Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 1 of 28 PageID #: 372
`Case 1:17-cv—00386—VAC-CJB Document 47-1 Filed 03/23/18 Page 1 of 28 PageID #: 372
`
`EXHIBIT A
`
`EXHIBIT A
`
`

`

`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 2 of 28 PageID #: 373
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`Agreed-Upon Constructions:
`
`
`
`Parties’ Agreed-Upon Construction:
`
`a memory location where the image to be displayed is
`temporarily ‘drawn’ without outputting it to the video
`card
`
`
`Defendants’ Proposed
`Construction
`
`a process which starts by
`providing a plurality of
`independently related
`logical states which include
`a set of programming
`options, where each
`programming option
`corresponds to different
`image characteristics
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`’096, 5:64-67 (“Videogames
`are processes which start by
`providing a plurality of
`independently related logical
`states which include a set of
`programming options, where
`each programming option
`corresponds to different image
`characteristics.”)
`
`Claims
`
`’096: 1, 2, 3, 6, 7, 13
`
`’218: 1, 6
`
`Claim Term(s)
`
`backbuffer
`
`
`
`
`
`Disputed Terms for Construction
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`“videogame”
`
`’096: 1, 5, 8,
`12, 16
`
`’218: 1, 2, 7,
`8
`
`
`A software program
`written in some computer
`language, with its
`objective to simulate a
`non-existent world and
`take a player or user into
`this world.
`
`Alternatively, Plaintiff
`respectfully asserts that
`the term, in context in the
`claim language, is readily
`understood by lay persons
`so no construction is
`necessary.
`
`
`“Any videogame is a software
`program written in some
`computer language. Its
`objective is to simulate a non-
`existent world and take a player
`or user into this world. Most
`videogames are focused in
`enhancing the visual and
`manual dexterity, pattern
`analysis and decision taking, in
`a competitive and improvement
`(difficulty level) environment,
`and are presented in large
`scenarios with a high artistic
`content. As a game engine,
`most videogames are divided
`into the following structure:
`videogame, game library with
`graphics and audio engines
`associated, the graphical engine
`contains the 2D source code
`and the 3D source code, and the
`audio engine contains the
`effects and music code. Every
`
`1
`
`

`

`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 3 of 28 PageID #: 374
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`backbuffers that are separate
`from each other such that
`left and right independent
`images could be generated
`and stored therein
`
`’096 File History, Interview
`summary 11/471,280
`September 18, 2009 (Ex. D):
`
`“Applicants argued that the
`two back buffers disclosed in
`Engstrom were connected and
`not separate therefrom such
`that to left and right
`independent images could be
`generated and stored therein.”
`
`
`block of the game engine
`mentioned is executed in a
`cyclic way called a game loop,
`and each one of these engines
`and libraries is in charge of
`different operations....”
`(Source: ‘096 Patent: col 3, 53-
`67; ‘218 Patent col 3, 53-67)
`
`See the plain reading of, e.g.,
`the ‘096 Patent: Claim 16, in
`the context of the term as used
`in the claim: “a videogame
`system configured to run
`instructions that when executed
`perform a method comprising
`the steps of ….”
`
`“left backbuffer”
`
` Figure [FIG.] 4a shows the
`creation of memory locations
`for the temporary graphics
`processing (left and right
`backbuffers) in which basically
`it adds and extra memory
`location, i.e., sets a right buffer
`in (400) and discriminates in
`(401) if TDVision technology
`is present; in an affirmative
`case, it sets the left buffer in
`(402) and ends in (403); when
`TDVision technology is not
`present the process ends at
`(403), as there was nothing to
`discriminate.
`
`2
`
`’096: 1, 2, 3,
`6, 7
`
`’218: 1, 6
`
`“left
`backbuffer”
`and “right
`backbuffer”
`
`“left backbuffer”
`A memory location where
`the left image to be
`displayed is temporarily
`stored.
`
`“right backbuffer”
`A memory location where
`the right image to be
`displayed is temporarily
`stored
`
`Alternatively, Plaintiff
`respectfully asserts that
`the phrases, in context in
`the claim language, are
`readily understood by lay
`persons so no
`
`

