UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`AMAZON.COM, INC. AND AMAZON WEB SERVICES, LLC,
`Petitioner
`
`V.
`
`PERSONALIZED MEDIA COMMUNICATIONS, LLC,
`Patent Owner
`
`Case No. TBD
`
`Patent 7,827,587
`
`DECLARATION OF CHARLES J. NEUHAUSER, Ph.D.
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF
`
`U.S. PATENT 7,827,587
`
`Amazon EX. 1001
`
`IPR Petition - USP 7,827,587
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`AMAZON.COM, INC. AND AMAZON WEB SERVICES, LLC,
`Petitioner
`
`V.
`
`PERSONALIZED MEDIA COMMUNICATIONS, LLC,
`Patent Owner
`
`Case No. TBD
`
`Patent 7,827,587
`
`DECLARATION OF CHARLES J. NEUHAUSER, Ph.D.
`IN SUPPORT OF PETITION FOR INTER PARTES REVIEW OF
`
`U.S. PATENT 7,827,587
`
`Amazon EX. 1001
`
`IPR Petition - USP 7,827,587
`
`
`
`I, Dr. Charles J. Neuhauser, do hereby declare:
`
`1.
`
`I am making this declaration at the request of Amazon.com, Inc. and
`
`Amazon Web Services, LLC (“Amazon”) in the matter of the Inter Partes Review
`
`of US Patent 7,827,587 (the “Harvey ‘587 patent”).
`
`2.
`
`I am being compensated for my work in this matter at my standard
`
`hourly rate of $400 for consulting services.
`
`I am being reimbursed at cost for any
`
`expenses. My compensation in no way depends upon the outcome of this
`
`proceeding.
`
`PERSONAL BACKGROUND
`
`3.
`
`I am an engineer by training and profession. My current CV is
`
`attached. I was awarded the degree of BSEE from the University of Notre Dame in
`
`1968. Directly after graduating I was employed by Bell Telephone Laboratories
`
`(now Alcatel-Lucent) as a Member of the Technical Staff. In this capacity I
`
`worked on the specification, testing, and development of computer controlled data
`
`and telephone switching systems for deployment in telephone central offices.
`
`While I was at Bell Telephone Laboratories I
`
`received my MSEE from
`
`Northwestern University under a company sponsored program.
`
`4.
`
`In 1971 I left Bell Telephone Laboratories to pursue a PhD in a newly
`
`formed CS/EE program at the Johns Hopkins University. My degree was awarded
`
`
`
`in 1980 based on my research into the use of emulation techniques in the
`
`evaluation of computer architectures.
`
`5.
`
`In 1974 while working on my PhD. research I joined the Digital
`
`Systems team at Stanford University as a research associate where I worked on the
`
`development of an emulation system used for architectural research. From about
`
`1972 I also worked part-time with Palyn Associates, Inc.
`
`(later Palyn-Gould
`
`Group) (“Palyn”) as a Member of the Technical Staff. At Palyn I worked initially
`
`on the development of a range of commercial products based on emulation
`
`concepts.
`
`6.
`
`In 1980 I joined Palyn full time as a member of their technical staff
`
`and later as Director of Engineering and by 1985 as Vice President of Engineering.
`
`Palyn was a consulting company with a range of international clients in the general
`
`field of computer technology. My responsibilities at Palyn related to two broad
`
`areas. First, I was responsible for directing product development on behalf of our
`
`clients, and second, I consulted directly with clients on issues related to processor
`
`and peripheral design. My work here related to main-frame processors,
`
`minicomputers, micro-computers, and systems that used such components.
`
`7.
`
`In my role directing product development I was responsible for the
`
`specification, design, testing, and debugging of a wide range of devices including
`
`mini-computers, microprocessors, and peripheral controllers, such as printers,
`
`
`
`communications, and printer interfaces. Work on these systems involved both
`
`hardware and software development.
`
`8.
`
`In 1994 I began working as an independent consultant first doing
`
`business as CTCS and later as Neuhauser Associates, Inc. Since that time my
`
`professional work has focused on technical analysis of systems primarily in the
`
`support of litigation or potential litigation.
