(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)(cid:3)
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`FO2GO
`Patent Owner
`____________
`
`
`
`Patent No. 7,173,651
`
`DECLARATION OF CHARLES ELDERING, PH.D.
`
`U.S. PATENT NO. 7,173,651 – CLAIMS 1-5
`
`
`
`
`
`
`
`(cid:3)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNIFIED PATENTS INC.
`EX1002
`Page 1 of 163
`
`

`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`TABLE OF CONTENTS
`
`INTRODUCTION ........................................................................................... 1  
`
`I.  
`
`II.   OVERVIEW OF THE ’651 PATENT ............................................................ 4  
`
`III.   LEVEL OF ORDINARY SKILL IN THE ART ............................................. 6  
`
`IV.   UNDERSTANDING OF LAW ...................................................................... 7  
`
`V.  
`
`VI.  
`
`CLAIM CONSTRUCTION ............................................................................ 9  
`
`INVALIDITY OF THE CHALLENGED CLAIMS ..................................... 10  
`
`A.   Ground 1: Matsumoto anticipates claims 2-5 ..................................... 10  
`
`1. Overview of Matsumoto ................................................................. 10  
`
`2. Claim 2 is anticipated by Matsumoto ............................................. 16  
`
`3. Claim 3 is anticipated by Matsumoto ............................................. 35  
`
`4. Claim 4 is anticipated by Matsumoto ............................................. 37  
`
`5. Claim 5 is anticipated by Matsumoto ............................................. 38  
`
`6. Claim Chart ..................................................................................... 40  
`
`B.  
`
`Ground 2: Matsumoto in view of Jones renders claim 1
`obvious. ............................................................................................... 58  
`
`1. Overview of Jones ........................................................................... 58  
`
`2. Claim 1 is obvious over Matsumoto in view of Jones .................... 60  
`
`3. Claim Chart ..................................................................................... 73  
`
`C.  
`
`Ground 3: Maurinus anticipates claims 2-5 ........................................ 87  
`
`1. Overview of Maurinus .................................................................... 87  
`
`2. Claim 2 is Anticipated by Maurinus ............................................... 92  
`
`3. Claim 3 is Anticipated by Maurinus ............................................. 108  
`
`
`
`
`
`
`
`UNIFIED PATENTS INC.
`EX1002
`Page 2 of 163
`
`

`
`IPR2016-_____
`U.S. Patent 7,173,651
`4. Claim 4 is Anticipated by Maurinus ............................................. 110  
`
`5. Claim 5 is Anticipated by Maurinus ............................................. 111  
`
`6. Claim Chart ................................................................................... 113  
`
`D.   Ground 4: Maurinus in view of Jones renders claim 1 obvious. ...... 132  
`
`1. Claim 1 is Obvious over Maurinus in view of Jones .................... 132  
`
`2. Claim Chart ................................................................................... 144  
`
`VII.   AVAILABILITY FOR CROSS-EXAMINATION .................................... 159  
`
`VIII.   RIGHT TO SUPPLEMENT ....................................................................... 160  
`
`IX.  
`
`JURAT ........................................................................................................ 160  
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNIFIED PATENTS INC.
`EX1002
`Page 3 of 163
`
`

`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`
`
`I, Charles Eldering, declare as follows:
`
`I.
`
`INTRODUCTION
`
`1. My name is Charles Eldering. I received a B.S. from Carnegie Mellon
`
`in Physics, a M.S. From Syracuse University in Solid State Science and
`
`Technology, and a Ph.D. in Electrical Engineering from the University of
`
`California. A copy of my curriculum vitae, which includes a more detailed
`
`summary of my background, experience, patents, and publications, is attached at
`
`EX1003.
`
`2.
`
`I have been retained by Unified Patents Inc. (“Unified”) as an
`
`independent expert consultant in the field of computer networks and digital media
`
`communications. I am being compensated for the time I spend on this matter, but
`
`my compensation is not dependent on and in no way affects the substance of my
`
`statements in this declaration.