`

`
`
`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 4 of 28 PageID #: 375
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`construction is necessary.
`
` Figure [FIG.] 4b shows the
`flowchart for the discrimination
`and display of the left camera
`and right camera image; the left
`view is set in (410), the image
`is drawn in the left backbuffer
`as a function of the camera
`position, the image is displayed
`in the left screen (412), then it
`is discriminated if it has
`TDVision format in (413) and
`in the affirmative case the right
`view position coordinates are
`calculated (414), the image is
`drawn in the right backbuffer as
`a function of the left camera
`position (415), then the image
`is displayed in the right
`screen(416), the process ends at
`(417).”
`(Source: see ‘098 Patent: col. 8,
`48-65; ‘218 Patent: col. 8, 46-
`63)
`
`“A backbuffer is used, which is
`a memory location where the
`image to be displayed is
`temporarily "drawn" without
`outputting it to the video card.
`(Source: ‘096 Patent: col. 6, 40-
`42; ‘218 Patent: col. 6, 40-42)
`
`See the plain reading of, e.g.,
`the ‘096 Patent: Claim 1, in the
`context of the term as used in
`the claim: “clearing the left and
`
`3
`
`

`

`
`
`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 5 of 28 PageID #: 376
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`right backbuffers in the
`videogame system; storing an
`image into the left backbuffer
`… when the image is in a three-
`dimensional format, calculating
`the coordinates of a second
`view position of the image and
`storing a second view position
`image into the right
`backbuffer.”
`
`See the plain reading of, e.g.,
`the ‘096 Patent: Claim 1, in the
`context of the term as used in
`the claim: “clearing the left and
`right backbuffers in the
`videogame system; storing an
`image into the left backbuffer
`… when the image is in a three-
`dimensional format, calculating
`the coordinates of a second
`view position of the image and
`storing a second view position
`image into the right
`backbuffer.”
`
`“right backbuffer”
`
` Figure [FIG.] 4a shows the
`creation of memory locations
`for the temporary graphics
`processing (left and right
`backbuffers) in which basically
`it adds and extra memory
`location, i.e., sets a right buffer
`in (400) and discriminates in
`
`4
`
`

`

`
`
`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 6 of 28 PageID #: 377
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`(401) if TDVision technology
`is present; in an affirmative
`case, it sets the left buffer in
`(402) and ends in (403); when
`TDVision technology is not
`present the process ends at
`(403), as there was nothing to
`discriminate.
` Figure [FIG.] 4b shows the
`flowchart for the discrimination
`and display of the left camera
`and right camera image; the left
`view is set in (410), the image
`is drawn in the left backbuffer
`as a function of the camera
`position, the image is displayed
`in the left screen (412), then it
`is discriminated if it has
`TDVision format in (413) and
`in the affirmative case the right
`view position coordinates are
`calculated (414), the image is
`drawn in the right backbuffer as
`a function of the left camera
`position (415), then the image
`is displayed in the right
`screen(416), the process ends at
`(417).”
`(Source: see ‘098 Patent: col. 8,
`48-65; ‘218 Patent: col. 8, 46-
`63)
`
` “A backbuffer is used, which is
`a memory location where the
`image to be displayed is
`temporarily "drawn" without
`
`5
`
`