`
`I have worked extensively in the
`
`analysis of patent claims both with respect
`
`to determining infringement and
`
`invalidity.
`
`I also have experience in software copyright and technical trade secret
`
`matters. From time to time I lead teams of engineers in testing and technical
`
`evaluations.
`
`9.
`
`At
`
`this time I have over 45 years of continuous professional
`
`experience in the field of processors and systems controlled by such processors.
`
`The Harvey ‘587 patent relates to system level interconnection of communication
`
`and computer devices.
`
`It also relates to their control by computers in response to
`
`signals. Over my engineering career I have designed many such computer
`
`controlled systems.
`
`10.
`
`Since 1972 I have had extensive experience with microprocessors and
`
`systems controlled by such devices.
`
`In addition to the specification, design,
`
`implementation, testing, debugging, and deployment of such hardware systems, I
`
`have also developed the support software for many such systems. Commonly, I, or
`
`
`
`the engineers I directed, made use of microprocessor-based systems to implement
`
`communications functions or to control larger processors’ systems. This included
`
`responding to certain protocols or developing our own protocols.
`
`11.
`
`In my current capacity as an independent consultant I have reviewed
`
`and verified the operation of a wide variety of technical systems,
`
`including
`
`processors, personal computers,
`
`industrial
`
`robots, chemical analysis systems,
`
`television devices, peripherals, and bus systems.
`
`12.
`
`In forming the opinions expressed in this report I have relied upon my
`
`education and my 45 years of professional experience.
`
`TECHNICAL BACKGROUND
`
`13.
`
`In the 1970s and 1980s, many different versions of television and data
`
`services were established in North America and Europe. Generically,
`
`these
`
`systems were sometimes referred to as “Teletext” and “Videotex.”
`
`l4.
`
`“Teletext” primarily referred to a system in which “pages” of text
`
`were encoded into a non-viewable portion of the television broadcast, which could
`
`then be decoded by properly-equipped receivers. Users could select and store
`
`particular pages for display. Videotex systems allowed users to separately query a
`
`remote database through a separate data line, typically over the telephone lines
`
`using a data modem.
`
`It was well-known in the field at least by 1980 that Teletext
`
`and Videotex systems could receive source data either by inserting the data in non-
`
`
`
`viewable portions of television broadcasts, or through direct database queries using
`
`a modem over a telephone network. Various standards were developed for the
`
`formatting of Teletext and Videotex pages in the 1970s through at least 1987.
`
`MATERIALS RELIED UPON
`
`15.
`
`For my opinions expressed herein, I have reviewed and relied on the
`
`following information:
`
`a. US. Patent No. 7,827,587 to Harvey (Ex. 1002)
`
`b. US. Patent No. 4,556,904 (“Monat”) (Ex. 1006)
`
`c. US. Patent No. 4,805,134 (“Calo”) (Ex. 1007)
`
`d. Gecsei, The Architecture of Videotex Systems (Ex. 1008)
`
`e. Broadcast Teletext Specification, September 1976 (Ex. 1009)
`
`f. Wireless World, April 1977 (Ex. 1010)
`
`g. Penguin Dictionary of Computers, Third Edition, 1985 (Ex. 1011)
`
`h. Webster’s New World Dictionary of Computer Terms, Third Edition,
`
`1988 (Ex. 1012)
`
`i. NAPLPS Standard, December 1983 (Ex. 1013)
`
`MY UNDERSTANDING OF THE RELEVANT LEGAL STANDARDS
`
`16.
`
`I have been asked to provide my opinion as to whether claim 9 of the
`
`Harvey ‘5 87 patent is anticipated or would have been obvious to a person of
`
`ordinary skill in the art at the time of the alleged invention in view of the prior art.
`
`
`
`17.
`
`I am an engineer by training and profession. The opinions I am
`
`expressing in the report involve the application of my engineering knowledge and
`
`experience to the evaluation of certain prior art with respect to the Harvey ‘587
`
`patent. My knowledge of applicable patent law is no different than that of any lay
`
`person. Therefore, I have requested the attorneys from Knobbe Martens, who
`
`represent Amazon, to provide me with guidance as to the applicable patent law in
`
`this matter. The paragraphs below express my understanding of how I must apply
`
`current principles related to patent validity in my analysis.
