TCL’S INVALIDITY CONTENTIONS FOR U.S. 7,746,413
`Exhibit A7: U.S. Application Publication No. 2001/0006382(“Sevat”)
`
`
`As demonstrated in the claim charts below, the 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 Sevat and (b) under 35 U.S.C. § 103(a) as obvious over Sevat 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-A6, A8-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.
`
`
`Prior Art: U.S. Appln. Pub. No. 2001/0006382 (“Sevat”)
`
`Sevat discloses a controlling method of an operation screen for operations of a remote control device.
`See, e.g., elements 1.a – 1.d.
`See also Abstract (“The invention relates to a display system comprising a display device capable of
`displaying information in multiple windows of the display device, enabling the user to select a
`window for controlling a parameter of said window in response to subsequent user supplied parameter
`control commands. The display system according to the invention comprises two or more remote
`controls, and association means for associating a respective remote control with a respective window.
`Upon reception of a control command from a remote control, the window associated with the remote
`control is selected, and the control command is applied to the selected window. In this way, multiple
`users are enabled to independently control a window displayed on the display device.”)
`To the extent that Plaintiff alleges that Sevat 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-A6, A8-A9,
`and O1.
`Sevat discloses acquiring an attribute of a remote control device.
`For example, Sevat discloses:
`
`1
`
`Claim Element
`
`’413
`Claim
`1.pre A controlling method of an
`operation screen for
`operations of a remote control
`device, comprising the steps
`of:
`
`1.a
`
`acquiring an attribute of a
`remote control device;
`
`
`
`Page 1 of 10
`
`CANON EXHIBIT 2004
`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00357
`
`

`

`’413
`Claim
`
`Claim Element
`
`Prior Art: U.S. Appln. Pub. No. 2001/0006382 (“Sevat”)
`
`¶9 (“An alternative embodiment of the display system according to the invention is characterized by
`said association means comprising, in each respective remote control, remote control identification
`means for transmitting, along with a transmitted parameter control command, a signal. Such an
`identification signal may be stored in the remote control in advance by the manufacturer, but
`advantageously, the remote control enables the user to select a respective one of a set of
`predetermined identities. For example, the user may assign a unique number to each of the available
`remote controls. Such a number, identifying the remote control, may be transmitted along with each
`parameter control command, for example, as a prefix. For example, the user may assign a unique
`number to each of the available remote controls. Such a number, identifying the remote control, may
`be transmitted along with each parameter control command, for example, as a prefix. The display
`device is then capable of determining which remote control transmitted the parameter control
`command, look up the associated window and control the appropriate parameter of the associated
`window.”)
`¶17 (“The television receiver 101 comprises an infrared (IR) receiver 104 for receiving IR signals
`from a remote control 105 and a remote control 106.”)
`¶21 (“In the present embodiment the user command unit 213 further comprises discrimination means
`221 for discriminating signals received by the user command unit 213 from the remote controls 215
`and 216, so as to determine from which remote control the received signals originate.”)
`¶21 (“For that purpose, the user command unit 213 comprises, in one embodiment, two distinct IR
`receivers 222 and 223, each adapted for receiving IR signals from a predetermined remote control, e.g.
`a remote control transmitting IR signals in accordance with a specific protocol.”)
`¶21 (“Each remote control may thus be assigned an identity, e.g. RC1 and RC2, which identity is
`transmitted to the television receiver along with each control command.”)
`¶21 (“In such cases, the remote controls may comprise means to adjust the identifying parameter, So
`as to uniquely identify the remote control.”)
`¶25 (“In a step 401 a control command is received from any of the remote controls.”); see also, FIG.
`4.
`To the extent that Plaintiff alleges that Sevat 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
`
`
`
`2
`
`Page 2 of 10
`
`

`

`’413
`Claim
`
`1.b
`
`Claim Element
`
`Prior Art: U.S. Appln. Pub. No. 2001/0006382 (“Sevat”)
`
`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
`
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibits A1-A6, A8-A9,
`and O1.
`Sevat 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.
`For example, Sevat discloses:
`¶19 (“The remote control 215 comprises window identification means 217, and the remote control 216
`comprises similar window identification means 218. The window identification means 217 and 218
`cause IR control commands transmitted by the remote controls 215 and 216 to be prefixed by a
`window identification signal identifying a window displayed on the display screen of the television
`receiver.”)
`¶19 (“When a control command is received while the television receiver is in the split-screen mode,
`the user command unit 213 interprets the window identification signal and transmits a command to the
`user command processor 210 so as to control the appropriate window in accordance with the window
`identification signal.”)
`¶19 (“The window identification transmitted by the remote controls 215 and 216 may be entered by
`the user, prestored by the manufacturer, or dynamically altered in dependence on the remote control’s
`position, as described above.”)
`¶19 (“The window identification means 217 and 218 thus constitute association means for associating
`the remote controls 215 and 216 with respective windows.”)
`¶21 (“In the present embodiment the user command unit 213 further comprises discrimination means
`221 for discriminating signals received by the user command unit 213 from the remote controls 215
`and 216, so as to determine from which remote control the received signals originate.”)
`¶21 (“The discrimination means maintain a table specifying which remote control is assigned to which
`window on the display screen. This table has a default content, e.g. RC1 controls the left window,
`while RC2 controls the right window, and the content can be altered by the user by means of the user
`command unit 213.”)
`¶25 (“In a step 402 the prefix is separated from the remote control command and a window
`identification is decoded from it. In a step 403, it is determined for which window the received control
`
`
`
`3
`
`Page 3 of 10
`
`