`

`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 7 of 28 PageID #: 378
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`outputting it to the video card.
`(Source: ‘096 Patent: col. 6, 40-
`42; ‘218 Patent: col. 6, 40-42)
`
`See the plain reading of, e.g.,
`the ‘096 Patent: Claim 1, in the
`context of the term as used in
`the claim: “clearing the left and
`right backbuffers in the
`videogame system; storing an
`image into the left backbuffer
`… when the image is in a three-
`dimensional format, calculating
`the coordinates of a second
`view position of the image and
`storing a second view position
`image into the right
`backbuffer.”
`
`See the plain reading of e.g.,
`the ‘096 Patent: Claim 16, in
`the context of the term as used
`in the claim: “a videogame
`system configured to run
`instructions that when executed
`perform a method comprising
`the steps of ….”
`
`
`
`6
`
`’096: 1, 8, 16
`(respectively)
`
`The steps do not have to
`be performed in the order
`recited.
`
`Plaintiff respectfully
`asserts that the phrase, in
`context in the claim
`language, is readily
`understood by lay persons
`so no construction is
`necessary.
`
`
`“storing an
`image into the
`left
`backbuffer;
`determining if
`the image is in
`a two-
`dimensional
`format or a
`three-
`dimensional
`format” (’096,
`cl. 1)
`
`and
`
`“storing a
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`The steps must be
`performed in the order
`recited.
`
`Figs. 4a, 4b, 8
`
`’096, 8:48-55 (“FIG.
`4 a shows the creation of
`memory locations for the
`temporary graphics processing
`(left and right backbuffers) in
`which basically it adds an
`extra memory location, i.e.,
`sets a right buffer in (400) and
`discriminates in (401) if
`TDVision technology is
`present; in an affirmative case,
`it sets the left buffer in (402)
`and ends in (403); when
`TDVision technology is not
`present the process ends at
`
`

`

`
`
`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 8 of 28 PageID #: 379
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`videogame
`image in the
`first buffer;
`determining
`when the
`videogame
`image is a
`two-
`dimensional or
`a three-
`dimensional
`image” (’096,
`cls. 8, 16)
`
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`(403), as there was nothing to
`discriminate.”)
`
`’096, 8:56-9:5 (“FIG.
`4 b shows the flowchart for the
`discrimination and display of
`the left camera and right
`camera image; the left view is
`set in (410), the image is
`drawn in the left backbuffer
`(411) as a function of the
`camera position, the image is
`displayed in the left screen
`(412), then it is discriminated
`if it has TDVision format in
`(413) and in the affirmative
`case the right view position
`coordinates are calculated
`(414), the image is drawn in
`the right backbuffer as a
`function of the left camera
`position (415), then the image
`is displayed in the right screen
`(416), the process ends at
`(417). If it is not necessary to
`discriminate in (413) as the
`image is provided in a current
`state-of-the-art format, the
`subroutine jumps to the final
`stage (417) and ends, as there
`is no need to calculate other
`coordinates and display
`parallel information. In one
`embodiment of the invention,
`the present application refers
`to the graphics-processing unit
`
`7
`
`

`

`
`
`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 9 of 28 PageID #: 380
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`shown in FIG. 5 (GPU
`HARDWARE), and to the
`graphics engine (GRAPHICS
`ENGINE, SOFTWARE)”)
`
`’096, 10:26-39 (“FIG. 8 shows
`the TDVision technology
`using the OpenGL algorithm
`(80) to display the left and
`right image for the object, it
`cleans the backbuffer (81),
`gets the pointer for the
`backbuffer (82), closes the
`backbuffer (83), redraws the
`scene (84), opens the
`backbuffer (85), unlocks the
`backbuffer pointer (86), sends
`the image to the left display
`surface; in (800) it
`discriminates if it is TDVision
`technology and in an
`affirmative case it cleans the
`memory (801) and gets a
`pointer for the backbuffer
`(802), closes the backbuffer
`(803), gets the coordinates for
`the new perspective (804),
`redraws the scene (805), opens
`the memory (806), unlocks the
`backbuffer pointer (807), and
`sends the image to the right
`display surface (808).”)
`
`’096, 11:1-20 (“Draw image in
`TDVision backbuffer” and
`“FUNCTION
`
`8
`
`

