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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________
`
`COMCAST CABLE COMMUNICATIONS, LLC,
`Petitioner,
`
`v.
`
`ROVI GUIDES, INC.,
`Patent Owner.
`__________
`
`Cases IPR2017-00866 and IPR2017-00867
`Patent 8,713,595 B2
`__________
`
`Record of Oral Hearing
`Held: June 6, 2018
`__________
`
`
`
`
`Before KARL D. EASTHOM, BARBARA A. BENOIT, and
`STACY B. MARGOLIES, Administrative Patent Judges.
`
`
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`Cases IPR2017-00866 and IPR2017-00867
`Patent 8,713,595 B2
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`
`APPEARANCES:
`
`ON BEHALF OF THE PETITIONER:
`
`
`FREDERIC M. MEEKER
`Banner & Witcoff
`1100 13th Street N.W., Suite 1200
`Washington D.C. 20005-4051
`(202) 824-3116
`fmeeker@bannerwitcoff.com
`
`BRADLEY C. WRIGHT
`Banner & Witcoff
`1100 13th Street N.W., Suite 1200
`Washington D.C. 20005-4051
`(202) 824-3000
`bwright@bannerwitcoff.com
`
`
`
`ON BEHALF OF THE PATENT OWNER:
`
`
`MARK D. ROWLAND
`Ropes & Gray
`1900 University Avenue, 6th Floor
`East Palo Alto, CA 94303-2284
`(650) 617-4000
`mark.rowland@ropesgray.com
`
`SCOTT A. MCKEOWN
`Ropes & Gray
`2099 Pennsylvania Avenue, N.W.
`Washington D.C. 20006-6807
`(202) 508-4740
`scott.mckeown@ropesgray.com
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`KEVIN J. POST
`Ropes & Gray
`1211 Avenue of the Americas
`New York, NY 10036-8704
`(212) 596-9181
`kevin.post@ropesgray.com
`
`
`
`The above-entitled matter came on for hearing on Wednesday, June
`
`6, 2018, commencing at 9:00 a.m. at the U.S. Patent and Trademark Office,
`600 Dulany Street, Alexandria, Virginia.
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`P R O C E E D I N G S
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`JUDGE MARGOLIES: Good morning and welcome. We are
`here for a final consolidated hearing in two inter partes reviews. Both are
`captioned Comcast Cable Communications v. Rovi Guides. The first case
`is IPR2017-866 concerning U.S. Patent Number 8,713,595 B2. The second
`case is IPR2017-867, also concerning U.S. Patent Number 8,713,595 B2.
`First, let me begin by introducing the panel. I am joined by Judge Easthom
`and Judge Benoit, and I am Judge Margolies. Let's get the parties'
`appearances. Who do we have appearing today on behalf of petitioner?
`MR. MEEKER: Good morning, Your Honor and Your Honors.
`Fred Meeker with the Law Firm of Banner & Witcoff representing Comcast
`Cable Communications, LLC. Brad Wright will be giving the first
`argument this morning for the 866 and 867. We also have Seth Kramer
`who's in-house counsel at Comcast with us today. Thank you.
`JUDGE MARGOLIES: Good morning, counsel. Who do we
`have appearing today on behalf of patent owner?
`MR. ROWLAND: Good morning. Mark Rowland of Ropes &
`Gray on behalf of the patent owner. The arguments today for this hearing
`will be presented by my colleagues, Scott McKeown and Kevin Post.
`There's also a pending motion to include certain evidence. That would be
`handled by Mr. Post. And also with us today is the client representative,
`Michael Schwartz, Joseph Schenker, and some of our summer associates.
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`JUDGE MARGOLIES: Good morning, counsel and summer
`associates. Thank you. We set forth the procedure for today's hearing in
`our oral argument order and, as a reminder, each party will have 60 minutes
`of total time to present arguments in both cases. Petitioner has the burden
`of proof and will go first. Petitioner will open jointly for both cases.
`Patent owner will then present opposition arguments jointly for both cases.
`Patent owner may also argue its motion to exclude filed in IPR2017-867, if
`it so chooses. And then to the extent petitioner has reserved time,
`petitioner will present arguments in reply for both cases and in opposition to
`the motion to exclude. Finally, if patent owner has reserved time, it may
`present reply arguments only in regard to the motion to exclude.
