Introduction and Summary of Opinions
`
`Summary of My Background
`
`DECLARATION OF TRAVIS N. BLALOCK, PH.D.
`
`REGARDING VALIDITY OF U.S. PATENT NO. RE39,470
`1.
`I, Travis N. Blalock, have been retained as a technical expert by Barco,
`Inc. (“Barco”) to provide my opinions and analysis in the above-captioned Inter Partes
`review. 2.
`This report sets forth my opinions regarding the validity of U.S. Patents
`No. RE39,470 titled “Digital Information System” (“the '470 patent”). If asked to do so,
`I anticipate testifying at a hearing based on the opinions expressed in this report.
`3.
`As explained more fully below, it is my opinion that claims 25-26 of the
`‘470 patent are invalid over prior art, specifically Japanese Patent Application Heisei
`07-168544 (“Nakamura”), and U.S. Patent No. 5,566,353 to Cho et al. (“Cho”).
`4.
`The information and opinions in this report are based on materials I
`have been provided by Barco’s counsel, including claim construction materials, the
`prosecution file histories, the patents and other references cited in the file history,
`and various additional patents, articles, texts, and other documentation that pre-date
`the filing of the patent, as well as my personal knowledge and experience. Where
`appropriate, I have included citations that are illustrative of the points expressed,
`which may also be supported by numerous other references.
`5.
`I am currently an Associate Professor of Electrical Engineering in the
`School of Engineering and Applied Sciences at the University of Virginia and have
`been since 1998. I earned my Bachelor of Science and Master of Science in Electrical
`Engineering from the University of Tennessee in 1985 and 1988, respectively. I
`earned my Ph.D. in Electrical Engineering from Auburn University in 1991, and the
`primary emphasis of my doctoral research was CMOS analog and digital integrated
`Petitioner Barco’s Exhibit 1002, page 1 of 29
`
` I.
`
`II.
`
`
`
`

`

`circuit design. I was full-time at the University from 1998 till 2013 when I reduced
`my time at the University to start an entrepreneurial enterprise. I still teach and
`work with students at the University. A copy of my CV is also attached as Ex. 1007.
`6.
`I cofounded and built a medical device company that was acquired by
`Analogic, Inc. in 2013. The company was created to develop and market a handheld
`ultrasound imaging device. Key technical contributions included fully custom mixed-
`signal front-end acquisition circuits, high speed data communications, image
`processing, and custom image display algorithms. I have been leading the handheld
`R&D group for Analogic since acquisition.
`7.
`In the early 1980’s I worked as a young engineer at Technology for
`Energy Corp. on a nuclear data acquisition and display system. The system had an
`overall basic architecture similar to that presented in the ‘470, ‘334, and ‘603 patents.
`The central control processor acquired image data from sub-systems all over the
`reactor, assembled and linked the data with additional graphics, and then sent the
`various images over communication networks for presentation at remote displays
`scattered all over the reactor and offsite. Users at each display site could dynamically
`choose and/or modify the display schedules as needed.
`8.
`From 1991 through August 1998, I worked at Hewlett Packard
`Laboratories, first as a Member of the Technical Staff, and then as a Principal Scientist.
`My work at Hewlett Packard Laboratories primarily
`involved design and
`implementation of digital and analog integrated circuits. I was the principal architect
`and designer of integrated circuits having a diverse range of applications, including
`CMOS analog signal processing integrated circuits for mass storage devices and
`optoelectronic image acquisition and processing integrated circuits. I also developed
`several custom design and high speed network management software tools.
`9.
`I have written widely in the field of electrical engineering, including
`several editions of a book that is used to teach principles of microelectronic circuit
`Petitioner Barco’s Exhibit 1002, page 2 of 29
`
`
`
`

