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Multimedia Patent Trust v. Directv

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA


August 15, 2011

MULTIMEDIA PATENT TRUST,
PLAINTIFF,
v.
DIRECTV, INC., ET AL., DEFENDANTS.

The opinion of the court was delivered by: Marilyn L. Huff, District Judge United States District Court

TENTATIVE CLAIM CONSTRUCTION ORDER FOR UNITED STATES PATENT NUMBER 5,227,878, PATENT NUMBER 5,136,377, PATENT NUMBER 5,500,678, AND PATENT NUMBER 4,958,226

On August 2, 2011, Plaintiff Multimedia Patent Trust and Defendants DirecTV, Inc. and Vizio, Inc. submitted their opening claim construction briefs. (Doc. Nos. 414-16.) After due consideration of the parties' briefing, the Court issues the following tentative claim construction order.

Claim Construction -- Legal Standard

The "bedrock principle" of patent law is that the "claims of a patent define the invention." Phillips v. AWH Corp., 415 F.3d 1303, 1312 (Fed. Cir. 2005). In construing claim terms, a court must determine the meaning of any disputed words from the perspective of one of ordinary skill in the pertinent art at the time of filing. Phillips, 415 F.3d at 1313.

The baseline for the analysis in claim construction is the "ordinary and customary meaning" of the claim term. Phillips, 415 F.3d at 1312-13. However, the "ordinary and customary meaning" phrase itself has a specialized meaning in patent law. It is the meaning that the term would have to a person of ordinary skill in the art at the time of the invention. Id. at 1313. That person having ordinary skill in the art is deemed "to read the claim term not only in the context of the particular claim in which the disputed term appears, but in the context of the entire patent, including the specification." Id. If the meaning of a term is not readily apparent, the court must then look to other intrinsic evidence to define the term. See id. at 1314.

A court must read claims "in view of the specification, of which they are a part." Markman v. Westview Instruments, Inc., 52 F.3d 967, 979 (Fed. Cir. 1995). A court may also look beyond the patent and consult the prosecution history, if in evidence, during claim construction. Phillips, 415 F.3d at 1317. The patent and its prosecution history "usually provides the technological and temporal context to enable the court to ascertain the meaning of the claim to one of ordinary skill in the art at the time of the invention." V-Formation, Inc. v. Benetton Group SpA, 401 F.3d 1307, 1310 (Fed. Cir. 2005). In addition to intrinsic evidence, a court may also consider pertinent extrinsic evidence. Phillips, 415 F.3d at 1317.

The analysis for a means-plus-function claim term is governed by 35 U.S.C. § 112, ¶ 6:

An element in a claim for a combination may be expressed as a means or step for performing a specified function without the recital of structure, material, or acts in support thereof, and such claim shall be construed to cover the corresponding structure, material, or acts described in the specification and equivalents thereof.

For a means-plus-function term, the analysis consists of two distinct steps. JVW Enters., Inc. v. Interact Accessories, Inc., 424 F.3d 1324, 1330 (Fed. Cir. 2005). First, the Court must identify the function associated with the claim language. Id. Second, then the Court must identify the corresponding structure in the written description that performs the function. Id. A "structure disclosed in the specification is [a] 'corresponding' structure only if the specification or prosecution history clearly links or associates that structure to the function recited in the claim." B. Braun Medical, Inc. v. Abbott Labs., 124 F.3d 1419, 1424 (Fed. Cir. 1997). A proper construction should account for "all structures in the specification corresponding to the claimed function" and it would be error to limit the structure to be just the preferred embodiment. Callicrate v. Wadsworth Mfg., Inc., 427 F.3d 1361, 1369 (Fed. Cir. 2005). "The corresponding structure to a function set forth in a means-plus-function limitation must actually perform the recited function, not merely enable the pertinent structure to operate as intended." Asyst Technologies, Inc. v. Empak, Inc., 268 F.3d 1364, 1371 (Fed. Cir. 2001).

Means-plus-function terms are terms which are "purely functional limitations that do not provide the structure that performs the recited function" and should be construed as under

35 U.S.C. § 112, ¶ 6. Depuy Spine, Inc. v. Medtronic Sofamor Sanek, Inc., 469 F.3d 1005, 1023 (Fed. Cir. 2006). "Use of the term 'means' in a patent claim limitation creates a presumption that the statutory means-plus-function provision has been invoked, but that presumption may be rebutted if the properly construed claim limitation itself recites sufficiently definite structure to perform the claimed function." Kemco Sales, Inc. v. Control Papers Co., Inc., 208 F.3d 1352, 1361 (Fed. Cir. 2000).

The Court reviews each claim and considered each construction in light of the applicable standards of law. The Court construes the claim terms in dispute as indicated in the boxes in the charts below.

IT IS SO ORDERED.

Amended Claim Construction Chart -- U.S. Patent No. 4,958,226

United States District Court, Southern District of California

Case No. 09-cv-0278-H (CAB)

CLAIM AGREED PLAINTIFF'S DEFENDANTS' COURT'S LANGUAGE PROPOSED PRELIMINARY PRELIMINARY PREVIOUS (Disputed Terms in CONSTRUCTION CONSTRUCTION CONSTRUCTION CONSTRUCTION BOLD) consistent with claims consistent with claims 2, 4, 6, and 12 2, 4, 6, and 12frame: frame: is divided into a complete set of a complete picture digital representations from a video sequence for an image consistent with claims consistent with claims consistent with claims any path that can 2-8, 11 and 12 2-8, 11 and 12 2-8, 11 and 12 carry electrical current: circuit:

MPT is collaterally any path that can estopped from carry electrical current Plaintiff agrees with relitigating this term. this construction.

However, plaintiff any path that can disputes that it is carry electrical current collaterally estopped. successive frames: successive frames: successive frames: one frame following

MPT is collaterally another; consecutive one frame following one frame following estopped from frames another; consecutive another; consecutive relitigating this term. frames frames one frame following

However, plaintiff another; consecutive disputes that it is frames collaterally estopped. consistent with claims consistent with claims consistent with claims sets of pixels (picture 2, 5 and 12 2, 5 and 12 2, 5 and 12 elements also called pels) that constitute a blocks: blocks: blocks: portion of a frame

MPT is collaterally sets of pixels (picture sets of pixels (picture estopped from elements also called elements also called relitigating this term pels) that constitute a pels) that constitute a portion of a frame portion of a frame sets of pixels (picture elements also called However, plaintiff pels) that constitute a disputes that it is portion of a frame collaterally estopped.

Function: encoding Function: encoding the blocks of some the blocks of some of the blocks of some of of said frames by said said frames by developing for frames by developing developing for each each block of such for each block of such block of such frames frames (a) an (a) an approximated approximated version version of said block version of said of said block derived derived from an from an approximated approximated version version of said block of said block developed for a developed for a version of said previous frame, and previous frame, and block developed (b) a code which (b) a code which represents the represents the frame, and (b) a deviation of said deviation of said block from said block from said approximated version approximated version deviation of said of said block of said block block from said

Structure: shift circuit Structure: subtractor version of said 15, subtractor 20, 20, DCT 30, quantizer DCT 30, quantizer 40, 40, coder 50, inverse inverse DCT 41, and DCT 41, adder 42, adder 42 (as shown in frame memory 12, Figure 1 and motion estimator 11, described in col. 1:56- shift circuit 15 (as 58, col. 3:64-col. shown in Fig. 1 and as 4:32) described at col. 3, line 64 - col. 4, line 32) including frame Fi input to subtractor 20 and motion estimator 11, the prediction block of pels signal input to subtractor 20, the buffer feedback signal input to quantizer 40, the coded prediction error output by coder 50, and including all inputs, outputs, and interconnections between these elements consistent with claims consistent with claims consistent with claims differences 2 and 12 2 and 12 2 and 12

deviations: deviations: deviations:

MPT is collaterally differences differences estopped from relitigating this term. However, plaintiff disputes that it is differences collaterally estopped.

Function: Function: approximating approximating the approximating the the blocks of those blocks of those of said blocks of those of said frames that are to be frames that are to be interpolated by interpolated by interpolated by combining combining approximated versions approximated versions of said blocks in of said blocks in versions of said selected ones of the selected ones of the blocks in selected frames that are frames that are ones of the frames encoded in said means encoded in said means that are encoded for encoding for encoding in said means for Structure: shift circuit Structure: frame 13, shift circuit 14, memory 12, shift and averager 17 (as circuits 13 and 14, and shown in Figure 1 and averager 17 (as shown described at col. 4:35- in Fig. 1 and as 49 and col. 5:35-47 described at col. 3, lines 65-67 and col. 4, lines 35-50) including the coded version of frame Fi-1 output by frame memory 12, the motion vector signal and coded versions of frames Fi-1 and Fi input to shift circuits 13 and 14, and the final prediction of frame Fi output by averager 17, and including all inputs, outputs, and interconnections between these elements Function: developing Function: developing responsive to said code that corresponds code that corresponds second means and to those pels in blocks to those pels in blocks to said frames to approximated by the approximated by said be interpolated second means that second means that for developing differ from differ from corresponding pels in corresponding pels in corresponds to frames to be said frames to be interpolated by greater interpolated by greater than a preselected than a preselected approximated by threshold threshold said second means that differ from Structure: subtractor Structure: frame corresponding 43, DCT 18, quantizer memory 16, subtractor 19, and coder 44 (as 43, DCT 18, quantizer shown in Figure 1 and 19, and coder 44 (as interpolated by described at col. 1:56- shown in Fig. 1 and as 58, col 3:19-25, and described at col. 4, col. 4:51-62) lines 51-62) including the actual frame Fi input to and output by frame memory 16, the actual frame Fi and the predicted frame Fi input to subtractor 43, the buffer feedback signal input to quantizer 19, the coded interpolation error signal output by coder 44, and including all inputs, outputs, and interconnections between these elements approximated: approximated: approximated:

predicted predicted predicted preselected preselected preselected threshold: threshold: threshold:

a value chosen in a value chosen in a value chosen in advance advance advance consistent with claims consistent with claims consistent with claims any path that can 2-8, 11 and 12 2-8, 11 and 12 2-8, 11 and 12 carry electrical current circuit:

MPT is collaterally any path that can any path that can estopped from carry electrical current carry electrical current relitigating this term.

However, plaintiff disputes that it is any path that can collaterally estopped. carry electrical current approximated: approximated: approximated: predicted predicted predicted consistent with claims consistent with claims consistent with claims any path that can 2-8, 11 and 12 2-8, 11 and 12 2-8, 11 and 12 carry electrical current

circuit: circuit: circuit:

MPT is collaterally encoded in any path that can Plaintiff agrees with estopped from carry electrical current this construction. relitigating this term.

However, plaintiff disputes that it is any path that can collaterally estopped. carry electrical current approximated: approximated: approximated: predicted predicted predicted consistent with claims consistent with claims 2, 4, 6, and 12 2, 4, 6, and 12

frame: frame:

a complete set of a complete picture digital representations from a video sequence for an image anticipated versions: anticipated versions:

(indefinite)

The referenced language is not indefinite.

The Court should construe the term as "estimated versions." anticipated: The proper term for construction, as estimated construed in Defendants' preliminary constructions, is: "anticipated versions" consistent with claims consistent with claims consistent with claims any path that can 2-8, 11 and 12 2-8, 11 and 12 2-8, 11 and 12 carry electrical current circuit:

MPT is collaterally any path that can any path that can estopped from carry electrical current carry electrical current relitigating this term.

However, plaintiff any path that can disputes that it is carry electrical current collaterally estopped. consistent with claims consistent with claims consistent with claims sets of pixels (picture 2, 5 and 12 2, 5 and 12 2, 5 and 12 elements also called pels) that constitute a blocks: blocks: blocks: portion of a frame

MPT is collaterally sets of pixels (picture sets of pixels (picture estopped from elements also called elements also called relitigating this term. pels) that constitute a pels) that constitute a portion of a frame portion of a frame sets of pixels (picture elements also called However, plaintiff pels) that constitute a disputes that it is portion of a frame collaterally estopped. consistent with claims consistent with claims consistent with claims any path that can 2-8, 11 and 12 2-8, 11 and 12 2-8, 11 and 12 carry electrical current frames circuit: circuit: circuit:

MPT is collaterally any path that can any path that can estopped from carry electrical current carry electrical current relitigating this term.

However, plaintiff any path that can disputes that it is carry electrical current collaterally estopped. consistent with claims consistent with claims 2, 4, 6, and 12 2, 4, 6, and 12 frame: frame:

a complete set of a complete picture digital representations from a video sequence for an image This term should be almost exactly one-given its plain half meaning to one of skill in the art, and therefore does not require construction.

If the Court determines that this term requires construction, the Court should construe the term as "nearly one-half." consistent with claims consistent with claims consistent with claims any path that can 2-8, 11 and 12 2-8, 11 and 12 2-8, 11 and 12 carry electrical current circuit:

MPT is collaterally any path that can any path that can estopped from carry electrical current carry relitigating this term. buffer means: buffer means:

buffer This term does not Function: buffering interposed require construction under 35 U.S.C. § Structure: buffer 60 112(6). (as shown in Fig. 1 and as described at If the Court col. 4, lines 16-18 and determines that this col. 4, lines 59-62) . term is governed by including the

35 U.S.C. § 112(6), quantized output the Court should coefficients and coded construe the term as interpolation error follows: input to and output from this element, and Function: To hold the feedback signals data (e.g., coded output by this element values or coded interpolation error) awaiting transmission.

Structure: buffer 60 (as shown in Figure 1 and described in col. 4:16-18, 59-60) interposed between interposed between the codes developed the codes developed by said means for by said means for encoding and said encoding and said third means and an third means and an output port of said output port of said circuit: circuit:

The referenced (indefinite) language is not indefinite.

This term should be given its plain meaning to one of skill in the art, and therefore does not require construction. consistent with claims consistent with claims consistent with claims any path that can 2-8, 11 and 12 2-8, 11 and 12 2-8, 11 and 12 carry electrical current circuit:

MPT is collaterally any path that can any path that can estopped from carry electrical current carry electrical current relitigating this term.

However, plaintiff any path that can

carry electrical current granularity: granularity: granularity:

coarseness coarseness coarseness

consistent with claims consistent with claims consistent with claims any path that can 2-8, 11 and 12 2-8, 11 and 12 2-8, 11 and 12 carry electrical current circuit:

any path that can MPT is collaterally any path that can carry electrical current estopped from carry electrical current relitigating this term.

