Case: 1:16-cv-03475 Document #: 1 Filed: 03/21/16 Page 1 of 20 PageID #:1
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`UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
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`T-REX PROPERTY AB,
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`Plaintiff,
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`v.
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`ZOOM MEDIA CORP.,
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`Defendant.
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`Civil Action No.: 1:16-cv-3475
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`JURY TRIAL DEMANDED
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`
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`PLAINTIFF’S COMPLAINT FOR PATENT INFRINGEMENT
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`Plaintiff T-Rex Property AB, by and through its undersigned counsel, files this Complaint
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`against Defendant Zoom Media Corp. as follows:
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`NATURE OF THE ACTION
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`1.
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`This is an action for patent infringement arising under the patent laws of the
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`United States, 35 U.S.C. § 1 et seq., including 35 U.S.C. §§ 271, 281, 283, 284 and 285.
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`PARTIES
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`2.
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`Plaintiff T-Rex Property AB is a company organized and existing under the laws
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`of Sweden with its principal place of business at Vårvägen 6, 18274 Stocksund, Sweden.
`3.
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`On information and belief, Defendant Zoom Media Corp. is a Delaware
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`corporation with a corporate office located at 549 West Randolph Street, Suite 600, Chicago, IL
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`60661.
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`JURISDICTION AND VENUE
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`4.
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`This Court has subject matter jurisdiction over this patent infringement action
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`under 28 U.S.C. §§ 1331 and 1338(a).
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`5.
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`This Court has personal jurisdiction over Defendant because, on information and
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`belief, Defendant has systematic and continuous contacts with Illinois and this judicial district,
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`because Defendant has a corporate office in the State of Illinois and has thereby purposefully
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`availed itself of the benefits and protections of the laws of the State of Illinois, and because
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`Defendant regularly transacts business in the State of Illinois and this judicial district.
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`Furthermore, this Court has personal jurisdiction over Defendant because, as described further
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`below, Defendant has committed acts of patent infringement giving rise to this action within the
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`State of Illinois and this judicial district and has thus established minimum contacts such that the
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`exercise of personal jurisdiction over Defendant does not offend traditional notions of fair play
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`and substantial justice.
`6.
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`Venue is proper in this Judicial District under 28 U.S.C. §§ 1391 and 1400(b).
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`THE PATENTS-IN-SUIT
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`7.
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`The allegations set forth in the foregoing paragraphs 1 through 6 are hereby re-
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`alleged and incorporated herein by reference.
`8.
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`On January 16, 2007, U.S. Patent Number RE39,470, entitled “Digital
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`Information System,” was duly and legally issued by the United States Patent and Trademark
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`Office. A true and correct copy of the ’470 Patent is attached as Exhibit A to this Complaint.
`9.
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`The ’470 Patent is a reissue of U.S. Patent Number 6,005,534, which was filed on
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`July 2, 1996 and which claims priority under 35 U.S.C. § 119(e) to U.S. Provisional Patent
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`Application Number 60/017,403, which was filed on May 14, 1996. The ’534 Patent also claims
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`priority under 35 U.S.C. § 119(a)-(d) to foreign patent application number 9601603-5, which
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`was filed on April 26, 1996 in Sweden. As “[p]riority under section 119, 365(a), 365(b), 386(a),
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`or 386(b) shall not be taken into account in determining the term of a patent,” (35 U.S.C. §
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`154(a)(3)) the ’470 Patent expires 20 years from July 2, 1996.
`10.
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`The innovations described by the ’470 Patent “relate[] to a method and apparatus
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`for controlling and coordinating” electronic displays “in a digital information system for
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`displaying information on at least one display device . . . said information being displayed in
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`places that are accessible to and frequented by a general public.” (’470 Patent at 1:15-21; 6:25-
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`29.) “An object of the present invention is to provide a flexible system in which external
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`information mediators are able to dynamically control in real time the transmission of display
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`instructions to a larger public in different places” “and to enable similar or specific information
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`to be displayed in places that are mutually far apart.” (Id. at 2:39-42; 2:52-54.)
