Hovsepian v. Apple, Inc.

Filing 158

Hovsepian v. Apple, Inc.

Doc. 158 Att. 2

EXHIBIT G

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PATENT Attorney Docket No . 02473 .0001-00000

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UN 2 1 1491 .

In re the application of Paul Yurt, et al . Serial No . 07/637,562 Filed : January 7, 1991

IN THE UNITED STATES PATENT AND TRADEGRQQye

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roup Art Unit : 262 xaminer : )

For : AUDIO AND VIDEO TRANSMISSION AND RECEIVING SYSTEM Hon . C=MisSioner of Patents and Trademarks Washington, DC 20231 Sir :

PETITION TO MARK SPECIAL UNDER M .P .S .P . 08 .02 VIII

..w o "" ~eu I NNEUN.HEDEASON N

Applicants hereby petition the Commissioner of Patents and Trademarks under M .P .E .P . S 708 .02 (VIII) to make this application special and receive accelerated examination . In accordance with that section, Applicants have enclosed a check for $80 .00 to cover the fee for this petition as set forth in 37 C .F .R . S 1 .17(i) . If any additional fees are required in connection with the filing of this Petition, please charge those fees to Deposit Account No . 06-916 . All claims presented for examination are believed to be directed to a single invention . If, however, the Examiner requires a restriction, Applicants provisionally elect for prosecution whichever group of claims contains method claims 18-21 . Also in accordance with M .P .E .P . 5708 .02 (VIII), Applicants affirm that a preexamination search has been made -1OBO GS 06/20/91 07637562 i3c 0-.00 CK

Fl"OW.

CAR0 ETT . B DUNNEK 000 1 ST"CR. q ~393 o0 " a900

The following references were developed during the searches and during subsequent investigations, and a copy of each of these references is enclosed along with a copy of PTO Form FS-A820 listing these references . DESCRIPTION OF THE CLAN= INVENTION

by an attorney who conducted searches in class 358, subclass 86 and class 455, subclasses 4, 5, 86, 102, 135, and 136 .

system to send requested programs to users in a relatively short time period, and allows users to store large quantities of requested material for playback at a desired time . reception system .
FINNEGAN, HENDERSON FARAAas, GARRETT S DUNHER
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particular time because the system has a buffering capability . By employing such buffering, the user has individualized control over the replay of requested programs . Moreover, requested programs are sent to the user in a compressed format . This enables the

The present invention is directed to an audio and video transmission and receiving system in which the user controls the access and the playback operations of selected material . The present invention affords the user greater access to and control over audio and video information than is possible in conventional systems . With the present invention, a user can request audio and video information to be sent to a selected destination . Further, the user is not constrained to having programs played at a

The entire system includes a transmission system and a The transmission system includes a source The material library from which a user makes a selection .

selected program is processed and compressed for storage in a -2-

?or "oe .aoo

compressed data library .

The system control computer controls

'-access to programs stored in the compressed data library and controls transmission of selected programs to a user . Once a selected program is transmitted, the reception system of the present invention receives the program and buffers it in a storage section . Because the program is buffered, the user can When replay choose to replay the stored program whenever desired . time at the receiving device requested by the user . Figs . 2A and 2B of the application are detailed block diagrams of a preferred implementation of the transmission system of the present invention . data library 118 . Fig . 2B shows an implementation of the compressed data storing means recited in claim 1 as the compressed Fig . 6 is a block diagram of a preferred implementation of the receiving system of the present invention . Fig . 6 shows an implementation of the storing means required in claim 22 as element 203 . Fig . 7 is a flowchart of a preferred method of distribution which shows the buffering step at step 418 . Claims 1-17 are directed to a transmission system for providing information to remote locations . library 111, for storing items . The system recited in those claims includes library means, for example source material A requested program is encoded in the identification encoding means, for example identification encoder 112, which assigns the requested program with a unique identification code .
F~NNEGAN. }fENDfRSal1 Fnxmaw. 6 DtwwVt . '3oo 1 &n-[P r r ~ua. .~. .CTC" .. . C[ :Coos

is requested, the program is decompressed and played back in real

The requested program is also converted by for example converter 123, and ordered into

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the converting means,

a sequence of addressable data block by the ordering means, for -3-

i t . .08 .0 .0

z ;:ample time encoder 114 and precompression processor 115 . Subsequently, the program is compressed by compression means, such as compressor 116, and stored in the compressed data storing means, which may be compressed data library 118 . The identification means, the conversion means, the ordering means, and the compressed data stores storing means will be collectively referred to as preprocessing elements . the requested program to the user . Claim 7 calls for a system control interface means for generating a visually-perceptible list of the items available in the compressed data library, and library access interface means, which may be library access interface 121, which receives in the compressed data library means . transmission requests and retrieves formatted data blocks stored Claims 18-21 cover a distribution method responsive to user This is shown in Figure 7 . The Transmitter means, for example transmitter format means 119 and transmitter 122, transmit

requests identifying information to be sent from a transmission system to remote locations . distribution method of independent claim 18 includes the steps of form (steps 413a-413e), storing audio and video information in a compressed data form (step 414) and user request of the stored The method also includes the steps of sending the After reception, the distribution information for transmission to a selected remote location (step 415) . compressed information to a remote location (step 416) and
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processing audio and information for storage in a compressed data

receiving it there (step 417) .

