)
`To the extent that Plaintiff alleges that Telek 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, Telek also discloses the corresponding structure(s) and
`function(s) claimed or their equivalents, as shown above, or renders them obvious in view of the
`knowledge of one skilled in the art.
`
`
`
`10
`
`Page 10 of 25
`
`

`

`’986
`Claim
`1.e
`
`Claim Element
`
`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.
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`Telek 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.
`For example, Telek discloses:
`6:30-39 (“Processing circuit 206 controls the operation the DMF 102. Processing circuit 206
`causes interface circuit 204, local memory 208, a display controller 210 and a display device 212
`to display images in response to signals received from interface circuit 204, a user input system
`214, and/or optional sensors 216 and audio system 218. Processing circuit 206 can comprise a
`microprocessor such as a programmable general purpose microprocessor, a dedicated micro-processor
`or micro-controller, or any other system that can be used to control operation of DMF 102.”)
`6:40-47 (“Among other things, processing circuit 206 is adapted to analyze data received from
`interface circuit 204 to determine whether the data comprises instructions, a digital image or
`other data and to determine appropriate steps for processing such data. Processing circuit 206
`can be adapted to edit, compress, modify or otherwise process and in this regard can be programmed
`for such use or can incorporate specific circuits such as signal processing circuits for this purpose.”)
`11:5-16 (“Processing circuit 206 is configured to determine a manner for presenting images, a
`sequence of sequence of images, video streams and other visual content on display unit 350. This
`can involve, for example, determining time intervals for presenting the visual content, time transition
`types between images. The interval transition time indicates the time interval between the current
`image and the next image to be displayed. The image transition is a mechanism of retiring the
`presentation of a current image while phasing in the next image. In one embodiment, the image
`transition moves current and next images in one direction as the current image move out while the
`next image moves.”)
`To the extent that Plaintiff alleges that Telek 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, Telek 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.
`
`
`
`11
`
`Page 11 of 25
`
`

`

`’986
`Claim
`2.pre
`
`2.a
`
`Claim Element
`
`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.
`
`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
`
`3.pre
`
`3.a
`
`
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Telek 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.
`For example, Telek discloses:
`25:10-21 (“As is illustrated in FIG. 24 the system 2410 incorporates three DFMs: first DMF 2304,
`second DMF 2306, and third DMF 2308, however this is done for simplicity and, in practice, a much
`larger number of DMFs can be used. As is also illustrated in FIG. 24 a controller 2420 is provided
`that is logically connected to first DMF 2304, second DMF 2306, and third DMF 2308 such that
`data can be exchanged therebetween. The method of such a logical connection can be made using
`any form of wired or wireless communication. As such a logical connection can be made between
`controller 2420 and first DMF 2304, second DMF 2306, and third DMF 2308 using any of the above
`described manners.”)
`To the extent that Plaintiff alleges that Telek 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, Telek 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.
`
`Telek 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.
`For example, Telek discloses:
`25:10-21 (“As is illustrated in FIG. 24 the system 2410 incorporates three DFMs: first DMF 2304,
`second DMF 2306, and third DMF 2308, however this is done for simplicity and, in practice, a much
`larger number of DMFs can be used. As is also illustrated in FIG. 24 a controller 2420 is provided
`12
`
`Page 12 of 25
`
`

`

`’986
`Claim
`
`Claim Element
`
`which logically disconnect
`the communication with the
`communication unit.
`
`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.
`
`5.pre
`
`The display apparatus
`according to claim 1,
`
`
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`that is logically connected to first DMF 2304, second DMF 2306, and third DMF 2308 such that
`data can be exchanged therebetween. The method of such a logical connection can be made using
`any form of wired or wireless communication. As such a logical connection can be made between
`controller 2420 and first DMF 2304, second DMF 2306, and third DMF 2308 using any of the above
`described manners.”)
`To the extent that Plaintiff alleges that Telek 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, Telek 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.
`
`Telek 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.
`For example, Telek discloses:
`9:51-55 (“In one embodiment, a digital module 314 includes a digital receiver circuit and a translation
`circuit (not shown in the figure). In one embodiment, the digital receiver circuit may include a
`universal serial bus (“USB”) port for receiving digital data from the interface block 314.”)
`To the extent that Plaintiff alleges that Telek 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, Telek 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.
`
`13
`
`Page 13 of 25
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`

`

`’986
`Claim
`
`
`Claim Element
`
`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.
`
`6.pre
`
`6.a
`
`A display apparatus
`comprising:
`
`a communication unit
`configured to communicate
`with an external device;
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`Telek 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, Telek discloses:
`9:51-55 (“In one embodiment, a digital module 314 includes a digital receiver circuit and a translation
`circuit (not shown in the figure). In one embodiment, the digital receiver circuit may include a
`universal serial bus (“USB”) port for receiving digital data from the interface block 314.”)
`18:9-20 (“FIG. 11 is a flowchart 1100 illustrating an embodiment of receiving data from various
`devices. The process begins at the start block and proceeds to block 1002 where the process receives
`data. At block 1004, the process examines whether the data comes from a camera. If block 1004 is
`false, the process proceeds to block 1008. However, if the block 1004 is true, which indicates that the
`data comes from the camera, the process receives the data using camera interface program at block
`1006. Camera interface program includes, but not limited to, identifying types of protocol used to
`transmit the code from the camera and translating the code to native language if it is needed.”)
`To the extent that Plaintiff alleges that Telek 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, Telek 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.
`Telek discloses a display apparatus.
`See, e.g., elements 6.a – 6.d.
`Telek discloses a communication unit configured to communicate with an external device.
`See, e.g., element 1.a.
`To the extent 35 U.S.C. § 112, ¶6 applies, Telek 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.
`
`
`
`14
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`Page 14 of 25
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`

`’986
`Claim
`6.b
`
`Claim Element
`
`a display unit configured to
`display an image received
`from the external device;
`
`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
`
`6.c
`
`6.d
`
`
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`Telek 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, Telek 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.
`Telek 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 logica