UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________________
`
`
`
`
`
`Broadsign International, LLC,
`
`Petitioner
`
`v.
`
`T-Rex Property AB,
`
`Patent Owner
`
`________________________
`
`
`
`Case Number IPR2016-01869
`U.S. Patent Number RE39,470
`Issue Date: January 16, 2007
`
`
`
`__________________________________________________________________
`
`DECLARATION OF JAIME G. CARBONELL, PH.D.
`__________________________________________________________________
`
`IPR2016-01869 – Ex. 1006
`Broadsign International, LLC, Petitioner
`1
`
`

`
`
`
`Table of Contents
`
`Page No(s).
`
`
`I.
`
`Introduction and Qualifications ......................................................................... 4
`1. Summary of My Opinions .......................................................................... 4
`2. Qualifications and Experience .................................................................... 5
`II. Materials Considered ......................................................................................... 8
`III. Person of Ordinary Skill in the Art .................................................................... 9
`IV. Invalidity Analyses ..........................................................................................10
`A. Standards for Anticipation and Obviousness .................................................10
`B. Scope and Content of the Prior Art ................................................................12
`V. Claim Construction ..........................................................................................13
`A. Communications Drive Routine Means .........................................................14
`B. “means for generating and dynamically updating an exposure list”..............16
`C. “means for displaying images” ......................................................................16
`VI. Claims 1–26 Are Unpatentable ........................................................................17
`A. Brief Summary of the Challenged Patent.......................................................17
`1. Background of the ’470 Patent. ................................................................17
`2. Prosecution History of the ’470 Patent .....................................................18
`B. Brief Summary of the Prior Art .....................................................................19
`1. Brief Overview of Nakamura ...................................................................19
`2. Brief Overview of Loban ..........................................................................21
`3. Brief Overview of Misaki .........................................................................22
`4. Brief Overview of Reilly ..........................................................................22
`C. Claims 1-6, 8, 10-18, 20, 22-26 are unpatentable under 35 U.S.C. § 103(a) as
`obvious based on Nakamura in view of Loban. .............................................23
`1. Claim 1 ......................................................................................................23
`
`2
`
`

`
`2. Claim 2 ......................................................................................................40
`3. Claim 3 ......................................................................................................41
`4. Claim 5 ......................................................................................................42
`5. Claims 6 ....................................................................................................44
`6. Claim 7 ......................................................................................................45
`7. Claim 8 ......................................................................................................48
`8. Claim 9 ......................................................................................................49
`9. Claim 12 ....................................................................................................50
`10. Independent Claim 13 ...............................................................................51
`11. Dependent Claims 14, 17–21, and 24 .......................................................52
`D. Claims 7, 9, 19, and 21 are unpatentable under 35 U.S.C. § 103(a) as obvious
`based on Nakamura in view of Loban and further in view of Reilly. ............52
`1. Claims 19 and 21 ......................................................................................55
`E. Claims 25 and 26 are anticipated under 35 U.S.C. § 102(a) based on
`Nakamura. ......................................................................................................55
`F. Exemplary Claim Charts ................................................................................56
`
`
`
`
`
`3
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`

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`
`
`I, Jaime G. Carbonell, Ph.D., hereby declare and state as follows:
`
`I.
`
`Summary of My Opinions
`
`Introduction and Qualifications
`1.
`U.S. Patent Number RE39,470 (hereinafter ’470 patent), which is a
`
`1.
`
`Reissued Patent of U.S. Patent Number 6,005,534 (hereinafter ’534 patent)
`
`purports to describe a system for selectively displaying digital information at one
`
`or more of a plurality of locations. The ’470 patent contains Claims 1–3, 5–9, 12–
`
`14, 17–21, 24–26 (the challenged claims), each of which are addressed herein. As
`
`I explain below, the challenged claims do not recite any feature that would have
`
`been regarded as novel or nonobvious to a person of ordinary skill in the art.
`
`Around April of 1996, the alleged foreign priority date of the ’470 patent, display
`
`information systems described by the ’470 patent were well-known. One
`
`particular reference, Japanese Patent Application Heisei 07-168544 to Nakamura
`
`(hereinafter Nakamura) was filed on December 15, 1993 and published on July 4,
`
`1995, well before the ’470 patent. Nakamura discloses a display control system
`
`that allows registered users (e.g. advertisers) to input display information to
`
`selectively show an advertisement on one or more displays, also located remotely.
`
`Nakamura discloses or suggests all of the supposedly inventive features of the ’470
`
`patent. As I will explain below, all of the challenged claims would have been
`
`obvious based on the prior art.
`
`4
`
`