`

`’413
`Claim
`
`Claim Element
`
`Prior Art: U.S. Appln. Pub. No. 2001/0006382 (“Sevat”)
`
`1.c
`
`displaying an operation
`screen related to the
`determined operation form
`displayed,
`
`command is meant, by testing the value of the window identification decoded from the prefix.”); see
`also, FIG. 4.
`To the extent that Plaintiff alleges that Sevat 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 Exhibit A1-A6, A8-A9,
`and O1.
`Sevat discloses displaying an operation screen related to the determined operation form displayed.
`For example, Sevat discloses:
`¶18 (“For example, the user may enter a channel number in order to Select the corresponding channel.
`The channel number is translated by the user command processor into an appropriate command which
`is used to control the tuner 202a or 202b to tune to the desired channel.”)
`¶19 (“The window identification means 217 and 218 cause IR control commands transmitted by the
`remote controls 215 and 216 to be prefixed by a window identification signal identifying a window
`displayed on the display screen of the television receiver.”)
`¶19 (“If the user command is a channel selection command, the user command processor 210 controls,
`in dependence on the window identification signal, the tuner 202a or the tuner 202b to select the
`desired channel, and the window means 211 to display the video signals of that channel in the desired
`window.”)
`¶25 (“If the window identity refers to a first window, it is determined in a step 404 whether the control
`command is a channel selection command. If so, a first tuner coupled with the first window is
`controlled in a step 406 to tune to the desired channel. Otherwise, the control command is interpreted
`in a step 407 as a parameter control command for controlling a parameter of the first window, e.g.
`brightness or contrast. If it is determined that the control command is meant for a second window, it is
`determined in a step 405 whether the control command is a channel selection command. If so, a
`second tuner coupled with the second window is controlled in a step 407 to tune to the desired
`channel. Otherwise, the control command is interpreted in a step 409 as a parameter control command
`for controlling a parameter of the second window.”), see also, FIG. 4.
`To the extent that Plaintiff alleges that Sevat 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
`
`
`
`4
`
`Page 4 of 10
`
`

`

`’413
`Claim
`
`1.d
`
`Claim Element
`
`Prior Art: U.S. Appln. Pub. No. 2001/0006382 (“Sevat”)
`
`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.
`
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibit A1-A6, A8-A9,
`and O1.
`Sevat 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, e.g., element 1.b.
`In addition, Sevat discloses:
`¶17 (“The location of the remote control 105 and the remote control 106 is not essential, e.g.
`exchanging their positions would not necessarily change the respective window controlled by them.”)
`¶17 (“For example, in an advanced embodiment the television receiver 101 is capable of determining
`the relative positions of the two remote controls, e.g. by comparing and storing the angles of incidence
`of the IR signals, and of associating the windows accordingly.”)
`¶17 (“Each time an IR signals is received, the position is compared with the previously stored
`positions, So as to detect an exchange of positions. Exchanging the positions of the remote controls
`will then change the window controlled by each respective remote control, and optionally, exchange
`each window's parameters, such as the channel displayed.”)
`¶19 (“The user command unit 213 and the user command processor 210 constitute window selection
`means for selecting a window to be controlled in response to the window identification signal supplied
`by the window identification means 217 and 218, respectively.”)
`¶23 (“Conflicts between simultaneously received IR signals from different remote controls may be
`resolved by just ignoring distorted IR signals, or reconstructing the distinct signals using information
`concerning IR protocol, frequency, angle of incidence, signal strength, etc.”)
`¶25 (“In a step 403, it is determined for which window the received control command is meant, by
`testing the value of the window identification decoded from the prefix.”)
`To the extent that Plaintiff alleges that Sevat 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 Exhibit A1-A6, A8-A9,
`and O1.
`
`
`
`5
`
`Page 5 of 10
`
`

