TCL’S INVALIDITY CONTENTIONS FOR U.S. 7,810,130
`Exhibit B5: U.S. Patent App. No. 2002/0174430 (“ELLIS”)
`
`As demonstrated in the claim charts below, the asserted claims of U.S. Patent No. 7,810,130 (“the ’130 patent”) are invalid (a) under
`one or more sections of 35 U.S.C. § 102 as anticipated by Ellis and (b) under 35 U.S.C. § 103(a) as obvious over Ellis 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 B1-B4, B6-B20, and O2, 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 ’130 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.
`
`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`1.pre A receiving apparatus for
`receiving a moving image-
`streaming content through an
`internet, the moving image-
`streaming content being
`internet broadcasting content,
`said apparatus comprising:
`
`Ellis discloses a receiving apparatus for receiving a moving image-streaming content through an
`internet, the moving image-streaming content being internet broadcasting content.
`
`For example, Ellis discloses:
`
`Abstract (“Methods and systems that provide enhanced personal video recorder (“PVR”) and
`interactive television program guide (“IPG”) functionality are provided”);
`
`¶ 158 (“Communications path 108 may be any suitable communications path, such as a satellite link, a
`cable link, a fiber-optic link, a microwave link, a telephone network link, an Internet link, or a
`combination of such links.”);
`
`see also ¶¶ 425, 480.
`
`See, e.g., elements 1.a – 1.f.
`
`1.a
`
`a receiving unit for receiving
`a moving image-streaming
`content which is internet
`broadcasting content by an
`access through the internet to
`
`Ellis discloses a receiving unit for receiving a moving image-streaming content which is internet
`broadcasting content by an access through the internet to a URL of the streaming content.
`
`For example, Ellis discloses:
`
`1
`
`Page 1 of 34
`
`CANON EXHIBIT 2002
`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00358
`
`

`

`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`a URL of the streaming
`content;
`
`¶ 158 (“Communications path 108 may be any suitable communications path, such as a satellite link, a
`cable link, a fiber-optic link, a microwave link, a telephone network link, an Internet link, or a
`combination of such links.”)
`
`¶ 170 (“Set-top box 202 may receive signals transmitted by distribution facility 110 (FIG. 1) (e.g.,
`audio, video, or interactive television application data).”);
`
`¶ 425 (“A PVR or an integrated PVR-IPG may integrate content from a variety of platforms. For
`example, a PVR may store content from broadcast television, from pay-per-view, from video-on-
`demand, from the Internet, from radio, from multimedia devices (e.g., video and still cameras), from
`personal computers, etc.”);
`
`¶ 480 (“A more advanced compression standard such as MPEG-4 may also allow for new features. For
`example, MPEG-4 allows objects in the video to be explicitly defined. A web address or commerce
`application could be linked to one of these objects.”);
`
`see also ¶¶ 162, 163, 179, 182.
`
`To the extent that Plaintiff alleges that Ellis 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 B1-B4, B6-B20, and O2.
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Ellis 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.
`
`Ellis discloses a memory unit for storing URL information of the moving image-streaming content
`received by the receiving unit.
`
`For example, Ellis discloses:
`
`FIG. 93:
`
`1.b
`
`a memory unit for storing
`URL information of the
`moving image-streaming
`content received by the
`receiving unit;
`
`2
`
`Page 2 of 34
`
`

`

`PROVIDE USER EQUIPMENT THAT|9002
`INCLUDES A PERSONALVIDEO
`
`STORE VIDEO FROMTHE NEW—_|gang
`
`
`CHANNEL OR NEW PROGRAM TO THE
`NEWLY ALLOCATED STRAIGHT
`BUFFER
`
`
`
`
`
`Page 3 of 34
`
`
`
`RECORDER
` CREATE A NEW STRAIGHT BUFFER ON Best
`
`THE PERSONAL VIDEO RECORDER
`WHEN A NEW CHANNEL OR NEW
`PROGRAM IS TUNED
`Farge ert org na ot ere
`|ALLOCATE A NEW BUFFER! 6606
`| SUITABLE FOR THE SIZE /
`OF THE PROGRAM
`eee ee
`
`FIG. 93
`
`3
`
`
`
`
`
`Page 3 of 34
`
`

