throbber
the Claim
`Claim 1
`1[a]. A process
`for the
`simultaneous
`storage and play
`back of
`multimedia data,
`comprising the
`steps of:
`
`EXHIBIT A
`Preliminary Infringement Claim Chart for U.S. Pat. No. 6,233,389
`Samsung DVRs
`
`Samsung DVRs1
`
`A Samsung DVR can simultaneously store and play back multimedia data. See, e.g.,
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), p. 2 ("Viewing one program while recording another program.” “Simultaneous Time
`Shifted Buffering for two Programs."); p. 9 (“Record two live TV programs simultaneously while watching two recorded
`programs on HDD.”)
`
`“TIME WARNER CABLE AND SAMSUNG FORGE AGREEMENT FOR TRU2WAY SET-TOP DEVELOPMENT,
`PURCHASE & DEPLOYMENT
`Release Date: 07/06/2009
`
`Time Warner Cable and Samsung today announced that they have signed a letter of commitment for the continued development,
`purchase and deployment of Samsung True2Way enabled set-top boxes, including the first second-source DVR.
`“We look to offer our customers advanced set-top boxes with features that are simple and easy to use,” said Mike Hayashi,
`Executive Vice President of Advanced Engineering for Time Warner Cable. “We have been a leader in the roll-out of Tru2Way
`devices and we are continuing to grow our relationship with Samsung, a CE company dedicated to the development of new
`equipment meeting the necessary standards and offering attractive feature sets.”
`Thomas Rhee, SVP, New Business Development for Samsung, added, “We are thrilled to have worked closely with Time
`Warner Cable to launch Tru2way on our family of cable set-tops including the SMT-H3090 and SMT-H3270 High Definition
`DVRs. As in Korea, we look forward to the expansion of Tru2way in North America.”
`This agreement further solidifies Time Warner Cable’s commitment to its deployment of Tru2Way enabled set-top boxes. To
`date Time Warner Cable has deployed over 2 million Tru2Way set-top boxes, of which approximately 400,000 are Samsung
`boxes.
`Time Warner Cable and Samsung also recently signed an MOU that focuses on collaborating in development of better home
`
`1 In this chart, reference is made to a Samsung DVR identified as SMT-H3090. The same analysis applies to other Samsung DVRs with the
`same functionality, including but not limited to set top boxes with DVR functionality bearing the model designations, SMT-H3272, SMTH3270, and
`SMT-H4372 and other DVRs having the same functionality. Additionally, this chart also references the specific processor included in the SMT-
`H3090. The same analysis applies to DVRs that include other processors with the same functionality, for example the processors in each of the
`accused DVRs.
`
`5463861
`
`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
`‘389 PATENT
`SAMSUNG DVRS
`
`SAMSUNG 1015
`
`1
`
`

`
`the Claim
`
`Samsung DVRs1
`networking solutions for entertainment. This work is part of Time Warner Cable’s continuing efforts to provide its customers
`with technology that brings new levels of ease and convenience.”
`http://www.timewarnercable.com/corporate/about/inthenews.ashx?PRID=2626&MarketID=0
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`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
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`SAMSUNG DVRS
`
`2
`
`

