TCL’S INVALIDITY CONTENTIONS FOR U.S. 7,810,130
`Exhibit B16: U.S. Patent No. 7,380,266 (“Stayt”)
`
`
`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 Stayt and (b) under 35 U.S.C. § 103(a) as obvious over Stayt 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-B15, B17-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.
`
`
`
`Prior Art: U.S. Pat. No. 7,380,266 (“Stayt”)
`
`Stayt 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, Stayt discloses:
`3:12-17 (“The invention is a method and apparatus for simulating simultaneous reception of a
`substantial number of television channels within a bandwidth smaller than that actually required to
`simultaneously receive such a number of channels . . . “);
`4:8-10 (“FIG.1 is a block diagram of a fiber optic communications network for providing television,
`telephone, and Internet services to a household.”);
`8:54-57 (“While the invention has been described in connection with a television service network and
`an integrated television/telephone/internet service network, it is equally applicable to essentially any
`type of data.”).
`See, e.g., elements 1.a – 1.f.
`Stayt 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.
`
`1
`
`Claim Element
`
`’130
`Claim
`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:
`
`1.a
`
`a receiving unit for receiving
`a moving image-streaming
`content which is internet
`
`
`
`Page 1 of 19
`
`CANON EXHIBIT 2003
`Roku, Inc. v. Canon Kabushiki Kaisha
`IPR2020-00358
`
`

`

`’130
`Claim
`
`Claim Element
`
`broadcasting content by an
`access through the internet to
`a URL of the streaming
`content;
`
`1.b
`
`a memory unit for storing
`URL information of the
`moving image-streaming
`content received by the
`receiving unit;
`
`Prior Art: U.S. Pat. No. 7,380,266 (“Stayt”)
`
`For example, Stayt discloses:
`4:8-10 (“FIG.1 is a block diagram of a fiber optic communications network for providing television,
`telephone, and Internet services to a household.”);
`5:43-49 (“For example, let us assume that an optical fiber from the curb into the household can
`support two telephone channels, two Internet channels and twelve full television channels. Thus, even
`when both telephones are in use, both Internet channels are in use and two television channels are in
`use,that leaves time slots that can support approximately ten channels available for buffering television
`programming.”);
`6:14-20 (“In the household, the cable 16 is coupled to a distributor box 18 which might, for instance,
`be placed on top of a television set, much like the converter box of standard cable television systems.
`The distributor box includes circuitry for frame synchronizing to the incoming data, parsing the time
`slots and distributing them to the correct location.”).
`see also 6:3-9; 6:32-35.
`To the extent that Plaintiff alleges that Stayt 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-B15, B17-B20, and O2.
`To the extent 35 U.S.C. § 112, ¶6 applies, Stayt 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.
`Stayt discloses a memory unit for storing URL information of the moving image-streaming content
`received by the receiving unit.
`For example, Stayt discloses:
`8:25-36 (“It should be understood that the retrieval, decoding and storage of buffered data and the
`receipt of the data for the channel selected for viewing on the television are continuing processes. For
`instance, during the loop of steps 212 and 214, although not shown as a separate step in the flow chart,
`the CPU, of course, continues to receive, decode and store buffered data. Each individual memory
`section in RAM 34 dedicated to a channel is written circularly. In one embodiment, as data becomes
`stale, i.e., the current time passes the time-stamp of the data, that data is marked stale and can be
`overwritten by newly incoming data.”);
`
`2
`
`Page 2 of 19
`
`

`

`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,380,266 (“Stayt”)
`
`1.c
`
`a display unit for displaying
`on a display screen the
`moving image-streaming
`content received by the
`receiving unit;
`
`1.d
`
`an operation unit for
`receiving an operation of
`turning off and turning on a
`
`see also FIG. 2; 6:32-35; 7:37-43, element 1.a.
`To the extent that Plaintiff alleges that Stayt 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-B15, B17-B20, and O2.
`To the extent 35 U.S.C. § 112, ¶6 applies, Stayt 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.
`Stayt discloses a display unit for displaying on a display screen the moving image-streaming content
`received by the receiving unit.
`For example, Stayt discloses:
`6:49-54 (“CPU 34 also is bi-directionally coupled to the television set 36 in order to transmit to the
`television set television data for the selected channel that is being received from the central office 14
`and to receive from the television set 36 the aforementioned channel selection information.”);
`7:64-8:5 (“FIG. 2 is a flow chart illustrating operation of the CPU 32 in accordance with one preferred
`embodiment of the present invention. In step 200, the CPU receives, decodes and stores buffered data
`as it comes in over the optical fiber. In step 202, it determines if the television is on. If not, it simply
`continues to retrieve, decode and store buffered data. If the television is on, then it also receives a
`direct feed of the channel selected by the television and sends it to the television (step 204).”);
`see also FIG. 2; 3:42-43; 6:31-35.
`To the extent that Plaintiff alleges that Stayt 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-B15, B17-B20, and O2.
`To the extent 35 U.S.C. § 112, ¶6 applies, Stayt 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.
`Stayt discloses an operation unit for receiving an operation of turning off and turning on a power
`source for supplying power.
`For example, Stayt discloses:
`
`3
`
`Page 3 of 19
`
`

