TCL’S INVALIDITY CONTENTIONS FOR U.S. 8,713,206
`Exhibit E7: U.S. Patent No. 7,877,696 (“Telek”)
`
`
`As demonstrated in the claim charts below, the asserted claims of U.S. Patent No. 8,713,206 (“the ’206 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 E1-E14, and O5, 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 ’206 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 control apparatus.
`See, e.g., elements 1.a – 1.c.
`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,
`
`Claim Element
`
`’206
`Claim
`1.pre A display control apparatus
`comprising:
`
`1.a
`
`a communication unit
`configured to communicate
`with an external device; and
`
`
`
`1
`
`Page 1 of 20
`
`CANON EXHIBIT 2006
`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00343
`
`

`

`’206
`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 20
`
`

`

`’206
`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 20
`
`

`

`’206
`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 20
`
`

`

`’206
`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 20
`
`

`

`’206
`Claim
`1.b
`
`Claim Element
`
`a display control unit
`configured to display, on a
`display unit, an image
`received from the external
`device via the communication
`unit, and if communication
`with the external device is
`disconnected, to stop the
`display of the image received
`from the external device,
`
`1.c
`
`wherein the display control
`unit varies a period of time
`from the disconnection to the
`stopping of the display of the
`image depending on a type of
`the external device.
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`Telek discloses a display control unit configured to display, on a display unit, an image received from
`the external device via the communication unit, and if communication with the external device is
`disconnected, to stop the display of the image received from the external device.
`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 E1-E14, and O5.
`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 that the display control unit varies a period of time from the disconnection to the
`stopping of the display of the image depending on a type of the external device.
`See, e.g., element 1.b.
`In addition, Telek discloses:
`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
`
`6
`
`Page 6 of 20
`
`

`

`’206
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`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 E1-E14, and O5.
`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.
`
`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 E1-E14, and O5.
`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 that if the communication with the external device is physically disconnected, the
`display control unit stops the display of the image after a predetermined first period of time elapses.
`For example, Telek discloses:
`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
`
`7
`
`2.pre
`
`2.a
`
`3.pre
`
`3.a
`
`The display control apparatus
`according to claim 1,
`wherein the display control
`unit stops the display of the
`image immediately or after a
`specific period of time
`elapses from the
`disconnection depending on a
`type of the external device.
`The display control apparatus
`according to claim 1,
`wherein if the communication
`with the external device is
`physically disconnected, the
`display control unit stops the
`display of the image after a
`predetermined first period of
`time elapses.
`
`Page 7 of 20
`
`

`

`’206
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`4.pre
`
`4.a
`
`The display control apparatus
`according to claim 3,
`wherein if the communication
`with the external device is
`logically disconnected, the
`display control unit stops the
`display of the image after a
`predetermined second period
`of time elapses, the
`predetermined second period
`of time being longer than the
`predetermined first period of
`time.
`
`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 E1-E14, and O5.
`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 3, as if fully set forth herein.
`
`Telek discloses that if the communication with the external device is logically disconnected, the
`display control unit stops the display of the image after a predetermined second period of time elapses,
`the predetermined second period of time being longer than the predetermined first period of time.
`For example, Telek discloses:
`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.”)
`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
`
`8
`
`Page 8 of 20
`
`

`

`’206
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`5.pre
`
`5.a
`
`The display control apparatus
`according to claim 1,
`wherein the communication
`unit is connected with the
`external device via a physical
`communication interface.
`
`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 E1-E14, and O5.
`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 that the communication unit is connected with the external device via a physical
`communication interface.
`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,
`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.
`
`9
`
`Page 9 of 20
`
`

`

`’206
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`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.)
`
`
`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
`
`10
`
`Page 10 of 20
`
`

`

`’206
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`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.”)
`
`11
`
`Page 11 of 20
`
`

`

`’206
`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.”)
`
`12
`
`Page 12 of 20
`
`

`

`’206
`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.
`
`
`
`13
`
`Page 13 of 20
`
`

`

`Claim Element
`
`’206
`Claim
`7.pre A display control apparatus
`comprising:
`
`7.a
`
`a communication unit
`configured to communicate
`with an external device; and
`
`7.b
`
`7.c
`
`a display control unit
`configured to display, on a
`display unit, an image
`received from the external
`device via the communication
`unit, and if communication
`with the external device is
`disconnected, to stop the
`display of the image received
`from the external device,
`
`wherein the display control
`unit varies a period of time
`from the disconnection to the
`stopping of the display of the
`image depending on a
`determination result as to
`whether the disconnection of
`the communication with the
`external device is a physical
`disconnection or a logical
`disconnection.
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`Telek discloses a display control apparatus.
`See, e.g., elements 7.a – 7.c.
`Telek discloses a communication unit configured to communicate with an external device.
`For example, Telek discloses:
`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.
`Telek discloses a display control unit configured to display, on a display unit, an image received from
`the external device via the communication unit, and if communication with the external device is
`disconnected, to stop the display of the image received from the external device.
`See, e.g., element 1.b.
`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 E1-E14, and O5.
`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 that he display control unit varies a period of time from the disconnection to the
`stopping of the display of the image depending on a determination result as to whether the
`disconnection of the communication with the external device is a physical disconnection or a logical
`disconnection.
`See, e.g., element 7.b.
`In addition, Telek discloses:
`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
`
`14
`
`Page 14 of 20
`
`

`

`’206
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`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.”)
`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 E1-E14, and O5.
`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 7, as if fully set forth herein.
`
`Telek discloses that the display control unit stops the display of the image immediately or after a
`specific period of time elapses from the disconnection depending on a determination result as to
`whether the disconnection of the communication with the external device is a physical disconnection
`or a logical disconnection.
`For example, Telek discloses:
`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,
`
`15
`
`8.pre
`
`8.a
`
`The display control apparatus
`according to claim 7,
`wherein the display control
`unit stops the display of the
`image immediately or after a
`specific period of time
`elapses from the
`disconnection depending on a
`determination result as to
`whether the disconnection of
`the communication with the
`external device is a physical
`
`Page 15 of 20
`
`

`

`’206
`Claim
`
`Claim Element
`
`disconnection or a logical
`disconnection.
`
`9.pre
`
`9.a
`
`The display control apparatus
`according to claim 7,
`wherein if the communication
`with the external device is
`physically disconnected, the
`display control unit stops the
`display of the image after a
`predetermined first period of
`time elapses.
`
`Prior Art: U.S. Pat. No. 7,877,696 (“Telek”)
`
`the image transition moves current and next images in one direction as the current image move out
`while the next image moves.”)
`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 E1-E14, and O5.
`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 7, as if fully set forth herein.
`
`Telek discloses that if the communication with the external device is physically disconnected, the
`display control unit stops the display of the image after a predetermined first period of time elapses.
`For example, Telek discloses:
`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