`
`the Claim
`[1b] accepting
`television (TV)
`broadcast signals,
`wherein said TV
`signals are based
`on a multitude of
`standards,
`including, but not
`limited to,
`National
`Television
`Standards
`Committee
`(NTSC)
`broadcast, PAL
`broadcast,
`satellite
`transmission,
`DSS, DBS, or
`ATSC;
`[1c] tuning said
`TV signals to a
`specific program;
`
`[1d] providing at
`least one Input
`Section, wherein
`said Input Section
`converts said
`specific program
`to an Moving
`
`5463861
`
`Samsung DVRs1
`A Samsung DVR accepts television broadcast signals. On information and belief, Samsung DVRs receive television
`programming in the form of QAM-modulated MPEG2 transport stream packets.
`
`See, e.g., (Samsung SMT-H3090 2008 Data Sheet), p.1 (“Samsung SMT-H3090 is Dual tuner Digital Video Recorder(DVR)
`which provides Standard Definition (SD), High-Definition(HD) and Analog video signals. Dual tuner DVR allows cable
`subscribers to watch and record two HD programs Simultaneously.”"), p. 2 ("In-band Tuner : 54 to 864MHz, Receiving 64 or
`256 QAM."));
`
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), p. 2 ("RF Input Tuning Range: 88 to 860 MHz."); (BCM7400 Product Brief)
`(showing BCM3420 and BCM3255 chips)
`
`On information and belief, Samsung DVRs accept ATSC broadcast signals.
`
`A Samsung DVR has tuners which can tune TV signals to a specific program. See, e.g., (Samsung SMT-H3090 2008 Data
`Sheet), p.1 (“Samsung SMT-H3090 is Dual tuner Digital Video Recorder(DVR) which provides Standard Definition (SD),
`High-Definition(HD) and Analog video signals. Dual tuner DVR allows cable subscribers to watch and record two HD
`programs Simultaneously.”"), p. 2 ("In-band Tuner : 54 to 864MHz, Receiving 64 or 256 QAM.")). For example, based on
`information and belief the Samsung DVRs tune to a specific frequency or a band of frequencies.
`
`A Samsung DVR has at least one Input Section, wherein said Input Section converts said specific program to a Moving Pictures
`Experts Group (MPEG) formatted stream for internal transfer and manipulation. The Input Section converts said specific
`program to an MPEG formatted stream, for example in the course of performing QAM demodulation and Analog-to-Digital
`conversion (A/D). A Samsung DVR will perform QAM demodulation and Analog-to-Digital conversion in the course of
`watching live television and recording a television program. See, e.g.,
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`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
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`SAMSUNG DVRS
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`3
`
`

`
`Samsung DVRs1
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), p. 2 ("RF Input Tuning Range: 88 to 860 MHz."); (BCM7400 Product Brief)
`(showing BCM3420 and BCM3255 chips):
`
`the Claim
`Pictures Experts
`Group (MPEG)
`formatted stream
`for internal
`transfer and
`manipulation;
`
`To the extent any differences are alleged to exist between this claim element and the above referenced functionality, such
`differences are insubstantial. On information and belief, the hardware and software in the Samsung DVRs perform substantially
`the same function as the Input Section, for example that of converting a specific program into an MPEG stream, in substantially
`the same way, for example by turning the input data, whatever its format, into a digital representation such as MPEG, to yield
`the same result, a properly formatted data stream for internal transfer and manipulation.
`
`A Samsung DVR has a Media Switch, wherein said Media Switch parses MPEG streams, said MPEG stream is separated into its
`video and audio components. The Media Switch parses MPEG streams, for example, on information and belief, in the course of
`PID filtering and start code detection. Broadcom chips used inside Samsung DVRs have PID filters or parsers that PID filter or
`parse multi-program transport streams to a single-program transport stream and start code detectors that perform start code
`detection. See, e.g.,
`
`- 4 -
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`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
`‘389 PATENT
`SAMSUNG DVRS
`
`[1e] providing a
`Media Switch,
`wherein said
`Media Switch
`parses said MPEG
`stream, said
`
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`4
`
`

`
`the Claim
`MPEG stream is
`separated into its
`video and audio
`components;
`
`Samsung DVRs1
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`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
`‘389 PATENT
`SAMSUNG DVRS
`
`5
`
`

`
`the Claim
`
`Samsung DVRs1
`
`Samsung SMT-H3090, Broadcom BCM74xx);
`
` (showing internal chips of
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`SAMSUNG DVRS
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`6
`
`

`
`the Claim
`
`Samsung DVRs1
`
`internal chips of Samsung SMT-H3090, Broadcom BCM3255).
`
` (showing
`
`To the extent any differences are alleged to exist between this claim element and the above referenced functionality, such
`differences are insubstantial. On information and belief, the hardware and software in the Samsung DVRs perform substantially
`the same function as the media switch, for example that of parsing an MPEG stream, in substantially the same way, for example
`by performing PID filtering, start code detection, or other analysis of the underlying data, to yield the same result, a data stream
`
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`SAMSUNG DVRS
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`7
`
`