`

`’130
`Claim
`
`Claim Element
`
`power source for supplying
`power;
`
`1.e
`
`a buffering unit for buffering
`the moving image-streaming
`content received by the
`receiving unit; and
`
`Prior Art: U.S. Pat. No. 7,380,266 (“Stayt”)
`
`3:25-31 (“For instance, 6 second intervals of the programming on each of the other channels can be
`trans-mitted at 3 minute intervals and stored in a buffer for immediate access. If the user watches any
`of the buffered channels for less than 6 seconds, the user can determine roughly what is being
`transmitted on that channel at that time.”);
`7:45-49 (“In such a feature, a viewer may press a button on a remote control to select a "thumbnail"
`feature. In response, the CPU can break up the television viewing screen into a plurality of low
`resolution motion thumbnail sketches of a plurality of different channels.”);
`7:64-8:5 (“FIG. 2 is a flow chart illustrating operation of the CPU 32 in accordance with one preferred
`embodiment of the present invention. In step 200, the CPU receives, decodes and stores buffered data
`as it comes in over the optical fiber. In step 202, it determines if the television is on. If not, it simply
`continues to retrieve, decode and store buffered data. If the television is on, then it also receives a
`direct feed of the channel selected by the television and sends it to the television (step 204).”)
`see also FIG. 2.
`To the extent that Plaintiff alleges that Stayt 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-B15, B17-B20, and O2.
`To the extent 35 U.S.C. § 112, ¶6 applies, Stayt 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.
`Stayt discloses a buffering unit for buffering the moving image-streaming content received by the
`receiving unit.
`For example, Stayt discloses:
`6:61-7:2 (“The CPU stores that information in RAM 34. RAM 34 is indexed such that all buffering
`information pertaining to a particular television channel is buffered in a particular set of locations.
`Accordingly, when the CPU first receives a signal from the television on line 37 indicating that the
`channel has been changed, it accesses the portion of the RAM dedicated to the channel which has been
`newly selected and transmits that buffered information to the television set for viewing.”)
`7:64-8:2 (“FIG. 2 is a flow chart illustrating operation of the CPU 32 in accordance with one preferred
`embodiment of the present invention. In step 200, the CPU receives, decodes and stores buffered data
`
`4
`
`Page 4 of 19
`
`

`

`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,380,266 (“Stayt”)
`
`as it comes in over the optical fiber. In step 202, it determines if the television is on. If not, it simply
`continues to retrieve, decode and store buffered data.”);
`see also FIG. 2; 5:27-41; 7:59-63.
`To the extent that Plaintiff alleges that Stayt 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-B15, B17-B20, and O2.
`To the extent 35 U.S.C. § 112, ¶6 applies, Stayt 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.
`Stayt 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, Stayt discloses:
`7:59-63 (“In a preferred embodiment of the invention, buffering can be performed well in advance,
`while the television is off, accordingly providing even greater bandwidth for buffering (i.e., the time
`slots that would be used for viewing can be used for buffering while the television is off).”);
`7:64-8:12 (“FIG. 2 is a flow chart illustrating operation of the CPU 32 in accordance with one
`preferred embodiment of the present invention. In step 200, the CPU receives, decodes and stores
`buffered data as it comes in over the optical fiber. In step 202, it determines if the television is on. If
`not, it simply continues to retrieve, decode and store buffered data. If the television is on, then it also
`receives a direct feed of the channel selected by the television and sends it to the television (step 204).
`Then, in step 206, the CPU determines whether the channel has been changed. If not, processing
`returns to step 200 and the retrieval, decoding and storage of buffering data as well as the receiving of
`a direct feed for the selected channel continues. If the channel is changed in step 206, however,
`
`5
`
`1.f
`
`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
`
`Page 5 of 19
`
`