`
`
`
`2. Qualifications and Experience
`
`I received Bachelor of Science degrees in both Physics and
`
`2.
`
`Mathematics in 1975 from the Massachusetts Institute of Technology. I received
`
`M.S., M.Phil., and Ph.D. degrees in Computer Science from Yale University in
`
`1976, 1977, and 1979, respectively.
`
`3.
`
`
`
`I have held the position of Allen Newell Professor of Computer
`
`Science at Carnegie Mellon University from 1995 to the present. I currently also
`
`hold the title of Director of the Language Technologies Institute at Carnegie
`
`Mellon University. I first joined Carnegie Mellon as an Assistant Professor of
`
`Computer Science in 1979. In 1987, I was appointed as a Professor of Computer
`
`Science at Carnegie Mellon.
`
`4.
`
`
`
`Since 1979 I have taught a wide variety of graduate and
`
`undergraduate courses at Carnegie Mellon that fall within the general field of
`
`Computer Science, including courses in software engineering, data mining, natural
`
`language processing, electronic commerce, and artificial intelligence. I have been
`
`involved in a number of different professional organizations and activities,
`
`including memberships in the Association of Computing Machinery (“ACM”), the
`
`Association for the Advancement of Artificial Intelligence (“AAAI”), and the
`
`Cognitive Science Society. I have also held leadership positions within
`
`professional organizations. From 1983 to 1985, I served as Chair of the ACM’s
`
`5
`
`

`
`
`
`Special Interest Group on Artificial Intelligence (“SIGART”). From 1988 to the
`
`present, I have been a Fellow of the AAAI. From 1990 to 1992, I served on the
`
`AAAI executive committee. I have also served on a number of different
`
`government committees,
`
`including
`
`the Computer, Information Science &
`
`Engineering Advisory Committee of the National Science Foundation (2010 to
`
`2014); the Human Genome Scientific Advisory Committee to the National Institute
`
`of Health, also known colloquially as the “Watson Committee” (from 1988
`
`through 1992); and the Scientific Advisory Committee of the Information Access
`
`Division of the National Institute of Standards and Technology (from 1997 through
`
`2001).
`
`5.
`
`
`
`I am an author or co-author on more than 330 technical papers
`
`published as invited contributions and/or in peer-reviewed journals or conferences.
`
`These papers present the results of my research, which is generally directed at
`
`computer implemented algorithms and methods that relate to machine learning,
`
`including such applications as mapping protein sequences to three-dimensional
`
`shapes, predicting protein folds, detecting financial fraud, and also related to
`
`natural
`
`language processing
`
`including performing
`
`inter-lingual machine
`
`translation, parsing natural language (a.k.a. “content analysis”) and text mining . I
`
`have served as an editor and peer-reviewer for a number of different technical
`
`journals in my field, including the Machine Learning Journal (from 1984 through
`
`6
`
`

`
`
`
`2000), the Machine Translation Journal (the 1980’s), and the Artificial
`
`Intelligence Journal (1984 through 2008). I was also a co-Editor of the book series
`
`Lecture Notes in Artificial Intelligence, which was published by Springer from
`
`1996 through 2008.
`
`6.
`
`
`
`I received a “recognition of service” award from
`
`the
`
`Association for Computing Machinery for my role as chair of the ACM’s special
`
`interest group in Artificial Intelligence (SIGART) between 1983 and 1985. In
`
`1986, I received the Sperry Fellowship for excellence in artificial intelligence
`
`research. In 1987, I received the Carnegie Mellon University Computer Science
`
`Department’s teaching award.
`
`
`
`I have also worked as a technical consultant on Computer Science
`
`applications for a variety of industrial clients. This includes consulting on data
`
`mining applications for Industrial Scientific Corporation (data mining to improve
`
`workplace safety); Carnegie Group Inc. (artificial intelligence and natural language
`
`processing); Citicorp (financial data mining, natural
`
`language); Wisdom
`
`Technologies
`
`(financial optimization); Dynamix Technologies
`
`(large-scale
`
`algorithms with applications to Homeland Security), and Meaningful Machines in
`
`natural language processing and machine translation. I have experience in many
`
`aspects of computing technology, including electronic commerce, where I
`
`regularly teach two classes every year, in databases, in telecommunications
`
`7
`
`