`

`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`¶ 161 (“Server 112 may include a local database 116 for storing various program guide information.
`Server 112 may include storage 117 for storing recorded programs remotely. Programs and/or related
`information may be recorded and/or stored remotely or locally at user equipment 122. A combination
`of local and remote storage and/or recording may also be used.”);
`
`¶ 179 (“PVR integrated set-top box 9902 may receive signals transmitted by distribution facility 110
`(FIG. 1). PVR integrated set-top box 9902 may include a storage device or memory for storing
`personal user preferences settings, user-selected reminders, recordings, program information, or other
`information.”);
`
`¶ 425 (“A PVR or an integrated PVR-IPG may integrate content from a variety of platforms. For
`example, a PVR may store content from broadcast television, from pay-per-view, from video-on-
`demand, from the Internet, from radio, from multimedia devices (e.g., video and still cameras), from
`personal computers, etc.”);
`
`see also FIGS. 2A-2C, 6, 26, 71, 94-104, 112; ¶¶ 13, 28, 31, 32, 35, 159, 167, 169, 170, 179, 182, 215.
`
`To the extent that Plaintiff alleges that Ellis 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 B1-B4, B6-B20, and O2.
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Ellis 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.
`
`Ellis discloses a display unit for displaying on a display screen the moving image-streaming content
`received by the receiving unit.
`
`For example, Ellis discloses:
`
`FIG. 114:
`
`1.c
`
`a display unit for displaying
`on a display screen the
`moving image-streaming
`content received by the
`receiving unit;
`
`4
`
`Page 4 of 34
`
`

`

`
`
`RESUME THE TELEVISION
`CONTENT FROM THE
`POINT AT WHICH THE|8708
`USER STARTED
`INTERACTING WITH THE
`INTERACTIVE TELEVISION
`
`APPLICATION
`
`FIG. 114
`
`
`
`5
`
`
`
`
`8702
`
`
`
`
`DISPLAY CURRENT
`TELEVISION CONTENT
`(A PROGRAM OR
`COMMERCIAL) FOR A
`USER
`
`
`
`
`
`
`
`
`8704
`
`
`PROVIDE THE USER WITH
`AN OPPORTUNITY TO
`INTERACT WITH AN
`INTERACTIVE TELEVISION
`APPLICATION
`
`
`
`
`
`AUTOMATICALLY PAUSE
`THE TELEVISION
`CONTENTUSING A LOCAL
`
`OR REMOTE STORAGE
`
`DEVICE WHEN THE USER
`STARTS TO INTERACT
`
`WITH INTERACTIVE
`
`TELEVISION APPLICATION
`
`
`EXITS INTERACTIVE TELEVISION APPLICATIC
`
`
` 8706
`
`
`
`
`
`
`
`
`
`
`Page 5 of 34
`
`Page 5 of 34
`
`

`

`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`¶ 34 (“An interactive television application may display recorded programs within a browse overlay, a
`program listings display screen, or within other listing screens.”);
`
`¶ 12 (An interactive television application may display a main menu display screen that may include
`options such as a program listings option, a video-on-demand option, a pay-per-view (“PPV”) option,
`or a current weather option to provide interactive services.”);
`
`¶173 (“Display device 206 may be a television, a computer monitor, a computer system with a monitor
`and speakers, a flat panel display, or any other suitable display device.”);
`
`¶174 (“Set-top box 202 may send audio/video signals and signals that are representative of graphics to
`display device 206 based on communications with PVR 208. Other arrangements for establishing
`communications and operations between PVR 208 and set-top box 202 may also be used.”);
`
`¶ 253 (“If desired, the application may allow the user to choose different buffer qualities based on
`channel, channel type, program type, or other factors. For example, one or more display screens or
`overlays may be displayed that include an option to assign different live television buffer qualities to
`different channels, an option to assign different live television buffer qualities to different programs
`types (e.g., movies, sports, documentary, talk show, new, or other program category or genre), an
`option to assign different live television buffer qualities to different channels types (e.g., cable
`channel, network, broadcast, or other channel type), or an option to assign different buffer qualities to
`other factors. The interactive television application may allow a user to move a highlight window
`within these display screens or overlays to make selections for the default settings (e.g. buffer quality)
`for the live television buffer. A display screen such as that shown in FIG. 20 for setting default
`recording quality by content type may be used to implement these live television buffer settings. These
`options may be accessed by a user through a PVR setup display screen or through other suitable
`means.”);
`
`see also FIGS. 2A-2C, 4, 16, 30-34; ¶¶ 5, 27, 169, 178, 205, 208, 274.
`
`To the extent that Plaintiff alleges that Ellis 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 B1-B4, B6-B20, and O2.
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Ellis 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.
`
`6
`
`Page 6 of 34
`
`