`
`3.
`
`I have been involved in computer engineering, fiber-optic, cable-
`
`based, and network telecommunications for over 20 years. At Expanse Networks, a
`
`company I founded in 2000, I worked extensively on developing designs, systems,
`
`and initial system prototypes and products for media communication systems. I
`
`
`
`
`
`1
`
`UNIFIED PATENTS INC.
`EX1002
`Page 4 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`also developed network architectures for content delivery and software for devices,
`
`such as head-end equipment and consumer electronic devices (e.g., set-top boxes).
`
`4. My experience at General Instrument Corporation from 1993 to 1995
`
`as the Manager of Fiber-to-the-Curb/Switched Digital Video Systems and
`
`Broadband Systems Engineering is also relevant to this matter. At General
`
`Instrument, I was involved in digital video system design and development for
`
`two-way interactive networks.
`
`5.
`
`I am not an attorney and offer no legal opinions, but in my work,
`
`including my work as a patent agent, I have had experience studying and analyzing
`
`patents and patent claims from the perspective of a person skilled in the art, and
`
`have developed patent portfolios. I have previously served as a patent analyst and
`
`research consultant and I am a named inventor on many patents.
`
`6.
`
`I have reviewed the specification, the claims, and the prosecution
`
`history of U.S. Patent No. 7,173,651 to Knowles (“’651 Patent” (EX1001)).
`
`7.
`
`I have reviewed and understand the following references:
`
`i. U.S. Patent No. 6,833,861 to Matsumoto et al. (“Matsumoto”)
`
`(EX1004). Matsumoto claims priority to Japanese Patent Application No. 9-
`
`072008, which was filed on March 25, 1997 and published as Japanese Patent
`
`
`
`
`
`2
`
`UNIFIED PATENTS INC.
`EX1002
`Page 5 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`Publication No. JP H 9-322114A on December 12, 1997 ( EX1005 includes a
`
`certified translation of JP H 9-322114A, referred to herein as “Matsumoto-JP”);
`
`ii. U.S. Patent No. 5,606,365 to Maurinus et al. (“Maurinus”) (EX1006);
`
`and
`
`iii. U.S. Patent No. 5,742,763 to Jones (“Jones”) (EX1007)
`
`8.
`
`I have been asked to consider whether the references listed above in
`
`paragraph 7 disclose or suggest the features recited in the claims of the ’651 Patent.
`
`I have also been asked to consider the state of the art and the prior art available
`
`before the effective filing date of the ’651 Patent. I have been informed that U.S.
`
`Patent Application No. 09/324,249 (“’249 Application”), which issued as the ’651
`
`Patent on February 6, 2007, was filed on June 2, 1999. I have also been informed
`
`that the ’249 Application claims priority to U.S. Provisional Patent Application
`
`No. 60/087,745 (“’745 Provisional Application”) filed on June 2, 1998. I have
`
`further been informed that because descriptive material was added and the claims
`
`were changed in the ’249 Application relative to the ’745 Provisional Application,
`
`the claims of the ’651 Patent may have different effective filing dates. For
`
`example the effective filing date for a claim may be June 2, 1999 or June 2, 1998,
`
`depending on the claim is supported by the ’745 Provisional Application.
`
`
`
`
`
`3
`
`UNIFIED PATENTS INC.
`EX1002
`Page 6 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`9. My opinions are provided in this declaration.
`
`10. To the best of my knowledge, I have no financial interest in Petitioner.
`
`Petitioner’s counsel has informed me that FO2GO (“FO2GO” or “Patent Owner”)
`
`purports to own the ’651 Patent. To the best of my knowledge, I have no financial
`
`interest in FO2GO, and I have had no contact with FO2GO or the named inventor
`
`of the patent, Andrew T. Knowles. To the best of my knowledge, I similarly have
`
`no financial interest in the ’651 Patent. To the extent any mutual funds or other
`
`investments I own have a financial interest in the Petitioner, Unified Patents Inc.,
`
`or the ’651 Patent, I am not aware of, nor do I have control over, any financial
`
`interest that would affect or bias my judgment.