`
`
`
`methods, in network-based systems, such as master-slave control devices, whether
`
`for displaying or capturing information, and in applications areas ranging from
`
`finance and advertisement models to display-based communications and customer-
`
`contact methods and algorithms.
`
`7.
`
`
`
`I am a named inventor on a number of issued U.S. Patents,
`
`including: U.S. Patent No. 5,677,835 (“Integrated authoring and translation
`
`system”); U.S. Patent No. 5,995,920 (“Computer-based method and system for
`
`monolingual document development”); U.S. Patent No. 6,139,201 (“Integrated
`
`authoring and translation system”); U.S. Patent No. 6,163,785 (“Integrated
`
`authoring and translation system”); and U.S. Patent No. 7,406,443 (“Method and
`
`system for multi-dimensional trading”).
`
`II. Materials Considered
`8.
`
`My analysis in this declaration is based on the following: (1)
`
`my education and experience in the field of display systems, computer systems and
`
`control instructions; (2) the ’470 patent and its prosecution history (respectively
`
`Ex. 1001, 1004); (3) the ’534 patent and its prosecution history (respectively (Ex.
`
`1003, 10005); and (4) documents that I have considered, including those listed in
`
`the chart below.
`
`Exhibit Number
`
`Description of the Exhibit
`
`1001
`
`U.S. Patent Number RE39,470
`
`8
`
`

`
`
`
`
`
`1002
`
`1003
`
`1004
`
`1005
`
`1007
`
`1008
`
`1009
`
`1010
`
`1011
`
`1012
`
`1013
`
`1014
`
`1015
`
`Complaint, Broadsign v. T-Rex Civil Action No. 1:16-
`cv-04586-LTS, Document 1
`
`U.S. Patent Number 6,005,534
`
`File History, U.S. Pat. App. 08/676,517
`
`File History, U.S. Pat. App. 09/821,969
`
`Japanese Patent Application Heisei 07-168544
`(“Nakamura”)
`
`U.S. Patent Number 5,612,741 to Loban
`
`U.S. Patent Number 5,005,010 to Misaki
`
`U.S. Patent Number 5,740,549 to Reilly
`
`In T-Rex Property AB v. Admirable, LLC, Complaint
`
`Rex Property AB v. CBS Corporation, Complaint
`
`T-Rex Property AB v. Prismview, LLC, Complaint
`
`T-Rex Property AB v. Barco, Inc., Complaint
`
`Excerpts from Macmillan Encyclopedia of Computers
`(Gary G. Bitter ed., Macmillan Publ. Co. 1992)
`
`9.
`
`
`
`I reviewed various prior art documents describing the state of
`
`the art at and around the time of the alleged invention of the ’470 patent. The prior
`
`art documents relied upon in the Petition are shown in the chart above.
`
`III. Person of Ordinary Skill in the Art
`10.
`
`I understand that my assessment of the ’470 patent claims
`
`should be viewed from the perspective of a person of ordinary skill in the art
`
`9
`
`

`
`
`
`(POSITA) as of the earliest claimed priority date, which I understand is around
`
`April 1996. I understand that a POSITA is a hypothetical person who is presumed
`
`to have known the relevant art at the time of the invention. I understand that the
`
`following factors may be considered in determining the level of ordinary skill in
`
`the art: (A) "type of problems encountered in the art;" (B) "prior art solutions to
`
`those problems;" (C) "rapidity with which
`
`innovations are made;" (D)
`
`"sophistication of the technology; and" (E) "educational level of active workers in
`
`the field. I also understand that there is no predominating factor.
`
`11.
`
`
`
`In my opinion concerning this matter, a person of ordinary skill
`
`in the art as of April 1996 would possess at least a bachelor’s degree in electrical
`
`engineering or computer science (or equivalent degree or experience) with
`
`practical experience or coursework in the design or development of systems for
`
`display control in a networked environment.
`
`12.
`
`
`
`I understand that my qualifications and experience exceed those
`
`of a POSITA. Nevertheless, my analysis and opinions about the ’470 patent are
`
`based on the perspective of POSITA as of April 1996.
`
`IV.
`
`Standards for Anticipation and Obviousness
`
`Invalidity Analyses
`A.
`13.
`
`
`
`In my opinion, the claims 1–3, 5–9, 12–14, 17–21, 24–26 of the
`
`’470 patent are all invalid as either anticipated by or obvious over the prior art.
`
`10
`
`