`11.
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`A system operating according to an embodiment of the ’470 Patent can include a
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`control center with a communication interface that connects devices to create and update a
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`display list in real time using control instruction fields sent from external mediators and to
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`transmit and display the desired images to one or more electronic displays that can be controlled
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`independently of other electronic displays. (Id. at 3:4-19; 4:42-45.) In embodiments, the control
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`center can include one or more servers, workstations, and databases stored on one or more
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`physical storage devices, and can include redundancy, of both computer hardware and the
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`information stored, where the devices can be connected using a network, such as a LAN (Local
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`Area Network) or by using a cable-carried ISDN solution (Integrated Services Digital Network)
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`or other fixed lines that have a similar capacity. (Id. at 4:57-5:16; 5:59-67; 6:41-59; 12:55-13:7.)
`12.
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`In one embodiment of the invention, personnel operating a work station can enter
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`information to be displayed from an external mediator via projector control instructions in the
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`exposure list created by the server. (Id. at 8:10-26.) Operators are able to interrupt a queue in the
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`server in order to update the exposure list with information generated centrally from the control
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`center or with information from an external information mediator. (Id.)
`13.
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`Information mediators can use an exposure program to deliver complete images
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`(e.g. an image, a series of images or a video clip) for display which would not require processing
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`by the control center. (Id. at 11:19-28.) These can be dynamically added to the exposure list by
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`the exposure handler. (Id.) External information mediators can thus deliver a complete image for
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`display (an image, a series of images or a video clip) which can be processed automatically and
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`inserted into the exposure list, or an administrator can select information from an external
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`mediator and process the information so that it can be inserted into the exposure list via the
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`exposure handler. (Id. at 8:27-41.)
`14.
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`On June 3, 2008, U.S. Patent Number 7,382,334, entitled “Digital Information
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`System,” was duly and legally issued by the United States Patent and Trademark Office. A true
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`and correct copy of the ’334 Patent is attached as Exhibit B to this Complaint.
`15.
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`The innovations described by the ’334 Patent relate to methods and arrangements
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`“for controlling and coordinating” digital display devices “in a digital information system for
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`displaying information on at least one display device” “wherein the information is displayed in
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`places that are accessible to and frequented by a general public.” (’334 Patent at Abstract; 1:13-
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`24; 5:20-32.) The present invention is able “to provide a flexible system in which external
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`information mediators are able to dynamically control in real time the transmission of display
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`instructions to a larger public in different places” “and to enable similar or specific information
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`to be displayed in places that are mutually far apart.” (Id. at 2:56-60; 3:5-11.)
`16.
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`A system operating according to an embodiment of the ’334 Patent can include a
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`control center with a communication interface that connects devices to create and update a
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`display list in real time using control instruction fields sent from external mediators and to
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`transmit and display the desired images to one or more electronic displays that can be controlled
`independently of other electronic displays. (Id. at 3:38-60; 5:29-30.) In embodiments, the control
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`center can include one or more servers, workstations, and databases stored on one or more
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`physical storage devices, and can include redundancy, of both computer hardware and the
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`information stored, where the devices can be connected using a network, such as a LAN (Local
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`Area Network) or by using a cable-carried ISDN solution (Integrated Services Digital Network)
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`or other fixed lines that have a similar capacity. (Id. at 6:17-45; 7:17-29; 11:60-67.) In some
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`embodiments, a relational database can be used to store image and video data and each electronic
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`display can be assigned a unique TCP/IP (Transmission Control Protocol /Internet Protocol)
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`address such that each display can be individually addressed and sent content for display. (Id. at
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`14:50-15:8.)
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`17.
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`In one embodiment of the invention, personnel operating a work station can enter
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`information to be displayed from an external mediator via projector control instructions in the
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`exposure list created by the server. (Id. at 9:45-61.) Operators are able to interrupt a queue in the
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`server in order to update the exposure list with information generated centrally from the control
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`center or with information from an external information mediator. (Id.)