`

`’130
`Claim
`
`Claim Element
`
`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.
`
`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:
`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;
`
`2.a
`
`2.b
`
`a memory unit for storing
`URL information of the
`moving image-streaming
`
`Prior Art: U.S. Pat. No. 7,380,266 (“Stayt”)
`
`processing proceeds to step 208 where the buffered data for the newly selected channel is retrieved
`and sent to the television for viewing.”);
`see also FIG. 2; 3:51-56; 6:61-7:11, 8:54-59
`To the extent that Plaintiff alleges that Stayt 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-B15, B17-B20, and O2.
`To the extent 35 U.S.C. § 112, ¶6 applies, Stayt 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.
`Stayt 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.
`
`Stayt 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 Stayt 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-B15, B17-B20, and O2.
`To the extent 35 U.S.C. § 112, ¶6 applies, Stayt 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.
`Stayt 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.
`
`6
`
`Page 6 of 19
`
`

`

`’130
`Claim
`
`2.c
`
`Claim Element
`
`content received by the first
`receiving unit;
`
`a second receiving unit for
`receiving a television
`broadcast program
`transmitted through a
`broadcast signal;
`
`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
`program on the display
`screen to the displaying of the
`
`Prior Art: U.S. Pat. No. 7,380,266 (“Stayt”)
`
`To the extent that Plaintiff alleges that Stayt 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-B15, B17-B20, and O2.
`Stayt discloses a second receiving unit for receiving a television broadcast program transmitted
`through a broadcast signal.
`For example, Stayt discloses:
`6:3-9 (“FIG. 1 is a block diagram of the relevant portion of a digital fiber optic communications
`network 10 in accordance with the present invention. The central office includes a transmitter 44 and
`receiver 46 for bidirectional communication via the network. The receiver 46 also receives television
`signals for a plurality of channels via an antennae array 48”);
`see also 1:15-19; 1:32-40; 6:12-20.
`To the extent that Plaintiff alleges that Stayt 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-B15, B17-B20, and O2.
`To the extent 35 U.S.C. § 112, ¶6 applies, Stayt 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.
`Stayt 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, Stayt discloses:
`7:64-8:12 (“FIG. 2 is a flow chart illustrating operation of the CPU 32 in accordance with one
`preferred embodiment of the present invention. In step 200, the CPU receives, decodes and stores
`buffered data as it comes in over the optical fiber. In step 202, it determines if the television is on. If
`not, it simply continues to retrieve, decode and store buffered data. If the television is on, then it also
`receives a direct feed of the channel selected by the television and sends it to the television (step 204).
`Then, in step 206, the CPU determines whether the channel has been changed. If not, processing
`returns to step 200 and the retrieval, decoding and storage of buffering data as well as the receiving of
`
`7
`
`Page 7 of 19
`
`

`

`’130
`Claim
`
`Claim Element
`
`moving image-streaming
`content on the display screen;
`
`2.e
`
`a buffering unit for buffering
`the moving image-streaming
`content received by the first
`receiving unit; and
`
`2.f
`
`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
`
`Prior Art: U.S. Pat. No. 7,380,266 (“Stayt”)
`
`a direct feed for the selected channel continues. If the channel is changed in step 206, however,
`processing proceeds to step 208 where the buffered data for the newly selected channel is retrieved
`and sent to the television for viewing.”);
`see also FIGS. 2, 3; 6:64-7:2.
`To the extent that Plaintiff alleges that Stayt 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-B15, B17-B20, and O2.
`To the extent 35 U.S.C. § 112, ¶6 applies, Stayt 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.
`Stayt 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 Stayt 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-B15, B17-B20, and O2.
`To the extent 35 U.S.C. § 112, ¶6 applies, Stayt 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.
`Stayt 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
`
`8
`
`Page 8 of 19
`
`

`

`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,380,266 (“Stayt”)
`
`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
`
`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, Stayt discloses:
`3:25-38 (“For instance, 6 second intervals of the programming on each of the other channels can be
`trans-mitted at 3 minute intervals and stored in a buffer for immediate access. If the user watches any
`of the buffered channels for less than 6 seconds, the user can determine roughly what is being
`transmitted on that channel at that time. If the user stays on that channel for longer than 6 seconds,
`then the television sends a signal to the central office indicating that the central office should now
`transmit that channel in full mode, rather than the one that it had previously been transmitting in full
`mode. The user typically would observe a "jump" in transmission at the point at which the buffer is
`truncated and the full channel transmission begins.”);
`7:64-8:12 (“FIG. 2 is a flow chart illustrating operation of the CPU 32 in accordance with one
`preferred embodiment of the present invention. In step 200, the CPU receives, decodes and stores
`buffered data as it comes in over the optical fiber. In step 202, it determines if the television is on. If
`not, it simply continues to retrieve, decode and store buffered data. If the television is on, then it also
`receives a direct feed of the channel selected by the television and sends it to the television (step 204).
`Then, in step 206, the CPU determines whether the channel has been changed. If not, processing
`returns to step 200 and the retrieval, decoding and storage of buffering data as well as the receiving of
`a direct feed for the selected channel continues. If the channel is changed in step 206, however,
`processing proceeds to step 208 where the buffered data for the newly selected channel is retrieved
`and sent to the television for viewing.”);
`7:14-23 (“In this manner, the information stream for the newly selected television channel commences
`prior to the end of the buffered data so that there is no gap of dead air between the end of the buffered
`data and the direct feed. In most instances, the switch from the buffered data to the direct feed will
`result in a visible, unnatural, jump in the scene being viewed since the end of the buffered data most
`likely will not match up with the real-time direct feed most of the time.”);
`see also FIGS. 2, 3; 3:51-56; 6:61-7:11; 7:44-53; 7:59-63.
`To the extent that Plaintiff alleges that Stayt 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-B15, B17-B20, and O2.
`
`9
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`Page 9 of 19
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`