`
`
`
`14.
`
`
`
`Counsel has informed me about invalidity by anticipation. I
`
`understand that a patent claim is anticipated when a single piece of prior art
`
`describes every element of the claimed invention, either expressly or inherently,
`
`and arranged in the same way as in the claim. For inherent anticipation to be
`
`found, it is required that the missing descriptive material is necessarily present in
`
`the prior art. I understand that, for the purpose of an IPR, prior art that anticipates
`
`a claim can include both patents and printed publications from anywhere in the
`
`world.
`
`15.
`
`
`
`I understand that a patent claim is unpatentable and invalid if
`
`the subject matter of the claim as a whole would have been obvious to a POSITA
`
`of the claimed subject matter as of the time of the invention at issue. I understand
`
`that the following factors must be evaluated to determine whether the claimed
`
`subject matter is obvious: (1) the scope and content of the prior art; (2) the
`
`difference or differences, if any, between each claim of the patent and the prior art;
`
`and (3) the level of ordinary skill in the art at the time the patent was filed.
`
`16.
`
`
`
`I understand that obviousness may be shown by considering
`
`more than one item of prior art. I have been informed and I understand that so-
`
`called objective
`
`indicia of non-obviousness, also known as “secondary
`
`considerations,” like the following are also to be considered when assessing
`
`obviousness: (1) commercial success; (2) long felt but unresolved needs; (3)
`
`11
`
`

`
`
`
`copying of the invention by others in the field; (4) initial expressions of disbelief
`
`by experts in the field; (5) failure of others to solve the problem that the inventor
`
`solved; and (6) unexpected results. I also understand that evidence of objective
`
`indicia of non-obviousness must be commensurate in scope with the claimed
`
`subject matter.
`
`B.
`17.
`
`Scope and Content of the Prior Art
`
`
`
`The scope and content of the prior art as of April 1996 would
`
`have broadly included digital information systems for controlling output. In my
`
`opinion, one of ordinary skill in the art as of April 1996 would have considered
`
`Nakamura, Loban, and Reilly to be within the same technical field as the subject
`
`matter set forth in the ’470 patent. Further, all of these references would be
`
`considered highly relevant prior art to the claims of the ’470 patent.
`
`18.
`
`
`
`Regarding the ’470 patent’s background section, it is my
`
`opinion that the allegations regarding the prior art were not accurate. Rather, it is
`
`my opinion certain prior-art systems relied on, and remain in reliance on, system
`
`administrators to control the instructions and processes recited from content
`
`creation to display execution. However, it is also my opinion that some prior-art
`
`systems already allowed users, such as advertisers or businesses, to create and edit
`
`content and schedule content display on devices independent of system-
`
`administrator terminals. It is my opinion that the prior art universe included
`
`12
`
`

`
`
`
`remote booking and scheduling by users, remote editing and update of creative
`
`content and scheduling information, selecting one or more display devices for
`
`content display, coordination of content among the selected displays, and dynamic
`
`scheduling. It is my opinion that that the problems discussed in the ’470 patent’s
`
`background section had already been addressed and overcome by the prior art by
`
`April 1996. Consequentially, it is my opinion that the alleged inventions of the
`
`’470 patent were already available in the prior art and that claims 1-26 are invalid
`
`for at least the reasons I discuss herein.
`
`V. Claim Construction
`19.
`
`Counsel has informed me that invalidity involves a two-step
`
`analysis. First, the scope and meaning of a claim is determined by construing the
`
`terms of the claim. Second, the construed claim is compared to the prior art. To
`
`satisfy the first step, I provide claim constructions for certain claim terms.
`
`20.
`
`
`
`Counsel has informed me that unexpired patents and expired
`
`patents are construed according to different standards, though the outcome may be
`
`substantially similar. Counsel has informed me that unexpired patents receive the
`
`“broadest reasonable construction in light of the specification of the patent in
`
`which it appears.”
`
`21.
`
`
`
`Counsel has informed me that the ’470 patent has expired and
`
`that claims in expired patents are construed under the Phillips standard. According
`
`13
`
`