`
`II. OVERVIEW OF THE ’651 PATENT
`11. The ’651 Patent recognizes that it was known to download a
`
`photograph from a digital camera to a computer, to forward such a photograph to
`
`others via e-mail, and to incorporate such a photograph on an Internet web page.
`
`EX1001 ’651 Patent at 1:25-32. However, the ’651 Patent states that image
`
`transfer between the digital camera and the computer via floppy disk, memory
`
`card, or infrared is convenient. Id. at 1: 33-52. The ’651 Patent also recognizes that
`
`an Internet archival service for conventional film processing was available, but
`
`
`
`
`
`4
`
`UNIFIED PATENTS INC.
`EX1002
`Page 7 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`states that there is no known similar service for digital photos. Id. at 1:57-2:3. The
`
`’651 Patent further recognizes that it was possible to assemble a portable device
`
`which can transfer data files to a destination computer, although such a system
`
`would require user input of a destination phone number for modem dialing or a
`
`host internet protocol (IP) address or an e-mail address to send an image to. Id. at
`
`2:57-64.
`
`12.
`
`In view of the above-recognized aspects, the ’651 Patent is directed to
`
`a system that requires comparatively less user input for configuration and
`
`operation. Id. at 2:64-67. The ’651 Patent teaches that a wireless camera device
`
`includes a digital camera to create a digital image, a memory to store a delivery IP
`
`address and a list of nicknames, and a radio frequency (RF) communications
`
`device. Id. at 4:51-67. The wireless camera device transmits a message to a server
`
`at the delivery IP address, where the message includes a recipient code (nickname)
`
`and at least one digital image. Id.
`
`13. The ’651 Patent further teaches that the server at the delivery IP
`
`address can store the received message or forward the received message to another
`
`IP address. Id. at 3:53-57. The server can resolve between nicknames, e-mail
`
`addresses, and IP addresses. Id. at 3:12-19.
`
`
`
`
`
`5
`
`UNIFIED PATENTS INC.
`EX1002
`Page 8 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`14. Thus, the ’651 Patent teaches that a user of the wireless camera device
`
`can select a nickname and the server can cause an image received from the wireless
`
`camera device to be delivered to an e-mail address or an IP address (corresponding
`
`to the nickname). Id. at 3:53-57, 3:12-19, and 4:51-67.
`
`15. As the prior art demonstrates, technologies that enable a camera user
`
`to select a recipient and send an image to a server with reduced user input were
`
`well-known prior to the effective filing date of the ’651 Patent. Additionally,
`
`storing images on a server and distributing images from a server to other devices
`
`were also well-known prior to the effective filing date of the ’651 Patent.
`
`III. LEVEL OF ORDINARY SKILL IN THE ART
`16.
`
`I have considered certain issues from the perspective of a person of
`
`ordinary skill in the art at the effective filing date of the’651 Patent. In my opinion,
`
`a person of ordinary skill in the art for the ’651 Patent would have a Master’s
`
`Degree in electrical engineering, computer science, or a related subject or the
`
`equivalent, and would also have at least three years of experience working with
`
`electronic
`
`devices,
`
`user
`
`interfaces,
`
`computer
`
`networks,
`
`and
`
`digital
`
`communications, or the equivalent.
`
`
`
`
`
`
`
`6
`
`UNIFIED PATENTS INC.
`EX1002
`Page 9 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`IV. UNDERSTANDING OF LAW
`17.
`
`I have considered certain issues from the perspective of a person of
`
`ordinary skill in the art at the time of the effective filing date of the ’651 Patent.
`
`18.
`
`I am not an attorney. For the purposes of this declaration, Petitioner’s
`
`counsel have informed me about certain aspects of the law that are relevant to my
`
`opinions.