`

`’130
`Claim
`
`1.d
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`an operation unit for
`receiving an operation of
`turning off and turning on a
`power source for supplying
`power;
`
`Ellis discloses an operation unit for receiving an operation of turning off and turning on a power
`source for supplying power.
`
`For example, Ellis discloses:
`
`FIG. 2A:
`
`
`
`
`
`7
`
`Page 7 of 34
`
`

`

`FIG. 3:
`
`
`¶ 169 (“FIG. 2A also shows that remote control 212 may be able to communicate with set-top box
`202, recording equipment 204, and display device 206 via a wireless link 214. Persons skilled in the
`art will appreciate that set-top box 202, recording equipment 204, remote control 212, and display
`device 206 may be interconnected differently than that shown in FIG. 2A and that components can be
`added or removed.”)
`
`¶ 184 (“FIG. 3 shows illustrative remote control 308 that may include various function buttons...
`Primary option buttons 302 may include power button 320, menu button 332 . . . Menu button 332
`may provide the user with the ability to cause a menu display screen to be displayed. . . . Exit button
`324 may provide the user with the ability to exit a program guide or other application.”);
`
`8
`
`Page 8 of 34
`
`

`

`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`¶ 294 (“If desired, a recording may be made without displaying any overlays. For example, a set-top
`box may be turned off when a recording is scheduled to begin. The application may tune to the
`selected program and begin recording to local storage without turning on user equipment.
`Alternatively, a program may be recorded on a remote server without any user notification.”);
`
`see also FIGS. 2A-2C; ¶¶ 20, 46, 169, 176, 178, 180.
`
`To the extent that Plaintiff alleges that Ellis 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 B1-B4, B6-B20, and O2.
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Ellis 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.
`
`Ellis discloses a buffering unit for buffering the moving image-streaming content received by the
`receiving unit.
`
`For example, Ellis discloses:
`
`FIG. 93:
`
`1.e
`
`a buffering unit for buffering
`the moving image-streaming
`content received by the
`receiving unit; and
`
`9
`
`Page 9 of 34
`
`

`

`PROVIDE USER EQUIPMENT THAT|9002
`INCLUDES A PERSONALVIDEO
`
`STORE VIDEO FROMTHE NEW—_|gang
`
`
`CHANNEL OR NEW PROGRAM TO THE
`NEWLY ALLOCATED STRAIGHT
`BUFFER
`
`
`
`
`
`Page 10 of 34
`
`
`
`RECORDER
` CREATE A NEW STRAIGHT BUFFER ON Best
`
`THE PERSONAL VIDEO RECORDER
`WHEN A NEW CHANNEL OR NEW
`PROGRAM IS TUNED
`Farge ert org na ot ere
`|ALLOCATE A NEW BUFFER! 6606
`| SUITABLE FOR THE SIZE /
`OF THE PROGRAM
`eee ee
`
`
`
`10
`
`
`
`Page 10 of 34
`
`