`
`
`
`to counsel, the words of the claim are generally given their ordinary and customary
`
`meaning, which is the meaning that the term would have to a POSITA at the time
`
`of the alleged invention. Counsel has informed me that to ascertain the meaning of
`
`a term, I should look to publicly-available sources that show what a POSITA
`
`would have understood the claimed term to mean, including: words of the claims
`
`themselves, the patent specification, the prosecution history, and extrinsic
`
`evidence.
`
`22.
`
`
`
`Counsel has informed me that a patentee may express a claim
`
`limitation as a “means-plus-function” limitation in which a means (or step) for
`
`performing a specified function is recited without the recital of structure, material,
`
`or acts in support. I understand that means-plus-function limitations are construed
`
`to cover the corresponding structure, material, or acts described in the specification
`
`and equivalents thereof. I understand that a claim limitation is presumed to be a
`
`means-plus-function limitation when it uses the term "means" or "step" and
`
`includes functional language. I understand that this presumption is overcome
`
`when the limitation itself further includes the structure necessary to perform the
`
`recited function.
`
`A. Communications Drive Routine Means
`23.
`
`The term “communications drive routine means” appears in
`
`method claim 1. I have been informed by counsel that when a method claim lacks
`
`14
`
`

`
`
`
`“step for” language, the method claim does not invoke 35 U.S.C. 112, sixth
`
`paragraph. I note that the specification states that “drive routine means” is an
`
`“interface” :
`
`Those external information mediators which connect to the control
`centre 12 via modems are, in one embodiment of the invention,
`connected to the control centre via specially designed interfaces (drive
`routine means) for data and telecommunication.
`
`24. Ex. 1001 at 5:36-40. The specification further states that the control
`
`centre 12 has “a communication interface 14 with the computerized devices 16, 18,
`
`20 situated on shifting positions or places for projector coordination and control.”
`
`Id. at 55-58. The specification gives an example of the interface as “a radio link
`
`which forms an interface between the control centre 12 and the computerized
`
`devices 16, 18, 20, this interface being a preferred interface, although not
`
`necessarily the sole possible interface.” Id. at 5:59-63. The specification describes
`
`“other interfaces” as “a cable-carried ISDN solution (Integrated Services Digital
`
`Network) or other fixed lines that have the same capacity.” Id. at 5:63-65.
`
`25.
`
`I am unaware of any other known meaning in the art for the term
`
`“communications drive
`
`routine means.”
`
` Accordingly,
`
`I agree
`
`that
`
`“communications drive routine means” should be construed as “communications
`
`interface.”
`
`15
`
`

`
`
`
`26.
`
`
`
`Claim 13 recites a “communications drive routine means to
`
`transmit said display information to said control center at any time.” Although this
`
`limitation uses the word “means,” I have been informed that I should construe it
`
`consistently with “drive routine means” as an “interface.”
`
`B.
`
`“means for generating and dynamically updating an exposure
`list”
`
`27.
`
`
`
`Claim 26 recites a “means for generating and dynamically
`
`updating an exposure list from said control instructions.” Because this limitation
`
`recites “means for” with an associated function, I have been informed that it
`
`invokes § 112 sixth paragraph. I have been further informed that, pursuant to §
`
`112 sixth paragraph, the limitation shall be construed to cover the corresponding
`
`structure described in the specification. I note that the specification describes an
`
`“exposure handler” as performing the function. Ex. 1001 at 11:18–29; Claim 1,
`
`Claim 13.
`
`C.
`28.
`
`“means for displaying images”
`
`
`
`Claim 26 recites a “means for displaying images in accordance
`
`with said exposure list associated with each one of said computerized devices.”
`
`Because this limitation recites “means for” with an associated function, I have been
`
`informed that it invokes § 112 sixth paragraph. I have been further informed that,
`
`pursuant to § 112 sixth paragraph, the limitation shall be construed to cover the
`
`corresponding structure described in the specification. The structure identified in
`
`16
`
`