`
`19. Petitioner’s counsel have informed me that a patent claim may be
`
`“anticipated” if each element of that claim is present either explicitly or inherently
`
`in a single prior art reference. Petitioner’s counsel have informed me that to be
`
`inherently present, the prior art reference must necessarily disclose the limitation,
`
`and the fact that the reference might possibly practice or contain a claimed
`
`limitation is insufficient to establish that the reference inherently teaches the
`
`limitation.
`
`20. Petitioner’s counsel have informed me that a patent claim can be
`
`considered to have been obvious to a person of ordinary skill in the art at the time
`
`of the effective filing date of the patent claim. This means that, even if all of the
`
`requirements of a claim are not found in a single prior art reference, the claim is
`
`not patentable if the differences between the subject matter in the prior art and the
`
`
`
`
`
`7
`
`UNIFIED PATENTS INC.
`EX1002
`Page 10 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`subject matter in the claim would have been obvious to a person of ordinary skill in
`
`the art at the time of the effective filing date.
`
`21. Petitioner’s counsel have informed me that a determination of whether
`
`a claim would have been obvious should be based upon several factors, including,
`
`among others: the level of ordinary skill in the art at the time of the effective filing
`
`date; the scope and content of the prior art; and what differences, if any, existed
`
`between the claimed invention and the prior art.
`
`22. Petitioner’s counsel have informed me that a single reference can
`
`render a patent claim obvious if any differences between that reference and the
`
`claims would have been obvious to a person of ordinary skill in the art.
`
`Alternatively, the teachings of two or more references may be combined as
`
`disclosed in the claims, if such a combination would have been obvious to one
`
`having ordinary skill in the art. In determining whether a combination based on
`
`multiple references would have been obvious, it is appropriate to consider, among
`
`other factors: whether the teachings of the prior art references disclose known
`
`concepts combined in familiar ways, and when combined, would yield predictable
`
`results; whether a person of ordinary skill in the art could implement a predictable
`
`variation, and would see the benefit of doing so; whether the claimed elements
`
`
`
`
`
`8
`
`UNIFIED PATENTS INC.
`EX1002
`Page 11 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`represent one of a limited number of known design choices, and would have a
`
`reasonable expectation of success by those skilled in the art; whether a person of
`
`ordinary skill would have recognized a reason to combine known elements in the
`
`manner described in the claim; whether there is some teaching or suggestion in the
`
`prior art to make the modification or combination of elements claimed in the
`
`patent; and whether the innovation applies a known technique that had been used
`
`to improve a similar device or method in a similar way.
`
`23. Petitioner’s counsel have informed me that one of ordinary skill in the
`
`art has ordinary creativity, and is not an automaton. Petitioner’s counsel have
`
`informed me that in considering obviousness, it is important not to determine
`
`obviousness using the benefit of hindsight derived from the patent being
`
`considered.
`
`V. CLAIM CONSTRUCTION
`24.
`
`I have been advised that the first step of assessing the validity of a
`
`patent claim is to interpret or construe the meaning of the claim.
`
`25.
`
`I have been further advised that in post-grant review proceedings
`
`before the U.S. Patent and Trademark Office, a patent claim receives the broadest
`
`reasonable construction in light of the specification of the patent in which it
`
`
`
`
`
`9
`
`UNIFIED PATENTS INC.
`EX1002
`Page 12 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`appears. I have also been advised that this means the claim terms are given their
`
`ordinary and customary meaning as would be understood by one of ordinary skill
`
`in the art unless that meaning is inconsistent with the specification of the patent.
`
`26.
`
`In my analysis I have given the claim terms their broadest reasonable
`
`interpretation in light of the specification. I have considered whether any claim
`
`term has been defined in the specification, and for those terms which lack a
`
`definition in the specification, I have similarly applied the broadest reasonable
`
`interpretation that is consistent with the interpretation that one skilled in the art
`
`would have applied at the time of the effective filing date of the ’651 Patent.