However, plaintiff disputes that it is any path that can collaterally estopped carry electrical current consistent with claims consistent with claims consistent with claims any path that can 2-8, 11 and 12 2-8, 11 and 12 2-8, 11 and 12 carry electrical current circuit:

any path that can MPT is collaterally any path that can carry electrical current estopped from includes a carry electrical current relitigating this term.

However, plaintiff any path that can disputes that it is carry electrical current collaterally estopped blocks

coded: coded: coded: change from one form

MPT is collaterally of representation change from one form change from one form estopped from to another of representation to of representation to relitigating this term. another another change from one form

However, plaintiff of representation to disputes that it is another collaterally estopped. approximated approximated approximated predicted blocks blocks: blocks: blocks:

MPT is collaterally predicted blocks predicted blocks estopped from relitigating this term. However, plaintiff disputes that it is predicted blocks collaterally estopped. consistent with claims consistent with claims consistent with claims sets of pixels (picture 2, 5 and 12 2, 5 and 12 2, 5 and 12 elements also called pels) that constitute a blocks: blocks: blocks: portion of a frame

MPT is collaterally sets of pixels (picture sets of pixels (picture estopped from elements also called elements also called relitigating this term. pels) that constitute a pels) that constitute a portion of a frame portion of a frame sets of pixels (picture elements also called However, plaintiff pels) that constitute a disputes that it is portion of a frame collaterally estopped. consistent with claims consistent with claims 2, 4, 6, and 12 2, 4, 6, and 12

frame: frame:

a complete set of a complete picture digital representations from a video sequence for an image consistent with claims consistent with claims consistent with claims differences 2 and 12 2 and 12 2 and 12 deviations: deviations: deviations:differences differences estopped from relitigating this term.

However, plaintiff disputes that it is differences collaterally estopped.

Plaintiff disputes that MPT is collaterally Function: it is collaterally estopped from The function is from estopped from relitigating this term. developing block offering a proposed approximations [the construction for this Function: developing combinations of term. block approximations predicted blocks with and from said codes that differences

Function: developing describe deviations between the actual block approximations from approximated blocks and the from said codes that blocks predicted blocks] describe deviations from said codes that from approximated Structure: decoder 22, describe deviations blocks DCT-1 24, adder 27, from approximated and shift circuit 26, blocks.

Structure: decoder 22, including all inputs inverse DCT 24, and outputs of these Corresponding adder 27, and shift elements related to the Structure: circuit 26 (as shown claimed function (See Decoder 22, DCT-1 in Fig. 2 and as Fig. 2; Col. 4, lines 3- 24, Adder 27, and described at col. 1:56- 10, 26-32, Col. 4, line Shift Circuit 26, 58, col. 4:3-10, 26-32, 63 to Col. 5, line 7). including all inputs col. 4:63-col. 5:7) and outputs of these elements related to the claimed function (See Fig. 2; Col. 4, lines 3-10, 26-32, Col. 4, line 63 to Col. 5, line 7). consistent with claims consistent with claims consistent with claims differences 2 and 12 2 and 12 2 and 12

deviations: deviations: deviations:

MPT is collaterally differences differences estopped from relitigating this term.

However, plaintiff disputes that it is differences collaterally estopped. block block block the combinations of approximations: approximations: approximations: predicted blocks with

MPT is collaterally differences the combinations of estopped from between the actual predicted blocks with the combinations of relitigating this term. blocks and the differences between predicted blocks with predicted blocks the actual blocks and differences between the combinations of the predicted blocks the actual blocks and predicted blocks with the predicted blocks differences between the actual blocks and However, plaintiff the predicted blocks disputes that it is collaterally estopped. approximated approximated approximated predicted blocks blocks: blocks: blocks:

predicted blocks predicted blocks MPT is collaterally estopped from

However, plaintiff relitigating this term. disputes that it is collaterally estopped. predicted blocks Plaintiff disputes that MPT is collaterally Function: it is collaterally estopped from The function is to approximations estopped from relitigating this term develop said and to said codes offering a proposed interpolated construction for this Function: to develop blocks responsive to deviations from term. said interpolated said block blocks responsive to approximations [the blocks to develop Function: develop said block combinations of said interpolated said interpolated approximations and to predicted blocks with blocks said codes that differences describe deviations between the actual Structure: decoder 25, from interpolated blocks and the inverse DCT 34, blocks. predicted blocks] and adder 35, shift circuits to said codes that 31 and 39, and Structure: decoder 25, describe deviations averager 32 (as shown DCT-1 34, adder 35, from interpolated in Fig. 2 and as and shift circuits 31 blocks.

described at col. 1:56- and 39, and averager Structure: 58, col. 4:63-65, col. 32, including all Decoder 25, DCT-1 5:7-23, 5:35-47) inputs and outputs of 34, Adder 35, and these elements related Shift Circuits 31 and to the claimed 39, and Averager 32, function (See Fig. 2; including all inputs Col. 4, lines 63-65 ; and outputs of these Col. 5, lines 7-23 elements related to the [description of the claimed function structure and inputs (See Fig. 2; Col. 4, that correspond to lines 63-65; Col. 5, these elements is at lines 7-23 [description Col. 4, lines 38-50]) of the structure and inputs that correspond to these elements is at Col. 4, lines 38-50]).

block block block the combinations of approximations: approximations: approximations: predicted blocks with differences

the combinations of the combinations of MPT is collaterally between the actual predicted blocks with predicted blocks with estopped from blocks and the differences between differences between relitigating this term predicted blocks the actual blocks and the actual blocks and the predicted blocks the predicted blocks the combinations of predicted blocks with However, plaintiff differences between disputes that it is the actual blocks and collaterally estopped. the predicted blocks consistent with claims consistent with claims consistent with claims differences 2 and 12 2 and 12 2 and 12

deviations: deviations: deviations:

differences

differences MPT is collaterally

estopped from

However, plaintiff relitigating this term disputes that it is collaterally estopped. differences difference frame: frame:

a complete set of a complete picture digital representations from a video sequence for an image consistent with claims consistent with claims hardware, which may 1, 8 and 29 1, 8 and 29 include a general-purpose processor coder: coder: programmed with hardware, which may hardware, which may appropriate software, include one or more include a general- that changes a video circuits or processors purpose processor signal from one form programmed with programmed with of representation to appropriate software, appropriate software, another that changes a video that changes a video signal from one form signal from one form of representation to of representation to another another

Function: This limitation must Function: predicting a predicting a next be construed under 35 next frame's signals frame's signals U.S.C. § 112(6).

Structure: inverse Function: As shown in Figure 2

377 - 1. 377 - 1.

Structure: CONSTRUCTION CONSTRUCTION CONSTRUCTION CONSTRUCTION andquantizer 39; inverse predicting a next and as described in

DCT 40; frame's signals in those portions of adder 41; and motion response to the 5:60-7:20 describing compensator 43 (as encoder output signals these elements: shown in Figure 2 and as Structure: adders 41 and 54; described at col. 6:9- motion vector subtracter 44; 31, 40-46) generator 13 (as multiplier 45; motion shown in Fig. 1 and compensator 43; its internal circuitry inverse quantizer 39; shown in Figs. 3-4, inverse DCT 40; and and described at cols. including all inputs, 4:35-47, 5:15-27, and outputs, and 7:33-10:49), including interconnections of the applied next these elements frames I(t) and I(t-1) necessary to the input to this element claimed function. and motion vectors MV(t-1) output by this element; motion vector selector/encoder 14 (as shown in Fig. 1 and its internal circuitry shown in Fig. 6, and described at cols. 4:43-51, 5:23-39, and 10:50-12:18 ),adder 41 (as shown in Fig. 2 and described at col. 6:19-22), including all inputs and outputs;

adder 54 (as shown in Fig. 2 and described at col. 6:19-24 ), including all inputs and outputs;

subtractor 44 (as shown in Fig. 2 and described at cols. 5:65-6:3, 6:31-37, and 6:41-44), including all inputs and outputs; multiplier 45 (as shown in Fig. 2 and described at cols. :65-6:3 and 6:35-39), including leak factor L(t-4) and displaced frame signal DF with the mean removed input to this element and the best estimation of image I(t-4) output by this element;

motion compensator 43 (as shown in Fig. 2 and described at cols. 5:32-37, 6:28-33, 6:40-41, and 12:20-32), including the motion vectors MV(t-4) and previous frame input to this element and the estimate of the image signal I(t-4) output by this element;

inverse quantizer 39 (as shown in Fig. 2 and its internal circuitry in Fig. 11

377 - 4. 377 - 4.CONSTRUCTION and described at cols. 6:9-18 and 18:36-68), including scale factors Sji and quantized superblock vector signals input to this element and inversely quantized frequency coefficients output by this element; and

inverse DCT 40 (as shown in Fig. 2 and described at cols. 6:9-14), including the inversely quantized frequency coefficients input to this element and approximated frame difference signals output by this element

Function: Function: This limitation must Function: developing developing the frame developing the frame be construed under 35 the frame difference difference signals difference signals U.S.C. § 112(6). signals mentioned mentioned earlier in mentioned earlier in earlier in the claim the claim from the claim from Function: from applied next applied next frame applied next frame developing the frame frame signals of an signals of an image signals of an image difference signals image frame and from frame and from output frame and from mentioned earlier in output signals of said signals of said output signals of said the claim from prediction means. prediction means prediction means applied next frame signals of an image Structure: Structure: frame and from output As shown in Figure 2 signals of said and described at 5:63-subtracter 36 (as prediction means. 6:3: shown in Figure 2 and described at col. 5:63- Structure: subtracters 35 and 36, 6:4, 6:40-46) subtractor 35 (as and all inputs, shown in Fig. 2 and outputs, and described at cols. interconnections of 5:63-6:3), including these elements the image signal I(t-4) necessary to the input to this element claimed function and the frame-mean signal M(t-4) input to this element and the mean excluded image signal I(t-4) output by this element; and subtractor 36 (as shown in Fig. 2 and described at cols. 5:63-6:3), including the mean excluded image signal I(t-4) input to this element and best estimation of image I(t-4) input to this element and the frame difference signals output by this element

Function: Function: This limitation must Function: quantizing quantizing the be construed under the difference signals

quantizing the difference signals 35 U.S.C. § 112(6). mentioned earlier in difference signals mentioned earlier in the claim in mentioned earlier in the claim in Function: accordance with a the claim in accordance with a quantizing the quantization schema accordance with a quantization schema difference signals that varies quantization schema that varies with the mentioned earlier in with the dictates of a that varies with the dictates of a control the claim in control signal dictates of a control signal accordance with a signal quantization schema Structure:

Structure: that varies with the Quantizer vector

(1) Quantizer vector dictates of a control selector 38 ("QVS"). selector 38 (as shown signal The QVS is shown in in Figure context in Figure 2, 2, and described at Structure: and its general role is col. 5:60-6:12 (the DCT 37 (as shown in described at 5:60-other elements Fig. 2, and as 6:12. (The other cited in this passage described at cols. 6:3- elements cited in this are not part of the 6, 14:27-36, and passage are not part of corresponding 14:66-67), including the structure for this the frame difference corresponding element) and/or col. signals input to this structure for this 14:67-col. element and element.) The internal 15:13); frequency domain circuitry coefficients output by of the QVS is shown

(2) Quantization this element; and in Figures 9 and 10, encoder 81 and and described at subtracter 84 (as quantizer vector 15:57-17:34. The shown in Figure 9 and selector 38 ("QVS") elements shown in as described at col. (as shown in Fig. 2, Figures 9 and 10 are 15:61-16:5, and its general role is part of the overall and col. 16:12-22); or described at cols. corresponding

5:60-6:12 and its structure for this

(3) Figure 10 (as internal circuitry as element. Certain described at col. shown in Figs. 9 and components in the 16:39-18:16) (The 10, and described at QVS are described variable length cols. 15:57-18:16), further at 17:34-encoders 46 and 47 including the 18:16. (The variable discussed in this frequency coefficient length encoders 46 passage are not part signals input to this and 47 discussed in of the corresponding element and the this passage are not structure for quantized superblock part of the this element.). vector signals output corresponding by this element structure for this element.)

quantization quantization a way of quantizing schema: schema: a way of quantizing a structured framework for quantizing said coder including means, responsive to Function: developing means, responsive to said applied next the control signal, develop said control frame signals, to which varies signal, which control develop said control throughout signal varies signal, which control the applied next frame throughout said signal varies with changes in at applied next frame throughout said least one selected with changes in at applied next frame characteristic of the least one selected with changes in at applied next frame characteristic of said least one selected signals applied next frame characteristic of said signals.: applied next frame Structure: perceptual signals: coder 49 (as shown in

Figure 2) including

Function: This limitation must at least one of the

developing the be construed under 35 following sets of control signal, which U.S.C. § 112(6). internal circuitry: varies throughout the applied next frame Function: (1) generator 93 (as with changes in at developing the control shown in Figure 12), least one selected signal mentioned where generator 93 characteristic of the earlier in the claim, includes at least applied next frame which varies texture processors 96 signals throughout the applied and 98, combiner 99, next frame with and mapping look up changes in at least one table 100 (as shown in Structure: selected characteristic Figure 13, and of the applied next described at 20:32- perceptual coder 49 frame signals in 21:12, 21:42-43, (as shown in Figure response to said 21:53-22:5), and

2) including at least applied next frame where texture one of the following signals processors 96 and 98 sets of internal each include at least circuitry: Structure: look-up table

(1) generator 93 (as perceptual coder 49 114 and one of the shown in Figure 12), (as shown in Fig. 2) accumulators 106, where generator 93 including at least one 107, or 1 08 (as includes at least of the following sets shown in Figure 14 texture processors 96 of internal circuitry: and described at and 98, combiner 99, 21:43-49); and mapping look up (1) perceptual table 100 (as shown processor 93 (as (2) generator 93 (as in Figure 13, and shown in Fig. 12), shown in Figure 12), described at 20:32- where perceptual where generator 93 21:12, 21:42-43, processor 93 includes includes at least: 21:53-22:5), and at least texture adder 101, brightness where texture processors 96 and 98, correction truncation processors 96 and 98 combiner 99, and circuit 97, and each include at least mapping look up table brightness correction look-up table 114 and 100 and base look-up table 110 (as one of the threshold look-up shown accumulators 106, table 111 (as shown in in Figure 13, and 107 or 108 (as shown Fig. 13, and described described at 21:27-34, in Figure 14 and at cols. 20:32-21:12, 22:6-10); or described at 21:43- 21:41-42, 21:53-22:5 49); and 22:12-22), and (3) rate processor 91 where texture (as shown in Figure processors 96 and 98 12 and described at

