Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 1 of 18
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`EXHIBIT F
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`EXHIBIT F
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 2 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`Application to ProScan HDTVs
`
`The ProScan family of Smart HDTVs are video apparatus capable of receiving streaming media
`input via a network connection. ProScan Smart HDTVs have been available since 2016.
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`Claim Interpretation
`
` A system capable of
`outputting A/V
`content in multiple
`formats. The system
`either includes a
`built-in display or can
`send a video output
`signal to an external
`display
`
`Support from
`Spec
` Abstract: “An
`audio/video
`production system
`facilitates
`professional
`quality image
`manipulation and
`editing. A program
`input may be
`translated into any
`of a variety of
`graphics or
`television formats,
`including NTSC,
`PAL, SECAM and
`HDTV, and stored
`as data-
`compressed
`images, using any
`of several
`commercially
`available methods
`such as Motion
`JPEG, MPEG,
`etc.”
`
`Source:
`https://web.archive.org/web/20160823103851/http://www.visions.ca:80/catalogue/category/ProductR
`esults.aspx?categoryId=5&brandId=494
`
`
`
`ProScan Smart TVs support receiving input video content via Internet streaming. The input format of
`the content depends on the source, but all streamed content is compressed (all video codecs use
`compression).
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`
` 1
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`
`Patent Claim
`Language
`1. A multi-format
`audio/video
`production system
`adapted for use
`with a display
`device, comprising:
`[1.0]
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 3 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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` …
`
` A multi-format
`audio/video
`production system
`adapted for use
`with a display
`device, comprising:
`
`
`
`
`
`
`
`Source: Proscan 40" 1080p 60Hz LED Smart TV (PLDED4079) User’s Manual
`http://legacy.curtisint.com/html/custservice/manuals/PRO_PLDED4079-SM_EN.PDF
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` 2
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 4 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`an input to receive
`a signal
`representative of
`an audio/video
`program in one of a
`plurality of display
`formats;
`[1.1]
`
`An input to receive
`an A/V signal (either
`separate signals or
`combined) in one of
`multiple display
`formats. The input
`A/V signal may either
`be a raw A/V signal,
`or a processed signal
`that has been
`converted from a raw
`signal to a video
`format.
`
`“The image
`dimensions chosen
`allow the use of
`conventional CCD-
`type cameras, but
`the use of digital
`processing directly
`through the entire
`signal chain is
`preferred, and this is
`implemented by
`replacing the typical
`analog RGB
`processing circuitry
`with fully digital
`circuitry.”
`Col. 3, lines 47-51.
`“In the alternative,
`the a signal
`representative of an
`audio/video program
`may already be
`stored in a
`previously
`processed format,
`such as
`compression:
`Images are recorded
`by writing the digital
`data to storage
`devices employing
`removable hard-disk
`drives, disk drives
`with removable
`media, optical or
`magneto-optical
`based drives, tape-
`based drives, or
`semiconductor-
`based memory
`devices, preferably
`in compressed-data
`form.” Col. 3, lines
`53-58
`
`Source: Proscan 40" 1080p 60Hz LED Smart TV (PLDED4079) User’s Manual
`http://legacy.curtisint.com/html/custservice/manuals/PRO_PLDED4079-SM_EN.PDF
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` 3
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 5 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`Technical overview
`The terms "tuner" and "receiver" are used loosely, and it is perhaps more appropriately called an ATSC
`receiver, with the tuner being part of the receiver (see Metonymy). The receiver generates the audio and video
`(AV) signals needed for television, and performs the following tasks: demodulation; error correction; MPEG
`transport stream demultiplexing; decompression; AV synchronization; and media reformatting to match what is
`optimal input for one's TV. Examples of media reformatting include: interlace to progressive scan or vice
`versa; picture resolutions; aspect ratio conversions (16:9 to or from 4:3); frame rate conversion; and image
`scaling. Zooming is an example of resolution change. It is commonly used to convert a low-resolution picture
`to a high-resolution display. This lets the user eliminate letterboxing or pillarboxing by stretching or cropping
`the picture. Some ATSC receivers, mostly those in HDTV TV sets, will stretch automatically, either by
`detecting black bars or by reading the Active Format Descriptor (AFD).
