TCL’S INVALIDITY CONTENTIONS FOR U.S. 8,078,767
`Exhibit C3: U.S. Patent No. 8,612,653 (“Nitta”)
`
`
`As demonstrated in the claim charts below, the asserted claims of U.S. Patent No. 8,078,767 (“the ’767 patent”) are invalid (a) under
`one or more sections of 35 U.S.C. § 102 as anticipated by 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,
`and/or the additional prior art references discussed in Exhibits C1-C14, and O3, the contents of which are hereby incorporated by
`reference into this chart. One of ordinary skill in the art, as of the alleged priority date of the ’767 patent, would have known to
`combine the prior art elements disclosed by the foregoing references using known methods, and to use these elements according to
`their established functions in order to achieve a known and predictable result.
`
`Except where specifically noted otherwise, this chart may apply the apparent interpretations of claim language as used by Plaintiff in
`its infringement contentions. Such use, however, does not imply that Defendants adopt or agree with Plaintiff’s interpretations in any
`way. Additionally, by providing contentions for claim preamble elements, Defendants do not take a position on whether the preamble
`is a claim limitation.
`
`
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`Nitta discloses a display apparatus.
`See, e.g., elements 1.a – 1.d.
`Nitta discloses a display 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
`
`Claim Element
`
`’767
`Claim
`1.pre A display apparatus
`characterized by comprising:
`
`1.a
`
`a display unit;
`
`
`
`1
`
`Page 1 of 28
`
`CANON EXHIBIT 2002
`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00343
`
`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`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 connection unit configured to connect an external device to be able to communicate
`with 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
`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
`
`1.b
`
`a connection unit configured
`to connect an external device
`to be able to communicate
`with the external device; and
`
`
`
`2
`
`Page 2 of 28
`
`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`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.”)
`4:4-16 (“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 control unit configured to control said display unit to make a display based on data
`received from the external device with which a communication connection is established via said
`connection unit.
`For example, 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
`3
`
`a control unit configured to
`control said display unit to
`make a display based on data
`received from the external
`device with which a
`communication connection is
`
`1.c
`
`
`
`Page 3 of 28
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`

`

`’767
`Claim
`
`Claim Element
`
`established via said
`connection unit,
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`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 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
`
`
`
`4
`
`Page 4 of 28
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`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`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.
`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 C1-C14, and O3.
`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 that acquires class information indicating a class of the external device
`from the external device via said connection unit, controls said display unit to continue the display
`based on the data received from the external device at the time of disconnection of the communication
`connection with the external device if the class of the external device indicated by the class
`information is a predetermined class, and controls said display unit to end the display based on the
`data received from the external device at the time of disconnection of the communication connection
`with the external device if the class of the external device indicated by the class information is not the
`predetermined class.
`See, e.g. element 1.c.
`In addition, Nitta discloses:
`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
`
`5
`
`characterized in that said
`control unit acquires class
`information indicating a class
`of the external device from
`the external device via said
`connection unit, controls said
`display unit to continue the
`display based on the data
`received from the external
`device at the time of
`disconnection of the
`communication connection
`with the external device if the
`class of the external device
`indicated by the class
`information is a
`predetermined class, and
`
`1.d
`
`
`
`Page 5 of 28
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`

`

`’767
`Claim
`
`Claim Element
`
`controls said display unit to
`end the display based on the
`data received from the
`external device at the time of
`disconnection of the
`communication connection
`with the external device if the
`class of the external device
`indicated by the class
`information is not the
`predetermined class.
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`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
`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.”)
`
`
`
`6
`
`Page 6 of 28
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`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`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
`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).
`
`
`
`7
`
`Page 7 of 28
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`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`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.
`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;
`
`
`
`8
`
`Page 8 of 28
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`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`(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
`
`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 C1-C14, and O3.
`
`
`
`
`
`9
`
`Page 9 of 28
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`

`

`’767
`Claim
`
`2.pre
`
`2.a
`
`Claim Element
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`The display apparatus
`according to claim 1,
`characterized in that the
`predetermined class is a class
`of a device which logically
`disconnects a communication
`connection.
`
`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.
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Nitta discloses a display apparatus characterized in that the predetermined class is a class of a device
`which logically disconnects a communication connection.
`11:16-28 (As shown in FIG. 4, each of the screens (GUIs) is provided with an “end” button. When the
`user operates the “end” button, the screen is changed to a selection screen in step S202. That is, the
`screen is changed to a GUI screen displaying an “end” button to be operated to completely break
`the USB connection and a “change connection” button to be operated to change the USB connection.
`When the user wants to end the outputting or printing of the content stored in the recording medium,
`the user operates the “end” button in step S202. When the user operates the “end” button, as
`shown in step S203 a, the screen returns to the initial screen such as the screen displayed in the
`playback mode, and the USB connection is thereby terminated. “)
`FIG. 4
`
`
`
`10
`
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`

`’767
`Claim
`
`Claim Element
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`3.pre
`
`3.a
`
`The display apparatus
`according to claim 1,
`characterized in that if the
`class information indicates a
`USB mass storage class, said
`control unit controls to end
`the display.
`
`See also 15:54-59.
`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 C1-C14, and O3.
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`
`
`Nitta discloses a display apparatus characterized in that if the class information indicates a USB mass
`storage class, said control unit controls to end the display.
`For example, Nitta discloses:
`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
`
`
`
`11
`
`Page 11 of 28
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`

`

`’767
`Claim
`
`Claim Element
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`the application layer above the transport layer. Accordingly, different communication specifications
`are applied.”)
`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
`
`See also 8:21-32; 9:10-18.
`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 C1-C14, and O3.
`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.
`
`
`
`
`
`12
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`

`’767
`Claim
`4.pre
`
`4.a
`
`Claim Element
`
`The display apparatus
`according to claim 1,
`characterized in that if the
`class information is class
`information indicating a USB
`imaging class, said control
`unit controls to continue the
`display.
`
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Nitta discloses a display apparatus characterized in that if the class information is class information
`indicating a USB imaging class, said control unit controls to continue the display.
`For example, Nitta discloses:
`1:37-57 (“An example of a slave device includes an imager, such as a video camera or a still camera.
`An imager that has a USB connection terminal and that can be connected via a USB cable
`outputs imaging data recorded on, for example, a recording medium in the imager and outputs
`the imaging data via the USB cable to the PC, which in turn can play or edit the imaging data.
`The communication standard “PictBridge” allows printing without using a PC by directly connecting a
`digital camera to a printer via a USB cable and directly outputting imaging data recorded on a
`recording medium in the imager (digital camera) to the printer.
`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.”)
`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.
`
`
`
`13
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`’767
`Claim
`
`Claim Element
`
`Prior Art: U.S. Patent No. 8,612,653 (“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
`
`See also 8:21-32; 9:10-18.
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`Page 14 of 28
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`’767
`Claim
`
`Claim Element
`
`Prior Art: U.S. Patent No. 8,612,653 (“Nitta”)
`
`5.pre
`
`5.a
`
`The display apparatus
`according to claim 4,
`characterized in that even if
`the class information is the
`class information indicating
`the USB imaging class, when
`the communication
`connection with the external
`device is disconnected during
`a communication with the
`external device, said control
`unit controls to end the
`display.
`
`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 C1-C14, and O3.
`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.
`Defendants incorporate by reference their contentions relating to claim 4, as if fully set forth herein.
`
`Nitta discloses a display apparatus characterized in that even if the class information is the class
`information indicating the USB imaging class, when the communication connection with the external
`device is disconnected during a communication with the external device, said control unit controls to
`end the display.
`For example, Nitta discloses:
`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 disconn