TCL’S INVALIDITY CONTENTIONS FOR U.S. 7,746,413
`Exhibit A2: U.S. Patent No. 7,234,111 (“Chu”)
`
`
`As demonstrated in the claim charts below, the asserted claims of U.S. Patent No. 7,746,413 (“the ’413 patent”) are invalid (a) under
`one or more sections of 35 U.S.C. § 102 as anticipated by Chu and (b) under 35 U.S.C. § 103(a) as obvious over Chu 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 A1, A3-A9, and O1, 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 ’413 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.
`
`
`Claim Element
`
`’413
`Claim
`1.pre A controlling method of an
`operation screen for
`operations of a remote control
`device, comprising the steps
`of:
`
`Prior Art: U.S. Pat. No. 7,234,111 (“Chu”)
`
`Chu discloses a controlling method of an operation screen for operations of a remote control device.
`For example, Chu discloses:
`Abstract (“A system for dynamically adapting a presentation generated with a scalable application to a
`display screen of any of a plurality of heterogeneous device platforms is disclosed. The system
`includes a device platform and a transformation module. The device platform is one of the
`heterogeneous device platforms and includes a display screen. The device platform is operable to
`initiate generation of a hierarchical configuration representing a plurality of graphical user interface
`components. The transformation module is operable to selectively arrange the graphical user interface
`components on a page as a function of the hierarchical configuration. In the addition, the
`transformation module is operable to selectively transform the graphical user interface components to
`maximize the fill of the display Screen by the page. “)
`1:7-10 (“The present invention relates generally to graphical user interfaces (GUI) and, more
`particularly, to a scalable GUI architecture to adapt applications to the user interface of different
`heterogeneous device platforms.”)
`3:16-22 (“The transformation manager module may generate a set of proposed device platform
`dependent pages. At least one of the device platform dependent pages may be selected to display the
`
`
`
`1
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`CANON EXHIBIT 2002
`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00355
`
`

`

`
`
`’413
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,234,111 (“Chu”)
`
`application GUI. Selection may be based on identifying the page(s) that provide the most desirable
`display on the display screen.”)
`4:46-53 (“The different heterogeneous device platforms may be any device that includes a display
`screen and the capability to run a scalable application. Exemplary heterogeneous device platforms
`include wireless phones, pocket personal computers (PCs), personal device assistants (PDAs), pagers,
`desktop computers, notebook computers, on board vehicle computers or any other wireline/wireless
`device with a display screen that is capable of executing a scalable application.”)
`5:1-7 (“In addition, the heterogeneous device platforms may include a user interface. The user
`interface may include, for example, a device display, a key board, a pointing device similar to a
`mouse, a touch screen, a keypad, audio capabilities or any other mechanism providing an interface for
`a user of one of the heterogeneous device platforms.”)
`6:35-51 (“Different heterogeneous device platforms may also include different input methods
`associated with the scalable application and the application GUIs. For example, a wireless phone may
`use a keypad as an input method, a Pocket PC may uses a stylus as an input method and a Notebook
`PC may use a keyboard and/or a mouse-like pointing device as an input method.”)
`See, e.g., elements 1.a – 1.d.
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`Chu discloses acquiring an attribute of a remote control device.
`For example, Chu discloses:
`8:27-32 (“The customizing module 14 operates to customize the device independent intermediate
`representation for a target device platform. The term “target device platform” identifies one of the
`heterogeneous device platforms where the scale able application is generating a presentation for
`display.”)
`8:47-51 (‘In one embodiment, the scalable application identifies the capabilities of a target device
`platform and provides the capabilities to the task manager module 18. In another embodiment, the task
`
`1.a
`
`acquiring an attribute of a
`remote control device;
`
`
`
`2
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`’413
`Claim
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`Claim Element
`
`Prior Art: U.S. Pat. No. 7,234,111 (“Chu”)
`
`1.b
`
`determining an operation
`form corresponding to the
`remote control device from
`among a plurality of operation
`forms previously stored based
`on the acquired attribute of
`the remote control device; and
`
`manager module 18 is capable of identifying the capabilities of a target device platform.”); see also
`8:63-67.
`9:1-3 (“The transformation manager module 20 operates to transform the intermediate representation
`into a device platform dependent presentation.”)
`See also FIGS. 1, 2, 10.
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`Chu discloses determining an operation form corresponding to the remote control device from among
`a plurality of operation forms previously stored based on the acquired attribute of the remote control
`device.
`See, e.g., element 1.a.