`

`design to undergraduates. I have written over 43 papers, 10 of which have appeared
`in refereed journals.
`10.
`I have contributed to or consulted on the design, fabrication, and/or
`operation of integrated circuits, including microelectronic integrated circuits, for
`organizations such as Hewlett-Packard, NASA Langley Research Center, Agilent
`Technologies and Displaytech.
`11.
`I am a named inventor on at least sixteen U.S. patents and several
`pending patent applications. Several of these patent and patent applications relate to
`analog circuitry or semiconductor design.
`12.
`I have been retained as an expert witness or technical consultant for the
`following companies: Micron Technology, Inc., Samsung, Inc., Agere, Inc., Agilent
`Technologies, Inc., Intel Inc., Cisco Systems, Inc., Sigmatel, Inc., Sound Design
`Technologies, Displaytech, Inc., AMI Semiconductor, ON Semiconductor, Apple, Inc.,
`and Analog Devices, Inc.
`13. My compensation for this matter is at a rate of $325 per hour with
`reimbursement for actual expenses. My compensation in this matter is not affected by
`the conclusions I reach in conducting my analysis. No part of my compensation
`depends upon the outcome of this matter.
`14.
`U.S. Pat. No. RE39,470 titled “Digital Information System” was filed on
`Mar. 30, 2001 and issued on Jan. 16, 2007. The ‘470 patent is a reissue of U.S. Pat. No.
`6,005,534 which was filed on Jul. 2, 1996 and issued on Dec. 21, 1999. Priority is
`claimed to Swedish patent application no. 9601603-5 dated Apr. 26, 1996 and U.S.
`application No. 60/017,403, filed on May 14, 1996.
`The ‘470 patent describes a digital information system for displaying
`15.
`information on displays located remotely with respect to a central control system.
`Petitioner Barco’s Exhibit 1002, page 3 of 29
`
`Background and Field of the Patents
`
`A.
`
`The ‘470 Patent Overview
`
`III.
`
`
`
`

`

` A computerized control center, a
`The system contains four primary parts:
`communication interface, remote station(s) with display devices, and information
`mediators. Ex. 1001, 4:42-51. The computerized control center combines data with
`requests from subscribers (information mediators) to create display control
`instructions which are sent to the remote stations and displayed according to the
`control instructions. Ex. 1001, 4:57-66, 5:1-8. The information mediators send info
`via e-mail to the control center containing display requests along with relevant
`display materials and information. Ex. Ex. 1001, 7:61-65.
`16.
`The information mediators can act in one of two ways. First, they can
`create and deliver picture sequences or films that can be introduced directly into the
`exposure list using special versions of the software used to create and modify
`exposure lists. Ex. 1001, 8:4-9. Second, they can submit picture material that is
`submitted to the control center for processing by personnel to generate the updated
`exposure lists. Ex. 1001, 8:10-26.
`17.
` The ‘470 patent identifies several shortcomings with conventional
`forms of distributed advertising at the time of the patent, noting that “[s]ystems that
`are used to show information in the form of advertisements, timetable messages or
`arrival and departure times in present-day public service infrastructures with regard
`to buses, trains, subway traffic, etc., are of a static nature. Such information is given
`on notice boards, posters, charts, tables, verbally through loudspeakers, and on digital
`displays, etc. A characteristic feature of such information media is that the
`information media is not coordinated, but is in the form of individual items which are
`controlled and updated separately, often manually.” Ex. 1001, 1:27-36.
`18.
`In addition, the ‘470 patent also asserts that it is different with respect
`to conventional display systems since in conventional systems, “[t]he display must be
`planned carefully beforehand, this planning often being carried out by experts within
`the technical field in question, so as to obtain a finished display product. For instance,
`when a company wishes to change its display and introduce a new picture series
`Petitioner Barco’s Exhibit 1002, page 4 of 29
`
`
`
`