(2) generator 93 (as each include at least 22:36-23:40) shown in Figure 12), look-up table 114 and where generator 93 one of the includes at least: accumulators 106, adder 101, brightness 107, or 108 (as shown correction truncation in Fig. 14 and circuitry 97, and described at cols. brightness correction 21:43-49), including look-up table 110 (as their interconnects, shown in Figure 13 the transformed image and described at information with the 21:27-34, 22:6-10); or mean removed İT(t-4) and temporal frame difference of the

(3) rate processor 91 transformed image (as shown in Figure information with the 12 and described at mean removed İ (t-4) 22:36-23:40).

input into this element and the perceptual thresholds PTij(t-4) output by this element; or

(2) perceptual processor 93 (as shown in Fig. 12), where perceptual processor 93 includes at least: adder 101, brightness correction truncation circuit 97, and brightness correction look-up table 110 and base threshold look-up table 111 (as shown in Fig. 13, and described at cols. 21:24-34, 22:6-22) including their interconnects, the transformed image information with the mean removed İT(t-4) and mean signal M(t-4) input into this element and the perceptual thresholds PTij(t-4) output by this element consistent with claims consistent with claims Any of the following 1, 4 and 9 1, 4 and 9 characteristics of the applied next frame selected selected signals, alone or in characteristic characteristic: combination: (1) a measure of texture, any characteristic of any of the following (2) a measure of the applied next frame characteristics of the brightness, or (3) a signals, applied next frame measure of buffer including, but not signals, alone or in fullness. limited to, a measure combination: (1) a of texture, a measure measure of texture, or of brightness, a (2) a measure of measure of buffer brightness fullness, temporal differences, frequency sensitivity, or distortion This limitation does This limitation must Function: developing not require be construed under 35 the control signal, construction under 35 U.S.C. § 112(6). which varies U.S.C. § 112 (6). The throughout "means . responsive Function: the applied next frame to said applied next developing the control at least with changes frame" limitation is signal, which varies to a measure of already recited in throughout the applied texture in the applied claim 1. Claim 4 only next frame at least next frame signals adds the "wherein with changes to a said selected measure of texture in Structure: perceptual characteristic is a the applied next frame coder 49 (as shown in measure of texture in signals Figure 2) including at applied next frame least a generator 93 signals" limitation. Structure: perceptual (as shown in Figure coder 49 (as shown in 12), where generator Fig. 2) including at 93 includes at least wherein said least perceptual the following internal processor 93 (as circuitry: shown in Fig. 12), where perceptual texture processors 96 processor 93 includes and 98, combiner 99, at least texture and mapping look up processors 96 and 98, table 100 (as shown in combiner 99, and Figure 13, and mapping look up table described at 20:32-100 and base 21:12, 21:42-43, threshold look-up 21:53-22:5:), where table 111 (as shown in texture processors 96 Fig. 13, and described and 98 each at cols. 20:32-21:12, include at least look-21:41-42, 21:53-22:5, up table 114 and one and 22:12-22), and of the accumulators where texture 106, 107, or 108 (as processors 96 and 98 shown in Figure 14 each include at least and described at look-up table 114 and 21:43-49) one of the accumulators 106, 107, or 108 (as shown in Fig. 14 and described at 21:43-49), including their interconnects, the transformed image information with the mean removed İT(t-4) and temporal frame difference of the transformed image information with the mean removed İT(t-4) input into this element and the perceptual thresholds PTij(t-4) output by this element consistent with claims consistent with claims 1, 4, 6, 17, 26, 27, 28 1, 4, 6, 17, 26, 27, 28 and 29 and 29

frame: frame:

a complete set of a complete picture digital representations from a video sequence for an image consistent with claims consistent with claims Any of the following 1, 4 and 9 1, 4 and 9 characteristics of the applied next frame selected selected signals, alone or in characteristic characteristic: combination: (1) a measure of texture, any characteristic of any of the following (2) a measure of the applied next frame characteristics of the brightness, or (3) a signals, applied next frame measure of buffer including, but not signals, alone or in fullness. limited to, a measure combination: (1) a of texture, a measure measure of texture, or of brightness, a (2) a measure of measure of buffer brightness fullness, temporal differences, frequency sensitivity, or distortion This limitation does This limitation must not require be construed under 35 construction under 35 U.S.C. § 112(6).

U.S.C. § 112 (6). The "means . responsive Function: to said applied next developing the control frame" limitation is signal, which varies already recited in throughout the applied claim 1. Claim 6 only next frame at least adds the "wherein with changes to a said measure of measure of texture in texture is a the applied next frame combination of a signals texture measure of said applied next Structure: frame signals and of perceptual coder 49 previously applied (as shown in Fig. 2) wherein said next frame signals" including at least limitation. perceptual processor 93 (as shown in Fig. 12), where perceptual processor 93 includes at least texture processors 96 and 98, combiner 99, and mapping look up tables 100 and base threshold look-up table 111 (as shown in Fig. 13, and described at cols. 20:32-21:12, 21:41-42-43, 21:53-22:5, and 22:12-22), and where texture processors 96 and 98 each include at least look-up table 114 and one of the accumulators 106, 107, or 108 (as shown in Fig. 14 and described at 21:43-49), including their interconnects, the transformed image information with the mean removed İT(t-4) and temporal frame difference of the transformed image information with the mean removed İT(t-4) input into this element and the perceptual thresholds PTij(t-4) output by this element consistent with claims consistent with claims 1, 4, 6, 17, 26, 27, 28 1, 4, 6, 17, 26, 27, 28 and 29 and 29

frame: frame:

a complete set of a complete picture digital representations from a video sequence for an image consistent with claims consistent with claims hardware, which may 1, 8 and 29 1, 8 and 29 include a general-purpose processor coder: coder: programmed with appropriate software, hardware, which may hardware, which may that changes a video comprising include one or more include a general- signal from one form circuits or processors purpose processor of representation to programmed with programmed with another appropriate software, appropriate software, that changes a video that changes a video signal from one form signal from one form of representation to of representation to another another Function: This limitation must Function: receiving signals from be construed under 35 receiving signals from said output buffer U.S.C. § 112(6). said output buffer that indicate

Structure: Function: the level of buffer . perceptual coder 49, receiving signals from fullness of said output and its said output buffer that buffer interconnection to indicate the level of BFF block 56 (as buffer fullness of said Structure: perceptual shown in Figure 2) output buffer coder 49, and its interconnection to Structure: BFF block 56, as perceptual coder 49 shown in Figure 2 (including internal circuitry rate processor 91 (as shown in Fig. 12 and described at cols. 22:36- 23:45) including buffer fullness input to this element and distortion level D output by this element; and

multiplier 92 (as shown in Fig. 12 and described at cols. 19:56-63 and 23:41-43) including distortion level D and perceptual thresholds PTij(t-4) input to this element and target distortion levels output by this element The referenced This language cannot language is not be construed because indefinite. it is invalid due to is a indefiniteness and

This term should be failure to satisfy 35 given its plain U.S.C. §§ 112(4) and meaning to one of (6). skill in the art, and therefore does not require construction. consistent with claims consistent with claims Any of the following 1, 4 and 9 1, 4 and 9 characteristics of the applied next frame selected selected signals, alone or in characteristic: characteristic: combination: (1) a measure of texture, any characteristic of any of the following (2) a measure of the applied next frame characteristics of the brightness, or (3) a signals, applied next frame measure of buffer including, but not signals, alone or in fullness. limited to, a measure combination: (1) a of texture, a measure measure of texture, or of brightness, a (2) a measure of measure of buffer brightness fullness, temporal differences, frequency sensitivity, or distortion consistent with claims consistent with claims 1, 4, 6, 17, 26, 27, 28 1, 4, 6, 17, 26, 27, 28 signals and 29 and 29

frame: frame:

a complete set of a complete picture digital representations from a video sequence for an image transform element transform element transform element signals: signals: signals: frequency domain coefficients frequency domain frequency domain coefficients coefficients Function: This limitation must developing frame be construed under 35 prediction signals U.S.C. § 112(6).

Structure: Function: inverse quantizer 39; developing frame inverse DCT 40; prediction signals in adder 41; and motion response to output compensator 43 (as signals of the encoder shown in Figure 2 and as described at col. Structure: 6:9-31, 40-46) motion vector generator 13 (as shown in Fig. 1 and its internal circuitry shown in Figs. 3-4, and described at cols. 4:35-47, 5:15-27, and col. 7:33-10:49 ), including the applied next frames I(t) and I(t-1) input to this element and motion vectors MV(t-1) output by this element;

motion vector selector/encoder 14 (as shown in Fig. 1 and its internal circuitry shown in Fig. 6, and described at cols. 4:43-51, 5:23-39, and 10:50-12:18 ), including the motion vector MV(t-1) input to this element and motion vectors MV(t-2) output by this element;

adder 41 (as shown in

Fig. 2 and described at col. 6:19-22), including all inputs and outputs; adder 54 (as shown in Fig. 2 and described at col. 6:19-24 ), including all inputs and outputs; subtractor 44 (as shown in Fig. 2 and described at cols. 5:65-6:3, 6:3531-37, and 6:41-44), including all inputs and outputs;

multiplier 45 (as shown in Fig. 2 and described at cols. 5:65-6:3 and 6:35-39), including leak factor L(t-4) and displaced frame signal DF with the mean removed input to this element and the best estimation of image I(t-4) outputs by this element; motion compensator 43 (as shown in Fig. 2 and described at cols. 5:32-37, 6:28-33, 6:40-41, and 12:20-32), including the motion vectors MV(t-4) and previous frame input to this element and all inputs and the estimate of the image signal I(t-4) output by this element outputs;

inverse quantizer 39 (as shown in Fig. 2 and its internal circuitry in Fig. 11 and described at cols. described at cols. 6:9-18 and 18:36-68), including scale factors Sji and quantized superblock vector signals input to this element and inversely quantized frequency coefficients output by this element; and inverse DCT 40 (as shown in Fig. 2 and described at cols. 6:9-14), including the inversely quantized frequency coefficients input to this element and approximated frame difference signals output by this element consistent with claims consistent with claims 1, 4, 6, 17, 26, 27, 28 1, 4, 6, 17, 26, 27, 28 and 29 and 29

frame: frame:

a complete set of a complete picture digital representations from a video sequence for an image Function: This limitation must developing frame be construed under 35 difference signals U.S.C. § 112(6).

Structure: Function: subtracter 36 (as developing frame shown in Figure 2 and difference signals in described at col 5:63- response to the frame 6:4, 40-46) prediction means and applied frame signals Structure: subtractor 35 (as shown in Fig. 2 and described at cols. 5:63-6:3), including the input to this element image signal I(t-4) input to this element and the frame mean signal M(t-4) input to this element and the mean excluded image signal I(t-4) output by this element; and

subtractor 36 (as shown in Fig. 2 and described at cols. 5:63-6:3), including the mean excluded image signal I(t-4) input to this element and best estimation of image I(t-4) input to this element and the frame difference signals output by this element Function: Function: This limitation must encoding frame be construed under 35

encoding the frame difference signals U.S.C. § 112(6). difference signals under direction of under direction of the said control signal Function: control signal encoding the frame mentioned earlier in Structure: difference signals the claim under direction of the

(a) (1) Quantizer control signal vector selector 38 (as mentioned earlier in shown in Figure 2 and the claim described at col. 6:6-9 (the other elements Structure: cited in this passage DCT 37 (as shown in are not part of the Fig. 2, and as corresponding described at cols. 6:3-structure for this 6, 14:27-36, and element), col. 6:63- 14:66-67), including 64, col. 7:12-15 and the frame difference col. 14:67-col. 15:18), signals input to this or (2) Quantization element and encoder 81 and frequency domain subtracter 84 (as coefficients output by shown in Figure 9 and this element; as described at col. 15:61-16:3, col. quantizer vector 16:12-22 and col selector 38 ("QVS") 16:23-32), or (3) (as shown in Fig. 2, Figure 10 (as and its general role is described at col. described at cols. 16:39-18:16) (The 5:60-6:12 and its variable length internal circuitry as encoders 46 and 47 shown in Figs. 9 and discussed in this 10, and described at passage are not part cols. 15:57-18:16), of the corresponding including the structure for this frequency coefficient element.); and signals input to this element and the

(b) at least one of quantized superblock variable length vector signals output encoders 46 and 47 by this element; and (as shown in FIG. 2 and described at col. variable length 17:41-46, 18:20-33). encoder 46 and 47 (as shown in Fig. 2 and described at cols. 17:46-18:33), including the quantized superblock vector signals input to this element and codebook vectors and quantized superblock vectors output by this element Function: This limitation must be construed under 35

developing said U.S.C. § 112(6). control signal

Function:

Structure: developing said perceptual coder 49 control signal in (as shown in Figure response to said

2), including rate encoder output signals processor 91 (as to control the number shown in Figure 12 of bits generated by and described at said coder means 22:36-23:40) while encoding the applied frame signals

Structure: buffer fullness and formatter 56 (as shown in Fig. 2 and described at cols. 23:47-24:52) including inputs codebook vectors and quantized superblock vectors as inputs and buffer fullness output by this element; and perceptual coder 49 (as shown in Fig. 2 including internal circuitry rate processor 91 (as shown in Fig. 12 and described at cols. 22:36-23:45) including buffer fullness input to this element and distortion level D output by this element This limitation does This limitation must not require be construed under 35 construction under 35 U.S.C. § 112(6).