`We are aware that patent owner has filed objections to some of the
`demonstrative slides. We are not going to rule on the objections at this
`point. Both parties are reminded that demonstrative slides are not evidence
`and will not be relied on for a final decision. Moreover, arguments raised
`for the first time during this hearing or in a demonstrative will not be given
`weight in our final decision.
`Are there any questions on behalf of patent owner at this time?
`MR. ROWLAND: No, Your Honor.
`JUDGE MARGOLIES: Thanks. And are there any questions on
`behalf of petitioner at this time?
`MR. WRIGHT: No, Your Honor.
`JUDGE MARGOLIES: Petitioner, would you like to reserve a
`certain amount of time for reply?
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`MR. WRIGHT: Yes, we would like to reserve 15 minutes of time
`for rebuttal, please. And also before we get started, we have extra copies of
`the handouts here. My colleague, Brian Emfinger, also from the Law Firm
`of Banner & Witcoff, if he may approach the bench to give you these copies,
`please.
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`JUDGE MARGOLIES: Yes, thank you. You may proceed when
`you're ready, counsel.
`MR. WRIGHT: Thank you. Brad Wright with the Law Firm of
`Banner & Witcoff, and I'll be addressing both the 866 and 867 proceedings.
`We have a lot of slides here. Obviously, we can't cover them all, but the
`two proceedings encompass four combinations of prior art. It's unlikely
`we'll be able to get to the fourth ground with all the material that we have to
`cover, but we'll see how it goes.
`If we can begin first with slide four, slide four addresses the
`instituted grounds. The first ground is obviousness over Lett in view of
`Granger and some of the dependent claims are addressed under obviousness
`over Lett in view of Granger and Young 121. That's the first combination
`of prior art. The second combination in the 866 proceeding is obviousness
`over Strubbe in view of Lett.
`If we could move to slide five, the next slide, please. So the
`primary issues in the 866 proceeding are, first, due to the interactive
`program guides of the Lett/Granger combination and the Strubbe/Lett
`combination direct the output of their tuners, as is required by the
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`independent claims. And the second issue to address is motivation to
`combine. Most of the other issues fall under one or more of these two.
`If we can move to slide six, please. Very quickly, I'd like to go
`through some of the undisputed facts that will hopefully simplify the
`resolution of this proceeding. First of all, the only claim limitation that the
`patent owner asserts is missing from the instituted grounds is the directing
`output of the tuner step that's recited in the independent claims. The patent
`owner did not request any interpretation of directing the output of tuners
`beyond its plain and ordinary meanings, so, even though we're under a
`Phillips type claim construction, the patent owner is putting glosses on the
`claim interpretation when it applies to prior art, but we're going to address it
`as a claim construction issue. And, finally, the patent specification never
`uses the word directing in connection with any of the tuning circuitry.
`If we could move to slide seven, please. Slide seven shows figure 2
`of the 595 patent, and, as you can see in figure 2, there is one box captioned
`"tuning circuitry element 72" that has a single output to a box labeled
`"genlock circuitry 82." That genlock circuitry synchronizes the output of
`the television signal that comes from the tuning circuitry 72 with the
`program guide information that comes out of the digital video circuitry box
`86 and supplies it to VCR 88 and display 84.
`You'll notice there's no illustration of two tuners, as required by the
`claims in here, and you'll notice that there's only a single output from tuning
`circuitry 72, not more than one output. You'll also notice that there's no
`switching circuitry in this arrangement.
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`If we could go to the next slide, eight, please. The entire disclosure
`in 595 patent of the support for recitation of the two tuners that are
`controlled by a single interactive program guide that directs the output of the
`two tuners is this highlighted sentence from column eight of the patent
`specification. The invention also contemplates the use of a set top box not
`shown, it acknowledges it's not shown, that includes two tuners, one each for
`the VCR 88 and display 84. So the patent owner has managed to parlay
`this sentence into a claim that's very detailed with respect to controlling the
`output of two tuners from an IPG.
`If we go to slide nine, the only other claim construction issue that the
`patent owner has raised has to do with the construction of interactive
`television program guide, but the patent owner has acknowledged that it's
`not necessary to resolve that because, presumably, they agree that the prior
`art in these combinations discloses that. And so here on the bottom of slide
`nine, you can see from a patent owner response they've acknowledged that
`this is not necessary to resolve.
`JUDGE MARGOLIES: And that is your position, as well?