`

`combined with sound, the process again becomes static by virtue of the need to
`employ experts to program and arrange the new display.” Ex. 1001, 2:7-14.
`19.
`The ‘470 patent identifies a need to allow for updates to occur
`“dynamically” and to grant third parties the ability to update information for display
`in a central control system without additional assistance: “Thus, present-day systems
`do not enable information to be updated dynamically for display in real time. Neither
`do present-day systems enable external mediators to update information for display
`in a central control system, nor yet the administrator who makes the display of
`information available, but it is the administrator who determines when, where and
`how the information shall be displayed." Ex. 1001, 1:54-60.
`20.
`The ‘470 patent states that one object of the invention is to “provide a
`flexible system in which external information mediators are able to dynamically
`control in real time the transmission of display instructions to a larger public in
`different places situated at any chosen distance apart through projectors which
`project information onto displays intended therefor.” Ex. 1001, 1:54-60.
`21.
`The only figure in the ‘470 patent specification is shown below:
`
`
`
`Petitioner Barco’s Exhibit 1002, page 5 of 29
`
`

`

`
`22.
`A system 10 includes a control centre 12 having a communication
`interface 14 which connects computerized devices 16, 18, 20 which are placed at
`desired distances from one another for the control of projectors 22 whose projector
`images or pictures are displayed in public places. Ex. 1001, 4:32-48. The projector 22
`can be “replaced with an electronic display (not shown), such as a large picture screen
`in LCD technology, light-emitting diode technology (LED technology) or the like.” Ex.
`1001, 6:25-29.
`23.
`The “control centre 12” includes working stations 32, which are used by
`personnel serving the control centre 12, in monitoring, checking, maintaining and
`updating functions in the central computer with its databases. Ex. 1001, 4:60-66. In
`addition, “external information mediators 24 are able to give control instructions to
`the projectors 22 with regard to the information that the external mediators 24 desire
`the system 10 to display via the projectors 22, each on its own initiative and
`communication-wise transparent via modems 26.” Ex. 1001, 5:8-13.
`Petitioner Barco’s Exhibit 1002, page 6 of 29
`
`
`
`

`

`The ‘470 patent explains that the “term information mediator (24) used
`24.
`in the following shall be interpreted in its widest meaning, i.e. as not only referring to
`advertising agencies but to all companies and private persons who wish to utilize the
`system 10 for commercial reasons or for the display of information that concerns a
`general public.” Ex. 1001, 5:18-23. The ‘470 patent further discloses that the external
`information mediators connect with the control centre 12 using “specially designed
`interfaces” for “data and telecommunication,” which may include code keys or other
`codes sent between the control centre 12 and the computer 24 of the external
`mediator, to avoid “unauthorized access to the display of such information and misuse
`of the system.” Ex. 1001, 5:36-54, 7:65-8:3. The external information mediators send
`information material to the control centre 12 by email. Ex. 1001, 7:61-64, 8:41-42.
`25.
`The control centre 12 includes a central computer 28 that is divided
`into three servers 1, 2, 3. Ex. 1001, 6:65-66. Server 1 receives material from external
`information mediators 24 via modems 26, server 2 sends information material to the
`station computers 34 that control the projectors 22, and the server 3 processes
`information and control instructions received from the information mediator 24. Ex.
`1001, 6:66-7:9, 10:51-64.
`26.
`In particular, “the exposure material or picture material (and other
`information), the exposure list, etc., are prepared in the exposure handler which is
`included in the server 3...” Ex. 1001, 10:61-64. The exposure handler 3 “carries out
`the important object of the invention with regard to the possibility of an external
`mediator 24 to organize the information delivered to the station 16, 18, 20 via an
`exposure list, this organizing of information being effected in real time via the modem
`26 and the server 1 that receives projector control information from the external
`mediator.” Ex. 1001, 7:10-17.
`27.
`According to the ‘470 patent, for “external information mediators 24 to
`be able to deliver complete pictures/films, the mediator will preferably have its own
`versions of the software that the exposure handler 3 uses for enabling pictures/films
`to be introduced transparently into the exposure list without processing via the
`Petitioner Barco’s Exhibit 1002, page 7 of 29
`
`
`
`