`18.
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`Information mediators can use an exposure program to deliver complete images
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`(e.g. an image, a series of images or a video clip) for display which would not require processing
`
`by the control center. (Id. at 12:12-22.) These can be dynamically added to the exposure list by
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`the exposure handler. (Id.) External information mediators can thus deliver a complete image for
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`display (an image, a series of images or a video clip) which can be processed automatically and
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`inserted into the exposure list, or an administrator can select information from an external
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`mediator and process the information so that it can be inserted into the exposure list via the
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`exposure handler. (Id. at 9:62-10:9.)
`19.
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`On August 6, 2002, U.S. Patent Number 6,430,603, entitled “System for Direct
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`Placement of Commercial Advertising, Public Service Announcements and Other Content on
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`Electronic Billboard Displays” was duly and legally issued by the United States Patent and
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`Trademark Office. A true and correct copy of the ’603 Patent is attached as Exhibit C to this
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`Complaint.
`20.
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`The innovations described by the ’603 Patent “relate[] to systems permitting
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`advertisers to target geographical regions and demographic groups with ever changing, current
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`advertising content without incurring the high fixed cost of traditional single-message
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`billboards.” (’603 Patent at 1:7-10.)
`21.
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`A system operating according to an embodiment of the ’603 Patent can include “a
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`central information processing center,” a network of “high resolution electronic displays located
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`in high traffic areas.” (Id. at 2:7; 1:15-16.) “The electronic displays preferably are large (e.g.,
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`23×33½ ft.) flat LED displays that are driven by their own video or image servers. (Id. at 2:16-
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`18.) “In preferred embodiments, each display is a . . . high resolution, full color display that
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`provides brilliant light emission from a flat panel screen.” (Id. at 2:62-65.) “Commercial
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`advertisers” can “directly send their own advertisements electronically to the network to be
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`displayed at locations and times selected by the advertiser.” (Id. at 1:12-18.)
`22.
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`A typical system can include a network that connects a central information
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`processing center with a number of electronic displays. (Id. at 2:7; 2:54-56.) “The means for
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`transmitting content information” from the central information processing center “to the display
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`locations may take a number of forms.” (Id. at 3:31-32.) “[T]he means include: [a] High speed
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`cable [b] Satellite [c] Dedicated phone [d] High speed line (e.g., ISDN) [e] Cellular or PCS [f]
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`Internet [g] Radio/radio pulse transmission [h] High speed optical fiber.” (Id. at 3:35-45.)
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`“[A]ny form” of network “may be utilized” depending on the system requirements “at various
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`locations within the network,” which can include combinations of the examples listed. (Id. at
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`3:32-33.)
`23.
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`In one embodiment, a display “takes the form of a 23 feet by 33½ feet seamless
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`flat screen display including multiple flat panel display modules.” (Id. at 4:49-51.) “The panels
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`utilize advanced semiconductor technology to provide high resolution, full color images utilizing
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`light emitting diodes” that can provide “a high spatial resolution” that is “easily viewable in
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`bright sunlight.” (Id. at 4:51-53, 62-65.) In such a display device, LEDs can be “aligned in an
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`integrated array with each pixel having a red, green and blue LED” and that if each “red, green
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`and blue emitter is accessed with 24 bit resolution” the resulting display “provid[es] 16.7 million
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`colors for every pixel” “produc[ing] the desired light output.” (Id. at 4:54-65.)
`24.
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`T-Rex is the assignee and owner of the right, title and interest in and to the ’470,
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`the ’334 and the ’603 Patents (henceforth collectively the “patents-in-suit”), including the right
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`to assert all causes of action arising under the patents-in-suit and the right to any remedies for
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`infringement.
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`COUNT I – INFRINGEMENT OF U.S. Patent No. RE39,470
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`25.