`MR. WRIGHT: Yes, that's correct. It's undisputed that this
`prior art meets their definition. If we go to slide ten, I'd like to just very
`briefly review why the patent was allowed in the first place. The patent
`examiner repeatedly rejected the claims over various prior art that showed an
`interactive program guide and prior art that showed multiple tuners. The
`patent examiner never accepted the argument that the patent owner is
`making here, that the prior art failed to show one IPG controlling two tuners.
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`The examiner never accepted that argument. Instead, the claims were only
`allowed after an examiner interview in which the examiner convinced the
`applicant to add limitations of receiving program schedule information,
`storing it in a memory, and then, finally, most critically where in a set top
`box includes two tuners. That's what got the claims allowed. The prior
`art cited by the patent examiner did not show one set top box with two
`tuners, and so that's what got the claims allowed. We found prior art that
`shows that and, as we'll see, it renders it obvious.
`If we can move to slide 13, I'm not going to read -- I'm sorry, 12.
`Slide 12. I'm not going to read all through claim one. Independent claim
`one is representative of the independent claims. But on the left-hand side,
`we've just summarized what the claim requires. It requires an interactive
`program guide with TV program information. Two tuners have to be
`controlled by the same guide. A first tuner outputs a first program to
`record with the video recorder. A second tuner outputs a second program
`to watch on a display device. The first and second TV programs are
`recorded and viewed at the same time. And, finally, most critically, the set
`top box has to include the two tuners.
`JUDGE BENOIT: Mr. Wright, can I jump back to claim
`construction for a minute?
`MR. WRIGHT: Yes.
`JUDGE BENOIT: Has there been any other tribunal who's given
`you a claim construction order or analysis related to this patent?
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`MR. WRIGHT: Yes. The District Court interpreted the claim
`interactive program guide and, essentially, adopted Comcast's position in the
`litigation.
`JUDGE BENOIT: Has that been made of record in this case?
`MR. WRIGHT: I believe it has, yes. The claim construction
`order is one of the exhibits, and I don't have the exhibit number right here,
`but, yes, it is of record in this case.
`JUDGE BENOIT: Great. Thank you. The other question I had,
`and I just want to make sure it goes on the record, that, even though they're
`undisputed issues in this case, that the petitioner has a burden of proving on
`patentability?
`MR. WRIGHT: Yes, that's right. But there is no point on us
`spending time on things that are undisputed.
`JUDGE BENOIT: Absolutely.
`MR. WRIGHT: Okay. If we could jump to slide 13, which is
`really just a divider slide, let's jump into the first combination which is Lett
`in view of Granger. I'm going to start with an overview of the two
`references, discuss the combination that's in the petition, and then talk about
`motivation to combine.
`So if we start with slide 14, Lett discloses an interactive program
`guide that is used to select TV programs for watching or recording. So
`Lett's terminal has a single tuner, and the IPG can control it for watching and
`it can also control it for recording, but there's just one of them so it can only
`do one or the other at a time. And so you can see in figure 4-A, the
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`interactive program guide has time slots across the top and program numbers
`and stations down the left side with programs embedded in the cells, a very
`conventional grid format for this sort of thing. And on the right-hand side
`are portions of the specification that explains how this works.
`If we can go to slide 15, please. So Lett has a terminal in figure 3.
`It has a single tuner, also called an up-down converter. And what's on slide
`15 is an excerpt from column seven of specification of Lett, and what it says,
`and I'm going to read just the highlighted parts, Figure 3 is a detailed block
`diagram of the decoder, also called the terminal. Referring to figure 3, a
`detailed block diagram of one of the subscriber terminals will now be
`described. Three sentences later, still talking about the same terminal in
`figure 3, it says, "More than one tuner may be provided (not shown) to
`provide, for example, picture-in-picture services of watch/record modes."
`Now, I have two observations about this. First of all, you'll notice
`that this sentence is strikingly similar to the disclosure in the 595 patent for
`an IPG controlling two tuners or two tuners in a set top box. And so the
`amount of disclosure that's in Lett is comparable to the amount of disclosure
`in the 595 patent.
`The second observation I have about this passage is its proximity to
`the discussion of the terminal in figure 3. So, clearly, Lett is suggesting
`that, although figure 3 shows one tuner, more than one tuner may be
`provided in the context of the terminal in figure 3. The reason I'm
`mentioning this is that the patent owner makes noise about something that's
`discussed more than ten paragraphs later.