`
`the Claim
`
`Samsung DVRs1
`including any additional information needed for its further processing.
`
`On information and belief, the MPEG stream is separated into its video and audio components, for example, the course of PID
`filtering, start code detection, and temporary storage in memory. Additionally, the streams are separated when presented to the
`video and audio decoders. In the course of PID filtering and start code detection, on information and belief, MPEG2 transport
`stream packets are discretely analyzed. Each MPEG2 transport stream packet contains audio or video data. The MPEG2
`transport stream packets are temporarily stored in memory (e.g., on-chip buffers, flash, and/or system DRAM), where each
`MPEG2 transport stream packet is held in a distinct memory location. As another example, the video and audio data packets of
`the MPEG data are separated when they are sent to separate decoders. For example, audio packets go to audio decoders while
`video packets go to video decoders
`
`Samsung DVRs may contain MPEG encoders, including the BCM7041:
`
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`SAMSUNG DVRS
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`8
`
`

`
`the Claim
`
`Samsung DVRs1
`
`Samsung SMT-H3090, Broadcom BCM7041).
`
` (showing internal chips of
`
`To the extent any differences are alleged to exist between this claim element and the above referenced functionality, such
`differences are insubstantial. On information and belief, the hardware and software in the Samsung DVRs perform substantially
`the same function as the Media Switch, that of parsing an MPEG stream and separating an MPEG stream into its video and
`audio components so that the video and audio components can be provided to the video and audio MPEG decoders, in
`substantially the same way, by performing PID filtering, start code detection, and separating the video and audio components, to
`yield the same result, an analyzed MPEG stream that is separated into audio and video components, and therefore would infringe
`under the doctrine of equivalents.
`
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`‘389 PATENT
`SAMSUNG DVRS
`
`9
`
`

`
`the Claim
`
`Samsung DVRs1
`Still further, on information and belief, the hardware and software in the Samsung DVRs perform substantially the same
`function as the Media Switch, that of parsing an MPEG stream and separating an MPEG stream into its video and audio
`components so that the video and audio components can be provided to the video and audio MPEG decoders, in substantially the
`same way, by sending the video and audio data to separate decoders, regardless of any order of processing in the DVR, to yield
`the same result, an analyzed MPEG stream that is separated into audio and video components for playback on a user's display,
`and therefore would infringe under the doctrine of equivalents.
`
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`SAMSUNG DVRS
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`10
`
`

`
`the Claim
`[1f] storing said
`video and audio
`components on a
`storage device;
`
`Samsung DVRs1
`A Samsung DVR stores video and audio components on a storage device. For example, Samsung DVRs allow users to store
`television programs to watch at a later time.
`
`See, e.g., (BCM7400 Product Brief) (showing SATA II interface to HDD):
`
`On information and belief, Samsung DVRs store MPEG2 transport stream packets on a hard disk drive (HDD) during recording.
`See, e.g.,
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), at 6:
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`SAMSUNG DVRS
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`11
`
`

`
`the Claim
`
`Samsung DVRs1
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`12
`
`

`
`the Claim
`[1g] providing at
`least one Output
`Section, wherein
`said Output
`Section extracts
`said video and
`audio components
`from said storage
`device;
`
`Samsung DVRs1
`A Samsung DVR has at least one Output Section, wherein said Output Section extracts said video and audio components from
`said storage device. For example, Samsung DVRs allow users to play back recorded television programs to watch at a later
`time. See, e.g.,
`
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), at 10:
`
`(Samsung SMT-H3090 2008 Data Sheet), at 1:
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`SAMSUNG DVRS
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`13
`
`

`
`the Claim
`
`Samsung DVRs1
`
`On information and belief, Samsung DVRs extract MPEG2 transport stream packets from a hard disk drive (HDD) during play
`back. See, e.g.,
`
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), at 6:
`
`To the extent any differences are alleged to exist between this claim element and the above referenced functionality, such
`differences are insubstantial. On information and belief, the hardware and software in the Samsung DVRs perform substantially
`the same function as the Output Section, for example that of extracting said video and audio components from said storage
`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
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`SAMSUNG DVRS
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`14
`
`