`In addition, Chu discloses:
`3:16-22 (“The transformation manager module may generate a set of proposed device platform
`dependent pages. At least one of the device platform dependent pages may be selected to display the
`application GUI. Selection may be based on identifying the page(s) that provide the most desirable
`display on the display screen.”)
`5:13-17 (“Capabilities of heterogeneous device platforms may include, for example, the type of device
`platform (e.g. wireless phone, PDA, laptop PC, etc.), the available user interfaces library, the size of
`the display screen and the resolution of the display screen.”)
`8:41-44 (“The task manager module 18 of one embodiment may operate to remove tasks (functions)
`from the device independent intermediate representation based on the capabilities of a target device
`platform.”)
`8:52-55 (“Tasks removed from the intermediate representation may include those tasks representative
`of functions/capabilities of a scaleable application that are not suitable for a target device platform.”)
`
`
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`3
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`’413
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,234,111 (“Chu”)
`
`8:63-67 (“In one embodiment, the task manager removes the tasks according to the capabilities of the
`target device platform and/or any other properties specified by application developers within the
`intermediate representation.”)
`9:1-3 (“The transformation manager module 20 operates to transform the intermediate representation
`into a device platform dependent presentation.”)
`9:8-12 (“Transformation of the intermediate representation involves dynamically configuring the
`intermediate representation based capabilities of the target device platform, the logic structure of the
`intermediate representation and/or properties specified by the application GUI.”)
`15:29-31 (“In one embodiment, the scalable application identifies the capabilities of a target device
`platform and provides the capabilities to the task manager module 18. In another embodiment, the task
`manager module 18 is capable of identifying the capabilities of a target device platform.”)
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`Chu discloses displaying an operation screen related to the determined operation form displayed.
`For example, Chu discloses:
`2:58-62 (“The graphical user interface components and logical panels may be arranged on at least one
`page of a presentation as first part of the dynamic configuration. The presentation may be displayed on
`a display screen of the target device platform.”)
`8:27-31 (“The customizing module 14 operates to customize the device independent intermediate
`representation for a target device platform. The term “target device platform identifies one of the
`heterogeneous device platforms where the scaleable application is generating a presentation for
`display.”)
`9:19-21 (“The render manager module 16 may operate to bring presentations onto the display Screen
`of the target device platform.”)
`9:56-58 (“The presentation may then be displayed on the display screen of the target device platform
`by the rendering manager module 16.”)
`
`1.c
`
`displaying an operation
`screen related to the
`determined operation form
`displayed,
`
`
`
`4
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`’413
`Claim
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`1.d
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,234,111 (“Chu”)
`
`wherein, in the step of
`determining the operation
`form, the operation form
`corresponding to the remote
`control device is determined
`by evaluating a degree of
`suitability between the remote
`control device and each of the
`plurality of operation forms
`based on the acquired
`attribute of the remote control
`device.
`
`22:60-62 (“The render manager module 16 then directs the display of the now device dependent
`application GUI on the display screen of the device platform 202 at block 276.”); see also FIG. 12
`(element 276), claims 1, 4, 7, 9, 10, 20, 30, 31, 33, 34, 37, 39, 40, 50).
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`Chu discloses that, in the step of determining the operation form, the operation form corresponding to
`the remote control device is determined by evaluating a degree of suitability between the remote
`control device and each of the plurality of operation forms based on the acquired attribute of the
`remote control device.
`See element 1.b.
`In addition, Chu discloses:
`2:50-52 (“Those logical panels and/or graphical user interface components suitable for the target
`device platform may be selected for retention in the intermediate representation.”)
`8:52-55 (“Tasks removed from the intermediate representation may include those tasks representative
`of functions/capabilities of a scaleable application that are not suitable for a target device platform.”)
`16:2-5 (“The transformation rules module 50 includes a plurality of transformation rules that may be
`utilized to transform the SGUI components represented in the IR tree 40 (FIG. 3).”)
`16:20-22 (‘The simple GUI transformation rules module 56 provides rules to transform SGUI
`components into SGUI components specific to the target device platform.”)
`16:31-34 (“In the illustrated example, the first SGUI component 70 represents a priority selection list
`in which “high” “medium,” or “low” priority may be selected by a user.”)
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`
`
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`5
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`2.a
`
`Claim Element
`
`’413
`Claim
`2.pre A controlling method
`according to claim 1,
`wherein the plurality of
`operation forms are different
`from each other in a
`combination of operation
`devices selected for use
`therein from among a
`plurality of operation devices.