`
`
`
`the specification as performing the function is a “display device.” Ex. 1001 at
`
`2:57–63; 4:32–42.
`
`VI. Claims 1–26 Are Unpatentable
`29.
`
` In my opinion, each of the ’470 patent claims are invalid for at
`
`least the reasons presented below.
`
`(1) Claims 1–3, 5–9, 12–14, 17–21, 24 are Unpatentable under 35 U.S.C. §
`
`103(a) as obvious based on Nakamura in view of Loban.
`
`(2) Claims 7, 9, 19, 21 are Unpatentable under 35 U.S.C. § 103(a) as obvious
`
`based on Nakamura in view of Loban and further in view of Reilly.
`
`(3) Claims 25-26 are Anticipated under 35 U.S.C. § 102(a) based on Nakamura.
`
`A. Brief Summary of the Challenged Patent
`1.
`Background of the ’470 Patent.
`
`
`30.
`
`The ’470 patent was filed as reissue application number
`
`09/821,969 (“the 969 application”) on March 30, 2001. Ex. 1001 at 1. The ’470
`
`patent is a reissue of U.S. Patent Number 6,005,534 (“the ’534 patent”) from
`
`application number 08/676,517 (the ’517 application), which was filed on July 2,
`
`1996, issued on December 21, 1999 and purported to claim the benefit of U.S.
`
`provisional application number 60/017,403 (filed May 14, 1996) and Swedish
`
`application number 9601603-5 (filed April 26, 1996).
`
`31.
`
`
`
`The ’470 patent relates to the abstract concept of displaying
`
`information, e.g. advertisements, on display devices in public places. Ex. 1001,
`
`17
`
`

`
`
`
`1:15–21. The ’470 patent alleges to overcome prior art systems by speeding up
`
`human-performed tasks via the use of conventional computers. For example, the
`
`prior art is replete with systems where administrators update display information
`
`and determine when, where, and how information is displayed. Id., 1:55–60.
`
`32.
`
`
`
`To address alleged problems in the art, the ’470 patent seeks to
`
`provide “external information mediators” with the capability to coordinate and
`
`control, dynamically and in real time, the display of information by allowing the
`
`mediators (e.g. advertisers) to transmit control instructions to the system. Id.,
`
`2:39–45. The arrangement claimed by the ’470 Patent includes a “control centre,”
`
`which receives
`
`instructions from a mediator via a modem, and which
`
`communicates these instructions to devices controlling projectors thus displaying
`
`the information. Id., 4:43–51.
`
`33.
`
`
`
`However, as described below, it is my opinion that the prior art
`
`teaches or discloses this exact “control centre” configuration and the claims must
`
`fall.
`
`2.
`
`
`34.
`
`Prosecution History of the ’470 Patent
`
`The ’517 application received a single non-final rejection,
`
`rejecting all claims as obvious in view of U.S. Patent Numbers 5,642,484 and
`
`5,448,263 (respectively, “Harrison” and “Martin”), neither of which are asserted in
`
`this Petition. .Ex. 1004 at 31.
`
`18
`
`

`
`
`
`35.
`
`
`
`On March 30, 2001, after the patent had issued, applicants filed
`
`a reissue application, citing unnecessarily restrictive claims and a defective
`
`specification. Ex. 1005 at 409. After amending the specification and claims during
`
`reissue prosecution, the claims were ultimately allowed based on the following
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`reason recited in the notice of allowance: “the features of claims 1 and 13 directed
`
`towards allowable subject matter are the receiving of control instructions from an
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`external mediator in combination with dynamically updating said specific exposure
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`list and providing a display by projector means” and “the feature of claims 25 and
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`26 directed towards allowable subject matter are the receiving of control
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`instructions from an external mediator in combination with dynamically updating
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`said specific exposure list having a specific content.” Ex. 1005 at 259. My opinion
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`is that both of these sets of features were known in the prior art, and the
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`combinations recited below teach or disclose each of the limitations of the
`
`challenged claims. Accordingly, it is my opinion that the claims are invalid.
`
`B.
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`36.
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`Brief Summary of the Prior Art
`1.
`
`
`Brief Overview of Nakamura
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`Nakamura discloses a display control system that allows
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`registered users (e.g. advertisers) to access a centralized computer to input
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`information from remote
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`locations and
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`to display
`
`that
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`information as
`
`19
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`