`
`VI. INVALIDITY OF THE CHALLENGED CLAIMS
`A. Ground 1: Matsumoto anticipates claims 2-5
`
`27.
`
`In this section, I explain why every element of claims 2-5 of the ’651
`
`Patent is found in U.S. Patent No. 6,833,861 (“Matsumoto,” EX1004), as arranged
`
`in the claims. Matsumoto claims priority to Japanese Patent Application No. 9-
`
`072008, which was filed on March 25, 1997 and published as Japanese Patent
`
`Publication No. JP H 9-322114A. EX1005 includes a certified translation of
`
`JP H 9-322114A and is referred to herein as “Matsumoto-JP.”
`
`1. Overview of Matsumoto
`
`
`
`
`
`10
`
`UNIFIED PATENTS INC.
`EX1002
`Page 13 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`28. Matsumoto discloses a digital photo processing system that includes a
`
`digital camera and a plurality of photo processing locations. See EX1004
`
`Matsumoto at Title. FIG. 5 of Matsumoto shows an exemplary digital photo
`
`processing system including a digital still camera 49 in wireless communication
`
`with reception equipment 60 and printing equipment 10.
`
`
`
`29. Matsumoto discloses that the digital still camera 49 can wirelessly
`
`transmit digital images to the reception equipment 60 for transfer to user selected
`
`printing equipment 10. Id. at FIG. 5. The user selected printing equipment 10 can
`
`
`
`
`
`11
`
`UNIFIED PATENTS INC.
`EX1002
`Page 14 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`then print the digital images and deliver the images to a user selected delivery
`
`location. Id. at FIG. 5. The user may select the printing equipment 10 or the
`
`delivery place by using a “place name” instead of an address. Id. at FIG. 5, 6:49-
`
`54, and 7:8-29.
`
`30. FIG. 3 of Matsumoto discloses the digital still camera 49. Id. at FIG.
`
`3.
`
`
`
`
`
`
`
`12
`
`UNIFIED PATENTS INC.
`EX1002
`Page 15 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`31. Matsumoto includes two embodiments of digital still cameras, which
`
`are designated digital still camera 49 (in FIGS. 3 and 5) and digital still camera 9
`
`(in FIG. 1). The digital still camera (9 or 49) includes a camera section (12 or 50)
`
`including an imaging section 15 and an image processor 16. Id. at FIGS. 1 and 3
`
`and 2:48-55. The imaging section 15 captures analog signals of an image using a
`
`triple plate sensor. Id. The image processor 16 processes/converts the captured
`
`analog signals into digital image data. Id.
`
`32. The digital still camera 49 also includes a data communication section
`
`13, including a data terminal 20 and a sending data memory 22. Id. at FIGS. 1 and
`
`3, 2:63-65, and 5:15-18. The data terminal 20 includes a modem and a radio
`
`sender-receiver for sending and receiving data through radio telephony. The
`
`sending data memory 22 stores addresses of the photo labs. In some examples, a
`
`photo lab includes the reception equipment 60 and the printing equipment 10. Id. at
`
`6:16-18
`
`33. The digital still camera 49 can send digital images and data to the
`
`reception equipment 60, Id. at 3:11-22, which may be included in a photo lab
`
`which houses the printing equipment 10. The digital still camera 49 also stores
`
`“place names” of the printing equipment 10 and delivery places. Id. at 6:16-18 and
`
`
`
`
`
`13
`
`UNIFIED PATENTS INC.
`EX1002
`Page 16 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`6:53-59. The place names may be nicknames associated with the actual addresses
`
`of the printing equipment 10 and delivery places. Id. The digital still camera 49
`
`includes an LCD panel 52 and key input 21 for displaying the place names and for
`
`user selection and input of the place names. Id. at FIG. 5, 7:3-5, and 7:16-17.
`
`34. Thus, Matsumoto discloses that the place name and the digital image
`
`are sent, for example in a message, from the digital still camera (9 or 49) to the
`
`reception equipment 60 via the radio sender-receiver of the data terminal 20.