`
`18.
`
`It is my understanding that in determining whether a patent claim is
`
`anticipated or obvious in view of the prior art, the Patent Office must construe the
`
`claim by giving the claim its broadest reasonable interpretation consistent with the
`
`specification. For the purposes of this review, I have analyzed each claim term in
`
`accordance with its plain and ordinary meaning under the required broadest
`
`reasonable interpretation.
`
`19.
`
`It is my understanding that a claim is anticipated under 35 U.S.C. §
`
`102 if each and every element and limitation of the claim is found either expressly
`
`or inherently in a single prior art reference.
`
`It is my understanding that a claim is
`
`unpatentable under 35 U.S.C. § 103 if the claimed subject matter as a whole would
`
`have been obvious to a person of ordinary skill in the art at the time of the
`
`invention.
`
`I also understand that an obviousness analysis takes into account the
`
`
`
`scope and content of the prior art, the differences between the claimed subject
`
`matter and the prior art, and the level of ordinary skill in the art at the time of the
`
`invention.
`
`I further understand that prior art should be read in context under an
`
`obviousness analysis, taking into account the background knowledge possessed by
`
`a person having ordinary skill in the art, and the inferences and creative steps that a
`
`person of ordinary skill in the art would employ.
`
`20.
`
`In determining the scope and content of the prior art,
`
`it
`
`is my
`
`understanding that a reference is considered appropriate prior art if it falls within
`
`the field of the inventor’s endeavor.
`
`In addition, a reference is prior art if it is
`
`reasonably pertinent
`
`to the particular problem with which the inventor was
`
`involved.
`
`A reference is
`
`reasonably pertinent
`
`if it
`
`logically would have
`
`commended itself to an inventor’s attention in considering his problem.
`
`If a
`
`reference relates to the same problem as the claimed invention, that supports the
`
`use of the reference as prior art in an obviousness analysis.
`
`21.
`
`To assess the differences between prior art and the claimed subject
`
`matter, it is my understanding that 35 U.S.C. § 103 requires the claimed invention
`
`to be considered as a whole. This “as a whole” assessment requires showing that
`
`one of ordinary skill in the art at the time of invention, confronted by the same
`
`problems as the inventor and with no knowledge of the claimed invention, would
`
`
`
`have selected the elements from the prior art and combined them in the claimed
`
`manner.
`
`22.
`
`It is my further understanding that the Supreme Court has recognized
`
`several rationales for combining references or modifying a reference to show
`
`obviousness of claimed subject matter. Some of these rationales include:
`
`combining prior art elements according to known methods to yield predictable
`
`results; simple substitution of one known element for another to obtain predictable
`
`results; a predictable use of prior art elements according to their established
`
`functions; applying a known technique to a known device (method or product)
`
`ready for improvement to yield predictable results; choosing from a finite number
`
`of identified; predictable solutions; with a reasonable expectation of success; and
`
`some teaching; suggestion; or motivation in the prior art that would have led one of
`
`ordinary skill to modify the prior art reference or to combine prior art reference
`
`teachings to arrive at the claimed invention.
`
`23.
`
`Lastly;
`
`I understand that an obviousness analysis must consider
`
`whether there are additional factors that would indicate that the invention was non-
`
`obvious. These factors include: (i) long-felt need; (ii) unexpected results; (iii)
`
`skepticism of the invention; (iv) teaching away from the invention; (v) commercial
`
`success;
`
`(vi) praise by others for the invention; and (vii) copying by other
`
`companies.
`
`
`
`24.
`
`In the present case, I am unaware of any evidence that would suggest
`
`that Claim 9 of the Harvey ‘5 87 patent would have been non-obvious.
`
`CLAIM CONSTRUCTION
`
`25.
`
`It
`
`is my understanding based on discussions with attorneys for
`
`Amazon that in a prior matter related to US Patent 7,860,131 that the Patent Trial
`
`and Appeal Board (“PTAB”) provided a construction of the term “control signa ”
`
`based on a specification substantially the same as that of the ‘587 patent.