`

`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`¶ 16 (“The interactive television application may provide a user with an opportunity to configure a
`recording buffer around a program that is scheduled to be recorded.”);
`
`¶ 28 (“A storage device such as a PVR may be used to buffer television content to provide a user with
`an opportunity to control the flow of current television content and to take other actions.”);
`
`¶ 30 (“A user may be allowed to control program flow using a buffer.”);
`
`¶ 32 (“Storage space in a storage device may be assigned automatically or manually to buffer
`programming. An interactive television application may automatically assign all or a portion of the
`storage space in a storage device to buffer programming. If desired, a user may be provided with an
`opportunity to set the total size to be used for buffering, set the total number of buffers that can be
`active at one time, set the size of each buffer, and set how often buffers should be deleted.”);
`
`¶ 253 (“If desired, the application may allow the user to choose different buffer qualities based on
`channel, channel type, program type, or other factors. For example, one or more display screens or
`overlays may be displayed that include an option to assign different live television buffer qualities to
`different channels, an option to assign different live television buffer qualities to different programs
`types (e.g., movies, sports, documentary, talk show, new, or other program category or genre), an
`option to assign different live television buffer qualities to different channels types (e.g., cable
`channel, network, broadcast, or other channel type), or an option to assign different buffer qualities to
`other factors. The interactive television application may allow a user to move a highlight window
`within these display screens or overlays to make selections for the default settings (e.g. buffer quality)
`for the live television buffer. A display screen such as that shown in FIG. 20 for setting default
`recording quality by content type may be used to implement these live television buffer settings. These
`options may be accessed by a user through a PVR setup display screen or through other suitable
`means.”);
`
`¶ 425 (“A PVR or an integrated PVR-IPG may integrate content from a variety of platforms. For
`example, a PVR may store content from broadcast television, from pay-per-view, from video-on-
`demand, from the Internet, from radio, from multimedia devices (e.g., video and still cameras), from
`personal computers, etc.”);
`
`see also FIGS. 2A-2C, 6, 26, 71, 94-104, 108, 112, 113; ¶¶ 29, 31, 32, 167, 169, 170, 171, 179, 182,
`289, 435; see also element 1.b.
`
`11
`
`Page 11 of 34
`
`

`

`’130
`Claim
`
`1.f
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`To the extent that Plaintiff alleges that Ellis 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 B1-B4, B6-B20, and O2.
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Ellis 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.
`
`Ellis discloses a control unit for (1) controlling, responsive to the receiving by the operation unit of the
`operation of turning off the power source, to read out the URL information stored in the memory unit,
`and (2) controlling, while the power source is in an off state, to periodically repeat accessing of a URL
`of the moving image-streaming content which had been displayed before the turning off the power
`source, so as to receive by the receiving unit and to buffer in the buffering unit the latest moving
`image-streaming content, and (3) controlling, responsive to the receiving by the operation unit of the
`operation of turning on the power source, to read out from the buffering unit the latest buffered
`moving image-streaming content and to start the displaying on the display screen of the latest buffered
`moving image-streaming content.
`
`For example, Ellis discloses:
`
`FIG. 114:
`
`a control unit for (1)
`controlling, responsive to the
`receiving by the operation
`unit of the operation of
`turning off the power source,
`to read out the URL
`information stored in the
`memory unit, and (2)
`controlling, while the power
`source is in an off state, to
`periodically repeat accessing
`of a URL of the moving
`image-streaming content
`which had been displayed
`before the turning off the
`power source, so as to receive
`by the receiving unit and to
`buffer in the buffering unit
`the latest moving image-
`streaming content, and (3)
`controlling, responsive to the
`receiving by the operation
`unit of the operation of
`turning on the power source,
`to read out from the buffering
`unit the latest buffered
`moving image-streaming
`
`12
`
`Page 12 of 34
`
`

`

`content and to start the
`displaying on the display
`screen of the latest buffered
`moving image-streaming
`content.
`
`
`
`13
`
`Page 13 of 34
`
`

`

`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`¶33 (“The television content may remain paused while the user interacts with the interactive television
`application or watches the stored video advertisement. The display of the television content may
`resume when the user exits the interactive television application. The display of the television content
`may resume from the point at which it was paused. If desired, the interactive television application
`may provide the user with an opportunity to select whether the television content should be resumed
`from the point at which it was automatically paused or resumed from its current point.”);
`
`¶ 294 (“If desired, a recording may be made without displaying any overlays. For example, a set-top
`box may be turned off when a recording is scheduled to begin. The application may tune to the
`selected program and begin recording to local storage without turning on user equipment.
`Alternatively, a program may be recorded on a remote server without any user notification.”);
`
`¶ 306 (“If the user selects to play the recording, the interactive television application may play the
`recording at step 2136. If desired, there may be multiple play options, for example to resume playing
`from the most recent point at which playing ended, or to restart playing from the beginning of the
`recorded program.”);
`
`see also FIGS. 6, 17, 29, 56, 77, 93, 115-120, 122; ¶¶ 5, 28, 170, 179, 181, 236, 290, 296, 310, 324,
`365, 425, 435, 438, 461, 462-466, 467, 468, 480.
`
`To the extent that Plaintiff alleges that Ellis 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 B1-B4, B6-B20, and O2.
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Ellis 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.
`
`Ellis discloses a receiving apparatus for receiving a moving image streaming content through an
`internet, the moving image streaming content being internet broadcasting content.
`
`See, e.g., elements 1.pre, 2.a – 2.f.
`
`14
`
`2.pre A receiving apparatus for
`receiving a moving image
`streaming content through an
`internet, the moving image
`streaming content being
`internet broadcasting content,
`said apparatus comprising:
`
`Page 14 of 34
`
`