U.S.C. § 112 (6). The "control means for Function: developing said developing said control signal." control signal in limitation is already response to said recited in claim 26. encoder output signals Claim 29 only adds to control the number the "where said of bits generated by control means is said coder means further responsive to while encoding the said applied frame applied frame signals; " limitation. and in response to said applied frame signals modifying the developed control signal based on said applied frame signals to control coding error signals created in said coder in the course of coding of said frame difference signals

Structure:

" perceptual coder 49

(as shown in Fig. 2) including:

perceptual processor 93 (as shown in Fig. 12 and its internal circuitry in Figs. 13 and 14 and described at cols. 19:1- 23:46), including the transformed image information with the mean removed İT(t-4) and mean signal M(t-4) input into this element and the perceptual thresholds PTij(t-4) output by this element;

rate processor 91 further including signal standard deviation values σ as an input; and

multiplier 92 (as shown in Fig. 12 and described at cols. 19:56-63 and 23:41-43), including distortion level D and perceptual thresholds PTij(t-4) input to this element and target distortion levels output by this element consistent with claims consistent with claims 1, 4, 6, 17, 26, 27, 28 1, 4, 6, 17, 26, 27, 28 and 29 and 29 frame:

a complete set of a complete picture digital representations from a video sequence for an image consistent with claims 1, consistent with claims 1, consistent with claims 1, a rectangular array of 7, 13 and 19 7, 13 and 19 7, 13 and 19 elements, at least 2 elements high and 2 NxM matrix: NxM matrix: NxM matrix: elements wide

a rectangular array of a rectangular array of a rectangular array of elements, at least 2 elements, at least 2 elements, at least 2 elements high and at elements high and at elements high and at least 2 elements wide least 2 elements wide least 2 elements wide consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by transform frequency coefficient frequency coefficient frequency coefficient coding, such as the signals: signals: signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete discrete discrete cosine cosine transform (DCT) cosine transform (DCT) transform (DCT) consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order:

the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are organized prior to are organized prior to are organized prior to encoding encoding encoding. scanning a first subset scanning a first subset scanning a first subset of the frequency of the frequency of the frequency coefficient signals: coefficient: coefficient:

organizing a first subset organizing a first subset organizing a first subset of frequency of frequency of frequency coefficients into a coefficients into a coefficients into a sequence prior to sequence prior to sequence prior to encoding encoding encoding

consistent with claims 1, consistent with claims 1, generating a video , the 7, 13, 19 7, 13, 19 signal using variable word length encoding generating an encoded generating an encoded video signal: video signal:

generating a video generating a video signal using variable signal using variable word length encoding or length encoding other entropy encoding consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by transform frequency coefficient frequency coefficient frequency coefficient coding, such as the signals: signals: signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete discrete discrete cosine cosine transform (DCT) cosine transform (DCT) transform (DCT)

consistent with claims 2, consistent with claims 2, 3, 7, 14, 15 and 19 3, 7, 14, 15 and 19 frame:

associated with a complete set of digital representations for an a complete picture from image a video sequence consistent with claims 2, consistent with claims 2, interlaced format or 3, 7, 14, 15 and 19 3, 7, 14, 15 and 19 progressive format frame format:

interlaced format or interlaced formatted progressive format picture or progressive formatted picture consistent with claims 2, consistent with claims 2, frame 3, 7, 14, 15 and 19 3, 7, 14, 15 and 19 is an interlaced

frame: frame:

a complete set of digital a complete picture from representations for an a video sequence image consistent with claims 2, consistent with claims 2, interlaced format or 3, 7, 14, 15 and 19 3, 7, 14, 15 and 19 progressive format

frame format: frame format:

interlaced format or interlaced formatted progressive format picture or progressive formatted picture consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order: the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are organized prior to are organized prior to are organized prior to encoding encoding encoding

consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by transform frequency coefficient frequency coefficient frequency coefficient coding, such as the signals: signals: signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete discrete discrete cosine cosine transform (DCT) cosine transform (DCT) transform (DCT) consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order:

the sequence into which the sequence into which the sequence into which frequency frequency frequency coefficients are organized prior to coefficients are coefficients are encoding. organized prior to organized prior to encoding encoding consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by transform frequency coefficient frequency coefficient frequency coefficient coding, such as the signals: signals: signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete discrete discrete cosine cosine transform (DCT) cosine transform (DCT) transform (DCT) consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order: the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are organized prior to are organized prior to are organized prior to encoding encoding encoding.

consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by frequency coefficient frequency coefficient frequency coefficient transform signals: signals: signals: coding, such as the discrete cosine signals containing signals containing signals containing transform (DCT) frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete discrete discrete cosine cosine transform (DCT) cosine transform (DCT) transform (DCT)

consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by transform frequency coefficient frequency coefficient frequency coefficient coding, such as the signals: signals: signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete discrete discrete cosine cosine transform (DCT) cosine transform (DCT) transform (DCT) consistent with claims 1, consistent with claims 1, consistent with claims 1, a rectangular array of 7, 13 and 19 7, 13 and 19 7, 13 and 19 elements, at least 2 elements high and 2 NxM matrix: NxM matrix: NxM matrix: elements wide

a rectangular array of a rectangular array of a rectangular array of elements, at least 2 elements, at least 2 elements, at least 2 elements high and 2 at elements high and at elements high and at least elements wide least 2 elements wide least 2 elements wide consistent with claims 7 consistent with claims 7 The Court construes the and 19 and 19 entire phrase as:

; alternatively selecting a alternatively selecting a alternatively selects a pre-determined predetermined scanning pre-determined scanning order in order in response to scanning order in response to whether the whether the picture is response to whether the video signal is progressive format or video signal is associated with interlaced format progressive format or progressive format or interlaced format interlaced format

consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 678 - 11.

13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order:

the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are are are organized prior to encoding. organized prior to organized prior to encoding encoding consistent with claims 2, consistent with claims 2, 3, 7, 14, 15 and 19 3, 7, 14, 15 and 19

frame: frame:

a complete set of digital a complete picture from representations for an a video sequence image consistent with claims 2, consistent with claims 2, interlaced format or 3, 7, 14, 15 and 19 3, 7, 14, 15 and 19 progressive format

frame format: frame format:

interlaced format or interlaced formatted progressive format picture or progressive formatted picture scanning the set of scanning the set of scanning the set of organizing the frequency coefficient frequency coefficient frequency coefficient frequency coefficients signals: signals: signals: into a sequence prior to encoding

organizing the organizing the organizing the frequency frequency frequency coefficients coefficients into a coefficients into a into a sequence prior to sequence prior to sequence prior to encoding encoding encoding frequency coefficient frequency coefficient consistent with claims 1, signals containing signals: signals: 7, 13 and 19 frequency coefficients created by transform consistent with claims 1, consistent with claims 1, frequency coefficient coding, such as the 7, 13 and 19 7, 13 and 19 signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete discrete discrete cosine cosine transform (DCT) cosine transform (DCT) transform (DCT) consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order:

the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are organized prior to are organized prior to are organized prior to encoding encoding encoding.

consistent with claims 1, consistent with claims 1, generating a video , the 7, 13, 19 7, 13, 19 signal using variable generating an encoded word length encoding video signal generating an encoded video signal generating a video signal using variable generating a video word length encoding or signal using variable other entropy encoding word length encodingr consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by transform frequency coefficient frequency coefficient frequency coefficient coding, such as the signals: signals: signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete discrete discrete cosine cosine transform (DCT) cosine transform (DCT) transform (DCT)

zigzag scanning order: zigzag scanning order: zigzag scanning order: the scanning order shown in Fig. 3 for an the scanning order MPT agrees with the scanning order 8x8 block, which may shown in Fig. 3 for an Defendants' proposed shown in Fig. 3 for an be scaled to fit different 8x8 block, which may construction for this 8x8 block, which may block sizes provided be scaled to fit different term. be scaled to fit different that the scanning block sizes provided block sizes provided procedure remains the that the scanning that the scanning same as that shown in procedure remains the procedure remains the Fig. 3. same as that shown in same as that shown in Fig. 3 Fig. 3. consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to scanning order: encoding. scanning order: scanning order: the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are organized prior to are organized prior to are organized prior to encoding. encoding encoding consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order:

the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are organized prior to are organized prior to are organized prior to encoding encoding encoding.

consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order:

the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are organized prior to are organized prior to are organized prior to encoding encoding encoding.

consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by transform frequency coefficient frequency coefficient frequency coefficient coding, such as the signals: signals: signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete discrete discrete cosine cosine transform (DCT) cosine transform (DCT) transform (DCT)

consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order:

the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are organized prior to are organized prior to are organized prior to encoding encoding encoding.

consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by transform frequency coefficient frequency coefficient frequency coefficient coding, such as the signals: signals: signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete discrete discrete cosine cosine transform (DCT) cosine transform (DCT) transform (DCT) consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order: the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are organized prior to are organized prior to are organized prior to encoding encoding encoding. consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by transform frequency coefficient frequency coefficient frequency coefficient coding, such as the signals: signals: signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete cosine discrete discrete cosine transform (DCT) cosine transform (DCT) transform (DCT)

consistent with claims consistent with claims hardware, which may 13 and 19 13 and 19 include a general-discrete purpose processor discrete cosine discrete cosine programmed with transform coefficient transform coefficient appropriate software, generator: generator: that uses a discrete cosine transform to hardware, which may hardware, which may create frequency include one or more include a general- coefficients circuits purpose processor or processors programmed with programmed with appropriate software, appropriate software, that uses a discrete that uses a discrete cosine transform to cosine transform or create frequency similar transform to coefficients create frequency coefficients

consistent with claims 1, consistent with claims 1, consistent with claims 1, a rectangular array of 7, 13 and 19 7, 13 and 19 7, 13 and 19 elements, at least 2 elements high and 2 NxM matrix: NxM matrix: NxM matrix: elements wide a rectangular array of a rectangular array of a rectangular array of elements, at least 2 elements, at least 2 elements, at least 2 elements high and at elements high and at elements high and at least 2 elements wide least 2 elements wide least 2 elements wide consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by transform frequency coefficient frequency coefficient frequency coefficient coding, such as the signals: signals: signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete discrete discrete cosine cosine transform (DCT) cosine transform (DCT) transform (DCT) consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order:

the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are organized prior to are organized prior to are organized prior to encoding encoding encoding.

consistent with claims consistent with claims 13 and 19 13 and 19

Function: generating an This limitation must be encoded video signal, construed under 35 the encoded video U.S.C. § 112(6). signal including the 678 - 23.

ordered set of frequency Function: generating an coefficient signals encoded video signal, the encoded video Structure: signal including the

(a) variable word length ordered set of frequency encoder 990 (as shown coefficient signals in Fig. 9 and as described Structure: variable word at 7:13-16); or length encoder 990 (as shown in Fig. 9 and as

(b) encoder 190 (as described at 7:13-37). shown in Fig. 1 and as described at col. 2:53-57). consistent with claims 1, consistent with claims 1, generating a video 7, 13, 19 7, 13, 19 signal using variable word length encoding generating an encoded generating an encoded video signal: video signal:

generating a video generating a video signal using variable signal using variable word length encoding or word length encoding other entropy encoding consistent with claims 2, consistent with claims 2, 3, 7, 14, 15 and 19 3, 7, 14, 15 and 19 frame:

a complete set of digital a complete picture from representations for an a video sequence image consistent with claims 2, consistent with claims 2, interlaced format or 3, 7, 14, 15 and 19 3, 7, 14, 15 and 19 progressive format

frame format: frame format:

interlaced format or interlaced formatted progressive format picture or progressive formatted picture consistent with claims 2, consistent with claims 2, 3, 7, 14, 15 and 19 3, 7, 14, 15 and 19

frame frame: frame:

a complete set of digital a complete picture from representations for an a video sequence image consistent with claims 2, consistent with claims 2, interlaced format or 3, 7, 14, 15 and 19 3, 7, 14, 15 and 19 progressive format frame format:

interlaced format or interlaced formatted progressive format picture or progressive formatted picture consistent with claims consistent with claims hardware, which may 13 and 19 13 and 19 include a general-purpose processor discrete cosine discrete cosine programmed with transform coefficient transform coefficient appropriate software, generator: generator: that uses a discrete cosine transform to hardware, which may hardware, which may create frequency include one or more include a general- coefficients circuits purpose processor or processors programmed with programmed with appropriate software, appropriate software, that uses a discrete that uses a discrete cosine transform to cosine transform or create frequency similar transform to coefficients create frequency coefficients consistent with claims 1, consistent with claims 1, consistent with claims 1, a rectangular array of 7, 13 and 19 7, 13 and 19 7, 13 and 19 elements, at least 2 elements high and 2 NxM matrix: NxM matrix: NxM matrix: elements wide a rectangular array of a rectangular array of a rectangular array of elements, at least 2 elements, at least 2 elements, at least 2 elements high and at elements high and at elements high and at least 2 elements wide least 2 elements wide least 2 elements wide consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by transform frequency coefficient frequency coefficient frequency coefficient coding, such as the signals: signals: signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete cosine discrete discrete cosine transform (DCT) cosine transform (DCT) transform (DCT) consistent with claims 7 consistent with claims 7 The Court construed the and 19 and 19 entire element as:

alternatively selecting a alternatively selecting a hardware, which may pre-determined predetermined scanning include a general-scanning order in order in response to purpose processor response to whether the whether the picture is programmed with video signal is progressive format or appropriate software associated with interlaced format that alternatively selects progressive format or a pre-determined interlaced format scanning order in response to whether the video signal is progressive format or interlaced format

consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order:

the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are organized prior to are organized prior to are organized prior to encoding encoding encoding consistent with claims 2, consistent with claims 2, 3, 7, 14, 15 and 19 3, 7, 14, 15 and 19

frame: frame:

a complete set of digital a complete picture from representations for an a video sequence image consistent with claims 2, consistent with claims 2, interlaced format or 3, 7, 14, 15 and 19 3, 7, 14, 15 and 19 progressive format frame format:

interlaced format or interlaced formatted progressive format picture or progressive formatted picture consistent with claims 1, consistent with claims 1, consistent with claims 1, signals containing 7, 13 and 19 7, 13 and 19 7, 13 and 19 frequency coefficients created by transform frequency coefficient frequency coefficient frequency coefficient coding, such as the signals: signals: signals: discrete cosine transform (DCT) signals containing signals containing signals containing frequency coefficients frequency coefficients frequency coefficients created by transform created by transform created by transform coding, such as the coding, such as the coding, such as the discrete cosine discrete discrete cosine transform (DCT) cosine transform (DCT) transform (DCT)

consistent with claims 1, consistent with claims 1, consistent with claims 1, the sequence into which 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, 4, 5, 7, 8, 9, 10, 11, 12, frequency coefficients 13, 16, 17, 18, 19 13, 16, 17, 18, 19 13, 16, 17, 18, 19 are organized prior to encoding.