`
`Specifically, in that review the PTAB found that one of ordinary skill in the art
`
`would have considered the term “control signal” to mean:
`
`“an electrical quantity that is operative to cause a responsive action
`
`in a device including but not
`
`limited to causing an output, an
`
`operation, or a sequence of operations. ”
`
`Decision Instituting Inter Partes Review of Patent 7,860,131, Exhibit 1004
`
`at 9. I will make use of this construction in the discussion below.
`
`26. With respect to the term “incomplete” processor instructions, it is my
`
`view that a person of ordinary skill in the art, reading this term in light of Claim 9
`
`as a whole, would consider a reasonable interpretation of the term to mean
`
`processor instructions that are “incomplete” because information will be added to
`
`the instructions prior to the instructions being transmitted to a particular receiver
`
`station. This may occur because the instructions are not in a form that is suitable
`
`
`
`for their intended use at the receiver station. For example, in the context of Claim
`
`9 and in view of the specification of the ‘587 patent,
`
`the claimed processor
`
`instructions may be incomplete because some other information or data is to be
`
`merged or placed within the instructions prior to the instructions being in a form
`
`appropriate for transmission or communication to a given system or component. In
`
`the Examples #9 and #10 of the ‘587 patent, discussed below, the Basic program
`
`has what may be considered “complete” instructions under some interpretations of
`
`the word, but those instructions are not considered complete according to the
`
`specification of the ‘587 patent until additional information is provided, such as
`
`calculated values that are added in place of certain variables in a formula. [‘587
`
`patent, 195:16— 196:7]
`
`ONE OF SKILL IN THE ART
`
`27.
`
`It is my understanding that when interpreting the claims of the Harvey
`
`‘587 patent I must do so based on the perspective of one of ordinary skill in the art
`
`at the relevant priority date. It is my understanding that the Petitioner believes that
`
`the appropriate priority date for claim 9 of the Harvey ‘587 patent is September
`
`1987. It is my understanding that the Respondent may propose that the appropriate
`
`priority date is November 1981.
`
`I have no opinion on what the appropriate priority
`
`date is.
`
`In general the references that I will use in this report would, by my
`
`understanding, be prior art to the September 1987 date.
`
`10
`
`
`
`28.
`
`The discussion which follows outlines the characteristics of a person
`
`of ordinary skill in the art in November of 1981 and September of 1987.
`
`29.
`
`The Harvey ‘5 87 patent describes the interconnection and operation of
`
`very well-known components. These components include television receivers,
`
`radio receivers,
`
`amplifiers, micro-computers
`
`(“personal
`
`computers”),
`
`audio
`
`recorders, and video recorders, among other things. In addition, the Harvey ‘587
`
`patent discusses at a general level various types of “signal decoders”, such as
`
`television line decoders, used to decode radio and television signals, and switches
`
`to direct these types of signals between various components. The Harvey ‘587
`
`patent also describes simple signal and message formats.
`
`30.
`
`The technology scope of the Harvey ‘587 patent may be discerned
`
`easily by a simple review of the figures. These figures show components that were
`
`very well known in 1981 (and in 1987). What they do not show is any unusual
`
`circuitry or interconnection of components. Basically,
`
`the Harvey ‘587 patent
`
`relates to the interconnection of well-known components and their control using
`
`widely known and understood techniques.
`
`11
`
`
`
`31.
`
`Based on my review of the specification of the Harvey ‘587 patent, it
`
`is my opinion that one of ordinary skill in the art would be an engineer with a
`
`Bachelor of Science in Electrical Engineering or a closely related fieldl. This
`
`person would have between three and five years of experience beyond graduation
`
`in the implementation of communications systems and controlling these systems
`
`(or similar types of systems) through the use of computer technology. Someone
`
`would be equally qualified if they had a Master’s of Science degree and somewhat
`
`less practical experience.
`
`32.