`
`35. FIG. 5 of Matsumoto also illustrates the reception equipment 60.
`
`
`
`
`
`14
`
`
`
`UNIFIED PATENTS INC.
`EX1002
`Page 17 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`36. The reception equipment 60 includes a buffer memory 62, a data
`
`receiver 61 and a data sender 66. Id. at FIG. 5 and 6:20-24. The reception
`
`equipment 60 includes a system controller 67 for controlling the reception
`
`equipment 60. Id. at FIG. 5 and 6:20-28. The reception equipment 60 receives the
`
`image data from the digital still camera 49 and stores the image data and control
`
`data at the buffer memory 62, including the place names. Id. at 6:27-32.
`
`37. Matsumoto discloses that the reception equipment 60 includes “a table
`
`for correlating place names with the addresses of the printing equipment 10 of the
`
`respective geographical areas, so the nearest printing equipment 10 to the present
`
`location of the camera 49 is selected based on the place name entered through the
`
`key input 21.” Id. at 6:53-59. Matsumoto also discloses that “[t]he address decoder
`
`63 decodes the address of the delivery place appointed by the user, that is included
`
`in the print delivery commands of the received data,” Id. at 6:30-32, which may be
`
`designated by place name. Id. at 7:8-30. Thus, Matsumoto describes that the
`
`reception equipment 60 can use the table to determine an address of the printing
`
`equipment 10 corresponding to the place name selected by a user.
`
`38. The reception equipment 60 sends a data file to the address of the
`
`printing equipment 10 corresponding to the user-selected place name. Id. at 6:37-
`
`
`
`
`
`15
`
`UNIFIED PATENTS INC.
`EX1002
`Page 18 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`59. The data file includes the digital image and in some examples can also include
`
`a decoded delivery place (other than the printing equipment 10). Id. The printing
`
`equipment 10 receives the data file and prints the digital images according to data
`
`file. If the data file includes a decoded deliver place, the printing equipment 10
`
`can deliver the digital image prints to the decoded delivery place. Id. at 7:8-30.
`
`2. Claim 2 is anticipated by Matsumoto
`
`39. Claim 2 recites: Digital photo processing system comprising:
`
`at least one wireless digital camera apparatus, wherein each said apparatus
`
`includes a processor, a memory, and a destination address and one or more
`
`previously defined recipient codes stored in said memory; user interface connected
`
`to said processor for at least displaying one or more said recipient codes and
`
`receiving signals indicating user selection of a displayed recipient code; a digital
`
`camera connected to said processor for capturing one or more digital images in
`
`response to signals from said user interface; a RF communications device
`
`connected to said processor; and processor control means, responsive to signals
`
`received from said user interface, for transmitting a message, including at least said
`
`selected recipient code and one said digital image, to said destination address via
`
`said RF communications device; and
`
`
`
`
`
`16
`
`UNIFIED PATENTS INC.
`EX1002
`Page 19 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`a server associated with said destination address and responsive to messages
`
`received at said destination address from each said wireless digital camera
`
`apparatus; a database storing account configuration data including recipient code
`
`data; a server communication device; and server control means for parsing said
`
`recipient code from each said message, retrieving from said database account
`
`configuration data that is associated with said recipient code, and processing each
`
`said message according to said account configuration data.
`
`a)
`
` “[d]igital photo processing system”
`
`40.
`
`In my opinion, Matsumoto discloses this limitation.
`
`41. Matsumoto discloses a “system for transferring image data from a
`
`camera to a printing system.” Matsumoto at Title and FIGS. 1, 3, and 5; see also
`
`Matsumoto-JP [0005]. The system includes a digital camera (9 or 49), reception
`
`equipment 60, and printing equipment 10. See Matsumoto at FIGS. 1, 3, and 5; see
`
`also Matsumoto-JP at [0005]. The digital camera 49 can transmit image data
`
`wirelessly to the reception equipment 60, which transfers the image data to the
`
`printing equipment 10 selected by the user. See Matsumoto at Abstract and FIG. 5;
`
`see also Matsumoto-JP at [0005]. The printing equipment 10 selected by the user
`
`processes the digital images and can deliver the processed digital images to a
`
`
`
`
`
`17
`
`UNIFIED PATENTS INC.