`
`
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`advertisements on one or more display devices, also located remotely. Ex. 1007 at
`
`0001, 0009. An exemplary system of Nakamura is depicted in Figure 1A:
`
`
`
`[Nakamura at Fig. 1A] The system comprises a master station (2), multiple slave
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`stations(1) with corresponding display devices(7), and multiple terminals(3) for
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`user input, creation software, posting software, and transmission/receptions means
`
`for communication among the aforementioned devices. Id. at 0013–0014.
`
`37.
`
`
`
`In operation, a registered user (e.g. mediator) accesses a
`
`terminal and inputs information to the content creation software and the posting
`
`software through the terminal. Id. at 0009, 0015. The creation software allows for
`
`uploading and processing media content assets so that the display content is
`
`displayable on a certain display device. Ex. 1007 at 0009, 0016 The posting
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`software allows a user to make a display reservation by specifying certain
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`parameters: the display content, the time, the location, the duration, the budget, and
`
`when and what manner to display the content. Id. at 0009, 0016.
`
`20
`
`

`
`
`
`38.
`
`
`
`The display time information or reservation information is
`
`registered and/or updated with the master station, i.e. the central computer or “the
`
`system,” on a successive, rolling basis as the reservations are completed by the
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`advertiser. Id. at 0017. To display the content, the master station transmits the
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`content to the slave station(s), where it is stored in temporary memory, for
`
`execution on the selected display device(s) in accordance with the specified
`
`parameters. Id. at 0024.
`
`
`
`2.
`
`
`39.
`
`Brief Overview of Loban
`
`Loban relates generally to display devices, particularly a video
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`billboard for outdoor use comprising one or more projectors. The billboard
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`displays messages, such as advertisements, in near real time from remote locations
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`in selected time slots. Ex. 1008 at 1:44–49. The billboard downloads message-
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`generating programs from a remote computer, which include information to
`
`determine when the message should be displayed, for how long, and other
`
`pertinent data. Ex. 1008 at 3:9–15.
`
`40.
`
`
`
`The video billboard comprises at least one projector in the form
`
`of a liquid crystal light valve (“LCLV”) projector. Ex. 1008 at 3:22–26. LCLV
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`projectors advantageously provide extremely high contrast ratio and brightness for
`
`outdoor use in sunlight. Id. The LCLV projector uses cathode ray tube (CRT)
`
`21
`
`

`
`
`
`technology according to well-known methods. Id. at 3:29–33. The billboard
`
`includes one or more lenses and a protective sheet or shield. Ex. 1008: 4:21–23.
`
`3.
`
`
`41.
`
`Brief Overview of Misaki
`Misaki discloses a head-up display having a projector being
`
`protected from dust and other small particles. The projector contains a light source,
`
`lens, a liquid crystal display and a lens cover. Ex. 1009 at 3:24–27. Regarding the
`
`lens cover, Misaki discloses that conventional head-up displays employ a
`
`transparent cover to protect a lens. Ex. 1009 at 1:45–50. An embodiment of
`
`Misaki’s display includes a reflection preventing means for the dual purpose of (a)
`
`protecting the lens from intensive light and (b) preventing dust and other small
`
`particulars from entering the projector. Ex. 1009 at 2:41–48. This reflection
`
`preventing means can shift between a covered and non-covered position. Ex. 1009
`
`at 2:31–38.
`
`4.
`
`
`42.
`
`Brief Overview of Reilly
`
`Reilly discloses an information and advertising distribution
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`system. Ex. 1010 at 2:62–63. An information server, i.e. a central computer, stores
`
`and updates a database of information items and advertisements. Ex. 1010 at 2:63–
`
`65. The information items and advertisements are each categorized so that each has
`
`an associated information category. Ex. 1010 at 2:65–66. The information database
`
`22
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`

`
`
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`also stores display scripts that control the information and advertisements
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`displayed. Ex. 1010 at 5:24–28.
`
`43. Remotely-located workstations
`
`include a display device, a
`
`communication interface for receiving information items and advertisements from
`
`the information server’s database, and local memory for storing the information
`
`items and advertisements. Ex. 1010 at 2:67–3:5. The workstation’s memory is used
`
`to store a local information database which includes information, advertisements,
`
`and display scripts, including at least a subset of the information located at the
`
`information server database. Ex. 1010 at 6:46–51. An update manager updates the
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`local information database and deletes items in the database. Ex. 1010 at 7:21–27.
`