`
`I am able to make this assessment because by 1981 I worked with,
`
`supervised, and hired engineers with these types of qualifications. These engineers
`
`had the requisite knowledge to make and use systems as described in the claim 9 of
`
`the Harvey ‘5 87 patent. Because I have worked with and supervised engineers with
`
`this background I know very well what their capabilities were in November 1981
`
`and how they would interpret the claim 9 of the Harvey ‘587 patent and the
`
`disclosures of the applicable prior art.
`
`1 By the
`
`1980’s most Electrical Engineering students
`
`took courses
`
`in
`
`communications and computer programming. Even in college these students
`
`would likely have had practical experience building system based on techniques
`
`similar to those described in the Harvey ‘587 patent.
`
`12
`
`
`
`33. Above I have outlined the characteristics of a person of ordinary skill
`
`in the art in November of 1981. This same background would be applicable to a
`
`person of ordinary skill in the art in September of 1987. Obviously, by this later
`
`date the breadth of skill that such a person would have would be somewhat broader
`
`than the similarly educated and experienced engineer from November of 1981.
`
`However, the education and degree of practical experience required (three to five
`
`years) would be the same. Such a person would, in September of 1987, be able to
`
`make use of the teachings of claim 9 of the Harvey ‘5 87. Furthermore this person
`
`would be able to understand and apply the prior art that I will cite. This includes
`
`the ability to understand how the prior art might be extended and combined in the
`
`ways I will describe below.
`
`I have a good feel for the capabilities of a person of
`
`ordinary skill in the art that I described because in 1987 I worked with, hired, and
`
`supervised engineers with this sort of background.
`
`SUMMARY OF THE HARVEY ‘587 PATENT
`
`34.
`
`The Harvey ‘587 patent contains nearly 300 columns of text and 22
`
`drawing sheets. For brevity, I have limited my summary of the Harvey ‘5 87 patent
`
`to one example embodiment described in the patent’s specification.
`
`I will do this
`
`not from today’s perspective over 25 years after the priority date, but rather from
`
`the perspective of what one of ordinary skill in the art would have understood in
`
`the early 1980s.
`
`13
`
`
`
`35.
`
`Basically,
`
`the Harvey ‘587 patent
`
`is
`
`related to the reception,
`
`distribution, storage and presentation of information carried on various types of
`
`electrical signals. The discussion and examples shown in the Harvey ‘587 patent
`
`relate to performing these activities in connection with standard radio and
`
`television signals. The Harvey ‘587 patent also assumes that such signals can
`
`include embedded control signals using what were well-known techniques in 1987.
`
`For the remainder of this section, all citations below are to the ‘587 patent (Ex.
`
`1002).
`
`36.
`
`I will provide a brief outline of a single example, identified in the ‘587
`
`patent as “Example #10.” Example #10 describes a remote program originating
`
`studio that transmits a commercial (labeled “program unit Q”) to a number of
`
`intermediate transmission stations.
`
`These intermediate transmission stations
`
`subsequently generate additional
`
`information and incorporate that additional
`
`information into a transmission to a number of ultimate receiver stations associated
`
`with television subscribers. 193:25-57. A computer 73 of a given intermediate
`
`transmission station contains “information relevant to the particular discounts and
`
`specials in effect at the particular markets in the vicinity of said station.” 193:58-
`
`66. As an example, the information may be “local-formula-and-item information”
`
`in the form of specific values for various variables (“a, p, q, d, Z, r, s, and dd”)
`
`14
`
`
`
`corresponding to information such as the cost of gasoline (“p”) and the distance
`
`between a given warehouse and market (“Z”). 187:9-54, 193:65—194:30.
`
`37.
`
`The ‘587 patent’s specification discloses that a program originating
`
`studio transmits a “generate-set-information message (#10)” to intermediate
`
`transmission station computers 73 that includes, among other information, an
`
`execution segment,
`
`information segment
`
`information of an “intermediate
`
`generation set of Q,” and an end of file signal. Receiving such a message at a
`
`given intermediate transmission station (“ITS”) computer 73 causes the computer
`
`to load information of the message. Once the ITS computer receives an end of file
`
`signal, the ITS executes the loaded information to perform a number of actions.