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`The allegations set forth in the foregoing paragraphs 1 through 24 are hereby re-
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`alleged and incorporated herein by reference.
`26.
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`Upon information and belief, in violation of 35 U.S.C. § 271(a), Defendant has
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`directly infringed and continues to directly infringe, literally or under the doctrine of equivalents,
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`one or more claims of the ’470 Patent by making, using, offering for sale, selling, or importing
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`devices or systems, in this judicial district and elsewhere in the United States (directly or through
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`intermediaries), that perform the steps of receiving control instructions from at least one external
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`information mediator, using the control instructions to generate an exposure list that specifies
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`three or more of the following items: i) what information content is to be displayed; ii) at which
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`of a plurality of locations the information content is to be displayed; iii) when the information
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`content is to be displayed for each location at which content is to be displayed; and iv) how long
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`the information content is to be displayed for each location at which content is to be displayed,
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`displaying images at one or more of the locations in accordance with the exposure list, and
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`permitting the exposure list to be dynamically updated as claimed in at least claim 25 of the ’470
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`Patent, without the authority of T-Rex.
`27.
`
`Upon information and belief, in violation of 35 U.S.C. § 271(a), Defendant has
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`directly infringed and continues to directly infringe, literally or under the doctrine of equivalents,
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`one or more claims of the ’470 Patent by making, using, offering for sale, selling, or importing
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`devices or systems, in this judicial district and elsewhere in the United States (directly or through
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`intermediaries), that comprise a computerized control center that has a plurality of
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`communication interfaces for receiving control instructions from at least one external
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`information mediator, the computerized control center includes a means for generating and
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`dynamically updating an exposure list from the control instructions, the exposure list specifying
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`three or more of the following items: i) what information content is to be displayed; ii) at which
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`of the plurality of locations the information content is to be displayed; iii) when the information
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`content is to be displayed for each location at which content is to be displayed; and iv) how long
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`the information content is to be displayed for each location at which content is to be displayed, a
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`computerized device situated at each one of the plurality of locations and electronically coupled
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`to the computerized control center, and a means for displaying images in accordance with the
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`exposure list associated with each one of the computerized devices as claimed in at least claim
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`26 of the ’470 Patent, without the authority of T-Rex.
`28. More specifically, the infringing devices and systems include Defendant’s Zoom
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`Fitness Video Network, which includes content, commercials and digital signage.
`29.
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`Upon information and belief, Defendant has directly infringed and continues to
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`directly infringe one or more claims of the ’470 Patent, including at least claims 25 and 26, by
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`operating its Zoom Fitness Video Network at health and fitness clubs in Illinois and elsewhere in
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`the United States.
`30.
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`In 1994, the traditional Out-of-Home advertising industry was in need of a
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`change, an evolutionary improvement. See Declaration of Mats Hylin (“Hylin Decl.”) at ¶ 8
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`(attached as Exhibit D, and hereby incorporated, in its entirety, by reference herein at paragraph
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`30). Mats Hylin, the first named inventor of the ’470 and the ’334 Patents, recognized that the
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`“demands from advertisers” were not being met; what advertisers wanted was “more flexibility
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`and speed” and “the possibility of changing the message” instead of “having the same
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`advertisement [displayed] during the whole period.” Id. This may be because advertisers wish to
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`avoid a stagnant message, or because advertisers desire campaign evaluation feedback —“the
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`results of a first campaign are fundamental in order to create the next campaign.” Id. at ¶ 15. Mr.
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`Hylin also recognized that in order “to increase the revenue from” the “most attractiv[ely
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`situated] billboards,” an approach that extended beyond merely increasing the rates was required.
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`Id. In addition to addressing these revenue issues, distribution efficiencies was “one of the most
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`important areas to create higher margins.” Id. at ¶ 6. One method to address this was through the
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`use of digital advertising copy—which could be distributed via “the internet, or any other
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`network”—rather than incur the costs associated with physical distribution and display of paper
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`or other printed advertising copy. Id. at ¶¶ 8-9.