`From: Wikipedia article, “ATSC Tuner”
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` 4
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 6 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`From: Wikipedia article, “ATSC Standards”
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` 5
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 7 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`Any type of storage
`device that supports
`asynchronous
`program recording
`and reproducing
`
`
`
`Memory buffers are used to support various operations relating to processing of the encoded video
`content received at an input, including decoding to recover frame pixel data, frame-rate conversion
`(as applicable) and up-scaling (as applicable). This memory will typically be some form of Dynamic
`Random Access Memory, such as DDR2 or DDR3 RAM or newer GDDR memory (Graphics DDR
`memory). These class of devices generally include at least one processor and provide facilities such
`as DSP and/or graphics processing units (GPU) (which may be built-in or separate from a CPU) for
`performing the various processing operations employed for producing display content from received
`input program content.
`
`Memory and graphics/image processing components are fundamental to all HDTVs and UHDTVs.
`
`
`
`
`“Images are
`recorded by
`writing the digital
`data to storage
`devices employing
`removable hard-
`disk drives, disk
`drives with
`removable media,
`optical or
`magneto-optical
`based drives,
`tape-based drives,
`or semiconductor-
`based memory
`devices,
`preferably in
`compressed-data
`form.” Col. 3,
`lines 53-58.
`
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`
` 6
`
`
`
`
`high-capacity video
`storage means
`including an
`asynchronous
`program recording
`and reproducing
`capability;
`[1.2]
`
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 8 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`a graphics
`processor in
`communication with
`the input, the high-
`capacity video
`storage means,
`and the operator
`control, enabling a
`user to perform the
`following functions:
`[1.3]
`
`
`The HD video signal is output internally (within circuitry in the UHDTV or HDTV) and provided as an
`input to the video display circuitry on the UHDTV or HDTV. All UHDTVs and HDTVs can display a
`progressive video signal having a pixel resolution of at least 1920x1080 pixels.
`
`Plain meaning. A
`graphics processor is
`any chip or
`apparatus capable of
`performing the
`claimed operations.
`
`
`“The graphics
`processor 82
`represents
`dedicated
`hardware that
`performs the
`various
`manipulations
`required to
`process the input
`video signals 84
`and the output
`video signals 86;”
`Col. 7, lines 6-9.
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` 7
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 9 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`a) convert the
`display format of
`the audio/video
`program received
`through the input
`into an intermediate
`production format,
`[1.3a]
`
`
`The HD video signal is output internally (within circuitry in the UHDTV or HDTV) and provided as an
`input to the video display circuitry on the UHDTV or HDTV. All UHDTVs and HDTVs can display a
`progressive video signal having a pixel resolution of at least 1920x1080 pixels.
`
`Input A/V signal is
`converted into a
`production format. If
`this production
`format is converted
`to another format, it
`is an intermediate
`format.
`
`General support
`throughout the
`specification
`regarding
`conversion
`between multiple
`formats. Also,
`“Depending on the
`original source
`material frame
`rate and
`intermediate
`conversions, the
`user would select
`the method likely
`to present the
`least amount of
`image
`impairment.” Col.
`13, lines 2-4.
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` 8
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 10 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`b) perform a frame-
`rate conversion of
`the audio/video
`program received
`through the input
`means using the
`asynchronous
`recording and
`reproducing
`capability
`associated with the
`high-capacity video
`storage means,
`and
`[1.3b]
`
`Plain meaning.