`
`the Claim
`
`[1h] wherein said
`Output Section
`assembles said
`video and audio
`components into
`an MPEG stream;
`
`Samsung DVRs1
`device, in substantially the same way, for example by reading the data from the storage device, to yield the same result, a
`retrieved data stream for further processing and display to a viewer.
`A Samsung DVR has at least one Output Section that assembles said video and audio components into an MPEG stream. On
`information and belief, MPEG2 transport stream packets are assembled into an MPEG2 transport stream, de-multiplexed, and
`packetized elementary streams are constructed when read from the disk and/or before being sent to a decoder.
`
`For example, Video and Audio data are read from the disk for playback.
`
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), at 10:
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`15
`
`

`
`the Claim
`
`(Samsung SMT-H3090 2008 Data Sheet), at 1:
`
`Samsung DVRs1
`
`On information and belief, Samsung DVRs extract MPEG2 transport stream packets from a hard disk drive (HDD) during play
`back. See, e.g.,
`
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), at 6:
`
`These video and audio data are assembled into an MPEG stream so that they can be processed and displayed by an MPEG
`
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`‘389 PATENT
`SAMSUNG DVRS
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`16
`
`

`
`the Claim
`
`decoder.
`
`Samsung DVRs1
`
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`17
`
`

`
`the Claim
`
`Samsung DVRs1
`
`BRCM 7405 Preliminary Hardware Data Module at 1-35
`
`To the extent any differences are alleged to exist between this claim element and the above referenced functionality, such
`differences are insubstantial. On information and belief, the hardware and software in the Samsung DVRs perform substantially
`the same function as the Output Section, for example that of assembling said video and audio components into an MPEG stream,
`in substantially the same way, for example by demultiplexing or packetizing the data, to yield the same result, a properly
`formatted data stream for presentation to the decoder.
`A Samsung DVR has an Output Section that sends said MPEG stream to a decoder. See, e.g., (BCM7400 Product Brief):
`
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`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
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`SAMSUNG DVRS
`
`[1i] wherein said
`Output Section
`sends said MPEG
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`18
`
`

`
`the Claim
`stream to a
`decoder;
`
`Samsung DVRs1
`
`(Samsung SMT-H3090 2008 User Guide), at 6:
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`SAMSUNG DVRS
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`19
`
`

`
`the Claim
`
`Samsung DVRs1
`
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`SAMSUNG DVRS
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`20
`
`

`
`the Claim
`[1j] wherein said
`decoder converts
`said MPEG
`stream into TV
`output signals;
`
`Samsung DVRs1
`A Samsung DVR has decoders that convert MPEG streams into TV output signals. On information and belief, the Broadcom
`chips used in Samsung DVRs contain video and audio decoders.
`
`See, e.g., (Broadcom BCM 7400 Product Brief), at 1:
`
`(Broadcom BCM 7400 Product Brief), at 2 (showing video decoders):
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`21
`
`

`
`the Claim
`
`Samsung DVRs1
`
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`22
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`

`
`the Claim
`[1k] wherein said
`decoder delivers
`said TV output
`signals to a TV
`receiver; and
`
`Samsung DVRs1
`A Samsung DVR delivers decoded TV output signals to a TV receiver. A Samsung DVR can be connected to a TV using
`HDMI, DVI, component, Y Output, Video Output, S-Video Out, Cable Out, or 1394 connectors. See, e.g.,
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), at 13-14:
`
`[1l] accepting
`control commands
`from a user,
`wherein said
`control commands
`are sent through
`
`A Samsung DVR accepts control commands from a user, wherein said control commands are sent through the system and affect
`the flow of an MPEG stream. The Samsung DVR software is responsive to front panel buttons and a remote control. On
`information and belief, the remote control sends IR signals that are received by the Samsung DVR. The hardware and software
`receives commands from a user, which affect the flow of data through the system, e.g., begin recording, channel change,
`trickplay, etc. See, e.g.,
`(BCM7400 Product Brief) (showing front panel controls input to the BCM7400 chip):
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`
`

`
`the Claim
`the system and
`affect the flow of
`said MPEG
`stream.
`
`Samsung DVRs1
`
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), at 10:
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`24
`
`