`

`working stations 32 in the control centre 12.” Ex. 1001, 8:4-9, 8:27-34, 11:23-28. One
`of ordinary skill in the art would take this to indicate that “its own version” means
`that the software is functionally equivalent to the central computer exposure handler
`software. 28.
`This would seem to imply that information mediator can always inject
`picture sequences/films when desired, but as disclosed in the ‘470 patent, a
`“mediator” cannot always immediately update the exposure list. Instead, the exposure
`handler (or the equivalent software used by the mediator) “collects and processes, i. e.
`allocates, information relating to projector control instructions” Ex. 1001, 7:26-28.
`The patent also states that “when available space is found in the exposure list or in
`alternative places in the exposure list,” information from a mediator will be “sorted
`into the exposure list in accordance with the wishes of the mediator.” Id., 7:26-32.
`Also, “if the exposure list is completely filled with instructions, the mediator
`instructions to the control centre remain in the queue list . . . in readiness for later
`inclusion in the exposure list.” Ex. 1001, 7:32-35. These conflicts will therefore be
`resolved by the exposure handler or an administrator in the control centre.
`29.
`Since the mediator version of the exposure handler software is
`equivalent to its counterpart in the control center, it is also bound by constraints such
`as “space available” limitations to directly making changes to the exposure list.
`30.
`Note also that the mediator does not have direct access to the
`projectors and therefore the exposure list. “Without the administrator needing to
`supply through the working stations 32 further information or authority permitting
`access of the external information mediators 24 to the central computer for
`transmitting system transparent control instructions to the projectors 22.” Even
`though the mediator is able to more directly impact the exposure list, communication
`is still from mediator to the central computer, not the station computers or the
`projectors and therefore the central computer still maintains final control over the
`projectors and the exposure list.
`Petitioner Barco’s Exhibit 1002, page 8 of 29
`
`
`
`

`

`The ‘470 patent defines this as “dynamic updating of the exposure list.”
`31.
`Ex. 1001, 8:4-12. In an alternative, external information mediators 24 which do not
`have access to software in the exposure handler can have their picture material or
`exposure material processed and added to an exposure list by personnel serving the
`working stations 32. Ex. 1001, 8:9-26, 8:35-42, 11:19-23.
`32.
`Based on these passages, it is clear to a person of ordinary skill in the
`art that “dynamic updating” does not indicate that the mediator can force immediate
`updating of the display. Instead, it indicates that after an “information mediator”
`provides the properly formatted display information, the exposure list is updated if
`and only if available space is found in the exposure list. Otherwise, the new display
`instructions are placed in some other available slot in the exposure list or queued for
`later addition to the exposure list.
`33.
`In addition to limiting “dynamic updating” when previously committed
`exposure lists are full, the ‘470 patent further discloses that control routines are used
`to screen content provided by eternal information mediators: “The control centre 12
`is also able to refrain from displaying information which conflicts with ‘good order’ or
`accepted morale and of a disturbing nature to the large majority of the public,
`possibly through the medium of working stations 32 and via control routines.” Ex.
`1001, 9:36-40.
`34.
`It should also be clear that information mediators cannot directly
`control the station computers and therefore the remote displays. “The station
`computer 34 then provides each projector computer 38 with the material to be
`exposed. Thus, one and the same information material can be shown on all screens,
`or certain screens can be chosen for specific information display. This facility is
`controlled via the exposure list or, when the need is acute, directly from the control
`centre 12.” Ex. 1001, 9:61-67.
`
`
`
`Petitioner Barco’s Exhibit 1002, page 9 of 29
`
`