scanning order: scanning order: scanning order:

the sequence into which the sequence into which the sequence into which frequency coefficients frequency coefficients frequency coefficients are organized prior to are organized prior to are organized prior to encoding encoding encoding. consistent with claims consistent with claims Function: 13 and 19 13 and 19 generating an encoded video signal, the Function: generating an This limitation must be encoded video signal encoded video signal, construed under 35 including the ordered the encoded video U.S.C. § 112(6). set of frequency signal including the coefficient signals ordered set of frequency Function: generating an coefficient signals encoded video signal, Structure: variable word the encoded video length encoder 990 (as Structure: signal including the shown in Fig. 9 and as

(a) variable word length ordered set of frequency described at 7:13-37) encoder 990 (as shown coefficient signals in Fig. 9 and as described Structure: variable word at 7:13-16); or length encoder 990 (as shown in Fig. 9 and as

(b) encoder 190 (as described at 7:13-37) shown in Fig. 1 and as described at col. 2:53-57). consistent with claims 1, consistent with claims 1, generating a video 7, 13, 19 7, 13, 19 signal using variable word length encoding generating an encoded generating an encoded video signal: video signal:

generating a video generating a video signal using variable signal using a variable word length encoding or word length encoding other entropy encoding Structure: input line 10 (as Function: receiving a Function: receiving a shown in Fig. 1 and digital video input signal digital video input signal described at col. 3:61-65) comprising a succession of

Structure: input line 10 (as digital representations shown in Fig. 1 and related to picture elements described at col. 3:61-65) making up at least one frame of a video image, the frame comprising a plurality of interlaced fields

Structure: input line 10 (as shown in Fig. 1 and described at col. 3:61-65) consistent with claims 1, 2, consistent with claims 1, 2, 13, 15, 23, 24, 26 and 31 13, 15, 23, 24, 26 and 31

frame: frame:

a complete set of digital representations for an a complete picture from a image video sequence interlaced fields: interlaced fields:

one of the two (or more) a set of odd horizontal parts into which a frame is scan lines and a set of even divided in interlaced horizontal scan lines that scanning together make up a complete picture from a video sequence Function: coding groups of Function: coding groups of Function: coding groups of digital representations digital representations digital representations representations related to related to frames of picture related to frames of picture related to frames of picture elements elements elements

Structure: (a) block Structure: formatting circuit 15A (as summing element 11 (as shown in Fig. 1 and as shown in Fig. 1A and as described at col. 6:59-66, described at col. 6 lines 6-col. 5:66-6:3 and Fig. 6 as 22) including the digital described at col. 19:1-18); video input signal and estimate of the video input

(b) discrete cosine signal input to this transform circuit 16 (as element, and the signal shown in Fig. 1 and as output by this element described at col. 7:5-19); relating to the error and between the digital video input signal and the

(c) visibility matrix estimate signal; selector and perceptual quantizer 19 (as shown in block formatting circuit Fig. 1 and as described at 15a (as shown in Fig. 1A col. 7:27-45, col. 5:66- and its internal circuitry as 6:3), or Figure 13 (as shown in Fig. 6, and as described at col. 24:61-col. described at col. 6, line 59 25:8). - col. 7, line 14 and col. 19, lines 1-18) including the coding type signal and the digital video input signal or the estimate error signal input to this element, and the blocks output by this element;

discrete cosine transform circuit 16 (as shown in Fig. 1A and as described at col. 6, line 62 -- col. 7, line 19 and col. 7, lines 27-30) including the blocks input to this element and the transform coefficients output by this element; visibility matrix selector and perceptual quantizer 19 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 13, and as described at col. 7, line 27 - col. 8, line 5, col. 9, lines 19-22, col. 9, lines 34-37, col. 13, lines 22-25, and col. 24, line 61 - col. 25, line 8) including the transform coefficients, coding type signal, picture type signal, digital input signal, estimate error signal, inter/intra type signal, and fullness signal input to this element, and the quantized transform coefficients and quantization parameter output by this element;

scan selector circuit 23 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 14, and as described at col. 8, line 36 -- col. 9, line 2 and col. 25, lines 9-25) including the quantized transform coefficients and coding type signal input to this element, and the ordered quantized transform coefficients output by this element; and

variable word length and fixed word length encoder and multiplexer 24 (as shown in Fig. 1A and as described at col. 8, line 36 -- col. 9 line 34, col. 12 lines 54-56, col. 12, lines 60-64, col. 13, lines 26-28, and col. 13, line 63 -- col. 14, line 1) including the ordered quantized transform coefficients, block class signal, quantization parameter, picture type signal, differential dc coefficient prediction, variable word length table select signal and differential motion vectors input to this element, and the coded transform coefficients output by this element; including all interconnections between these elements consistent with claims 1, consistent with claims 1, 23, 24, 25 and 31 23, 24, 25 and 31

groups of digital groups of digital representations: representations:

This term should be given a number of macroblocks, its plain meaning to one of submacroblocks, and skill in the art, and blocks of picture elements, therefore does not require for example, 16x16 construction. macroblocks of picture elements, 16x8 subblocks of picture elements, and 8x8 blocks of picture elements

Function: coding groups of Function: coding groups of Function: coding groups of digital representations digital representations digital representations representations related to related to interlaced fields related to interlaced fields related to interlaced fields in the frames in the frames in the frames

Structure: Structure: summing

(a) block formatting circuit element 11 (as shown in 15A (as shown in Fig. 1 Fig. 1A and as described at and as described at col. col. 6 lines 6-22) including 6:59-66, col. 5:66-6:3 and the digital video input Fig. 6 as described at col. signal and estimate of the 19:1-18); video input signal input to this element, and the signal

(b) discrete cosine output by this element transform circuit 16 (as relating to the error shown in Fig. 1 and as between the digital video described at col. 7:5-7:19); input signal and the and estimate signal;

(c) visibility matrix block formatting circuit selector and perceptual 15a (as shown in Fig. 1A quantizer 19 (as shown in and its internal circuitry as Fig. 1 and as described at shown in Fig. 6, and as col. 7:27-45, col. 5:66- described at col. 6, line 59 6:3), or Figure 13 (as - col. 7, line 14 and col. described at col. 24:61-col. 19, lines 1-18) including 25:8). the coding type signal and the digital video input signal or the estimate error signal input to this element, and the blocks output by this element;

discrete cosine transform circuit 16 (as shown in Fig. 1A and as described at col. 6, line 62 -- col. 7, line 19 and col. 7, lines 27-30) including the blocks input to this element and the transform coefficients output by this element;

visibility matrix selector and perceptual quantizer 19 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 13, and as described at col. 7, line 27 - col. 8, line 5, col. 9, lines 19-22, col. 9, lines 34-37, col. 13, lines 22-25, and col. 24, line 61 - col. 25, line 8) including the transform coefficients, coding type signal, picture type signal, digital input signal, estimate error signal, inter/intra type signal, and fullness signal input to this element, and the quantized transform coefficients and quantization parameter output by this element;

scan selector circuit 23 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 14, and as described at col. 8, line 36 -- col. 9, line 2 and col. 25, lines 9-25) including the quantized transform coefficients and coding type signal input to this element, and the ordered quantized transform coefficients output by this element; and variable word length and fixed word length encoder and multiplexer 24 (as shown in Fig. 1A and as described at col. 8, line 36 -- col. 9 line 34, col. 12 lines 54-56, col. 12, lines 60-64, col. 13, lines 26-28, and col. 13, line 63 -- col. 14, line 1) including the ordered quantized transform coefficients, block class signal, quantization parameter, picture type signal, differential dc coefficient prediction, variable word length table select signal and differential motion vectors input to this element, and the coded transform coefficients output by this element; including all interconnections between these elements consistent with claims 1, consistent with claims 1, 23, 24, 25 and 31 23, 24, 25 and 31 roups of digital groups of digital representations: representations:

This term should be given a number of macroblocks, its plain meaning to one of submacroblocks, and skill in the art, and blocks of picture elements, therefore does not require for example, 16x16 construction. macroblocks of picture elements, 16x8 subblocks of picture elements, and 8x8 blocks of picture elements Function: producing a field Function: producing a field frame coding type signal frame coding type signal which directs a selected Structure: one, but not both, of the

(1) block adaptive frame coding means or the frame/field coding field coding means to code analyzer 14 (as shown in the digital video input Fig. 1 and as described at signal col. 6:22-58, col. 5:66-6:3); and Structure: switching element 13a (as shown in

(2) thresholder and Fig. 1A and as described at comparator 240 (as shown col. 13, lines 19-22) in Fig. 5 and as described including the inter/intra at col. 18:57-61). type coding signal that controls this element; and block adaptive frame/field coding analyzer 14 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 5, and as described at col. 6, lines 22-58 and col. 18, lines 11-68) including the digital video input signal or the estimate error signal input to this element, and the coding type signal output by this element; and including the interconnection between these elements consistent with claims 1, consistent with claims 1, 14, 17, 23 and 26 14, 17, 23 and 26 coding type: coding type:

frame coding or interlaced field coding frame or field coding consistent with claims 2, fields: 23, 24 and 31 comprise alternating

The "fields" in this claim fields: refer to "interlaced fields" of claim 1. a set of odd horizontal scan lines and a set of even horizontal scan lines that together make up a complete picture from a video sequence consistent with claims 1, 2, consistent with claims 1, 2, 13, 15, 23, 24, 26 and 31 13, 15, 23, 24, 26 and 31

frame: frame:

a complete set of digital a complete picture from a representations for an video sequence image Function: receiving a Plaintiff agrees with MPT is collaterally Function: receiving a compressed digital video Defendants' proposed estopped from relitigating compressed digital video bit steam construction. this term. bit stream

Structure: input line 50 (as However, plaintiff disputes Function: receiving a Structure: input line 50 (as shown in Fig. 2 and that it is collaterally compressed digital video shown in Fig. 2 and described at col. 14 , lines estopped. bit steam described at col. 14, lines ; and8-10) 8-10)

Structure: input line 50 (as shown in Fig. 2 and described at col. 14 , lines 8-10) means responsive to a Function: selectively and Plaintiff disputes that it is MPT is collaterally Function: selectively and adaptively performing collaterally estopped from estopped from relitigating adaptively performing motion compensated offering a proposed this term. motion decoding of frames of the construction for this term. compensated decoding of compressed digital video Structure: circuit 100 (as frames of the compressed bit stream and fields of the Structure: shown in Fig. 2 and its digital video compressed video bit (a) decoder 54 (as shown internal circuitry as shown bit stream and fields of the and stream in Fig. 2 and described at in Figs. 3, 4A, and 4B and compressed video bit col. 14:10-15, 8:62-68); as described at col. 15 line stream . 22 to col. 18 line 10);

(b) block unformatter 72A circuit 94 (as shown in Fig. Structure: circuit 100 (as (as described at col. 14:56- 2 and the circuitry within shown in Fig. 2 and its 61, 6:59-66, col. 5:66-6:3) circuit 94 as shown and internal circuitry as shown and Fig. 7 (as described at described in Figs. 15, 16A, in Figs. 3, 4A, and 4B and 19:19- 38); and 16B, and the as described at col. 15 line description of circuit 94 22 to col. 18 line 10);

(c) summing element 74 and its internal circuitry set circuit 94 (as shown in (as described at col. 14:60- forth in col. 15 lines 11-28 Fig. 2 and the circuitry

68); and and in col. 25 line 26 to within circuit 94 as shown col. 27 line 34); summing and described in Figs. 15,

(d) estimation circuit 100 element 92; picture stores 16A, and 16B, and the (as shown in Fig. 2, and as 100C and 100A; circuit 54 description of circuit 94 described at col. 15:23- (as shown in Fig. 2, and as and its

42), and described in Fig. 12 and at internal circuitry set forth col. 14 lines 5-68 and col. in col. 15 lines 11-28 and

i. Fig. 3 (as described at 24 lines 47-60); circuit 80 in col. 25 line 26 to col. 27 col. 15:47-col. 16:27, (as shown in Fig. 2 and as line 34); summing element including previous picture described at col. 15 lines 92; picture stores 100C store 100c) or 4-10); and including all and 100A; circuit 54 (as interconnections of these shown in Fig. 2, and as ii. Fig. 4 (as described elements described in Fig. 12 and at at col. 16:28-col. 18:10, col. 14 lines 5-68 and col. including previous picture 24 lines 47-60); store 100c and next picture circuit 80 (as shown in store 100a) or Fig. 2 and as described at col. 15 lines 4-10); and

iii. Fig. 3 and Fig. 4 (as including all described at col. 15:47- interconnections of these 18:10, including previous elements picture store 100c and next picture store 100a) consistent with claims 13, consistent with claims 13, a signal that identifies one 15 and 31 15 and 31 of two or more available modes of

motion compensation motion compensation motion compensation to type signal: type signal: be used in motion

MPT is collaterally compensated a signal that identifies one estopped from relitigating decoding of a video signal of two or more available this term. modes of motion compensation to be used in a signal that identifies one motion compensation of two or more available modes of motion However, plaintiff disputes compensation to be used in that it is collaterally motion compensated estopped. decoding of a video signal consistent with claims 1, 2, consistent with claims 1, 2, 13, 15, 23, 24, 26 and 31 13, 15, 23, 24, 26 and 31

frame: frame:

a complete set of digital a complete picture from a representations for an video sequence image consistent with claims 13, consistent with claims 13, consistent with claims 13, in a manner that selects 15 and 23-26 15 and 23-26 15 and 23-26 from among two or more options

selectively: selectively: selectively:

MPT is collaterally in a manner that selects in a manner that selects estopped from relitigating from among two or more from among two or more this term. options options

in a manner that selects

However, plaintiff disputes from among two or more that it is collaterally options estopped. consistent with claims 13, adaptively: in a manner that changes 26 and 32 MPT is collaterally in response to the motion estopped from relitigating compensation adaptively: this term. type signal

Plaintiff disputes that it is in a manner that changes collaterally estopped from in response to the motion offering a proposed compensation type signal construction for this term.