`

`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 10 of 28 PageID #: 381
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`’096: 1, 8, 16
`
`’218: 1, 7, 12
`
`“storing a[n] . .
`. image into
`the . . .
`[back]buffer”
`
`Storing an image at a
`memory location where
`the image to be displayed
`is temporarily “drawn.”
`
`Alternatively, Plaintiff
`respectfully asserts that
`the phrase, in context in
`the claim language, is
`readily understood by lay
`persons so no
`construction is necessary.
`
`
` “A backbuffer is used, which is
`a memory location where the
`image to be displayed is
`temporarily "drawn" without
`outputting it to the video card.
`(Source: ‘096 Patent: col. 6, 40-
`42; ‘218 Patent: col. 6, 40-42)
`
` Figure [FIG.] 4a shows the
`creation of memory locations
`for the temporary graphics
`processing (left and right
`backbuffers) in which basically
`it adds and extra memory
`location, i.e., sets a right buffer
`in (400) and discriminates in
`(401) if TDVision technology
`is present; in an affirmative
`case, it sets the left buffer in
`(402) and ends in (403); when
`TDVision technology is not
`present the process ends at
`(403), as there was nothing to
`discriminate.
` Figure [FIG.] 4b shows the
`flowchart for the discrimination
`and display of the left camera
`and right camera image; the left
`view is set in (410), the image
`is drawn in the left backbuffer
`as a function of the camera
`position, the image is displayed
`
`9
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`DRAWBACKBUFFERTDV()
`” description).
`
`temporarily ‘drawing’ an
`image into the backbuffer
`
`
`’096 Figs. 4b, 6
`
`’096, 5:41-45 (“FIG.
`4 b shows a block diagram of a
`subroutine for setting the right
`camera view after drawing an
`image in the right backbuffer
`as a function of the right
`camera vector. The subroutine
`also discriminates if the
`TDVision technology format
`is used.”)
`
`’096, 5:51-43 (“FIG.
`6 represents a block diagram
`of an algorithm which allows
`the drawing of information in
`the TDVision backbuffer and
`presenting it on-screen in
`DirecTX 3D format.”)
`
`’096, 6:40-47 (“A backbuffer
`is used, which is a memory
`location where the image to be
`displayed is temporarily
`‘drawn’ without outputting it
`to the video card. If this is
`done directly on the video
`memory screen, a flicker on
`the screen would be observed;
`therefore the information is
`
`

`

`
`
`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 11 of 28 PageID #: 382
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`in the left screen (412), then it
`is discriminated if it has
`TDVision format in (413) and
`in the affirmative case the right
`view position coordinates are
`calculated (414), the image is
`drawn in the right backbuffer as
`a function of the left camera
`position (415), then the image
`is displayed in the right
`screen(416), the process ends at
`(417).”
`(Source: see ‘098 Patent: col. 8,
`48-65; ‘218 Patent: col. 8, 46-
`63)
`
`See plain reading of, e.g., the
`‘096 Patent, Claim 16, in the
`context of the term as used in
`the claim: “a videogame
`system configured to run
`instructions that when executed
`perform a method comprising
`the steps of … storing a
`videogame image in the first
`buffer.”
`
`
`10
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`drawn and processed quickly
`in the backbuffer. This
`backbuffer is usually located
`within the physical RAM
`memory of the video or
`graphics acceleration card.”)
`
`’096, 6:52-53 (“Create a
`memory location for
`temporary processing, called
`doublebuffer or backbuffer.”)
`
`’096, 8:56-65 (“FIG.
`4 b shows the flowchart for the
`discrimination and display of
`the left camera and right
`camera image; the left view is
`set in (410), the image is
`drawn in the left backbuffer
`(411) as a function of the
`camera position, the image is
`displayed in the left screen
`(412), then it is discriminated
`if it has TDVision format in
`(413) and in the affirmative
`case the right view position
`coordinates are calculated
`(414), the image is drawn in
`the right backbuffer as a
`function of the left camera
`position (415), then the image
`is displayed in the right screen
`(416), the process ends at
`(417).”)
`
`’096, 9:42-9:64 (“Regarding
`
`