`

`B.
`
`‘470 Patent Claim Constructions
`
`“External Information Mediator” (Independent Claims 25 and 26)
`
`Independent claims 25 and 26 both recite “at least one external
`35.
`information mediator.” The specification of the ’470 patent states that “[t]he term
`information mediator (24) used in the following shall be interpreted in its widest
`meaning, i.e. as not only referring to advertising agencies but to all companies and
`private persons who wish to utilize the system 10 for commercial reasons or for the
`display of information that concerns a general public.” Ex. 1001 5:18-23.
`36. With respect to “external,” the ’470 patent distinguishes between
`personnel located in a control center of the disclosed system who use working
`stations located in the control center of the system and “external” information
`mediators connected to the control center via modems. Ex. 1001 5:6-17; 5:36-54; and
`8:4-54. 37.
`Consistent with the intrinsic record of the ’470 patent, a person of
`ordinary skill in the art would understand the term “external information mediator”
`to mean “any companies or private persons who are external to the control center.”
`38.
`Claim 25 recites “permitting said exposure list to be dynamically
`updated.” The ‘470 patent explicitly refers to “dynamic updating of the exposure list”
`as occurring when an information mediator has “its own versions of the software that
`the exposure handler 3 uses for enabling pictures/films to be
`introduced
`transparently into the exposure list without processing via the working stations 32 in
`the control centre 12.” Ex. 1001 8:4-9, 8:27-34, 11:23-28. According to the ‘470
`patent, this type of updating is different from updating in which external information
`mediators 24 do not have access to software used in the exposure handler, and
`therefore need their picture material or exposure material processed and added to an
`Petitioner Barco’s Exhibit 1002, page 10 of 29
`
` “Permitting said Exposure List to be Dynamically Updated” (Independent
`Claim 25)
`
`
`
`

`

`exposure list by personnel serving the working stations 32. Ex. 1001 8:9-26, 8:35-42,
`11:19-23. 39. With respect to the “dynamic updating of the exposure list,” the ‘470
`patent further states that “an external information mediator 24 is able to put through
`information to the system 12 twenty-four hours a day, whereupon the information
`can be included instantaneously in an exposure list,” “the digital information system is
`able to insert a change at short notice,” and that the system is “highly flexible and
`enables quick changes to be made with regard to what shall be exposed on the
`exposure means, where it shall be exposed and when.” Ex. 1001 5:31–35, 9:23-28.
`40.
`Regardless of whether an information mediator engages in “dynamic
`updating” by creating content with their “own versions of the software that the
`exposure handler 3 uses,” whether this “completed” or “finished” content is added to
`the exposure list depends on whether or not the exposure list is already full.
`According to the ‘470 patent and the understanding of a person of ordinary skill in the
`art, whether or not control instructions created by an information mediator is
`included in an exposure list is determined by the status of the exposure list. Ex. 1001
`7:25-35. If the exposure list is already full, new instructions from mediators will not
`be placed in the exposure list right away, but will instead “remain in the queue list . . .
`in readiness for later inclusion in the exposure list.” Id.
`41.
`These passages indicate that “dynamic updating” in the context of the
`‘470 patent does not necessarily result in automatic inclusion in the exposure list –
`only the possibility of automatic inclusion if there happens to be space available.
`42.
`As such, “dynamic updating” as used in the ‘470 patent relates to how
`an external mediator creates the content and the resulting possibility of inclusion in
`an exposure list without further processing, but does not encompass automatically
`updating the exposure list with the content in all cases. “Dynamic updating” as used
`in the ‘470 patent deals with how an external mediator creates the content and the
`resulting possibility of inclusion in an exposure list without further processing, but
`Petitioner Barco’s Exhibit 1002, page 11 of 29
`
`
`
`