The term should be construed as "capable of changing in response to a condition" motion compensated motion compensated motion compensated decoding a compressed decoding: decoding: decoding: video signal using data

MPT is collaterally representing decoding a compressed decoding a compressed estopped from relitigating motion vectors that was video signal using data video signal using data this term. produced and transmitted representing motion representing motion during the compression vectors that was produced vectors that was produced decoding a compressed process, where "decoding" and transmitted during the and transmitted during the video signal using data means taking a compression process, compression process, representing motion compressed version of a where "decoding" means where "decoding" means vectors that was produced video signal and taking a compressed taking a compressed and t1616ransmitted reproducing either the version of a video signal version of a video signal during the compression original video signal or an and reproducing either the and reproducing either the process, where "decoding" estimate of the original original video signal or an original video signal or an means taking a video signal estimate of the original estimate of the original compressed version of a video signal video signal video signal and reproducing either the However, plaintiff disputes original video signal or an that it is collaterally estimate of the original estopped. video signal consistent with claims 13, consistent with claims 13, consistent with claims 13, taking a compressed 14, 15 and 17 14, 15 and 17 14, 15 and 17 version of a video signal and reproducing

decoding: decoding: decoding: either the original video

MPT is collaterally signal or an estimate of taking a compressed Plaintiff agrees with estopped from relitigating the original video signal version of a video signal Defendants' proposed this term. and reproducing either the construction. original video signal or an taking a compressed estimate of the original However, plaintiff disputes version of a video signal video signal that it is collaterally and reproducing either the estopped. original video signal or an estimate of the original video signal selectively and adaptively selectively and adaptively performing motion performing motion performing motion compensated decoding in compensated decoding: compensated decoding: a manner that

MPT is collaterally selects from among two or Plaintiff disputes that it is estopped from relitigating more options and that collaterally estopped from this term. changes in offering a proposed response to the motion construction for this term. performing motion compensation type signal compensated decoding in a This term should be manner that selects from construed as "performing among two or more motion compensated options and that changes in decoding in a manner that response to the motion selects from among two or compensation type signal more options and that changes in response to a condition" consistent with claims 13, consistent with claims 13, consistent with claims 13, taking a compressed decoding 14, 15 and 17 14, 15 and 17 14, 15 and 17 version of a video signal and reproducing

decoding: decoding: decoding: either the original video

MPT is collaterally signal or an estimate of taking a compressed taking a compressed estopped from relitigating the original video signal version of a video signal version of a video signal this term. and reproducing either the and reproducing either the original video signal or an original video signal or an taking a compressed estimate of the original estimate of the original version of a video signal video signal video signal and reproducing either the original video signal or an However, plaintiff disputes estimate of the original that it is collaterally video signal estopped.

This element is not Function: adaptive inverse governed by 35 U.S.C. § scanning responsive to a 112(6). coding type signal

If the Court determines Structure: inverse scan that this element must be selector 64 (as shown in construed under 35 U.S.C. Fig. 2 and its internal § 112(6), the Court should circuitry as shown in Fig. construe the element as 14, and as described at col. follows: 14 lines 18-23 and col. 25 lines 9-25; configured to Function: performing choose between at least inverse scanning two of the vertical scan pattern, the zigzag scan Structure: pattern, and the scan

(1) inverse scan selector 64 patterns shown in Figs. 1E (as shown in Fig. 2 and as and 1F) including the DCT described at col. 14:18- coefficients, inter/intra

23); or type signal and coding type signal input to this

(2) Fig. 14 (as described at element, and the inverse col. 25:9-25). ordered DCT coefficients output by this element consistent with claims 14, consistent with claims 14, 15, 31 and 33 31 and 33

adaptive: adaptive:

Plaintiff disputes that it is No construction is collaterally estopped from necessary. This term offering a proposed should be given its construction for this term. ordinary meaning.

This term should be construed consistent with the term "adaptively," defined above, as "capable of changing in response to a condition" coding type: coding type:

consistent with claims 1, consistent with claims 1, 14, 17, 23 and 26 14, 17, 23 and 26

frame or field coding frame coding or interlaced field coding

consistent with claims 13, consistent with claims 13, consistent with claims 13, taking a compressed decoding 14, 15 and 17 14, 15 and 17 14, 15 and 17 version of a video signal and reproducing

decoding: decoding: decoding: either the original video

MPT is collaterally signal or an estimate of taking a compressed taking a compressed estopped from relitigating the original video signal version of a video signal version of a video signal this term. and reproducing either the and reproducing either the original video signal or an original video signal or an taking a compressed estimate of the original estimate of the original version of a video signal video signal video signal and reproducing either the original video signal or an However, plaintiff disputes estimate of the original that it is collaterally video signal estopped. means responsive to a Function: producing an Plaintiff disputes that it is MPT is collaterally Function: producing an adaptive motion collaterally estopped from estopped from relitigating adaptive motion compensated estimate of a offering a proposed this term. compensated estimate of a decoded video signal construction for this term. decoded video signal

Structure: circuit 100 (as shown in Fig. 2 and its Structure: circuit 100 (as Structure: internal circuitry as shown shown in Fig. 2 and its estimation circuit 100 (as in Figs. 3, 4A, and 4B and internal circuitry as shown shown in Fig. 2 and as as described at col. 15 line in Figs. 3, 4A, and 4B and ; described at col. 15:23-42) 22 to col. 18 line 10); and as described at col. and picture stores 100C and 15 line 22 to col. 18 line 100A; including 10); [ ] and picture stores

i. Fig. 3 (as described at interconnections of these 100C and 100A; including col. 15:47-col. 16:27, elements interconnections of these including previous picture elements store 100c) or

ii. Fig. 4 (as described at col. 16:28-col. 18:10, including previous picture store 100c and next picture store 100a), or

iii. Fig. 3 and Fig. 4 (as described at col. 15:47-18:10, including previous picture store 100c and next picture store 100a). consistent with claims 13, consistent with claims 13, consistent with claims 13, in a manner that selects 15 and 23-26 15 and 23-26 15 and 23-26 from among two or more options

selectively: selectively: selectively:

MPT is collaterally in a manner that selects in a manner that selects estopped from relitigating from among two or more from among two or more this term. options options

in a manner that selects

However, plaintiff disputes from among two or more that it is collaterally options estopped. frame motion vectors: frame motion vectors: frame motion vectors: motion vectors for

MPT is collaterally producing signals motion vectors for motion vectors for estopped from relitigating representing frames of producing signals producing signals this term. picture elements representing frames of representing frames of picture elements picture elements motion vectors for producing signals However, plaintiff disputes representing frames of that it is collaterally picture elements estopped. consistent with claims 1, 2, consistent with claims 1, 2, 13, 15, 23, 24, 26 and 31 13, 15, 23, 24, 26 and 31

frame: frame:

a complete set of digital a complete picture from a representations for an video sequence image consistent with claims 13, consistent with claims 13, a signal that identifies one 15 and 31 15 and 31 of two or more available modes of motion compensation motion compensation motion compensation to type signal: type signal: be used in motion

MPT is collaterally compensated a signal that identifies one estopped from relitigating decoding of a video signal of two or more available this term. modes of motion compensation to be used in a signal that identifies one motion compensation of two or more available modes of motion However, plaintiff disputes compensation to be used in that it is collaterally motion compensated estopped. decoding of a video signal decoded video signal: decoded video signal: decoded video signal: a video signal that has

MPT is collaterally been decoded a video signal that has a video signal that has estopped from relitigating been decoded been decoded. this term.

However, plaintiff disputes a video signal that has that it is collaterally been decoded estopped. consistent with claims 14, adaptive: capable of changing in 15, 31 and 33 MPT is collaterally response to the motion estopped from relitigating compensation adaptive: this term. type signal

Plaintiff disputes that it is capable of changing in collaterally estopped from response to the motion offering a proposed compensation type signal construction for this term.

This term should be construed consistent with the term "adaptively," defined above, as "capable of changing in response to a condition" field motion vectors: field motion vectors: field motion vectors: motion vectors for

MPT is collaterally producing signals motion vectors for motion vectors for estopped from relitigating representing fields of producing signals producing signals this term. picture elements. representing fields of representing fields of picture elements picture elements motion vectors for producing signals However, plaintiff disputes representing fields of that it is collaterally picture elements estopped. means responsive to the Function: producing a Plaintiff disputes that it is MPT is collaterally Function: producing a decoded estimate error collaterally estopped from estopped from relitigating decoded estimate error signal offering a proposed this term. signal construction for this term.

Function: producing a Structure: (as shown in Function: producing a decoded estimate error Figs. 2, 7,12, 13, and 14 decoded estimate error signal and as described signal at col.14 lines 5-68, at col. Structure: Structure: (as shown in 19 lines 19-38, and at col.

Figs. 2, 7, 12, 13, and 14 24 line 47 to col. 25 line demultiplexer 54 (as lines 5-68, at col. 19 lines (see Fig. 14 for internal shown in Fig. 2 and as 19-38, and at col. 24 line circuitry); circuit 66 (see described at col.14:10-18, 47 to col. 25 line 25): Fig. 13 for internal col. 8:62-9:2, col. 9:14- circuit 54; circuit 64 (see circuitry); circuit 72; and

22); Fig. 14 for internal circuit 72A (see Fig. 7 for circuitry); circuit 66 (see internal circuitry); and all

(b) inverse scan selector 64 Fig. 13 for internal interconnections between (as shown in Fig. 2 and as circuitry); circuit 72; and these elements described at col. 14:18- circuit 72A (see Fig. 7 for

23); internal circuitry); and all interconnections between

(c) visibility matrix and these elements dequantizer 66 (as shown in Fig. 2 and as described at col. 14:23-31, col. 7:27-45, col. 5:66- 6:3);

(d) inverse discrete cosine transform circuit 72 (as shown in Fig. 2 and as described at col. 14:45-50); and

(e) block unformatting circuit 72A (as shown in Fig. 2 and as described at col.14:56-61, col. 5:66-6:3, and col. 6:59-66, and Fig. 7 as described at col. 19:19-38).

means responsive to the Function: producing a Plaintiff disputes that it is MPT is collaterally Function: producing a decoded video signal collaterally estopped from estopped from relitigating decoded video signal offering a proposed this term. construction for this term. Structure: (as shown in

Function: producing a Fig. 2 and as described at . Function: producing a decoded video signal col. 14 lines 50-68): decoded video signal summing element 74 and

Structure: (as shown in including all inputs and Structure: summing Fig. 2 and as described at outputs of this element element 74 (as shown in col. 14 lines 50-68): Fig. 2 and as described at summing element 74 and col. 14:50-68) including all inputs and outputs of this element consistent with claims 13, consistent with claims 13, consistent with claims 13, taking a compressed decoding 14, 15 and 17 14, 15 and 17 14, 15 and 17 version of a video signal and reproducing

decoding: decoding: decoding: either the original video

MPT is collaterally signal or an estimate of taking a compressed taking a compressed estopped from relitigating the original video signal version of a video signal version of a video signal this term. and reproducing either the and reproducing either the original video signal or an original video signal or an taking a compressed estimate of the original estimate of the original version of a video signal video signal video signal and reproducing either the original video signal or an However, plaintiff disputes estimate of the original that it is collaterally video signal estopped.

Function: receiving a Function: receiving a compressed digital video compressed digital video signal signal comprising at least one DC coefficient Structure: input line 50 (as representation related to ; shown in Fig. 2 and the video signal described at col. 14:8-10) Structure: variable word length decoder and demultiplexer 54 (as shown in Fig. 2 and as described at col. 14, lines 10-18, and the inverse of the operation of the encoder and multiplexer 24, as described at col. 8, line 36 -- col. 9 line 34, col. 12 lines 54-56, col. 12, lines 60-64, col. 13, lines 26-28, col. 13, line 63 -- col. 14, line 1) including the bit stream input to this element

means for producing an Function: producing an Function: producing an estimated DC coefficient estimated DC coefficient in response to a coding ; and, Structure: prediction type signal circuit 60 (as shown in Fig. 2 and as described at col. Structure: intra DC 14:37-40, col. 5:66-6:3) coefficient prediction circuit 60 (as shown in Fig. 2, as described at col. 14, lines 36-39, and configured to operate in accordance with Fig. 8 (as described at col. 19, line 39 - col. 20, line 64) and Fig. 9 (as described at col. 20, line 65 -- col. 21, line

49)) including the intra DC coefficient signal and coding type signal input to this element, and the intra DC coefficient prediction signal output by this element

means for producing a Function: producing a Function: producing a decoded DC coefficient decoded DC coefficient signal signal in response to the

DC coefficient Structure: summing representation and the . element 58 (as shown in estimated DC coefficient

Fig. 2, and as described at col. 14:32-40) Structure: summing element 58 (as shown in Fig. 2 and as described at col. 14, lines 31-39) including the differential DC coefficient signal and intra DC coefficient prediction signal input to this element, and the intra DC transform coefficient signal output by this element consistent with claims 1, consistent with claims 1, 14, 17, 23 and 26 14, 17, 23 and 26

coding type: coding type:

frame or field coding frame coding or interlaced field coding

Structure: input line 10 (as Function: receiving a Function: receiving a shown in Fig. 1 and digital video input signal digital video input signal described at col. 3:61-65) comprising a succession of

Structure: input line 10 (as digital representations of shown in Fig. 1 and picture elements making described at col. 3:61-65) up at least one video frame, the frame comprising a plurality of fields

Structure: input line 10 (as shown in Fig. 1 and described at col. 3:61-65) consistent with claims 23, consistent with claims 2, 24 and 31 23, 24 and 31

fields: fields:

subsets of a frame a set of odd horizontal consisting of groups of scan lines and a set of even contiguous picture horizontal scan lines that elements together make up a complete picture from a video sequence consistent with claims 1, 2, consistent with claims 1, 2, 13, 15, 23, 24, 26 and 31 13, 15, 23, 24, 26 and 31

frame: frame:

a complete set of digital a complete picture from a representations for an video sequence image Function: selectively Function: selectively Function: selectively encoding groups of digital encoding groups of digital encoding groups of digital representations in the input representations in the input representations in the input signal relating to one of signal relating to one of signal relating to one of frames and fields frames and fields frames and fields

Structure: Structure:

(a) summing element 11 summing element 11 (as (as shown in Fig. 1 and as shown in Fig. 1A and as described at col. 6:6-22); described at col. 6 lines 6 -- 22) including the digital

(b) block formatting circuit video input signal and 15A (as shown in Fig. 1 estimate of the video input and as described at col. signal input to this 6:59-66, col. 5:66-6:3), element, and the signal and Fig. 6 (as described at output by this element col. 19:1-18); relating to the error between the digital video

(c) discrete cosine input signal and the transform circuit 16 (as estimate signal; shown in Fig. 1 and as described at col. 7:5-col. block formatting circuit 7:19); and 15a (as shown in Fig. 1A and its internal circuitry as

(d) visibility matrix shown in Fig. 6, and as selector and perceptual described at col. 6, line 59 quantizer 19 (as shown in - col. 7, line 14 and col. Fig. 1 and as described at 19, lines 1-18) including col. 7:27-45, col. 5:66-6:3) the coding type signal and or Fig. 13 (as described at the digital video input col. 24:61-col. 25:8). signal or the estimate error signal input to this element, and the blocks output by this element;

discrete cosine transform circuit 16 (as shown in Fig. 1A and as described at col. 6, line 62 -- col. 7, line 19 and col. 7, lines 27-30) including the blocks input to this element and the transform coefficients output by this element;

visibility matrix selector and perceptual quantizer 19 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 13, and as described at col. 7, line 27 - col. 8, line 5, col. 9, lines 19-22, col. 9, lines 34-37, col. 13, lines 22-25, and col. 24, line 61 - col. 25, line 8) including the transform coefficients, coding type signal, picture type signal, digital input signal, estimate error signal, inter/intra type signal, and fullness signal input to this element, and the quantized transform coefficients and quantization parameter output by this element; scan selector circuit 23 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 14, and as described at col. 8, line 36 -- col. 9, line 2 and col. 25, lines 9-25) including the quantized transform coefficients and coding type signal input to this element, and the ordered quantized transform coefficients output by this element; and

variable word length and fixed word length encoder and multiplexer 24 (as shown in Fig. 1A and as described at col. 8, line 36 -- col. 9 line 34, col. 12 lines 54-56, col. 12, lines 60-64, col. 13, lines 26-28, and col. 13, line 63 -- col. 14, line 1) including the ordered quantized transform coefficients, block class signal, quantization parameter, picture type signal, differential dc coefficient prediction, variable word length table select signal and differential motion vectors input to this element, and the coded transform coefficients output by this element; including all interconnections between these elements consistent with claims 23, consistent with claims 2, 24 and 31 23, 24 and 31

fields: fields:

subsets of a frame a set of odd horizontal consisting of groups of scan lines and a set of even contiguous picture horizontal scan lines that elements together make up a complete picture from a video sequence consistent with claims 1, consistent with claims 1, 23, 24, 25 and 31 23, 24, 25 and 31

groups of digital groups of digital representations: representations:

This term should be given a number of macroblocks, its plain meaning to one of submacroblocks, and skill in the art, and blocks of picture elements, therefore does not require for example, 16x16 construction. macroblocks of picture elements, 16x8 subblocks of picture elements, and 8x8 blocks of picture elements consistent with claims 13, consistent with claims 13, consistent with claims 13, in a manner that selects 15 and 23-26 15 and 23-26 15 and 23-26 from among two or more options

selectively: selectively: selectively:

MPT is collaterally in a manner that selects in a manner that selects estopped from relitigating from among two or more from among two or more this term. options options

in a manner that selects

However, plaintiff disputes from among two or more that it is collaterally options estopped. consistent with claims 1, 2, consistent with claims 1, 2, 13, 15, 23, 24, 26 and 31 13, 15, 23, 24, 26 and 31

frame: frame:

a complete set of digital a complete picture from a representations for an video sequence image

means responsive to the Function: ascertain a Function: ascertain a predetermined predetermined characteristic present in characteristic present in the input signal the input signal prior to Structure: encoding for producing a field/frame encoding type

(1) block adaptive signal which directs the frame/field coding encoding means to encode analyzer 14 (as shown in a selected one, but not Fig. 1 and as described at both, of the groups of col. 6:22-58, col. 5:66- digital representations 6:3); and relating to frames and fields in the input signal

(2) submacro block vertical correlation Structure: . computer 244, submacro switching element 13a (as block vertical correlation shown in Fig. 1A and as computer 252, and macro described at col. 13, lines block vertical correlation 19-22) including the computer 236 (as shown in inter/intra type coding Fig. 5 and as described at signal that controls this col. 18:14-20, 18:27-51). element; and

block adaptive frame/field coding analyzer 14 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 5, and as described at col. 6, lines 22-58 and col. 18, lines 11-68) including the video input signals or the estimate error signal input to this element, and the coding type signal output by this element; and including the interconnection between these elements field/frame coding type: field/frame coding type:

consistent with claims 1, consistent with claims 1, 14, 17, 23 and 26 14, 17, 23 and 26

frame or field coding frame coding or interlaced field coding

consistent with claims 1, consistent with claims 1, 23, 24, 25 and 31 23, 24, 25 and 31

groups of digital groups of digital representations: representations:

This term should be given a number of macroblocks, its plain meaning to one of submacroblocks, and skill in the art, and blocks of picture elements, therefore does not require for example, 16x16 construction. macroblocks of picture elements, 16x8 subblocks of picture elements, and 8x8 blocks of picture elements

Function: selectively Function: selectively Function: selectively transforming first groups transforming first groups transforming first groups of digital representations of digital representations of digital representations relating to one of frames of relating to one of frames of relating to one of frames of picture elements and fields picture elements and fields picture elements and fields of picture elements into of picture elements into of picture elements into second groups of digital second groups of digital second groups of digital representations relating to representations relating to representations relating to one of frames of picture one of frames of picture one of frames of picture elements and fields of elements and fields of elements and fields of picture elements picture element picture elements

Structure: Structure: . (a) block formatting circuit switching element 13a (as

15A (as shown in Fig. 1 shown in Fig. 1A and as and as described at col. described at col. 13, lines 6:59-66, col. 5:66-6:3) and 19-22) including the Fig. 6 (as described at col. inter/intra type coding 19:1-18); and signal that controls this element;

(c) discrete cosine transform circuit 16 (as block adaptive frame/field shown in Fig. 1 and as coding analyzer 14 (as described at col. 7:5-col. shown in Fig. 1A and its 7:19). internal circuitry as shown in Fig. 5, and as described at col. 6, lines 22 -- 58, col. 7, lines 38-40, and col. 18, lines 11-68) including the digital video input signal or the estimate error signal input to this element, and the coding type signal output by this element;

block formatting circuit 15a (as shown in Fig. 1A and its internal circuitry as shown in Fig. 6, and as described at col. 6, line 59 - col. 7, line 14 and col. 19, lines 1-18), including the coding type signal and the digital video input signal or the estimate error signal input to this element, and the blocks output by this element; and

discrete cosine transform circuit 16 (as shown in Fig. 1A and as described at col. 6, line 62 -- col. 7, line 19 and col. 7, lines 27-30), including the blocks input to this element and the transform coefficients output by this element; including all interconnections between these elements consistent with claims 1, 2, consistent with claims 1, 2, 13, 15, 23, 24, 26 and 31 13, 15, 23, 24, 26 and 31 rame:

a complete set of digital a complete picture from a representations for an video sequence image consistent with claims 23, consistent with claims 2, 24 and 31 23, 24 and 31 fields: fields:

subsets of a frame a set of odd horizontal consisting of groups of scan lines and a set of even contiguous picture horizontal scan lines that elements together make up a complete picture from a video sequence consistent with claims 1, consistent with claims 1, 23, 24, 25 and 31 23, 24, 25 and 31

groups of digital groups of digital representations: representations:

This term should be given a number of macroblocks, its plain meaning to one of submacroblocks, and skill in the art, and blocks of picture elements, therefore does not require for example, 16x16 construction. macroblocks of picture elements, 16x8 subblocks of picture elements, and 8x8 blocks of picture elements

consistent with claims 13, consistent with claims 13, consistent with claims 13, in a manner that selects 15 and 23-26 15 and 23-26 15 and 23-26 from among two or more options

selectively: selectively: selectively:

MPT is collaterally in a manner that selects in a manner that selects estopped from relitigating from among two or more from among two or more this term. options options

in a manner that selects

However, plaintiff disputes from among two or more that it is collaterally options estopped.

Function: transforming Function: transforming Function: transforming groups of digital groups of digital groups of digital transforming representations in the input representations in the input representations in the input means for video signal into groups of video signal into groups of video signal into groups of frequency coefficients frequency coefficients frequency coefficients related to the input video related to the input video related to the input video signal signal signal

Structure: discrete cosine Structure: discrete cosine transform circuit 16 (as transform circuit 16 (as shown in Fig. 1 and as shown in Fig. 1A and as described at col. 7:5-col. described at col. 6, line 62 7:19) -- col. 7, line 19 and col. 7, lines 27-30) including the blocks input to this element and the transform coefficients output by this element consistent with claims 1, consistent with claims 1, 23, 24, 25 and 31 23, 24, 25 and 31

groups of digital groups of digital representations: representations:

This term should be given a number of macroblocks, its plain meaning to one of submacroblocks, and skill in the art, and blocks of picture elements, therefore does not require for example, 16x16 construction. macroblocks of picture elements, 16x8 subblocks of picture elements, and 8x8 blocks of picture elements consistent with claims 13, consistent with claims 13, consistent with claims 13, in a manner that selects 15 and 23-26 15 and 23-26 15 and 23-26 from among two or more options

selectively: selectively: selectively:

MPT is collaterally in a manner that selects in a manner that selects estopped from relitigating from among two or more from among two or more this term. options options

in a manner that selects

However, plaintiff disputes from among two or more that it is collaterally options estopped.

Function: adaptively Function: adaptively performing a discrete performing a discrete transforming cosine transform of the cosine transform of the input video signal input video signal in response to the frame/field Structure: encoding type signal

(a) block formatting circuit Structure: block formatting 15A (as shown in Fig. 1 circuit 15a (as shown in and as described at col. Fig. 1A and its internal 7:5-col. 7:10, col. 5:66- circuitry as shown in Fig. 6:3) and Fig. 6 (as 6, and as described at col. described at col. 19:1-18); 6, line 59 to col. 7, line 14 and and col. 19, lines 1-18) including the coding type

(b) discrete cosine signal and the digital video transform circuit 16 (as input signal or the estimate shown in Fig. 1 and as error signal input to this described at col. 7:5-col. element, and the blocks 7:19) output by this element; and

discrete cosine transform circuit 16 (as shown in Fig. 1Aand as described at col. 6, line 62 -- col. 7, line 19 and col. 7, lines 27-30), including the blocks input to this element and the transform coefficients output by this element; including all interconnections between these elements consistent with claims 13, consistent with claims 26 26 and 32 and 32

adaptively: adaptively:

Plaintiff disputes that it is No construction is collaterally estopped from necessary. This term offering a proposed should be given its construction for this term. ordinary meaning.

The term should be construed as "capable of changing in response to a condition" consistent with claims 1, 2, consistent with claims 1, 2, 13, 15, 23, 24, 26 and 31 13, 15, 23, 24, 26 and 31

frame: frame:

a complete set of digital a complete picture from a representations for an video sequence image frame/field coding type: frame/field coding type:

consistent with claims 1, consistent with claims 1, 14, 17, 23 and 26 14, 17, 23 and 26

frame or field coding frame coding or interlaced field coding

This term should be given a vertical correlation its plain meaning to one of between successive skill in the art, and horizontal lines of a frame a therefore does not require macroblock and a vertical construction. correlation between evenly numbered horizontal lines and a vertical correlation between oddly numbered horizontal lines in corresponding field submacroblocks Function: performing Function: performing Function: performing motion compensation motion compensation motion compensation means

Structure: Structure: motion estimation circuit 37 (as

(a) summing element 11 shown in Fig. 1B and as (as shown in Fig. 1 and as described at col. 10, lines described at col. 6:6-22); 11-18, col. 12, lines 10-16, and col. 12, lines 37-42)

(b) prediction selector 38B including the digital video (as shown in Fig. 1 and as input signal, signals described at col. 10:23-48, relating to the contents of col. 12:10-12:36) and the stores 36a and 36c, and the picture type signal i. Fig. 3 (as described at input to this element, and col. 15:47-col. 16:27, the motion vectors output including previous picture by this element; store 36c) or estimation circuit 38 (as ii. Fig. 4 (as described shown in Fig. 1B and its at col. 16:28-col. 18:10, internal circuitry as shown including previous picture in Figs. 3, 4A, and 4B, and store 36c and next picture as described at col. 10, line store 36a), or 14 -- col. 12, line 36, and col. 15 line 47 to col. 18

iii. Fig. 3 and Fig. 4 (as line 10) including the described at col. 15:47- motion vectors, picture 18:10, including previous type signal, and contents picture store 36c and next of the next picture store picture store 36a). 36a and the previous picture store 36c, input to this element, and the motion compensation type signal and estimate of the video input signal output by this element; and

next picture store 36a and previous picture store 36c (as shown in Figs. 1B, 3, 4A, and 4B, and as described at col. 9, line 68 -- col. 10, line 10, col. 15, lines 55-57, col. 16, lines 35-37, and col. 16, lines 40-42) including the frames of video data input to and output by these elements; including all interconnections between these elements Function: quantizing the Function: quantizing the Function: quantizing the digital video input signal digital video input signal digital video input signal means

Structure: visibility matrix Structure: visibility matrix selector and perceptual selector and perceptual quantizer 19 (as shown in quantizer 19 (as shown in Fig. 1 and as described at Fig. 1A and its internal col. 7:27-45, col. 5:66- circuitry as shown in Fig. 6:3), or Fig. 13 (as 13, and as described at col. described at col. 24:61-col. 7, line 27 - col. 8, line 5, 25:8) col. 9, lines 19-22, col. 9, lines 34-37, col. 13, lines 22-25, and col. 24, line 61 to col. 25, line 8) including the transform coefficients, coding type signal, picture type signal, digital input signal, estimate error signal, inter/intra type signal, and fullness signal input to this element, and the quantized transform coefficients and quantization parameter output by this element Function: performing Function: performing Function: performing variable word length variable word length variable word length means encoding encoding encoding