`31. More particularly, claim 25 “solves specific needs and problems over other
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`technologies that existed in 1996.” Declaration of Zaydoon Jawadi (“Jawadi Decl.”) ¶ 22
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`(attached as Exhibit E, and hereby incorporated, in its entirety, by reference herein at paragraph
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`31). Such problems and shortcomings included “controlling and coordinating digital signage
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`displays in concrete, specific ways beyond merely scheduling content to be displayed on remote
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`screens.” Id. More specifically, “[p]rior to the inventions disclosed in claim 25 . . . there was no
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`flexible way for external information mediators . . . to dynamically control and coordinate,
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`display devices located in different places.” Id. at ¶ 23. “Content from external information
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`mediators could not be directly displayed; instead, displaying such content required
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`administrative processing and manual intervention to update the display systems.” Id.
`32.
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`The inventions embodied in claim 25 “improved the operation of digital signage
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`that existed in 1996” by “impos[ing] meaningful limitations” that “allow[ed] external
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`information mediator(s) to dynamically control and coordinate display devices located in
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`different places, extending the usefulness of the digital signage technology.” Id. at ¶¶ 26-27.
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`“[C]laim 25 of the ’470 Patent incorporates unique, innovative, non-conventional, non-generic
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`elements” that work together to improve the operation of a digital signage system. Id. at ¶ 28.
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`“The functions, application, and implementations of these elements inherently and necessarily
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`are rooted in and require computer technology, communication technology, and digital display
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`technology in order to overcome specific problems arising in the realm of digital signage in
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`1996.” Id. at ¶ 29. Importantly, “the claim goes beyond the mere concept of simply using a
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`computer to perform distributed signage.” Id. “This is because computers, communication
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`interfaces, and digital display devices are not ancillary or incidental additions but germane and
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`integral parts of the inventions disclosed by claim 25 of the ’470 Patent.” Id. The limitations of
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`claim 25 “relate to the functioning of hardware and software” that are “inextricably tied to digital
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`signage computer technology, communication technology, and digital display technology” such
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`that the “unique, innovative, non-conventional, non-generic” hardware and software incorporated
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`in claim 25 are used to achieve these technological innovations. Id. at ¶¶ 28, 30.
`33.
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`The physical combination of elements that are referenced in claim 25 represent an
`innovation over the prior art. More particularly, claim 25 references an “information mediator.”
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`At the time of the invention, in about the 1995 to 1996 time frame, the term “information
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`mediator,” within the context of the field of art, could have referred to “an agent between
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`producer and consumer of information” where the “agent could be a software component,
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`software with accompanying hardware, a system, an organization (such as advertising agency) or
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`an individual.” Id. at ¶ 33. Claim 25 also references “location(s)” which at the time of the
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`invention could have referred, again within the context of the field of art, to “a particular
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`physical or geographical place or position where the message or advertisement is displayed on an
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`electronic display device.” Id. at ¶ 34. Taking into account the meaning of these terms, as well as
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`the claim as a whole, implementation of claim 25 would require “industrial computers, servers,
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`PCs, networking routers or switches, networking cables, computer graphics capabilities, display
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`devices . . . database management systems as well as specialized software drivers to interface
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`between mediators and system computers, to decipher control lists, to create and update exposure
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`lists, and to decipher and act upon exposure lists.” Id. at ¶ 35. Such a combination of elements
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`represented a significant and non-conventional innovation over the prior art which resulted in an
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`improvement in the operation of digital signage. Id. at ¶ 38.
`34.
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`“Furthermore, claim 25 . . . is distinct and different from the other claims of the
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`’470 Patent.” Id. at ¶ 37. “In particular, claim 25 . . . is distinct and different from claim 26 of the
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`’470 Patent.” Id. For example, “[c]laim 26 discloses a computerized control center,
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`communication interfaces, means for generating and dynamically updating an exposure list, a
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`means for displaying images and a computerized device situated at each location—limitations
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`that claim 25 does not disclose.” Id.