`

`does not encompass automatically updating the exposure list according to the
`mediator’s wishes in all cases.
`43.
`The “dynamic” updating disclosed in the ‘470 patent permits delivery of
`updates to the exposure list from external information mediators to occur “when and
`as needed.” The so-called “dynamic” updating of the ‘470 patent permits delivery of
`updates to the exposure list from external information mediators to occur “when and
`as needed,” with an important exception. The updating is constrained by limitations
`discussed earlier, space availability in the exposure list, Ex. 1001, 7:26-36, and public
`appropriateness of the content. Ex. 1001, 9:36-40. This is consistent with the
`Microsoft Computer Dictionary definition of “dynamic” as “…some action or event that
`occurs when and as needed.” Microsoft Computer Dictionary Fourth Edition, 158,
`(1999) (Ex. 1005).
`44.
`Given the constraints discussed in the ‘470 patent, a person of ordinary
`skill in the art would understand that “permitting said exposure list to be dynamically
`updated” means “permitting said updates to said exposure list to be updated when
`and as needed,” but not to mean automatically updating the exposure list with the
`content or instructions received from the information mediator in all cases. This is
`consistent with most practical systems that are described by typical responses, but
`are limited or modified by particular constraints appropriate to the system.
`45. With respect to “generating an exposure list from said control
`instructions,” the ‘470 patent states “[s]erver 3 functions to process information and
`control instructions received from the information mediator 24” and further explains
`that “a queue, or line, is created from the information material received by the server
`1, in accordance with some known line or queuing method, such as FIFO (First In First
`Out), LIFO (Last In First Out) or Round Robin, etc., wherein the server 3 or exposure
`handler 3 has set-up or created an exposure list which covers a twenty-four hour
`period for information exposure or display via projectors 22.” Ex, 1001, 7:7-10, 7:18-
`Petitioner Barco’s Exhibit 1002, page 12 of 29
`
`“Means for Generating and Dynamically Updating an Exposure List From Said
`Control Instructions” (Independent Claim 26)
`
`
`
`

`

` “Means for Displaying Images” (Independent Claim 26)
`
`25. Accordingly, the corresponding structure for the function of “generating an
`exposure list from the control instructions” is a special purpose server computer
`programmed to create an exposure list from control instructions, in which the
`exposure list covers a set time period for information exposure or display.
`46.
`A person of ordinary skill in the art would understand “means for
`generating and dynamically updating an exposure list” to mean a special purpose
`server computer programmed to (1) create an exposure list from control instructions,
`in which the exposure list covers a set time period for information exposure or
`display and (2) collect, create or allocate information relating to display control
`instructions and then sort or file the display control instructions in the exposure list
`when and as needed, and equivalents thereof, but is not interpreted to encompass
`automatically updating the exposure list with the content received from the
`information mediator in all cases, as discussed above.
`47.
`Claim 26 recites “means for displaying images in accordance with said
`exposure list associated with each one of said computerized devices.” Ex. 1001
`18:24–26. This is a means-plus-function limitation that is construed under 35 U.S.C. §
`112 ¶ 6. 48.
`The function of the “means for displaying images in accordance with
`said exposure list associated with each one of said computerized devices” is
`“displaying images in accordance with the exposure list associated with each one of
`the computerized devices.” The specification of the ‘470 patent clearly associates two
`alternative structures with performing this function: (1) projectors 22, depicted in the
`Figure, or (2) “an electronic display (not shown), such as a large picture screen in LCD
`technology, light-emitting diode technology (LED technology) or the like.” Ex. 1001
`6:1-41 and 9:44-67. Thus, the corresponding structure in the ‘470 patent for
`performing the function of “displaying images in accordance with the exposure list
`associated with each one of the computerized devices” is either a projector or an
`Petitioner Barco’s Exhibit 1002, page 13 of 29
`
`
`
`

`

`C.
`
`LEVEL OF ORDINARY SKILL IN THE ART
`
`electronic display, such as a large picture screen in LCD technology, LED technology
`or the like. 49.
`In my opinion, a person of ordinary skill in the art would understand
`the “means for displaying images” to cover a projector, an electronic display, such as a
`large picture screen in LCD technology, LED technology or the like, and equivalents
`thereof.
`50.
`A person of ordinary skill in the art at the time of the inventions 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. A
`person having this background would understand how to design and build the
`systems for remotely controlling displays in a networked environment, including
`those claimed in the patents discussed in this declaration.
`51. My opinions are given from the perspective of a person of ordinary skill
`in the art at the time of filing of the patents challenged by Barco: April or May, 1996
`for the ‘470 and ‘334 patents, and April 1999 for the ‘603 patent, the earliest filing
`dates for which priority is claimed, even if my opinion is expressed in the present
`tense. As of April, 1996, I satisfied the standard of a person of ordinary skill in the art
`described above.
`52.
`Nakamura discloses an advertising display control system that has the
`same structure as the digital information system disclosed in the challenged patents.
`Like the ‘470 patent, Nakamura discloses a computerized control center (a “master
`station”), communication capability (“can receive and transmit data
`in the
`communication range”), remote station(s) with display devices (“display of the
`transmitted contents 8 in the posting reservation time frame T at the slave stations”),
`Petitioner Barco’s Exhibit 1002, page 14 of 29
`
`Overview of the Prior Art
`
`A.
`
`Nakamura
`
`IV.
`
`
`
`