`

`
`
`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 12 of 28 PageID #: 383
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`the software, some special
`characteristics are added
`within a typical work
`algorithm, as well as a call to a
`TDVision subroutine, as it is
`shown in FIG. 6. . . .
`
`Create TDVision backbuffer
`(602) in which a left
`backbuffer is created in
`memory, if it is TDVision
`technology then it creates a
`right backbuffer in memory. . .
`
`Drawing the information in the
`TDVision backbuffer and
`display on screen (608), in
`which the right camera view is
`set. Drawing the image in the
`right backbuffer as a function
`of the current right camera
`vector, and displaying the
`image on the right screen
`(front buffer). If it is TDVision
`technology, then: Calculate the
`left pair coordinates, set the
`left camera view, draw the
`image in the left backbuffer as
`a function of the current vector
`of the left camera, display the
`information on the right screen
`(front buffer) which may use
`hardware modification.”)
`
`’096, 11:1-20 (“Draw image in
`
`11
`
`

`

`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 13 of 28 PageID #: 384
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`TDVision backbuffer” and
`“FUNCTION
`DRAWBACKBUFFERTDV()
`” description).
`
`
`’096, 12:16-19 (“A coordinate
`calculation method of the
`secondary stereoscopic camera
`(SETXYZTDV()) allows
`obtaining three-dimensional
`computer visual systems for
`the generation of stereoscopic
`images by animation, display
`and modeling in software
`programs. This method allows
`obtaining spatial coordinates
`(x,y,z) that are assigned to two
`computer-generated virtual
`visualization cameras . . .”
`
`’096, 12:54-56 (“The output
`parameters will be the
`coordinates of the secondary
`camera observing the same
`objective point, i.e., (Xs, Ys,
`Zs) . . .”)
`
`’218, Claim 7 (“calculating
`first position coordinates . . .”
`and “calculating . . . second
`spatial coordinates . . .”)
`
`Points in space that are
`located by their positions in
`relation to intersecting x, y,
`and z axes.
`
`’096: 1, 4, 5,
`8, 12, 16
`
`’218: 1, 3, 4,
`5, 7, 9, 10, 13,
`14
`
`
`“spatial
`coordinates”
`
`“spatial
`coordinates
`(x,y,z)”
`
`“position
`coordinates”
`
`and
`
`“coordinates
`of [a/the] . . .
`view position”
`
`
`Coordinates are the set of
`values in an (x, y, z)
`coordinate system.
`
`Plaintiff’s Comment
`Plaintiff understands
`Defendants’ term to be
`construed as
`“coordinates,” and
`proposes its counter-
`construction based on that
`belief. Plaintiff
`respectfully submits that
`the various modifiers of
`the term “coordinates,”
`are different terms that
`require different
`constructions based on the
`intrinsic evidence and the
`context of use in the
`claims. Since
`Defendants’ proposed a
`construction is of what
`appears to be just the term
`“coordinates,” Plaintiff is
`responding to that
`construction, but
`respectfully reserves the
`right to propose counter-
`constructions to the full
`
`“It is important to note that the
`minimum image units (FIG. 3)
`are comprised of minimum
`control units called a “vertex”,
`which represent one point in the
`xyz space.”
`(Source: ‘098 Patent: col. 7,
`26-28; ‘218 Patent, col. 7, 25-
`27)
`
` “A coordinate calculation
`method of the secondary
`stereoscopic camera
`(SETXYZTDV()) allows
`obtaining three-dimensional
`computer visual systems for the
`generation of stereoscopic
`images by animation, display
`and modeling in software
`programs. This method allows
`obtaining spatial coordinates (x,
`y, z) that are assigned to two
`computer-generated virtual
`visualization cameras to obtain
`a stereoscopic vision by using
`any software program that
`simulates the third dimension
`and generates the images by
`means of the object’s
`movement, or by the “virtual
`
`12
`
`