`Frame-rate
`conversion
`corresponds to a
`change in the frame
`rate as received at
`the input to a
`different frame-rate
`
`General support
`throughout the
`specification,
`including,
`In practice,
`materials may be
`converted from
`any other format
`including video at
`any frame rate or
`standard. After the
`production effects
`have been
`performed, the
`output signals may
`be configured for
`any use required,
`including, but not
`limited to, HDTV
`at 30 fps shown as
`164,
`NTSC/widescreen
`at 30 fps shown as
`166, PAL-
`SECAM/widescree
`n at 25 fps shown
`as 170, or HDTV
`at 25 fps shown as
`172. “ Col. 13,
`lines 37-47
`
`ProScan PLDED4079 and PLDED3279 are smart HDTVs that employ UltraSMR (Ultra Smooth
`Motion Rate) technology that minimizes motion blur and is used to give smooth motion in movies,
`sports, and gaming.
`ProScan SmartTV has UltraSMR technology, which is a motion smoothing technology that uses
`frame interpolation or motion processing. It inserts artificial frames of video between the actual
`frames provided by the source, that results in an increase in frame rate.
`
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` 9
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 11 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`Source: Proscan 40" 1080p 60Hz LED Smart TV (PLDED4079) User’s Manual
`http://legacy.curtisint.com/html/custservice/manuals/PRO_PLDED4079-SM_EN.PDF
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`10
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 12 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`c) output a program
`having a display
`format or frame
`rate different than
`that of the
`audio/video
`program received
`through the input.
`[1.3c]
`
`General support
`throughout the
`specification,
`including that for
`the immediately
`prior claim
`element. Also
`various resolution
`conversions are
`discussed in
`specification and
`shown in Figs. 1a,
`1b, 1c, and 1d.
`
`
`
`
`Plain meaning. The
`frame-rate and/or
`display format is
`different than the
`frame-rate and/or
`display format of the
`input A/V content.
`This may include a
`different frame-rate,
`different resolution,
`or the same
`resolution with a
`different format (e.g.,
`1080p to 1080i)
`
`
`ProScan PLDED4079 and PLDED3279 are smart HDTVs that employ UltraSMR (Ultra Smooth
`Motion Rate) technology that minimizes motion blur and is used to give smooth motion in movies,
`sports, and gaming.
`ProScan SmartTV has UltraSMR technology, which is a motion smoothing technology that uses
`frame interpolation or motion processing. It inserts artificial frames of video between the actual
`frames provided by the source, that results in an increase in frame rate.
`
`
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`11
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 13 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`
`Source: Proscan 40" 1080p 60Hz LED Smart TV (PLDED4079) User’s Manual
`http://legacy.curtisint.com/html/custservice/manuals/PRO_PLDED4079-SM_EN.PDF
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`12
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 14 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`2. The multi-format
`audio/video
`production system
`of claim 1, wherein
`the graphics
`processor is
`operative to output
`a program in a
`standard television
`format regardless
`of the display
`format of the input
`program.
`[2.0]
`
`“The invention
`comprises a
`plurality of
`interface units,
`including a
`standard/widescre
`en interface unit
`operative to
`convert the video
`program in the
`input format into
`an output signal
`representative of a
`standard/widescre
`en formatted
`image, and output
`the signal to an
`attached display
`device. A high-
`definition
`television interface
`unit is operative to
`convert the video
`program in the
`input format into
`an output signal
`representative of
`an HDTV-
`formatted image,
`and output the
`signal to the
`display device.”
`Col 2, li 20-27.
`
`
`
`Output is a
`standardized
`television format,
`such as any existing
`or future HDTV
`format.
`
`ProScan PLDED4079 and PLDED3279 are smart HDTVs that employ UltraSMR (Ultra Smooth
`Motion Rate) technology that minimizes motion blur and is used to give smooth motion in movies,
`sports, and gaming.
`ProScan SmartTV has UltraSMR technology, which is a motion smoothing technology that uses
`frame interpolation or motion processing. It inserts artificial frames of video between the actual
`frames provided by the source, that results in an increase in frame rate.
`
`
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`
`13
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 15 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`3. The multi-format
`audio/video
`production system
`of claim 1, wherein
`the graphics
`processor is
`operative to output
`a program in a
`widescreen format
`regardless of the
`display format of
`the input program.