`
`the Claim
`
`Samsung DVRs1
`
`To the extent any differences are alleged to exist between this claim element and the above referenced functionality, such
`differences are insubstantial. On information and belief, the hardware and software in the Samsung DVRs perform substantially
`the same function, for example that of accepting control commands from a user, in substantially the same way, for example by
`including hardware and/or software interfaces that can accept user commands, to yield the same result, wherein said control
`commands are sent through the system and affect the flow of said MPEG stream.
`
`Claim 2
`The process of
`claim 1, wherein
`said Input Section
`directs said
`MPEG stream to
`the destination
`
`5463861
`
`In addition to the features described above regarding claim 1, Samsung DVRs include an input section that directs an MPEG
`stream to a destination indicated by said control commands.
`
`For example, when a Samsung DVR receives a command to record a television program, an input section, including for example
`tuners, parsers, and other processing devices may direct MPEG data to any of memory, hard disks, and/or optical storage
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`

`
`the Claim
`indicated by said
`control
`commands.
`
`devices.
`
`Samsung DVRs1
`
`Claim 3
`The process of
`claim 1, wherein
`said Output
`Section extracts
`said video and
`audio components
`from the storage
`device indicated
`by said control
`commands.
`
`5463861
`
`In addition to the features described above regarding claim 1, Samsung DVRs include an output section that extracts video and
`audio components from the storage device indicated by said control commands.
`
`For example, when a Samsung DVR receives a command to play back a television program, an output section, including for
`example decoders, demodulators, and other processing devices may extract video and audio data from any of memory, hard
`disks, and/or optical storage devices for display to a viewer.
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`

`
`the Claim
`
`Samsung DVRs1
`
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`

`
`Samsung DVRs1
`
`A Samsung DVR can simultaneously store and extract video and audio components from a storage device, for example, in the
`course of simultaneously recording and playing back television programming. See, e.g.,
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), p. 2 ("Viewing one program while recording another program.” “Simultaneous Time
`Shifted Buffering for two Programs."); p. 9 (“Record two live TV programs simultaneously while watching two recorded
`programs on HDD.”)
`
`To the extent any differences are alleged to exist between this claim element and the above referenced functionality, such
`differences are insubstantial. On information and belief, the hardware and software in the Samsung DVRs perform substantially
`the same function, for example storing and extracting of said video and audio components from said storage device, in
`substantially the same way, for example by performing these actions substantially simultaneously, to yield the same result,
`wherein said storing and extracting appear to occur at the same time.
`
`In addition to the features described above regarding claim 1, Samsung DVRs include a Media Switch that calculates and
`logically associates a time stamp to said video and audio components.
`
`For example, when a Samsung DVR records a program a local timestamp may be generated by a processor and internal clock,
`and stored with the video and audio date. See, e.g., BRCM 7405 functional description at page 1-22:
`
`the Claim
`Claim 5
`The process of
`claim 1, wherein
`the storing and
`extracting of said
`video and audio
`components from
`said storage
`device are
`performed
`simultaneously.
`
`Claim 6
`The process of
`claim 1, wherein
`said Media
`Switch calculates
`and logically
`associates a time
`stamp to said
`video and audio
`components.
`
`5463861
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`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
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`SAMSUNG DVRS
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`

`
`Samsung DVRs1
`
`In addition to the features described above regarding claim 1, Samsung DVRs include a Media Switch that extracts time stamp
`values from a digital TV stream and logically associates said time stamp values to said video and audio components.
`
`For example, when a Samsung DVR receives and records digital input stream, it may include a time stamp, such as a
`presentation time stamp (PTS) that is included in that stream. The PTS will be extracted and stored with the input data stream.
`See, e.g., BRCM 7405 functional description at page 1-22:
`
`the Claim
`Claim 7
`The process of
`claim 1, wherein
`said Media
`Switch extracts
`time stamp values
`from a digital TV
`stream and
`logically
`associates said
`time stamp values
`to said video and
`audio
`components.
`
`5463861
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`SAMSUNG DVRS
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`29
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`