`35.
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`Claim 25 embodies an entirely new combination of special purpose and
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`interconnected physical equipment to present information publicly. The inventions embodied in
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`claim 25 arose in a specialized context—back in or about the 1995 to 1996 time frame—and the
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`inventors came up with a specific solution, manifested in a concrete combination of devices,
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`interfaces, and software, networked together with physical displays viewable by the target
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`audience, to resolve particular problems.
`36.
`
`The inventions embodied in claim 26 also “improved the operation of digital
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`signage that existed in 1996” Id. at ¶ 45. “[C]laim 26 of the ’470 Patent incorporates unique,
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`innovative, non-conventional, non-generic elements.” Id. at ¶ 47. These elements include a
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`“computerized control center[,] . . . means (within the computerized control center) for
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`generating and dynamically updating an exposure list . . . [and] computerized devices” which are
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`situated at “a plurality of locations.” Id. at ¶¶ 40, 47. The computerized devices are
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`“electronically coupled to the computerized control center” and include a means “for displaying
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`images in accordance with the exposure list.” Id. at ¶ 47. The limitations of claim 26 “relate to
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`both the hardware and software technology for digital signage, as well as to the functioning of
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`hardware and software technology for digital signage” and are “manifested in a concrete
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`combination of devices, interfaces, and software, networked together with physical displays
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`viewable by the target audience.” Id. at ¶¶ 41, 49.
`37.
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`The physical combination of elements that are referenced in claim 26 represent an
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`innovation over the prior art. More particularly, in addition to “information mediator” and
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`“location(s),” claim 26 references “communication interfaces.” At the time of the invention, in
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`about the 1995 to 1996 time frame, the term communication interfaces, within the context of the
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`field of art, could have referred to “electronic hardware, software, and protocols allowing
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`systems (such as computers) to communicate and exchange data.” Id. at ¶ 54. Claim 26 also
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`references a “computerized control center” which at the time of the invention could have
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`referred, again within the context of the field of art, to “a computer or set of computers that
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`control and coordinate the interaction between networked computers or equipment.” Id. at ¶ 55.
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`Such a combination of elements represented a significant and non-conventional innovation over
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`the prior art which resulted in an improvement in the operation of digital signage. Id. at ¶ 59.
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`38.
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`Claim 26 embodies an entirely new combination of special purpose and
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`interconnected physical equipment to present information publicly. The inventions embodied in
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`claim 26 arose in a specialized context—back in or about the 1995 to 1996 time frame—and the
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`inventors came up with a specific solution, manifested in a concrete combination of devices,
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`interfaces, and software, networked together with physical displays viewable by the target
`
`audience, to resolve particular problems.
`39.
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`Defendant has had knowledge of the ’470 Patent since at least the date that this
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`Complaint was served.
`40.
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`Because of Defendant’s infringing activities, T-Rex has suffered damages and
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`will continue to suffer damages in the future. T-Rex is entitled to recover from Defendant the
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`damages sustained by T-Rex as a result of Defendant’s wrongful acts in an amount subject to
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`proof at trial, which, by law, cannot be less than a reasonable royalty, together with interest and
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`costs as fixed by this Court under 35 U.S.C. § 284.
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`COUNT II – INFRINGEMENT OF U.S. Patent No. 7,382,334
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`41.
`
`The allegations set forth in the foregoing paragraphs 1 through 40 are hereby re-
`
`alleged and incorporated herein by reference.
`42.