method includes buffering the received information (step 418) and -4-

a

playing it back in real time at a time requested by the user (step 419) . The distribution method recited in claim 21 further includes, the step of storing a list of items available to the user from at least one compressed data library, and providing the user with the list so that the user may remotely select a particular item for transmission . Claims 22-32 are directed to a receiving system responsive to a user input identifying an item stored in a source material library to be played back to the subscriber at a location remote from the source material library, the item containing information to be sent from a transmitter to the receiving system . The reception system 200 comprises transceiver means, such as transceiver 201, which receives requested information from the transmitter as compressed formatted data . The received converted into a format suitable for storage and in the receiver format conversion means, which may be receiver format converter 202, and then stored as .fompressed data in the storage means, for example storago 203 . for example When playback is requested, the decompressing means, W"?

udio decompressor 209 and video decompressor 208, decompresses the information and the output conversion means, such as output converter 206, plays back the decompressed information in real tim e at a time specified by the user . As recited in claim 27, the output data conversion means further comprises digital video output means, for example video for example

FINNEUNa}{ENDEfl80N F,,R,nom. GARRETT U DIRJNEl1

output converter 211, and analog video output means, analog v ide o output converter 213 .

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According to claim 30, the

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output data conversion means also includes digital audio output means, for example digital audio output converter 212, and analog Claim 32 recites that the transceiver means, such as transceiver 201, receives information via any one of telephone, cable television systems, MAN, and microwave . ISDN, broadband ISDN, satellite, common carrier, computer channels, converter 214 . audio output means, for example analog audio output

DETAILED DESCRIPTION OF THE REFEPJKNCES A. 1. EFERENCES CITED IN THE SPECIFICATION ap Patent No . 4,963,995

transceiver portion of the specification, discloses an audio/video apparatus (VCR-ET) that includes a compression capability . The VCR-ET of Lang is an improved audio/video recorder which has usefulness and functionality ." See col . 1, lines 65-68 .

Lana , which is discussed in the Background of Invention

"added features and functions which significantly enhance its

Specifically, Lang discloses an audio/video transceiver with the capability of editing or copying from one video tape to another using only a single tape deck . L_ang further discloses a VCR-ET See Col . 7, which can re-transmit a program to a second VCR-ET . lines 60-64 .

Lang does not disclose a transmission system as recited in

independent claim 1 because Lang does not teach or suggest a transmission system for providing information to remote locations
FINNEGIN, HENDE9l5ON F,Xneow, GARREn

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which includes library means for storing items . -6-

Lang also does

not teach or suggest an identification encoding means for

retrieving the information for the items from the library means and for assigning a unique identification code to the retrieved information !Ana also is not concerned with providing a distribution method responsive to user requests identifying information to be sent from a transmission system to remote locations . method claimed in independent claim 18 . Because Lang. i s directed to an improved VCR, Lang does not disclose a receiving system which is responsive to user requests for items from a source material library . While Lang mentions that video libraries are "envisioned," there is no disclosure of how material would be requested or retrieved from such libraries . See cal . 7, line 67 of Lang . Particularly, Lana does not teach that user requests will cause items stored in a source material library to be sent from a transmitter to a receiving system, as called for in independent claim 22 . 2. Monslow et al . . U .S . Patent No . 4,850,320 Monslow et al ., which is also described in the Background of Invention section of the specification, discloses a system which broadcasts viewer-selected material to a viewer at a prescribed time . However, the Monslow et al . system requires multiple users in multiple locations to view the requested material at the time it is broadcast, rather than allowing each viewer to choose his or
.-cc* FINNFCAN . HENDE.WN 0 FAxAWm. LAAKETT B DVNNE. 0 ia00 I STwt[T. .. ~ . ..5.."airs . o c :0005

Accordingly,

Lang fails to teach or suggest the steps of the distribution

her own viewing time .

once the choice is made, the user cannot

change it because Monslow et al . does not provide for buffering a

SA

selected program so that the user can play it back at a desired time . ee col . 6, line 60 through col . 7, line 28 . Further, in Monslow et al ., the viewer-chosen program is transmitted to the television receiver of the requesting viewer . The requestor therefore does not have a choice of where the information that they request is sent . and col . 5, lines 27-39 . With regard to the claims, Monslow et al . does not teach or suggest the preprocessing elements called for in independent claim 1, the buffering step required in independent claim 18, or the storage means recited in independent claim 22 . 3. braham, U .S . Patent No . 4 .590 .516 See the Abstract, Fig . 1,