`
`In addition to the features described above regarding claim 1, Samsung DVRs include fast playback and fast reverse playback.
`
`Samsung DVRs1
`
`the Claim
`Claim 12
`The process of
`claim 1, further
`comprising the
`step of:
`increasing the
`decoder system
`clock rate for fast
`playback or fast
`reverse playback
`
`On information and belief, at least one of these fast playback and fast reverse playback modes are implemented by, among other
`things, increasing the decoder system clock rate. For example, the PCR block may be used by rate managers to control the
`playback rate of the decoders.
`
`5463861
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`30
`
`

`
`the Claim
`
`Samsung DVRs1
`
`In addition to the features described above regarding claim 1, Samsung DVRs include slow playback and slow reverse playback.
`
`Claim 13
`The process of
`claim 1, further
`comprising the
`step of:
`decreasing the
`decoder system
`clock rate for
`slow playback or
`slow reverse
`playback.
`
`On information and belief, at least one of these slow playback and slow reverse playback modes are implemented by, among
`other things, decreasing the decoder system clock rate. For example, the PCR block may be used by rate managers to control the
`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
`‘389 PATENT
`SAMSUNG DVRS
`
`- 31 -
`
`5463861
`
`31
`
`

`
`the Claim
`
`playback rate of the decoders.
`
`Samsung DVRs1
`
`5463861
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`32
`
`

`
`the Claim
`Claim 18
`The process of
`claim 1, wherein
`said Media
`Switch has a data
`bus connecting it
`to a CPU and
`DRAM.
`
`Samsung DVRs1
`
`In addition to the features described above regarding claim 1, Samsung DVRs include a Media Switch that has a data bus
`connecting it to a CPU and DRAM.
`
`For example, Samsung DVRs may include a processor that includes, for example, an EBI with a data bus that connects to either
`of CPU, e.g. a MIPs processor or the like, and DRAM, including memory used for DMA or other storage or buffering functions.
`See, e.g. BRCM7405 Functional Description at 1-83
`
`Claim 19
`The process of
`claim 1, wherein
`said Media
`
`5463861
`
`In addition to the features described above regarding claim 1, Samsung DVRs include a Media Switch that shares an address bus
`with a CPU and DRAM.
`
`- 33 -
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`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
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`SAMSUNG DVRS
`
`33
`
`

`
`the Claim
`Switch shares an
`address bus with a
`CPU and DRAM
`
`Samsung DVRs1
`For example, Samsung DVRs may include a processor that includes, for example, an EBI with a shared address bus that
`connects to both a CPU, e.g. a MIPs processor or the like, and DRAM, including memory used for DMA or other storage or
`buffering functions. See, e.g. BRCM7405 Functional Description at 1-83
`
`Claim 20
`The process of
`claim 1, wherein
`said Media
`Switch operates
`asychronously
`
`5463861
`
`In addition to the features described above regarding claim 1, Samsung DVRs include a Media Switch that operates
`asychronously and autonomously with a CPU.
`
`For example, Samsung DVRs may include a processor that includes, for example, a PCI bus that allows the media switch to
`
`- 34 -
`
`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
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`SAMSUNG DVRS
`
`34
`
`

`
`the Claim
`and autonomously
`with a CPU.
`
`Samsung DVRs1
`operate asynchronously and autonomously from the CPU. See, e.g. BRCM7405 Functional Description at 1-83
`
`Claim 21
`The process of
`claim 1, wherein
`said storage
`device is
`connected to said
`Media Switch.
`
`5463861
`
`In addition to the features described above regarding claim 1, Samsung DVRs include a storage device that is connected to said
`Media Switch.
`
`For example, the Samsung DVRs include, among other things, a hard drive operatively connected to the media switch for storing
`multimedia data.
`
`- 35 -
`
`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
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`
`35
`
`

`
`the Claim
`
`Samsung DVRs1
`
`5463861
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`36
`
`