`

`’130
`Claim
`
`Claim Element
`
`Prior Art: U.S. Pat. No. 7,380,266 (“Stayt”)
`
`3.pre
`
`3.a
`
`moving image-streaming
`content and to start the
`displaying on the display
`screen of the latest buffered
`moving image-streaming
`content.
`The receiving apparatus
`according to claim 1,
`wherein the control unit is
`further configured to,
`responsive to the receiving by
`the operation unit of the
`operation of turning on the
`power source, (a) read out the
`URL information stored in
`the memory unit, (b) receive
`by the receiving unit the
`latest moving image-
`streaming content by
`accessing the URL of the
`moving image-streaming
`content which had been
`displayed before the turning
`off the power source, and (c)
`change the content displayed
`on the display screen from
`the latest moving image-
`streaming content, which had
`been buffered in the buffering
`unit while the power source
`had been in an off state, to
`the moving image-streaming
`
`To the extent 35 U.S.C. § 112, ¶6 applies, Stayt 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.
`
`Stayt discloses a receiving apparatus wherein the control unit is further configured to, responsive to
`the receiving by the operation unit of the operation of turning on the power source, (a) read out the
`URL information stored in the memory unit, (b) receive by the receiving unit the latest moving image-
`streaming content by accessing the URL of the moving image-streaming content which had been
`displayed before the turning off the power source, and (c) change the content displayed on the display
`screen from the latest moving image-streaming content, which had been buffered in the buffering unit
`while the power source had been in an off state, to the moving image-streaming content being received
`by the receiving unit.
`For example, Stayt discloses:
`7:64-8:12 (“FIG. 2 is a flow chart illustrating operation of the CPU 32 in accordance with one
`preferred embodiment of the present invention. In step 200, the CPU receives, decodes and stores
`buffered data as it comes in over the optical fiber. In step 202, it determines if the television is on. If
`not, it simply continues to retrieve, decode and store buffered data. If the television is on, then it also
`receives a direct feed of the channel selected by the television and sends it to the television (step 204).
`Then, in step 206, the CPU determines whether the channel has been changed. If not, processing
`returns to step 200 and the retrieval, decoding and storage of buffering data as well as the receiving of
`a direct feed for the selected channel continues. If the channel is changed in step 206, however,
`processing proceeds to step 208 where the buffered data for the newly selected channel is retrieved
`and sent to the television for viewing.”);
`7:14-23 (“In this manner, the information stream for the newly selected television channel commences
`prior to the end of the buffered data so that there is no gap of dead air between the end of the buffered
`data and the direct feed. In most instances, the switch from the buffered data to the direct feed will
`
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`Page 10 of 19
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`’130
`Claim
`
`Claim Element
`
`content being received by the
`receiving unit.
`
`4.pre
`
`4.a
`
`The receiving apparatus
`according to claim 2,
`wherein the control unit is
`further configured to,
`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, (a) read
`out the URL information
`stored in the memory unit, (b)
`receive by the receiving unit
`the latest moving image-
`streaming content by
`accessing the URL of the
`moving image-streaming
`content which had been
`displayed before stopping of
`
`Prior Art: U.S. Pat. No. 7,380,266 (“Stayt”)
`
`result in a visible, unnatural, jump in the scene being viewed since the end of the buffered data most
`likely will not match up with the real-time direct feed most of the time.”);
`see also FIG. 2; 6:61-7:11.
`To the extent that Plaintiff alleges that Stayt 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-B15, B17-B20, and O2.
`To the extent 35 U.S.C. § 112, ¶6 applies, Stayt 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 2, as if fully set forth herein.
`
`Stayt discloses a receiving ap