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`JUDGE MARGOLIES: That's right. So in column nine, from
`line 60 to 65 approximately, it says an additional subscriber terminal for dual
`tuner operation.
`MR. WRIGHT: Yes, that's right. So in two different places,
`Lett is talking about two different things. Here it's talking about figure 3
`two tuners may be provided, not shown in the figure, for picture-in-picture
`services of watch/record modes. Now, I'll get to watch/record modes in a
`few minutes. I've got a couple of slides on that. When Lett is referring
`more than ten paragraphs later to another terminal, it's talking about how this
`one set top converter can be connected through another through a data port.
`But that doesn't negate what Lett said up here about two tuners in the
`terminal of figure 3.
`So the patent owner takes the position that there's only one
`embodiment of using two tuners in Lett, and that embodiment is you must
`have two set top converters, but that's not a fair reading of Lett. Lett
`clearly shows here in figure 3 more than one tuner can be provided. It says
`that without any reference to any other set top converters. Later, more than
`ten paragraphs later when it's talking about other ways of communicating
`with external devices, it mentions that you can connect through the data port
`to communicate with the second set top terminal. And I'll address this a
`little more in a few minutes because I've got some other slides that I think
`will help explain this.
`If we could move to slide 16, please, I want to talk about the
`watch/record mode in Lett. So it says two tuners can be provided for
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`watch/record mode. Petitioner's expert, Dr. Rhyne, explained what that
`means. Two tuners means that you can use one tuner for watching and
`another tuner for recording. The patent owner's position is watch/record
`mode means watch or record, but that makes no sense because you wouldn't
`need two tuners to do that. You could watch or record with one tuner.
`So, clearly, the watch/record mode that's referenced in Lett is a mode in
`which one tuner is used for watching and another tuner is used for recording.
`In fact, we had a linguistics expert who provided a declaration explaining
`what the slash means in watch/record with reference to the evidence in this
`case.
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`If we could go to slide 17, please, slide 17 shows figure 4 of
`Granger. So Granger is the secondary reference, and you can see that it
`teaches two tuners that enable simultaneous watching and recording of two
`different channels. And you can see that in the specification, column five,
`line 24 on the left, and color-coded on the right-hand side. The top tuner in
`red outputs to a TV set, and the bottom tuner in blue outputs to a VCR. So
`Granger teaches two tuners in a set top box for simultaneously watching and
`recording.
`If we go to the next slide, 18, so what is the combination? So the
`combination is Lett's set top terminal where Lett suggests that more than one
`tuner can be included, not shown in the terminal, should be modified to
`include two tuners as taught by Granger, and the IPG in Lett -- remember in
`Lett the only thing there is for controlling the tuners is the IPG. That's it.
`So the combination is adding a second tuner to Lett's single-tuner
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`embodiment would have resulted in Lett's IPG controlling both tuners.
`And that's explained here in the petition and in Dr. Rhyne's declaration.
`If we could go to slide 19, please. I want to address the limitation
`that -- and, first, we're just dealing with the combination. I'll get to
`motivation to combine in a couple of minutes. So element 1-G is the claim
`limitation that the patent owner says is missing from the combination. So
`claim element 1(g) requires directing an output of the first turner of the first
`TV program to the video recorder so that the first TV program to be
`recorded is recorded. And on slide 19, we cited where in the petition with
`citation to the expert declaration this is found in the record. And if we go
`to the next slide 20, the rest of element 1-G requires that an output of the
`second tuner of the second TV program selected to be viewed goes to the
`display device such that the second program selected to be viewed is
`displayed by the display device. And so at the bottom of slide 20, we have
`a citation to the petition and supporting declaration as to where this is found
`in the record.
`If we can go to slide 21, please. So the patent owner says that the
`output of Lett's and Granger's tuners can't be directed because they only
`have one place to go. In other words, the top tuner in Granger goes to one
`place and the bottom tuner in Granger goes to a second place. That's their
`position.
`If we go to the next slide, 22, essentially this is the same argument.
`The patent owner, in viewing an interpretation to directing here that requires
`more than is required by the claims.
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`If we could go to slide 23, please. First of all, the claims don't say
`anything about how the tuner's outputs are directed. Remember back in
`figure 2 there's no circuitry shown for switching or doing anything special.