`
`the Claim
`Claim 22
`The process of
`claim 1, wherein
`said Media
`Switch allows the
`CPU to queue up
`Direct Memory
`Access (DMA)
`transfers
`
`Samsung DVRs1
`
`In addition to the features described above regarding claim 1, Samsung DVRs include a Media Switch allows the CPU to queue
`up Direct Memory Access (DMA) transfers.
`
`For example, a Samsung DVR includes a processor that includes, for example, a MIPS CPU and a DMA controller that may
`queue up transfers to various busses, memory locations, and/or host controllers. See, e.g. BRCM function description at figure 1-
`1:
`
`Claim 23
`The process of
`
`5463861
`
`In addition to the features described above regarding claim 1, Samsung DVRs include a media switch that is implemented in
`EXHIBIT A TO TIVO INFRINGEMENT CONTENTIONS
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`
`37
`
`

`
`the Claim
`claim 1, wherein
`said Media
`Switch is
`implemented in
`hardware.
`
`hardware.
`
`Samsung DVRs1
`
`For example, a Samsung DVR includes a processor, such as a BRCM7405 that may be implemented as a "system on chip" or
`physical hardware instantiation. See, e.g., Function description at 1-4:
`
`Claim 31
`31[a]. A process
`for the
`simultaneous
`storage and play
`back of
`multimedia data,
`comprising the
`steps of:
`
`5463861
`
`A Samsung DVR can simultaneously store and play back multimedia data. See, e.g.,
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), p. 2 ("Viewing one program while recording another program.” “Simultaneous Time
`Shifted Buffering for two Programs."); p. 9 (“Record two live TV programs simultaneously while watching two recorded
`programs on HDD.”)
`
`“TIME WARNER CABLE AND SAMSUNG FORGE AGREEMENT FOR TRU2WAY SET-TOP DEVELOPMENT,
`PURCHASE & DEPLOYMENT
`Release Date: 07/06/2009
`
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`

`
`the Claim
`
`Samsung DVRs1
`
`Time Warner Cable and Samsung today announced that they have signed a letter of commitment for the continued development,
`purchase and deployment of Samsung True2Way enabled set-top boxes, including the first second-source DVR.
`“We look to offer our customers advanced set-top boxes with features that are simple and easy to use,” said Mike Hayashi,
`Executive Vice President of Advanced Engineering for Time Warner Cable. “We have been a leader in the roll-out of Tru2Way
`devices and we are continuing to grow our relationship with Samsung, a CE company dedicated to the development of new
`equipment meeting the necessary standards and offering attractive feature sets.”
`Thomas Rhee, SVP, New Business Development for Samsung, added, “We are thrilled to have worked closely with Time
`Warner Cable to launch Tru2way on our family of cable set-tops including the SMT-H3090 and SMT-H3270 High Definition
`DVRs. As in Korea, we look forward to the expansion of Tru2way in North America.”
`This agreement further solidifies Time Warner Cable’s commitment to its deployment of Tru2Way enabled set-top boxes. To
`date Time Warner Cable has deployed over 2 million Tru2Way set-top boxes, of which approximately 400,000 are Samsung
`boxes.
`Time Warner Cable and Samsung also recently signed an MOU that focuses on collaborating in development of better home
`networking solutions for entertainment. This work is part of Time Warner Cable’s continuing efforts to provide its customers
`with technology that brings new levels of ease and convenience.”
`http://www.timewarnercable.com/corporate/about/inthenews.ashx?PRID=2626&MarketID=0
`A Samsung DVR has an input device that may include cable input, tuners, an analog to digital converter, and/or, on information
`and belief, other components such as the Broadcom BCM3255 or other similar chip that may perform QAM demodulation,
`including chips made by other third parties. See, e.g., (Samsung SMT-H3090 2008 Data Sheet), p.1 (“Samsung SMT-H3090 is
`Dual tuner Digital Video Recorder(DVR) which provides Standard Definition (SD), High-Definition(HD) and Analog video
`signals. Dual tuner DVR allows cable subscribers to watch and record two HD programs Simultaneously.”"), p. 2 ("In-band
`Tuner : 54 to 864MHz, Receiving 64 or 256 QAM."));
`
`http://www.timewarnercable.com/MediaLibrary/1/1/FAQ/Digital%20Cable/Samsung/Samsung_SMT_3090HD_UserGuide.pdf
`(Samsung SMT-H3090 2008 User Guide), p. 2 ("RF Input Tuning Range: 88 to 860 MHz."); (BCM7400

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