`
`4.pre A controlling method
`according to claim 1,
`
`Prior Art: U.S. Pat. No. 7,234,111 (“Chu”)
`
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Chu discloses a controlling method wherein the plurality of operation forms are different from each
`other in a combination of operation devices selected for use therein from among a plurality of
`operation devices.
`For example, Chu discloses:
`5:66-6: (“The display screen size may impact the quality of visual presentation as well as the layout of
`components forming pages of the presentation on the display screen.”)
`6:3-7 (“The components forming the pages may be referred to as graphical user interface (GUI)
`components. GUI components are displayed features of the presentation that may be fixed, animated
`and/or interactive in the context of a display screen.”)
`6:35-42 (“Different heterogeneous device platforms may also include different input methods
`associated with the scalable application and the application GUIs. For example, a wireless phone may
`use a keypad as an input method, a Pocket PC may uses a stylus as an input method and a Notebook
`PC may use a keyboard and/or a mouse-like pointing device as an input method.”)
`7:12-19 (“For example, a PDA may include more touch screen related GUI components in
`a corresponding GUI library. On the other hand, a wireless phone, for example, may include only
`indication related GUI components in a corresponding GUI library. As known in the art, GUI libraries
`are compilations of pre-developed GUI components that may be accessed to produce a presentation.”)
`9:8-12 (“Transformation of the intermediate representation involves dynamically configuring the
`intermediate representation based capabilities of the target device platform, the logic structure of the
`intermediate representation and/or properties specified by the application GUI.”)
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`6
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`’413
`Claim
`4.a
`
`Claim Element
`
`wherein the plurality of
`operation forms are different
`from each other in a layout of
`a display element
`constructing the operation
`screen.
`
`5.a
`
`5.pre A controlling method
`according to claim 1,
`further comprising a step of,
`in case that the acquired
`attribute of the remote control
`device cannot be specified,
`acquiring an attribute of the
`remote control device from
`outside, and updating a
`database in which attributes
`of remote control devices are
`previously stored.
`
`Prior Art: U.S. Pat. No. 7,234,111 (“Chu”)
`
`Chu discloses a controlling method wherein the plurality of operation forms are different from each
`other in a layout of a display element constructing the operation screen.
`For example, Chu discloses:
`16:2-5 (“The transformation rules module 50 includes a plurality of transformation rules that may be
`utilized to transform the SGUI components represented in the IR tree 40 (FIG. 3).”)
`16:20-22 (‘The simple GUI transformation rules module 56 provides rules to transform SGUI
`components into SGUI components specific to the target device platform.”)
`16:31-34 (“In the illustrated example, the first SGUI component 70 represents a priority selection list
`in which “high” “medium,” or “low” priority may be selected by a user.”)
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Chu discloses a controlling method further comprising a step of, in case that the acquired attribute of
`the remote control device cannot be specified, acquiring an attribute of the remote control device from
`outside, and updating a database in which attributes of remote control devices are previously stored.
`For example, Chu discloses:
`20:52-21:6 (“An exemplary utilization of the SGUI architecture within a communication system will
`now be described. FIG. 10 is an exemplary embodiment of a communication system 200 that includes
`a device platform 202, a transformation server 204 and a library server 206 in operable
`communication over a network 208. The device platform 202 may be any of the previously described
`heterogeneous device platforms. The transformation server 204 and the library server 206 may be any
`device performing a server function within the network 208. In one embodiment, one or more server
`computers that include an operating system operate as the transformation server 204 and the library
`server 206. Exemplary operating systems include Microsoft Windows NT, UNIX or any other
`operating system capable of supporting server functionality. The servers 204, 206 may include the
`ability to store and access data as well as execute applications, such as, for example, portions of the
`SGUI architecture. The network 208 may include the Internet, a public or private intranet, an extranet
`7
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`’413
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,234,111 (“Chu”)
`
`and/or any other form of network configuration to enable transfer of data and commands via wireless,
`fiber optic and/or wireline communications.”); see also 21:7-21:62.
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`Chu discloses a computer-readable medium in which a program is stored, the program making a
`computer execute the controlling method according to claim 1.
`See, e.g., elements 1.pre – 1.d.
`In addition, Chu discloses:
`5:23-27 (“In the presently preferred embodiments, the heterogeneous device platforms are mobile
`devices executing scalable applications created with Java technology. Java technology includes a Java
`programming language operating on a Java Virtual Machine (Java VM).”)
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`Chu discloses a display controlling apparatus for making an operation screen for operations of a
`remote control device displayed in a display unit.
`See elements 1.pre, 7.a – 7.d, 6.
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`Chu discloses an acquiring unit which acquires an attribute of a remote control device.