`EX1002
`Page 20 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`delivery location selected by the user. See Matsumoto at Abstract and FIG. 5; see
`
`also Matsumoto-JP at [0005].
`
`42. Thus, in my opinion, by describing the digital camera 49, the
`
`reception equipment 60, and the printing equipment 10, Matsumoto discloses a
`
`“digital photo processing system.”
`
`b)
`
`“at least one wireless digital camera apparatus, wherein each said
`apparatus includes a processor, a memory”
`
`43.
`
`In my opinion, Matsumoto discloses this limitation.
`
`44. Matsumoto discloses that the digital still camera (9 or 49) includes a
`
`camera section (12 or 50), a data communication section (13 or 53), and a system
`
`controller 14. Matsumoto at FIGS. 1 and 3; 2:43-49; see also Matsumoto-JP at
`
`[0008]-[0009]. The camera section 12 includes an image processor 16. Id. The data
`
`communication section (13 or 53) includes a sending data memory 22. Id. A person
`
`of ordinary skill in the art would understand that the image processor 16 teaches
`
`the processor of claim 2 of the ‘651 Patent.
`
`45. Thus, in my opinion, by describing that the digital still camera 9 or 49
`
`(“a wireless digital camera apparatus”) includes the image processor 16
`
`(“processor”) and the sending data memory 22 (“memory”), Matsumoto discloses
`
`
`
`
`
`18
`
`UNIFIED PATENTS INC.
`EX1002
`Page 21 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`“at least one wireless digital camera apparatus, wherein each said apparatus
`
`includes a processor, a memory.”
`
`c)
`
`“a destination address”
`
`46.
`
`In my opinion, Matsumoto discloses this limitation.
`
`47. Matsumoto discloses that the sending data memory 22 stores
`
`“addresses of the plurality of photo labs” (“destination address”). Matsumoto at
`
`FIG. 5; 6:16-20; see also Matsumoto-JP at [0034]. Matsumoto describes that the
`
`“addresses of the plurality of photo labs” (“destination address”) can include a
`
`telephone number of a transmission destination, such as the reception equipment
`
`60 or a photo lab, Matsumoto at FIG. 5; 5:26-31; see also Matsumoto-JP at [0030].
`
`Additionally, Matsumoto describes that in some embodiments the photo lab can
`
`include reception equipment 60. Matsumoto at FIG. 5; 6:16-20; see also
`
`Matsumoto-JP at [0034].
`
`48. Thus, in my opinion, by describing that the sending data memory 22
`
`(“memory”) stores addresses of the plurality of photo labs (“destination address”),
`
`Matsumoto discloses “a destination address.”
`
`d)
`
`“and one or more previously defined recipient codes stored in said
`memory”
`
`49.
`
`In my opinion, Matsumoto discloses this limitation.
`
`
`
`
`
`19
`
`UNIFIED PATENTS INC.
`EX1002
`Page 22 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`50. As explained above, In my opinion, by describing that the sending
`
`data memory 22 stores addresses of photo labs, Matsumoto discloses “a destination
`
`address.” Matsumoto at FIG. 3; 5:26-31; see also Matsumoto-JP at [0030].