`

`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.a
`
`4.pre A controlling method
`according to claim 1,
`wherein the plurality of
`operation forms are different
`from each other in a layout of
`a display element
`constructing the operation
`screen.
`
`Prior Art: U.S. Appln. Pub. No. 2001/0006382 (“Sevat”)
`
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Sevat 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, Sevat discloses:
`¶19 (“The remote control 215 comprises window identification means 217, and the remote control 216
`comprises similar window identification means 218. The window identification means 217 and 218
`cause IR control commands transmitted by the remote controls 215 and 216 to be prefixed by a
`window identification signal identifying a window displayed on the display screen of the television
`receiver.”)
`¶19 (“When a control command is received while the television receiver is in the split-screen mode,
`the user command unit 213 interprets the window identification signal and transmits a command to the
`user command processor 210 so as to control the appropriate window in accordance with the window
`identification signal.”)
`To the extent that Plaintiff alleges that Sevat 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 Exhibit A1-A6, A8-A9,
`and O1.
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Sevat 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.
`See, e.g., element 2.a
`To the extent that Plaintiff alleges that Sevat 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 Exhibit A1-A6, A8-A9,
`and O1.
`
`
`
`6
`
`Page 6 of 10
`
`

`

`5.a
`
`Claim Element
`
`’413
`Claim
`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.
`
`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
`
`
`
`Prior Art: U.S. Appln. Pub. No. 2001/0006382 (“Sevat”)
`
`Defendants incorporate by reference their contentions relating to claim 1, as if fully set forth herein.
`
`Sevat 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.
`¶25 (“For example, in a television receiver capable of displaying programs broadcast by different TV
`channels in a split screen mode, two users can select programs independently for both windows. The
`programs may, for example, be received from an antenna, a cable network, a satellite dish, a DVD
`player or a recording device.”)
`To the extent that Plaintiff alleges that Sevat 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 Exhibit A1-A6, A8-A9,
`and O1.
`Sevat 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, Sevat discloses:
`¶29 (“The invention can be implemented by means of hardware comprising several distinct elements,
`and by means of a suitably programmed computer. In the device claim enumerating several means,
`several of these means can be embodied by one and the same item of hardware.”).
`To the extent that Plaintiff alleges that Sevat 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 Exhibit A1-A6, A8-A9,
`and O1.
`Sevat discloses a display controlling apparatus for making an operation screen for operations of a
`remote control device displayed in a display unit.
`See, e.g., elements 7.a – 7.d, 6.
`To the extent that Plaintiff alleges that Sevat 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
`7
`
`Page 7 of 10
`
`

`

`’413
`Claim
`
`7.a
`
`Claim Element
`
`unit, the apparatus
`comprising:
`an acquiring unit which
`acquires an attribute of a
`remote control device;
`
`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,
`
`Prior Art: U.S. Appln. Pub. No. 2001/0006382 (“Sevat”)
`
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibit A1-A6, A8-A9,
`and O1.
`Sevat 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 Sevat 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 Exhibit A1-A6, A8-A9,
`and O1.
`To the extent 35 U.S.C. § 112, ¶6 applies, Sevat 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.
`Sevat 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 Sevat 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 Exhibit A1-A6, A8-A9,
`and O1.
`To the extent 35 U.S.C. § 112, ¶6 applies, Sevat 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.
`Sevat 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 Sevat 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
`
`
`
`8
`
`Page 8 of 10
`
`

`

`’413
`Claim
`
`Claim Element
`
`Prior Art: U.S. Appln. Pub. No. 2001/0006382 (“Sevat”)
`
`7.d
`
`wherein the determining unit
`determines the operation form
`corresponding to the remote
`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.
`
`ordinary skill in the art, AAPA, and/or in view of the references identified in Exhibit A1-A6, A8-A9,
`and O1.
`To the extent 35 U.S.C. § 112, ¶6 applies, Sevat 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.
`Sevat 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
`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 Sevat 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 Exhibit A1-A6, A8-A9,
`and O1.
`To the extent 35 U.S.C. § 112, ¶6 applies, Sevat 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.
`
`Sevat 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 Sevat 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 Exhibit A1-A6, A8-A9,
`and O1.
`
`
`
`9
`
`Page 9 of 10
`
`

`

`Claim Element
`
`’413
`Claim
`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
`constructing the operation
`screen.
`
`10.a
`
`11.a
`
`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. Appln. Pub. No. 2001/0006382 (“Sevat”)
`
`Defendants incorporate by reference their contentions relating to claim 7, as if fully set forth herein.
`
`Sevat 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 Sevat 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 Exhibit A1-A6, A8-A9,
`and O1.
`Defendants incorporate by reference their contentions relating to claim 7, as if fully set forth herein.
`
`Sevat 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 Sevat 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 Exhibit A1-A6, A8-A9,
`and O1.
`To the extent 35 U.S.C. § 112, ¶6 applies, Sevat also discloses the corresponding structure(s) and
`function(s) claimed or their equivalents, as shown above, or renders them obvious in view of the
`knowledge of one skilled in the art.
`
`10
`
`Page 10 of 10
`
`