`
`These actions are described in Example #10 as:
`
`(a) computing the specific
`
`"formula-and-item-of-this-transmission-information” of the given ITS according to
`
`prerecorded data stored at
`
`the ITS computer 73;
`
`(b) compiling the specific
`
`formula-and-item-of-this-transmission information into one or more machine
`
`language program modules; (c) linking the specific module or modules to other
`
`program modules to become “complete program instruction set information” for
`
`the given instance of transmission Q; and (d) recording this information in memory
`
`for later transmission to receiver stations. 195: 16-47.
`
`38.
`
`The examples provided in the
`
`‘587 patent’s
`
`specification for
`
`computing information at the ITS computer include executing received information
`
`15
`
`
`
`to compute specific values that replace variable names in a ”higher language line of
`
`program code” until “complete program instruction set information exists in higher
`
`language code at particular memory.” This higher language code, such as Basic
`
`code, is then compiled and linked with other compiled modules to generate an
`
`executable file named ”PROGRAMEXE.”
`
`195 :48-196:7.
`
`The ‘587 Patent
`
`implies that this program may later be transmitted in a message from the ITS to a
`
`number of subscriber stations in the area of the given ITS.
`
`BACKGROUND ON US PATENT 4,556,904 (“MONAT”)
`
`39.
`
`US Patent 4,556,904 (“Monat”) is titled “Teletext System Having
`
`User Prompt Commands”.
`
`It was filed on March 4, 1983 and would,
`
`to my
`
`understanding, be prior art to the Harvey ‘587 patent.
`
`40. Monat discloses a teletext based information transmission and
`
`reception system. The system of Monat provides a solution to the problem of
`
`displaying certain teletext characters on viewer terminals that have different
`
`keyboard character sets.
`
`[Monat 1:13-18; 1:30-40] Monat Fig.
`
`1 provides an
`
`illustration of the problem with respect to the display of menu prompt symbols.
`
`Monat Fig. 1 depicts an example of teletext receiver and the problem that Monat
`
`solves. On the screen of the television receiver (10) is a menu (18).
`
`In some
`
`teletext systems interactive menus are provided to make user navigation simpler.
`
`In this example there are four menu selection items (referred to as “prompts” in
`
`16
`
`
`
`Monat), each representing a teletext page that the Viewer may Visit. To access a
`
`page in the menu the user would enter the item number followed by the “hash
`
`sign” (# or pound symbol as it is termed in Monat). When this is done the teletext
`
`receiver would select the new page.
`
`[Monat 2:5 3-61]
`
`[Monat Fig. l ]
`
`US Patent Dec. 3,1985
`
`Sheetlof3
`
`4,556,904
`
`l6
`NEWS /
`1 #WOR/LD NEWS 2
`/
`/ t
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`1
`‘ 3*LOCAL EWS / {1:37"
`l 4 #SPORTS NEws/
`,l NEXT WORLD NEVIS
`
`A
`.
`
`‘
`
`’
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Teletext systems are under consideration for transmitting textual
`
`materials to users haVing teleVision receivers equipped with memories
`
`and decoders which capture the teletext information and display the
`
`data in character or graphical form on the screen of the associated
`
`teleVision receiver.
`
`[Monat l : 13-18]
`
`17
`
`
`
`Some manufacturers may include keyboards with symbols which
`
`exactly match the symbols used to identify material in the teletext
`
`menus, whereas other manufacturers may elect
`
`to manufacture
`
`keyboards having a fewer number of keys, for example, or having
`
`different symbols than those actually used in the transmission of
`
`teletext to identify the menu items. This in turn can lead to user
`
`confusion about which symbols he might key or use to select desired
`
`information if the symbols do not exactly match what is transmitted.
`
`[Monat 1:30—40]
`
`The receiver is assumed to be in its teletext receiving mode and is
`
`displaying an image on the video screen 18 of a news ”menu”. The
`
`menu comprises four items labeled 1 through 4. Behind each item on
`
`the menu is the prompting symbol signified by a lb. sign (#). For a
`
`user to access menu item 1 ”world news” the user would be prompted
`
`by the 1#. symbol to enter the number 1 followed by the # on his
`
`keyboard unit 12.
`
`[Monat 2:53-61]
`
`41.