`

`
`
`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 14 of 28 PageID #: 385
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`phrases in its brief, if
`necessitated by the
`Defendants’ position and
`arguments.
`
`Alternatively, Plaintiff
`respectfully asserts that
`the phrase, in context in
`the claim language, is
`readily understood by lay
`persons so no
`construction is necessary.
`
`
`camera” movement observed at
`that moment by the computer-
`generated object. * * *
` An additional 3D modeling
`and animation characteristic is
`added to the previous programs
`by means of the coordinate
`transformation equations,
`namely:
`x=x' cos φ-y' sin φ
`y=x' sin φ+y' cos φ
` The exact position is
`calculated for a second or
`secondary camera, directly
`linked to the first camera and
`by this means two simultaneous
`images are obtained from
`different perspectives
`simulating the human being's
`stereoscopic visual perspective.
`This procedure, by means of an
`algorithm, calculates in real-
`time the position of the
`secondary camera to place it in
`the adequate position, and to
`obtain the modeling image and
`representation of the second
`camera, achieved using the
`coordinate transforming
`equations, taking the camera to
`the origin the angle and
`distance between the secondary
`camera and the object or
`objective are calculated, then
`the primary camera, objective
`and secondary camera are
`
`13
`
`

`

`
`
`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 15 of 28 PageID #: 386
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`repositioned in the obtained
`position. Then, seven
`parameters need to be known,
`namely, the first coordinates
`(Xp, Yp, Zp) of the primary
`camera in the original
`coordinate system, the fourth
`parameter is the equivalent
`distance to the average
`separation of the eyes (6.5 to
`7.0 cm), and the three
`coordinates of the objective's
`position when observed by the
`cameras.
`(Source: ‘096 Patent: col. 12,
`13-53; ‘218 Patent: col. 12, 17-
`58)
`
`NOTE: A full discourse on the
`coordinate transformation may
`be found as follows: ‘096
`Patent: col. 12, 13 through col.
`13, 20; ‘218 Patent: col. 12, 17
`through col. 13, 25.
`
`See the plain reading of, e.g.,
`the ‘096 Patent: Claim 1, in the
`context of the term as used in
`the claim: “clearing the left and
`right backbuffers in the
`videogame system; storing an
`image into the left backbuffer
`… when the image is in a three-
`dimensional format, calculating
`the coordinates of a second
`view position of the image and
`
`14
`
`

`

`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 16 of 28 PageID #: 387
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`“buffer”
`
`’096: 8, 9, 10,
`11, 13, 14, 16,
`17, 18, 19
`
`’218: 7, 8, 11,
`12, 13
`
`Any memory location
`where the image to be
`displayed is temporarily
`"drawn" without
`outputting it to the video
`card.
`
`Alternatively, Plaintiff
`respectfully asserts that
`the phrase, in context in
`the claim language, is
`readily understood by lay
`persons so no
`construction is necessary.
`
`
`storing a second view position
`image into the right
`backbuffer.”
`
`
` Figure [FIG.] 4a shows the
`creation of memory locations
`for the temporary graphics
`processing (left and right
`backbuffers) in which basically
`it adds and extra memory
`location, i.e., sets a right buffer
`in (400) and discriminates in
`(401) if TDVision technology
`is present; in an affirmative
`case, it sets the left buffer in
`(402) and ends in (403); when
`TDVision technology is not
`present the process ends at
`(403), as there was nothing to
`discriminate.
` Figure [FIG.] 4b shows the
`flowchart for the discrimination
`and display of the left camera
`and right camera image; the left
`view is set in (410), the image
`is drawn in the left backbuffer
`as a function of the camera
`position, the image is displayed
`in the left screen (412), then it
`is discriminated if it has
`TDVision format in (413) and
`in the affirmative case the right
`view position coordinates are
`calculated (414), the image is
`drawn in the right backbuffer as
`
`15
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`a frontbuffer or a backbuffer
`
`’096, Abstract (“The system
`has a videogame engine
`controlling and validating the
`image perspectives, assigning
`textures, lighting, positions,
`movements and aspects
`associated with each object
`participating in the game;
`creates left and right
`backbuffers, creates images
`and presents the information in
`the frontbuffers. The system
`allows handling the
`information of data associated
`to the xyz coordinates of the
`object's image in real-time,
`increases the RAM for the left-
`right backbuffer, with the
`possibility to discriminate and
`take the corresponding
`backbuffer, whose information
`is sent to the frontbuffer or
`additional independent display
`device sharing a memory in an
`immerse manner.”)
`
`’096, 5:41-45 (“FIG.
`4 b shows a block diagram of a
`subroutine for setting the right
`camera view after drawing an
`image in the right backbuffer
`
`