`

`’130
`Claim
`
`2.a
`
`2.b
`
`2.c
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`a first receiving unit for
`receiving a moving image-
`streaming content which is
`internet broadcasting content
`by an access through an
`internet to a URL of the
`moving image-streaming
`content;
`
`a memory unit for storing
`URL information of the
`moving image-streaming
`content received by the first
`receiving unit;
`
`a second receiving unit for
`receiving a television
`broadcast program
`transmitted through a
`broadcast signal;
`
`Ellis discloses a first receiving unit for receiving a moving image-streaming content which is internet
`broadcasting content by an access through an internet to a URL of the moving image-streaming
`content.
`
`See, e.g., element 1.a.
`
`To the extent that Plaintiff alleges that Ellis 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 B1-B4, B6-B20, and O2.
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Ellis 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.
`
`Ellis discloses a memory unit for storing URL information of the moving image-streaming content
`received by the first receiving unit.
`
`See, e.g., element 1.b.
`
`To the extent that Plaintiff alleges that Ellis 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 B1-B4, B6-B20, and O2.
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Ellis 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.
`
`Ellis discloses a second receiving unit for receiving a television broadcast program transmitted through
`a broadcast signal.
`
`For example, Ellis discloses:
`
`¶ 253 (“If desired, the application may allow the user to choose different buffer qualities based on
`channel, channel type, program type, or other factors. For example, one or more display screens or
`overlays may be displayed that include an option to assign different live television buffer qualities to
`different channels, an option to assign different live television buffer qualities to different programs
`types (e.g., movies, sports, documentary, talk show, new, or other program category or genre), an
`option to assign different live television buffer qualities to different channels types (e.g., cable
`channel, network, broadcast, or other channel type), or an option to assign different buffer qualities to
`
`15
`
`Page 15 of 34
`
`

`

`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`other factors. The interactive television application may allow a user to move a highlight window
`within these display screens or overlays to make selections for the default settings (e.g. buffer quality)
`for the live television buffer. A display screen such as that shown in FIG. 20 for setting default
`recording quality by content type may be used to implement these live television buffer settings. These
`options may be accessed by a user through a PVR setup display screen or through other suitable
`means.”);
`
`¶ 170 (“Set-top box 202 may receive signals transmitted by distribution facility 110 (FIG. 1) (e.g.,
`audio, video, or interactive television application data). Set-top box 202 may include a storage device
`(e.g., a hard drive) or memory for storing personal user preferences settings, for storing user-selected
`reminders, or for storing other information. For illustrative purposes, the present invention will be
`described in the context of user television equipment 200, which uses set-top box 202 as its receiver or
`tuner. If desired, user television equipment 200 may include multiple tuners which may be used for
`simultaneously watching one program and recording another.”);
`
`see also ¶¶ 29, 161, 444.
`
`To the extent that Plaintiff alleges that Ellis 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 B1-B4, B6-B20, and O2.
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Ellis 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.
`
`Ellis discloses an operation unit for receiving an operation of switching from a displaying of the
`moving image-streaming content on a display screen to a displaying of the television broadcast
`program on the display screen, and an operation of switching from the displaying of the television
`broadcast program on the display screen to the displaying of the moving image-streaming content on
`the display screen.
`
`For example, Ellis discloses:
`
`FIG. 3:
`
`16
`
`2.d
`
`an operation unit for
`receiving an operation of
`switching from a displaying
`of the moving image-
`streaming content on a
`display screen to a displaying
`of the television broadcast
`program on the display
`screen, and an operation of
`switching from the displaying
`of the television broadcast
`
`Page 16 of 34
`
`