`
`As Monat Fig.
`
`1
`
`illustrates, a problem arises when the viewer’s
`
`remote control (12) does not include a key with the hash symbol (the prompt
`
`character). Monat points out that receiver systems and keyboards may be provided
`
`by different manufacturers and therefore, there may be no common symbol to use
`
`as the prompt character.
`
`[Monat 1:30-40] To solve this problem Monat proposes a
`
`system in which the prompt character is replaced at the viewer’s teletext receiver
`
`with a prompt character that is on the viewer’s keyboard.
`
`In the example, the
`
`18
`
`
`
`prompt character is ‘#’ displayed on the menu (18). To select the first menu item
`
`(i.e. world news) the viewer would need to enter ‘ l#’. Although the keyboard (12)
`
`lacks a ‘#’ symbol the system of Monat will detect the prompt character and
`
`replace it with a character that is on the viewer’s keyboard.
`
`In this example, the
`
`sequence ‘l#’ would appear on the screen as ‘la’ and thus the prompt character
`
`would be one that is on the user’s keyboard [Monat 3:12-20]
`
`Some manufacturers may include keyboards with symbols which
`
`exactly match the symbols used to identify material in the teletext
`
`menus, whereas other manufacturers may elect
`
`to manufacture
`
`keyboards having a fewer number of keys, for example, or having
`
`different symbols than those actually used in the transmission of
`
`teletext to identify the menu items. This in turn can lead to user
`
`confusion about which symbols he might key or use to select desired
`
`information if the symbols do not exactly match what is transmitted.
`
`[Monat 1:30—40]
`
`In the receiver the teletext decoder is arranged in such a manner as to
`
`detect the occurrence of the prompt symbol identifying character and
`
`then perform a symbol conversion prior to displaying the character so
`
`as to display characters which agree with the legends on the remote
`
`keyboard control unit 12.
`
`In this case upon occurrence of the
`
`nonvisible controlled character the symbols l#, 2#, 3# and 4# would
`
`be converted for example to the symbols la, 2a, 3a and 4a.
`
`[Monat
`
`3:12—20]
`
`19
`
`
`
`42.
`
`The system of Monat consists of two parts, a teletext transmitter and a
`
`teletext receiver, generally, Monat Figs. 2 and 3, respectively.
`
`The teletext
`
`transmitter of Monat is enhanced to detect prompt characters and then to insert a
`
`non-displayable control code adjacent to the prompt character. The modified
`
`teletext data is then sent to the receiver of Monat Fig. 3.
`
`[Monat 3:19-24] The
`
`receiver of Monat is modified to detect the non-displayable control code (usually
`
`referred to in Monat as a “prompt identification code character”) and to replace the
`
`transmitted prompt character (i.e. the ‘#’) with the appropriate displayable prompt
`
`character available on the viewer’s keyboard.
`
`In this manner the transmitted
`
`display prompt ‘l#’ would appear as ‘la’ in the example receiver, although it
`
`might appear as ‘ l#’ in another receiver.
`
`[Monat 3:12-20]
`
`[Monat Fig. 2]
`
`2O
`
`
`
`US. Patent Dec. 3, 1985
`
`Sheet 2 of 3
`
`4,556,904
`
`MENU
`FORMAT
`DATA
`
`202
`
`USER
`PROMPT
`DETECTOR
`
`204
`
`PROMPT
`IDENTIFRCAUON
`CODE
`GENERATION
`
`206
`
`DATA
`INSERTER
`
`
`
`TELETEXT
`PAGE DATA
`
`SO RCE
`
`'
`
`
`
`
`
` TELETEXT
`PAGE
`
`STORAGE
`
`MEMORY
`
` TELETEXT
`
`
`VIDEO
`
`
`
`TELEVISION
`AND AUDN
`
`TRANSMNTER
`
`SOURCE
`
`
`
`ENCODER
`
`
`
`. Fig. 2
`
`FIG. 2 is a block diagram of a teletext encoding system for inserting
`
`the nonVisible prompt control character which identifies the user
`
`prompting symbols of the teletext data stream.