`
`Upon information and belief, in violation of 35 U.S.C. § 271(a), Defendant has
`
`directly infringed and continues to directly infringe, literally or under the doctrine of equivalents,
`
`one or more claims of the ’334 Patent by making, using, offering for sale, selling, or importing
`
`devices or systems, in this judicial district and elsewhere in the United States (directly or through
`
`intermediaries), that perform the steps of generating an exposure list comprising control
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`instructions for coordinating and controlling electronic displays with regard to what shall be
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`exposed, when it shall be exposed, where it shall be exposed and for how long it shall be
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`exposed, using a control center for coordinating and controlling electronic displays, where the
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`control center is able to create and update the exposure list in real time, with control instruction
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`fields via dynamic booking of information, in time for exposure, from mediators, and where the
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`exposure list enables each electronic display to be controlled, independently of other electronic
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`displays, to receive the same or different information in accordance with the exposure list for the
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`exposure of respective electronic display as claimed in at least claim 22 of the ’334 Patent,
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`without the authority of T-Rex.
`43.
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`Upon information and belief, in violation of 35 U.S.C. § 271(a), Defendant has
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`directly infringed and continues to directly infringe, literally or under the doctrine of equivalents,
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`one or more claims of the ’334 Patent by making, using, offering for sale, selling, or importing
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`devices or systems, in this judicial district and elsewhere in the United States (directly or through
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`intermediaries), that comprise a computerized control center means, where the control center has
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`communication interfaces against; a computerized means for coordinating and controlling
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`electronic displays; and an exposure handler means whereby the control center functions, in real
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`time and through the medium of the exposure handler, to create and update an exposure list that
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`has control instruction fields, via dynamic booking of display information from mediators and
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`where the exposure list contains control instructions, that coordinate and control the electronic
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`displays in question with respect to what shall be exposed, where it shall be exposed, when it
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`shall be exposed, and for how long it shall be exposed, and enables each electronic display,
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`independently of other electronic displays, to receive the same or different information according
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`to the exposure list for exposure or display by the respective electronic display as claimed in at
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`least claim 32 of the ’334 Patent, without the authority of T-Rex.
`44. More specifically, the infringing devices and systems include Defendant’s Zoom
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`Fitness Video Network, which includes content, commercials and digital signage.
`45.
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`Upon information and belief, Defendant has directly infringed and continues to
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`directly infringe one or more claims of the ’334 Patent, including at least claims 22 and 32, by
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`operating its Zoom Fitness Video Network at health and fitness clubs in Illinois and elsewhere in
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`the United States.
`46.
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`Claim 22 the ’334 Patent “solves specific needs and problems over other
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`technologies that existed in 1996.” Jawadi Decl. at ¶ 63. Such problems and shortcomings
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`included “controlling and coordinating digital signage displays in concrete, specific ways beyond
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`merely scheduling content to be displayed on remote screens.” Id. More specifically, “[p]rior to
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`the inventions disclosed in claim 22 . . . there was no flexible way for external information
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`mediators . . . to dynamically control and coordinate, in real time, display devices located in
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`different places.” Id. at ¶ 64. “Content from external information mediators could not be directly
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`displayed, and particularly not in real time or in near real time; instead, displaying such content
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`required administrative processing and manual intervention to update the display systems.” Id.
`47.
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`The inventions embodied in claim 22 “improved the operation of digital signage
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`that existed in 1996” by “impos[ing] meaningful limitations” that “allow[ed] external
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`information mediator(s) to dynamically control and coordinate, in real time, display devices
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`located in different places, extending the usefulness of the digital signage technology.” Id. at ¶¶
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`67-68. “[C]laim 22 of the ’334 Patent incorporates unique, innovative, non-conventional, non-
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`generic elements” that work together to improve the operation of a digital signage system. Id. at
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`¶ 69. “The functions, application, and implementations of these elements inherently and
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`necessarily are rooted in and require computer technology, communication technology, and
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`digital display technology in order to overcome specific problems arising in the realm of digital
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`signage in 1996.” Id. at ¶ 70. Importantly, “the claim goes beyond the mere concept of simply
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`using a computer to perform distributed signage.” Id. “This is because computers,
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`communication interfaces, and digital display devices are not ancillary or incidental additions but
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`germane and integral parts of the inventions disclosed by claim 22 of the ’334 Patent.” Id. The
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`limitations of claim 22 “relate to the functioning of hardware and s