`There's only one output coming from the tuning circuitry that goes to
`genlock. There's absolutely nothing in there. There's nothing in the
`claims that require a particular type of direction. They don't require a non-
`dedicated connection or a dedicated connection. They don't say anything
`about it, and they clearly don't exclude a dedicated connection.
`If we go to the next slide, 24, there's no support in the specification
`or in the prosecution history for directing as requiring a selection. What
`they're implying is that the user has to be able to select which tuner goes to
`the VCR and which tuner goes to the TV, but the claims don't say anything
`about that, the specification doesn't support that, nothing in the prosecution
`history supports that. And as we saw, the 595 patent only illustrates tuning
`circuitry, nothing else that would support that definition.
`If we could go to slide 25, patent owner's own expert admitted that
`the 595 patent does not explain how the two tuners are connected to the
`VCR and the display. So they're trying to import a limitation into the
`claims that's not supported.
`If we quickly jump to slide 171 --
`JUDGE EASTHOM: So is it your position that Granger's interface
`directs the two tuners? How do you read that limitation on the
`combination?
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`MR. WRIGHT: So actually let's go to slide 27 because that
`addresses the question that you've asked. So what is the plain and ordinary
`meaning of directing? When you read it in light of what's disclosed in the
`patent specification, it only requires that the IPG directs the output of the
`tuners by causing them to tune to and simultaneously output channels
`carrying TV programs. So one goes to the recorder and one goes to the
`TV. There's no selection required. They're implying that there has to be a
`switch somewhere in the circuitry so that one can be switched to the other,
`one or the other, but the claims don't require that and, as we've said, there's
`nothing in the patent specification or prosecution history that supports that.
`So the next step is -- I'm sorry. The next slide, 28, in our reply, we
`identified a dictionary definition, which may be helpful in this case since the
`patent specification doesn't provide any gloss, and one of the ordinary
`meanings of the verb "direct" is to cause to move in or follow a direct or
`straight course. So what the 595 patent does disclose is that there's a
`control command issued to the tuning circuitry, and the tuning circuitry
`causes the selected program to be output. That's all it is. So it causes the
`program to be output.
`JUDGE BENOIT: And so why did you select the fifth enumerated
`definition? Does your expert support why this definition is being put
`forward?
`MR. WRIGHT: It appears to be the one that's most relevant to
`the circumstances of this case. Obviously, English words have a lot of
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`different nuances and overtones. This one appeared to be one that's most
`natural for lining up with the claim language in light of the specification.
`JUDGE BENOIT: And does your expert testify to that?
`MR. WRIGHT: I would have to check on what exactly he
`testified. Perhaps you could pull that over there. I'll see if I can answer
`that as soon as we get this. On paragraph 15 of his second declaration, Dr.
`Rhyne says, "It's my understanding that the dictionary definition of the verb
`direct includes the cause to move or follow a direct or straight course. It's
`the best of my opinion that a POSITA would have understood the output of a
`tuner can be directed to a device, regardless of whether that tuner is
`connected to a circuit that is dedicated to the device or whether that tuner is
`connected to a circuit that can be switched between multiple devices." So
`that's the testimony that we have in the record.
`JUDGE MARGOLIES: Thank you for pointing that out. But
`getting back to the issue of directing versus selecting, it seems like at some
`point you have to choose which path you're going to go to. Is it your point
`that that's not in the claim?
`MR. WRIGHT: It's not in the claims. I'll show you in a few
`minutes they have put a different gloss on it that they actually say that it
`requires switching. So in several different places, they're trying to put a
`gloss on it that's not in the claim and it, frankly, is not supported by the
`disclosure. I mean, there's no switching circuitry. There's nothing
`disclosed in figure 2 that would allow the user to specify which tuner goes to
`which device. Remember it's tuning circuitry with one line. The one line
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`goes to genlock. Genlock has nothing to do with switching. It has to do
`with synchronizing the video signal with the EPG data and outputting a
`combined picture. And then there's just two lines that go to a VCR and a
`TV. Nothing in there that has anything to do. And remember the patent
`specification never uses the word direct anywhere, so there's just no support
`for their gloss on this term.
`If we could, are there any other questions on this claim? And,
`again, this is being framed as a claim construction issue because they've
`shuffled it back in the application of the prior art. But it really is a claim
`construction issue. And there's no support for their position.