`[3.0]
`
`“The invention
`comprises a
`plurality of
`interface units,
`including a
`standard/widescre
`en interface unit
`operative to
`convert the video
`program in the
`input format into
`an output signal
`representative of a
`standard/widescre
`en formatted
`image, and output
`the signal to an
`attached display
`device.” Col. 2,
`lines 20-24
`
`Output format is
`widescreen format
`
`
`
`
`
`
`Source: Proscan 40" 1080p 60Hz LED Smart TV (PLDED4079) User’s Manual
`http://legacy.curtisint.com/html/custservice/manuals/PRO_PLDED4079-SM_EN.PDF
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`14
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`4. The multi-format
`audio/video
`production system
`of claim 1, wherein
`the graphics
`processor is
`operative to output
`a program in an
`enhanced-definition
`format regardless
`of the display
`format of the input
`program.
`[5.0]
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 16 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`Output is Enhanced
`format
`
`“The graphics
`processor may be
`configured to
`accept or output
`these signals in
`the standard
`NTSC, PAL, or
`SECAM formats,
`and may
`additionally be
`utilized in other
`formats as
`employed in
`medical imaging
`or other
`specialized
`applications, or for
`any desired format
`for computer
`graphics
`applications.”
`Col 8, lines 24-29.
`
`“For other HDTV
`frame rates,
`aspect ratios, and
`line rates, intra-
`frame and inter-
`frame interpolation
`and image
`conversions may
`be performed by
`employing
`comparable
`techniques well
`known in the art of
`computer graphics
`and television.”
`Col 8, lines 35-39.
`
`
`
`
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`
`
`Source: Proscan 40" 1080p 60Hz LED Smart TV (PLDED4079) User’s Manual
`http://legacy.curtisint.com/html/custservice/manuals/PRO_PLDED4079-SM_EN.PDF
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`15
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 17 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`5. The multi-format
`audio/video
`production system
`of claim 4, wherein
`the enhanced-
`definition format is
`an HDTV format.
`[5.0]
`
`Output is HDTV
`format
`
`“A high-definition
`television interface
`unit is operative to
`convert the video
`program in the
`input format into
`an output signal
`representative of
`an HDTV-
`formatted image,
`and output the
`signal to the
`display device.”
`Col 2, lines 25-27.
`
`
`
`
`
`
`
`
`Source: Proscan 40" 1080p 60Hz LED Smart TV (PLDED4079) User’s Manual
`http://legacy.curtisint.com/html/custservice/manuals/PRO_PLDED4079-SM_EN.PDF
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`16
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`Case 1:21-cv-20026-CMA Document 1-8 Entered on FLSD Docket 01/05/2021 Page 18 of 18
`CLAIM CHART FOR US PATENT NO 5,999,220 as applied to ProScan HDTVs and related models
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`9. The multi-format
`audio/video
`production system
`of claim 1, wherein
`the graphics
`processor is further
`operative to
`perform an
`interpolation
`operation with
`respect to the
`program received
`through the input
`so as to reduce the
`number of pixels
`associated with the
`production format
`as compared to the
`input display
`format.
`[9.0]
`
`
`“For example, if
`the input program
`signals were
`provided at a 25
`fps rate
`(corresponding to
`a 625-line
`broadcast
`system), the signal
`processor would
`perform image
`resizing and inter-
`frame interpolation
`to convert the
`signal to 30 fps
`(corresponding to
`a 525-line
`broadcast
`system).” Col. 10,
`lines 24-29.
`
`Plain meaning.
`Interpolation used to
`reduce the number of
`pixels
`
`
`
`
`
`
`
`
`
`Source: Proscan 40" 1080p 60Hz LED Smart TV (PLDED4079) User’s Manual
`http://legacy.curtisint.com/html/custservice/manuals/PRO_PLDED4079-SM_EN.PDF
`
`
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`17
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