`
`[Monat 3:20-24]
`
`In the receiver the teletext decoder is arranged in such a manner as to
`
`detect the occurrence of the prompt symbol identifying character and
`
`then perform a symbol conversion prior to displaying the character so
`
`21
`
`
`
`as to display characters which agree with the legends on the remote
`
`keyboard control unit 12.
`
`In this case upon occurrence of the
`
`nonvisible controlled character the symbols l#, 2#, 3# and 4# would
`
`be converted for example to the symbols la, 2a, 3a and 4a.
`
`[Monat
`
`3:12-20]
`
`43. Monat Fig. 2 depicts a teletext transmitter modified according to the
`
`disclosure of Monat. Teletext page data, which would include menus such as
`
`shown in Monat Fig. l, is received from teletext data source (200). The teletext
`
`pages received would include menus, such as those shown in Monat Fig. l, and
`
`might be stored on a disk, or received from a wire service or the like.
`
`[Monat 3:24-
`
`27] Menu format data is also provided to the system of Monat Fig. 2. This
`
`information is used to identify the menu format and prompt characters received
`
`from the teletext page data source (200).
`
`[Monat 3:28-32] The teletext page data
`
`and the menu format data is applied to user prompt detector (202), which locates
`
`menu prompt characters within the received teletext page data.
`
`[Monat 3:30-32]
`
`The system comprises a teletext page data source 200 which may be a
`
`mass storage device or it may comprise a source of continuous
`
`information such as wire service stories, news flashes, etc.
`
`[Monat
`
`3:24—27]
`
`The output of data source 200 is applied to a user prompt detector unit
`
`202 which receives a source of menu format data.
`
`[Monat 3 :28-30]
`
`22
`
`
`
`Detector 202 compares the teletext data stream with the menu format
`
`data and identifies all
`
`teletext characters corresponding to user
`
`prompts.
`
`[Monat 3 : 30-3 2]
`
`44. When user prompt detector locates a prompt code in the teletext page
`
`data it causes prompt identification code generator (204) to generate a special non-
`
`displayable character, referred to in Monat as a “prompt
`
`identification code
`
`character”.
`
`[Monat 3:32-42] This code is passed to the data inserter 206 which
`
`places the prompt identification code character into the teletext page data adjacent
`
`to the user prompt character.
`
`[Monat 3:38-42] The resulting modified teletext
`
`page data is then placed into teletext page storage memory (208). The following
`
`blocks, teletext encoder (210) and summer (214), read the modified teletext page
`
`data from the teletext page storage memory (210), encode the data and place it in
`
`the television signal.
`
`[Monat 3:43-54]
`
`The signal can be combined with a
`
`television video signal or full frame teletext (i.e. with no video) can be transmitted.
`
`[Monat 5:38-52]
`
`45. Monat Fig. 3 illustrates a receiver system that is compatible with the
`
`teletext transmitter of Monat Fig. 2. TV receiver (304) is a conventional television
`
`front end (i.e. tuner, IF, detector).
`
`In teletext mode, video signal, 81, from the TV
`
`receiver (304) is sent to PCM detector (310) which extracts the teletext page data
`
`from the signal.
`
`[Monat 3:67-4:9]
`
`In the system of Monat this teletext page data
`
`23
`
`
`
`will contain the prompt character and the prompt identification code character
`
`wherever there is, for example, a menu item prompt. This data is passed to teletext
`
`identifier (312) which determines if the current line contains teletext page data. If
`
`it does, the data is placed in memory (314) under control of controller (316).
`
`Keyboard (12) is used to set controller (316) to identify a particular teletext page
`
`requested by the user.
`
`[Monat 4: 1 1-18]
`
`The video signal 81 is applied to the input of a pulse code modulation
`
`(PCM) detector 310 which senses the luminance signal variations
`
`during the vertical interval representative of the teletext signal and
`
`produces a binary output signal S2 conveying the teletext information.
`
`Signal S2 is applied to a teletext identifier unit 312 and to a memory
`
`unit 314. Unit 312 receives timing signals from t.v. processing unit
`
`304 for identifying the particular lines of the vertical interval where
`
`the teletext signal
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