`
`51. Additionally, Matsumoto discloses that a place name (“recipient
`
`code”) may be used instead of an actual address. Matsumoto at 6:53-59; see also
`
`Matsumoto-JP at [0036]. In Matsumoto, place names (“recipient codes”) may be
`
`used for designating the printing equipment 10 and may be used for designating a
`
`delivery destination. Matsumoto at 6:53-59 and 7:8-30; see also Matsumoto-JP at
`
`[0036] and [0037]. A delivery destination may include, for example, a location
`
`where the user would like to pick up photographs or where the user would like the
`
`photographs to be delivered. Matsumoto at 7:8-30; see also Matsumoto-JP at
`
`[0037]. Place names are displayed on an LCD panel 52 of the digital still camera
`
`49. Matsumoto at FIG. 3; 7:3-5 and 7:16-17; see also Matsumoto-JP at [0036] and
`
`[0037]. In my opinion, a person skilled in the art would understand the disclosure
`
`in Matsumoto of place names (“recipient codes”) being displayed on the LCD
`
`panel 52 of the digital still camera 49 as disclosing that the place names (“recipient
`
`codes”) are stored in memory, such as the sending data memory 22. For example,
`
`the place names stored in memory would be retrieved from the memory and
`
`
`
`
`
`20
`
`UNIFIED PATENTS INC.
`EX1002
`Page 23 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`provided to the LCD panel 52 for display. Additionally or alternatively, the place
`
`name may be stored in a memory or buffer of the LCD panel 52.
`
`52. Thus, in my opinion, by describing place names (“recipient codes”)
`
`being stored in memory, Matsumoto discloses “one or more previously defined
`
`recipient codes stored in a memory.”
`
`e)
`
`“user interface connected to said processor for at least displaying
`one or more said recipient codes”
`
`53.
`
`In my opinion, Matsumoto discloses this limitation.
`
`54. Matsumoto discloses that the digital still camera 49 includes the LCD
`
`panel 52 and a key input 21 controlled by a system controller 14 (collectively a
`
`“user interface”). Matsumoto describes that the LCD panel 52 can display a list of
`
`place names (“recipient codes”). Matsumoto at FIG. 3; 7:16-17; see also
`
`Matsumoto-JP at [0037].
`
`55. Thus, in my opinion, by describing that the LCD panel 52 displays a
`
`list of place names (“recipient codes”), Matsumoto discloses a “user interface
`
`connected to said processor for at least displaying one or more said recipient
`
`codes.”
`
`f)
`
`
`
`
`
`“and receiving signals indicating user selection of a displayed
`recipient code”
`
`21
`
`UNIFIED PATENTS INC.
`EX1002
`Page 24 of 163
`
`

`
`
`
`IPR2016-_____
`U.S. Patent 7,173,651
`
`56.
`
`In my opinion, Matsumoto discloses this limitation.
`
`57. Matsumoto discloses that the digital still camera 49 includes the LCD
`
`panel 52 and a key input 21 controlled by a system controller 14 (collectively a
`
`“user interface”). In Matsumoto, the place names can be entered through the key
`
`input 21. Matsumoto at FIGS. 3-5; 6:53-59; see also Matsumoto-JP at [0036].
`
`58. Thus, in my opinion, by describing the ability of a user to select a
`
`displayed place name (“recipient code”) using a key input 21, Matsumoto discloses
`
`“receiving signals indicating user selection of a displayed recipient code.”
`
`g)
`
`“a digital camera connected to said processor for capturing one or
`more digital images in response to signals from said user interface”
`
`59.
`
`In my opinion, Matsumoto discloses this limitation.
`
`60. Matsumoto discloses that the digital still camera 49 includes a camera
`
`section (12 or 50). Matsumoto at FIGS. 1 and 3; 2:43-49 and 5:22-25; see also
`
`Matsumoto-JP at [0008]-[0009] and [0029]. The camera section (12 or 50)
`
`includes an imaging section 15 (“digital camera”) for capturing digital images
`
`connected to the image processor 16 (“processor”). Matsumoto at FIGS. 1 and 3;
`
`2:43-49; see also Matsumoto-JP at [0008]-[0009]. The imaging section 15 (“digital
`
`camera”) can include a triple-plate type sensor for capturing image signals. Id.
`
`Matsumoto discloses