`

`and information mediators (“registered users” at “terminals”). Ex. 1003[Abstract];
`Figs. 1(A)-1(D), ¶¶ [0009], [0012]. The display devices of Nakamura each have
`associated computer devices along with data storage. Each such location is referred
`to in Nakamura as a “slave station.” Ex. 1003, [Abstract].
`53.
`Also like the asserted patents, Nakamura discloses that any authorized
`company or person can send control instructions for the display devices to the
`computerized control. Ex. 1003, ¶¶ [0015], [0016], and [0018]. As with the “dynamic
`updating” aspect of the ‘470 patent, Nakamura discloses providing users (information
`mediators) with access to the software used to prepare display content and “posting
`software” so that they can deliver finished picture sequences/films to the
`computerized control center which do not require additional processing via work
`stations in the control center (master station) in order to be transparently inserted
`into an exposure list. Ex. 1003, ¶¶ [0015], [0016], and [0018]. From the Nakamura
`abstract, “[d]isplay contents are prepared using display content preparation support
`software operated within the system, and display conditions, such as location and
`time, are set using posting support software operated within the system.” Ex. 1003,
`[Abstract]. 54.
`The Nakamura patent actually describes a system with more flexibility
`than the ‘470 patent. “The system 10 displays the surrounding or adjacent
`reservation situation based on the content records which had been previously
`reserved, including the posting time before and after the reserved posting is to take
`place, for example, whether or not someone else in the same industry had made a
`reservation, and asks for reconfirmation of the display reservation under the
`surrounding conditions.” Ex. 1003, ¶ [0022]. Users can review display schedules
`from other users before confirming their own reservation.
`55.
`Once a display reservation is confirmed by the user, it is “automatically
`stored in the system 10 when listed in the reservation record. All display reservation
`steps relative to the specific slave stations 1 are completed when the data is stored in
`the system.” Ex. 1003, ¶ [0024]. Users are allowed to make complete reservations on
`Petitioner Barco’s Exhibit 1002, page 15 of 29
`
`
`
`

`

`the control centre (master station) without additional processing. Ex. 1003, ¶¶
`[0022]-[0024].
`56.
`Nakamura discloses that external users can create content and also
`schedule when and where that content will be played, without help or input from
`anyone else. Ex. 1003, ¶¶ [0009], [0015],[0016],and [0018]. Ex. 1003, ¶ 0009
`discloses “display content posting support software, which assists the selection of a
`single or plural slave stations to be reserved for display . . . setting the display
`duration t and posting reservation time frame, and display related procedural
`processing, including editing of multiple display reservations.”
`57.
`Nakamura describes the steps of operating the system in [0018] and
`summarizes as :“In other words, he selects and reserves a display location, date, time,
`and time period using the processing P in accordance with his budget. The reserved
`display contents are stored by the system 10, including the master station 2, and the
`system 10 executes the display after allocating the posting time and performing a
`prescribed editing so as not to compromise public order and standards of decency.”
`Ex. 1003, ¶ [0018]. The user selects and reserves a display location, date, time, and
`time period in accordance with his budget and the content is checked/edited for
`decency by the system.
`58.
`Nakamura also describes the automatic checking of the content after
`the reservation is made to adhere to decency standards. Recall the ‘470 patent
`described a similar process: “[t]he control centre 12 is also able to refrain from
`displaying information which conflicts with ‘good order’ or accepted morale and of a
`disturbing nature to the large majority of the public, possibly through the medium of
`working stations 32 and via control routines.” Ex. 1001, 9:36-40. Nakamura similarly
`describes: “[t]he reserve