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Multimedia Patent Trust v. Directv

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 ...


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