`

`
`
`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 17 of 28 PageID #: 388
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`a function of the left camera
`position (415), then the image
`is displayed in the right
`screen(416), the process ends at
`(417).”
`(Source: see ‘098 Patent: col. 8,
`48-65; ‘218 Patent: col. 8, 46-
`63)
`
`“A backbuffer is used, which is
`a memory location where the
`image to be displayed is
`temporarily "drawn" without
`outputting it to the video card.
`(Source: ‘096 Patent: col. 6, 40-
`42; ‘218 Patent: col. 6, 40-42)
`
`See the plain reading of, e.g.,
`the ‘096 Patent: Claim 1, in the
`context of the term as used in
`the claim: “clearing the left and
`right backbuffers in the
`videogame system; storing an
`image into the left backbuffer
`… when the image is in a three-
`dimensional format, calculating
`the coordinates of a second
`view position of the image and
`storing a second view position
`image into the right
`backbuffer,” and similar
`contexts related to
`“frontbuffers,” “first buffers,”
`and “second buffers.”
`
`
`16
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`as a function of the right
`camera vector. The subroutine
`also discriminates if the
`TDVision technology format
`is used.”)
`
`’096, 5:51-58 (“FIG.
`6 represents a block diagram
`of an algorithm which allows
`the drawing of information in
`the TDVision backbuffer and
`presenting it on-screen in
`DirecTX 3D format.”)
`
`’096, 5:56-58 (“FIG. 8 shows
`the block diagram of the on-
`screen information display by
`means of the left and right
`backbuffers using the OpenGL
`algorithm.”)
`
`’096, 6:40-42 (“A backbuffer
`is used, which is a memory
`location where the image to be
`displayed is temporarily
`“drawn” without outputting it
`to the video card.”)
`
`8:48-9:15 (“FIG. 4 a shows the
`creation of memory locations
`for the temporary graphics
`processing (left and right
`backbuffers) in which
`basically it adds an extra
`memory location, i.e., sets a
`right buffer in (400) and
`
`

`

`
`
`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 18 of 28 PageID #: 389
`
`Exhibit A - Proposed Claim Constructions for
`U.S. Patent Nos. 7,666,096 (“’096”) and. 8,206,218 (“’218”)
`
`Claim(s)
`
`Term(s)
`
`Techno View’s Proposed
`Construction
`
`Techno View’s Citations to
`Intrinsic Evidence
`
`Defendants’ Proposed
`Construction
`
`
`Defendants’ Citations to
`Intrinsic Evidence
`
`discriminates in (401) if
`TDVision technology is
`present; in an affirmative case,
`it sets the left buffer in (402)
`and ends in (403); when
`TDVision technology is not
`present the process ends at
`(403), as there was nothing to
`discriminate.
`
`FIG. 4 b shows the flowchart
`for the discrimination and
`display of the left camera and
`right camera image; the left
`view is set in (410), the image
`is drawn in the left backbuffer
`(411) as a function of the
`camera position, the image is
`displayed in the left screen
`(412), then it is discriminated
`if it has TDVision format in
`(413) and in the affirmative
`case the right view position
`coordinates are calculated
`(414), the image is drawn in
`the right backbuffer as a
`function of the left camera
`position (415), then the image
`is displayed in the right screen
`(416), the process ends at
`(417). If it is not necessary to
`discriminate in (413) as the
`image is provided in a current
`state-of-the-art format, the
`subroutine jumps to the final
`stage (417) and ends, as there
`
`17
`
`

`

`
`
`Case 1:17-cv-00386-VAC-CJB Document 47-1 Filed 03/23/18 Page 19 of