`

`program on the display
`screen to the displaying of the
`moving image-streaming
`content on the display screen;
`
`
`
`17
`
`Page 17 of 34
`
`

`

`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`¶ 453 (“FIG. 109 shows an illustrative sequence of events for recording a current program that is
`provided based on the steps of FIG. 108. With reference now to FIG. 109, video 8202 containing video
`for a current program on channel 2 may be displayed when the user selects to switch away from a
`program that the user was watching on channel 5. A buffer for the program on channel 5 may have
`existed when the user changed the channel to channel 2. After watching video 8202 for a period of
`time, the user may decide to switch back to channel 5. Video 8204 containing current video of the
`program on channel 5 may be displayed when the user selects to change the channel back to channel
`5.”);
`
`¶ 29 (“In a multi-tuner environment, the buffer for a program may contain the portions of the video
`that the user may have missed by tuning away. Multiple tuners may be implemented to permit the
`PVR to buffer different programs in parallel. Multiple tuners may also be used to record one program
`while watching another program or to record two or more programs at the same time.”);
`
`¶ 362 (“Types of broadcasts may include PPV, VOD, broadcast, cable, local access, and other suitable
`broadcast types. Display screen 3800 may include move up option 3806 and move down option 3808
`that may be used to change the delete priority that is associated with broadcast types.”);
`
`see also FIGS. 2A-2C, 100, 122; ¶¶ 20, 46, 169, 170, 176, 180, 184, 187, 358.
`
`To the extent that Plaintiff alleges that Ellis 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 B1-B4, B6-B20, and O2.
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Ellis 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.
`
`Ellis discloses a buffering unit for buffering the moving image-streaming content received by the first
`receiving unit.
`
`See, e.g., element 1.e.
`
`To the extent that Plaintiff alleges that Ellis 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 B1-B4, B6-B20, and O2.
`
`18
`
`2.e
`
`a buffering unit for buffering
`the moving image-streaming
`content received by the first
`receiving unit; and
`
`Page 18 of 34
`
`

`

`’130
`Claim
`
`2.f
`
`Claim Element
`
`Prior Art: U.S. Pat. App. No. 2002/0174430 (“Ellis”)
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Ellis 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.
`
`Ellis discloses a control unit for (1) controlling, responsive to the receiving by the operation unit of the
`operation of switching from the displaying of the moving image-streaming content on the display
`screen to the displaying of the television broadcast program on the display screen, (a) to stop the
`displaying of the moving image-streaming content on the display screen and to start the displaying of
`the television broadcast program on the display screen, (b) to read out the URL information stored in
`the memory unit, (2) controlling, while the television broadcast program is displayed on the display
`screen, to periodically repeat accessing of a URL of the moving image-streaming content which had
`been displayed before starting the displaying of the television broadcast program on the display screen,
`so as to receive by the receiving unit and to buffer in the buffering unit the latest moving image-
`streaming content, and (3) controlling, responsive to the receiving by the operation unit of the
`operation of switching from the displaying of the television broadcast program on the display screen to
`the displaying of the moving image-streaming content on the display screen, to read out from the
`buffering unit the latest buffered moving image-streaming content and to start the displaying on the
`display screen of the latest buffered moving image-streaming content.
`
`For example, Ellis discloses:
`
`FIG. 114:
`
`a control unit for (1)
`controlling, responsive to the
`receiving by the operation
`unit of the operation of
`switching from the displaying
`of the moving image-
`streaming content on the
`display screen to the
`displaying of the television
`broadcast program on the
`display screen, (a) to stop the
`displaying of the moving
`image-streaming content on
`the display screen and to start
`the displaying of the
`television broadcast program
`on the display screen, (b) to
`read out the URL information
`stored in the memory unit, (2)
`controlling, while the
`television broadcast program
`is displayed on the display
`screen, to periodically repeat
`accessing of a URL of the
`moving image-streaming
`content which had been
`displayed before starting the
`displaying of the television
`broadcast program on the
`display screen, so as to
`
`19
`
`Page 19 of 34
`
`

`

`receive by the receiving un