`See, e.g., elements 1.a, 6.
`To the extent that Plaintiff alleges that Chu 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
`
`6
`
`A computer-readable medium
`in which a program is stored,
`the program making a
`computer execute the
`controlling method according
`to claim 1.
`
`7.pre A display controlling
`apparatus for making an
`operation screen for
`operations of a remote control
`device displayed in a display
`unit, the apparatus
`comprising:
`
`7.a
`
`an acquiring unit which
`acquires an attribute of a
`remote control device;
`
`
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`’413
`Claim
`
`7.b
`
`a determining unit which
`determines an operation form
`corresponding to the remote
`control device from among a
`plurality of operation forms
`previously stored in a storing
`unit based on the attribute of
`the remote control device
`acquired by the acquiring
`unit; and
`
`7.c
`
`a controlling unit which
`displays an operation screen
`related to the operation form
`which is determined by the
`determining unit displayed,
`
`7.d
`
`wherein the determining unit
`determines the operation form
`corresponding to the remote
`
`
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,234,111 (“Chu”)
`
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`To the extent 35 U.S.C. § 112, ¶6 applies, Chu 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.
`Chu discloses a determining unit which determines an operation form corresponding to the remote
`control device from among a plurality of operation forms previously stored in a storing unit based on
`the attribute of the remote control device acquired by the acquiring unit.
`See, e.g., elements 1.b, 6.
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`To the extent 35 U.S.C. § 112, ¶6 applies, Chu 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.
`Chu discloses a controlling unit which displays an operation screen related to the operation form
`which is determined by the determining unit displayed.
`See, e.g., elements 1.c, 6.
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`To the extent 35 U.S.C. § 112, ¶6 applies, Chu 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.
`Chu discloses a determining unit wherein the determining unit determines the operation form
`corresponding to the remote control device by evaluating a degree of suitability between the remote
`
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`’413
`Claim
`
`Claim Element
`
`control device by evaluating a
`degree of suitability between
`the remote control device and
`each of the plurality of
`operation forms based on the
`attribute of the remote control
`device acquired by the
`acquiring unit.
`
`8.a
`
`8.pre A display controlling
`apparatus according to claim
`7,
`wherein the plurality of
`operation forms are different
`from each other in a
`combination of operation
`devices selected for use
`therein from among a
`plurality of operation devices.
`
`10.pre A display controlling
`apparatus according to claim
`7,
`wherein the plurality of
`operation forms are different
`from each other in a layout of
`a display element
`
`10.a
`
`
`
`Prior Art: U.S. Pat. No. 7,234,111 (“Chu”)
`
`control device and each of the plurality of operation forms based on the attribute of the remote control
`device acquired by the acquiring unit.
`See, e.g., elements 1.d, 6.
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`To the extent 35 U.S.C. § 112, ¶6 applies, Chu 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.
`
`Chu discloses a display controlling apparatus wherein the plurality of operation forms are different
`from each other in a combination of operation devices selected for use therein from among a plurality
`of operation devices.
`See, e.g., elements 2.a, 6.
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`Defendants incorporate by reference their contentions relating to claim 7, as if fully set forth herein.
`
`Chu discloses a display controlling device wherein the plurality of operation forms are different from
`each other in a layout of a display element constructing the operation screen.
`See, e.g., elements 4.a, 6.
`To the extent that Plaintiff alleges that Chu 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
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`Claim
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`Claim Element
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`11.a
`
`constructing the operation
`screen.
`11.pre A display controlling
`apparatus according to claim
`7,
`further comprising a unit
`which, in case that the
`attribute of the remote control
`device acquired by the
`acquiring unit cannot be
`specified, acquires an
`attribute of the remote control
`device from outside, and
`updates a database in which
`attributes of remote control
`devices are previously stored.
`
`Prior Art: U.S. Pat. No. 7,234,111 (“Chu”)
`
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`Defendants incorporate by reference their contentions relating to claim 7, as if fully set forth herein.
`
`Chu discloses a display controlling device further comprising a unit which, in case that the attribute of
`the remote control device acquired by the acquiring unit cannot be specified, acquires an attribute of
`the remote control device from outside, and updates a database in which attributes of remote control
`devices are previously stored.
`See, e.g., elements 5.a, 6.
`To the extent that Plaintiff alleges that Chu does not explicitly disclose this claim limitation, this
`limitation is inherent and/or it would have been obvious in view of the knowledge of a person of
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1, A3-A9, and
`O1.
`To the extent 35 U.S.C. § 112, ¶6 applies, Chu 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.
`
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