Structure: Structure: variable word encoder and multiplexer length choice analyzer 23a 24 (as shown in Fig. 1 and (as shown in Fig. 1A and as described at col. 8:62- its internal circuitry as 68, col. 9:14-22) shown in Fig. 10, configured to use the tables shown in Figs. 1G-1N, and as described at col. 9, lines 3-13) including the ordered quantized transform coefficients and picture type signal input to this element, and the variable word length table select signal output by this element;

scan selector circuit 23 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 14, and as described at col. 8, line 36 -- col. 9, line 2 and col. 25, lines 9-25) including the quantized transform coefficients and coding type signal input to this element, and the ordered quantized transform coefficients output by this element; and

variable word length and fixed word length encoder and multiplexer 24 (as shown in Fig. 1A and as described at col. 8, line 36 -- col. 9 line 34, col. 12 lines 54-56, col. 12, lines 60-64, col. 13, lines 26-28, and col. 13, line 63 -- col. 14, line 1) including the ordered quantized transform coefficients, block class signal, quantization parameter, picture type signal, transform coefficients, differential dc coefficient prediction, variable word length table select signal and differential motion vectors input to this element, and the coded transform coefficients output by this element; including all interconnections between these elements Structure: input line 10 (as Function: receiving a Function: receiving a shown in Fig. 1 and digital video input signal digital video input signal described at col. 3:61-65) comprising a succession of

Structure: input line 10 (as digital representations of shown in Fig. 1 and picture elements making described at col. 3:61-65) up at least one video frame, the frame comprising a plurality of fields

Structure: input line 10 (as shown in Fig. 1 and described at col. 3:61-65) consistent with claims 23, consistent with claims 2, 24 and 31 23, 24 and 31

fields: fields:

subsets of a frame a set of odd horizontal consisting of groups of scan lines and a set of even contiguous picture horizontal scan lines that elements together make up a complete picture from a video sequence

performing Function: performing Function: performing Function: performing adaptive motion adaptive motion adaptive motion compensated encoding of compensated encoding of compensated encoding of groups of digital groups of digital groups of digital representations in the input representations in the input representations in the input signal relating to one of signal relating to one of signal relating to one of frames and fields in the frames and fields in the frames and fields in the

; and, input signal input signal input signal

Structure Structure:

(a) prediction selector 38B motion vector prediction (as shown in Fig. 1 and as circuit 41 (as shown in Fig. described at col. 10:23-48, 1A and the circuitry within col. 12:10-12:36) and circuit 41 as shown and described in Figs. 15, 16A,

i. Fig. 3 (as described at and 16B, and the col. 15:47-col. 16:27, description of circuit 41 including previous picture and its internal circuitry set store 36c) or forth in col. 12 lines 39-49 and in col. 25 line 26 - col.

ii. Fig. 4 (as described at 27 line 34); col. 16:28-col. 18:10, including previous picture variable word length and store 36c and next picture fixed word length encoder store 36a), or and multiplexer 24 (as shown in Fig. 1A and as

iii. Fig.3 and Fig. 4 (as described at col. 8, line 36 described at col. 15:47- -- col. 9 line 34, col. 12 18:10, including previous lines 54-56, col. 12, lines picture store 36c and next 60-64, col. 13, lines 26-28, picture store 36a); and col. 13, line 63 -- col.

14, line 1) including the

(b) summing element 11 ordered quantized (as shown in Fig. 1 and as transform coefficients, described at col. 6:6-22); block class signal, quantization parameter, the

(c) block formatting circuit picture type signal, and 15A (as shown in Fig. 1 differential motion vectors and as described at col. input to this element, and 6:59-66, col. 5:66-6:3), the coded transform and Fig. 6 (as described at coefficients output by this col. 19:1-18); element; and

(d) discrete cosine summing element 42 (as transform circuit 16 (as shown in Fig. 1A and as shown in Fig. 1 and as described at col. 12 lines described at col. 7:5-col. 50-53) including the 7:10); and motion vector estimate and the motion vector signal

(e) visibility matrix input to this element, and selector and perceptual the differential motion quantizer 19 (as shown in vector signal output by this Fig. 1 and as described at element; including all col. 7:27-45, col. 5:66- interconnections between 6:3) or Fig. 13 (as these elements described at col. 24:61-col. 25:8). consistent with claims 14, consistent with claims 14, 15, 31 and 33 31 and 33

adaptive: adaptive:

Plaintiff disputes that it is No construction is collaterally estopped from necessary. This term offering a proposed should be given its construction for this term. ordinary meaning.

This term should be construed consistent with the term "adaptively," defined above, as "capable of changing in response to a condition" consistent with claims 1, 2, consistent with claims 1, 2, 13, 15, 23, 24, 26 and 31 13, 15, 23, 24, 26 and 31

frame: frame:

a complete set of digital a complete picture from a representations for an video sequence image consistent with claims 1, consistent with claims 1, 23, 24, 25 and 31 23, 24, 25 and 31

groups of digital groups of digital representations: representations:

This term should be given a number of macroblocks, its plain meaning to one of submacroblocks, and skill in the art, and blocks of picture elements, therefore does not require for example, 16x16 construction. macroblocks of picture elements, 16x8 subblocks of picture elements, and 8x8 blocks of picture elements

means responsive to the Function: producing a Function: producing a motion compensation type motion compensation type signal signal for controlling the adaptive motion

Structure: compensated encoding motion compensated means prediction analyzer 38A (as shown in Fig. 1 and as Structure: motion described at col. 12:25- estimation circuit 37 (as

30). shown in Fig. 1B and as described at col. 10, lines 11-18, col. 12, lines 10-16, and col. 12, lines 37-42) including the digital video input signal, signals relating to the contents of the stores 36a and 36c, and the picture type signal input to this element, and the motion vectors output by this element; estimation circuit 38 (as shown in Fig. 1B and its internal circuitry as shown in Figs. 3, 4A, and 4B, and as described at col. 10, line 14 -- col. 12, line 36, and col. 15 line 47 - col. 18 line 10) including the motion vectors, picture type signal, and contents of the next picture store 36a and the previous picture store 36c, input to this element, and the motion compensation type signal and estimate of the video input signal output by this element; and

next picture store 36a and previous picture store 36c (as shown in Figs. 1B, 3, 4A, and 4B, and as described at col. 9, line 68 -- col. 10, line 10, col. 15, lines 55-57, col. 16, lines 35-37, and col. 16, lines 40-42) including the frames of video data input to and output by these elements; including all interconnections between these elements consistent with claims 13, consistent with claims 13, a signal that identifies one 15 and 31 15 and 31 of two or more available modes of

motion compensation motion compensation motion compensation to type signal: type signal: be used in motion compensated a signal that identifies one MPT is collaterally decoding of a video signal of two or more available estopped from relitigating modes of motion this term. compensation to be used in motion compensation a signal that identifies one of two or more available However, plaintiff disputes modes of motion that it is collaterally compensation to be used in estopped. motion compensated decoding of a video signal means for receiving Function: receiving digital Function: receiving a Function: receiving digital video input signals digital video input signal video input signals

Structure: input line 10 (as Structure: input line 10 (as Structure: input line 10 (as shown in Fig. 1 and shown in Fig. 1 and shown in Fig. 1 and described at col. 3:61-65) described at col. 3:61-65) described at col. 3:61-65) means for performing Function: performing Function: performing variable word length variable word length encoding adaptively encoding adaptively in response to the video input Structure: signals a) variable word length Structure: choice analyzer 23A (as block formatting circuit shown in Fig. 1 and 15a (as shown in Fig. 1A described at col. 9:3-8 and and its internal circuitry as as shown in Figure 10 and shown in Fig. 6, and as as described at col. 21:50- described at col. 6, line 59 23:23), and encoder and - col. 7, line 14 and col. multiplexer 24 (as shown 19, lines 1-18) including in Fig. 1 and as described the coding type signal and at col. 9:8-30); see also the digital video input col. 4:65-68; or signal or the estimate error signal input to this

b) encoder and multiplexer element, and the blocks 24 (as shown in Fig. 1 and output by this element; as described at col. 9:8-30) and discrete cosine transform circuit 16 (as shown in Fig.

i. scan selector 23 (as 1A and as described at col. described at col. 8:36- 6, line 62 -- col. 7, line 19 9:8); or and col. 7, lines 27-30) including the blocks input

ii. Fig. 14 (as described at to this element and the col. 25:9-25) transform coefficients output by this element;

visibility matrix selector and perceptual quantizer 19 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 13, and as described at col. 7, line 27 - col. 8, line 5, col. 9, lines 19-22, col. 9, lines 34-37, col. 13, lines 22-25, and col. 24, line 61 - col. 25, line 8) including the transform coefficients, coding type signal, picture type signal, digital input signal, estimate error signal, inter/intra type signal, and fullness signal input to this element, and the quantized transform coefficients and quantization parameter output by this element;

variable word length choice analyzer 23a (as shown in Fig. 1A and its internal circuitry as shown in Fig. 10, configured to use the tables shown in Figs. 1G-1N, and as described at col. 9, lines 3-13) including the ordered quantized transform coefficients and picture type signal input to this element, and the variable word length table select signal output by this element;

scan selector circuit 23 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 14, and as described at col. 8, line 36 -- col. 9, line 2 and col. 25, lines 9-25) including the quantized transform coefficients and coding type signal input to this element, and the ordered quantized transform coefficients output by this element; and

variable word length and fixed word length encoder and multiplexer 24 (as shown in Fig. 1A and as described at col. 8, line 36 -- col. 9 line 34, col. 12 lines 54-56, col. 12, lines 60-64, col. 13, lines 26-28, and col. 13, line 63 -- col. 14, line 1) including the ordered quantized transform coefficients, block class signal, quantization parameter, picture type signal, transform coefficients, differential dc coefficient prediction, variable word length table select signal and differential motion vectors input to this element, and the coded transform coefficients output by this element; including all interconnections between these elements consistent with claims 13, consistent with claims 26 26 and 32 and 32

adaptively: adaptively:

Plaintiff disputes that it is No construction is collaterally estopped from necessary. This term offering a proposed should be given its construction for this term. ordinary meaning.

The term should be construed as "capable of changing in response to a condition"

Function: transforming the Function: transforming the Function: transforming the digital video input signals digital video input signals digital video input signals into transform coefficients into transform coefficients into transform coefficients means of transforming

Structure: discrete cosine Structure: block formatting transform circuit 16 (as circuit 15a (as shown in ; shown in Fig. 1 and as Fig. 1A and its internal described at col. 7:5-7:30) circuitry as shown in Fig.

6, and as described at col. 6, line 59 - col. 7, line 14 and col. 19, lines 1-18), including the coding type signal and the digital video input signal or the estimate error signal input to this element and the blocks output by this element; and

discrete cosine transform circuit 16 (as shown in Fig. 1A and as described at col. 6, line 62 -- col. 7, line 19 and col. 7, lines 27-30), including the blocks input to this element and the transform coefficients output by this element; including the interconnection between these elements encoding means being Function: performing The proper term for adaptive variable word construction is: length coding

"a means for performing

Structure: variable world length encoding adaptively in

a) variable word length response to the video choice analyzer 23A (as input signals" shown in Fig. 1 and . described at col. 9:3-8 "the encoding means and as shown in Figure 10 being responsive to the and as described at col. transform coefficients for 21:50- 23:23), and encoder performing adaptive and multiplexer 24 (as variable word length shown in Fig. 1 and as encoding" described at col. 9:8-30); see also col. 4:65-68; Function: or performing variable word length encoding adaptively

b) encoder and multiplexer in response to the video 24 (as shown in Fig. 1 and input signals and the as described at col. 9:8-30) transform coefficients and

i. scan selector 23 Structure: (as described at block formatting circuit col. 8:36- 9:8); or 15a (as shown in Fig. 1A

ii. Fig. 14 (as and its internal circuitry as described at col. shown in Fig. 6, and as 25:9-25) described at col. 6, line 59

- col. 7, line 14 and col. 19, lines 1-18) including the coding type signal and the digital video input signal or the estimate error signal input to this element, and the blocks output by this element;

discrete cosine transform circuit 16 (as shown in Fig. 1A and as described at col. 6, line 62 -- col. 7, line 19 and col. 7, lines 27-30) including the blocks input to this element and the transform coefficients output by this element;

visibility matrix selector and perceptual quantizer 19 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 13, and as described at col. 7, line 27 - col. 8, line 5, col. 9, lines 19-22, col. 9, lines 34-37, col. 13, lines 22-25, and col. 24, line 61 - col. 25, line 8) including the transform coefficients, coding type signal, picture type signal, digital input signal, estimate error signal, inter/intra type signal, and fullness signal input to this element, and the quantized transform coefficients and quantization parameter output by this element;

variable word length choice analyzer 23a (as shown in Fig. 1A and its internal circuitry as shown in Fig. 10, configured to use the tables shown in Figs. 1G- 1N, and as described at col. 9, lines 3-13) including the ordered quantized transform coefficients and picture type signal input to this element, and the variable word length table select signal output by this element; scan selector circuit 23 (as shown in Fig. 1A and its internal circuitry as shown in Fig. 14, and as described at col. 8, line 36 -- col. 9, line 2 and col. 25, lines 9-25) including the quantized transform coefficients and coding type signal input to this element, and the ordered quantized transform coefficients output by this element; and

variable word length and fixed word length encoder and multiplexer 24 (as shown in Fig. 1A and as described at col. 8, line 36 -- col. 9 line 34, col. 12 lines 54-56, col. 12, lines 60-64, col. 13, lines 26-28, and col. 13, line 63 -- col. 14, line 1) including the ordered quantized transform coefficients, block class signal, quantization parameter, picture type signal, transform coefficients, differential dc coefficient prediction, variable word length table select signal and differential motion vectors input to this element, and the coded transform coefficients output by this element; including all interconnections between these elements consistent with claims 14, consistent with claims 14, 15, 31 and 33 31 and 33

adaptive: adaptive:

Plaintiff disputes that it is No construction is collaterally estopped from necessary. This term offering a proposed should be given its construction for this term. ordinary meaning.

This term should be construed consistent with the term "adaptively," defined above, as "capable of changing in response to a condition"

As amended by the Certificate of Correction.

20110815

© 1992-2011 VersusLaw Inc.



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