`If we can move to slide 29, please, which is a divider slide, I'd like to
`move on to the motivation to combine Lett and Granger. And if we could
`start with slide 30, the next few slides we're not going to go through all of
`them but are generally directed to the what of the combination, the why of
`the combination, and the how of the combination.
`So at the highest level, let's remember here this is basically patenting
`duplication of parts, right? Instead of one tuner, we have two tuners. And
`as we all know, the MPE says that's not a patentable advance. So what's
`happening here is they've gotten a patent on a sentence out of their patent
`specification, but the prior art shows a very similar sentence with respect to
`a single tuner set top converter. It would have been obvious to apply
`Granger's teachings of how to implement a multi-tuner set top converter to
`Lett's teachings of a single tuner set top terminal to obtain Lett's suggested
`set top box of having more than one tuner. So just to recap, Lett has one
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`tuner that's controlled for watching or recording by an IPG, and it says, by
`the way, there could be more than one tuner, not shown, very similar to what
`the 595 patent discloses, and this would be nothing more than predictably
`applying Granger's known technique of two tuners in the set top box. And
`remember that's the feature that the patent examiner couldn't find, that's the
`feature that the patent examiner said was the advance over the art.
`Applying that known technique to a device that's ready for improvement.
`How do we know it's ready for improvement? Because Lett says so itself.
`It says you could have more than one tuner.
`So this is set forth in the petition at pages 24 to 25 --
`JUDGE MARGOLIES: Getting back to that statement, does the
`argument, I guess, fall apart if that sentence is really not meant to apply to
`that single decoder or terminal?
`MR. WRIGHT: No, it does not. First of all, as we'll see in a
`few minutes, we explain on page 15 of our petition Granger also says that
`it's a better design to have two tuners in one set top box instead of having
`two set top converters. And the reason is that two set top converters is a
`duplication of everything and that would lead to excessive costs and
`difficulties with connection. So Granger still teaches the advantages of
`putting two tuners in one set top converter, to answer your question.
`If we could go to slide 31, please. So the improvement to Lett's
`single tuner set top box would be the ability to simultaneously watch and
`record different TV channels at the same time with the same device, as
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`implied by Lett's watch/record mode sentence. That's the sentence that
`suggests how you would use the two tuners if they were implemented.
`If we go to slide 32, please, I want to switch to the why of the
`combination. So, again, Lett suggests more than one tuner to provide a
`watch/record mode, which, as we said, means watching one and recording a
`different one using a different tuner. That would have motivated a person
`to modify the single tuner embodiment of Lett by adding a second tuner to
`enable that mode. Why? Because Lett doesn't show the second tuner,
`doesn't have implementation details of the second tuner, so a person wanting
`to implement that suggestion in Lett would have found it by looking at
`Granger. And, again, just as a reminder, Granger is the magic two
`terminals, two tuners in one set top box that the examiner couldn't find. So
`that would have led one to Granger to implement a two tuner in one set top
`box configuration.
`If you go to slide 33, please. Both Lett and Granger teach that
`providing multiple tuners enables simultaneous viewing and recording and a
`person of skill in the art would have recognized that Granger's configuration
`was suitable to apply to Lett's single set top box. This is explained in the
`petition and in Dr. Rhyne's expert declaration.
`If we go to slide 34, I alluded to this earlier. Granger also teaches
`the drawbacks of using two set top converters: a complicated connection and
`excessive costs. The patent owner says that it would be excessively costly
`to have two tuners in one set top box, but it would be hugely more expensive
`to have two set top converters, which, of course, would have two tuners in
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`two set top boxes. So Granger's solution is to put two tuners in a single set
`top converter, and this is explained in the petition, page 15, and in Granger
`at column three.
`If we go to the next slide, 36, I'm sorry, 35, this is just explaining this
`point in a little more detail. If we go to slide 36, the next few slides which
`I'm going to skip over address the how of the combination. We've laid this
`out in the briefing. Unless somebody has a question on it --
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`JUDGE EASTHOM: I have one question about claim one. The
`one clause says where a set top box includes two tuners, one each for said
`video recorder and said display device. It seems that that's calling for a
`tuner that can connect to both of those devices. Each one of them can
`connect to two of the devices.
`MR. WRIGHT: Actually, with all due respect, I would say that
`that reads the opposite way. It seems to suggest that one tuner is dedicated
`to the display device and one tuner is
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