Abraham '516, which is another reference described in the Background of Invention portion of the specification, discloses a combined telephone and modulated carrier communication system . Abraham '516, a user at a subscriber station 10 uses a standard telephone set 16 to contact program service station 12 . selects a program from the library 36 . The user In

A telephone communication

link is established with the station 12 through the switching gear 20, and when the program selection operation from the library 36 is completed, a return signal is heard by the subscriber through the telephone . The user then hangs up the telephone which A After initiates program readout and sets the billing computer 28 . timed message period precedes transmission of the program . the billing operation is performed .

the message period ends, the selected program is transmitted and
FINNECAN, HENDERSON FARAICW, CARRETT & DUNNER .000 1 STOCCT n w w.5-OT15.. .1 70005 707 -00 -000

During the message period,

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of the program . the subscriber can call up and cancel transmission and Fig . 1 . See col . 4, line 38 through col . 5, line 3 path, The system in Abraham '516 uses a dedicated signal Also, the receiver has no storage capability .

audio/video rather than multiple common carriers, to transmit programming . which Furthermore, the system provides for only display functions, is ordered, and, limits viewing to the time at which the material does not allow for like Monslow et al ., the Abraham '516 system functions of existing VCR the stop, pause, and multiple viewing technology .

this simultaneous transmission of the requested material, compressed data storage reference does not teach or suggest the buffering step required means recited in independent claim 1, the in claim 22 . in claim-18, or the storage means called for 4. alter U .S . Patent No . 4,506 .387

discloses relative Because Abraham '516, like Monslow et al .,

of Invention section Walter , also discussed in the Background dedicated, multiof the specification, discloses a fully the viewer's conductor, optical cable system that is wired to viewer some control premises . Although the system affords the

that a location over accessing the material, it requires The dedicated cable . designated by the viewer be wired with a be at that location Walter system further requires that the viewer material . for both ordering and viewing the audio/video the memory modules In Walter , information is retrieved from output of desired material 24-35 . A host computer 20 controls over optical fibers 129, 94, 96, 98, and 100 to data receiving -9-

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system 146 .

compressed form .

provision in Walter for storing the requested material in a

After selection from memory modules, there is no Therefore, Walter does not teach or suggest the

Additionally, there is no teaching or suggestion in Walter that only a portion of an item stored in the library modules 24-34 can be sent to a subscriber, as further recited in independent claim 1 . Walter shows memory module 102 in the data receiving data is stored in memory module 102 . system 14, but there is no indication in Walter that compressed ecause non-compressed data ccordingly Walter

preprocessing elements required in independent claim 1 .

quantity of data which may be stored therein .

is stored in the memory module, the user is limited as to the

does not teach or suggest buffering the received information, which is compressed, at the remote location, as recited in independent claim 18, or a receiver including storage means, coupled to receiver format conversion means, for storing
B. 1.

compressed formatted data, as set forth in independent claim 22 .
EFERENCES CITED IN THE SEARCH REPORT OF 09/07/90 umels t al . U .S . Patent No . 4,949,169

Lumels

high speed communication link in a video-graphics display window environment . A "primary objective" of Lumelsky et al .
i . :3

t al . discloses an audio-video data interface for a

to

"provide a simple interface to a high speed digital communication
FINNEUN. HENDERSON FA"svlv, GARAETT 6 Dt1NNtR uoo a .7wIR, w ,. 202 .08 .00C

network such that full motion video window images and its audio sampled by one node can be transmitted over the network to other nodes ." See col . 5, lines 25-30 and Figs . IA and 1B . - 1 0-

Because Lumelsky et al . i s directed to interface architecture for connecting video display devices, it is not directed to a transmission system or a receiving system, as respectively recited in independent claims I and 22 . Further, because Lumelskv et al . i s concerned only with interconnecting display devices, it is not concerned with the distribution of information from a transmitter to a receiver, and therefore it does not teach or suggest buffering received information at a remote location, as recited in the distribution method of independent claim 18 . 2. Fenwick et al ., U.S . Patent No . 4 .947 .244 Fenwi cy et al . discloses a video program distribution system . The system includes controller 116 which receives and responds to user requests from monitors 102 . Col . 3, lines 29-36 . players . The controller 116 also controls See the switch 114 which is connected to the video sources 112 .

The video sources 112 are video cassette

The number of video cassette players used in a system See Col . 5, lines 15-20 .

will vary between thirty-two and ninety depending on the range of programming desired .

In Fenwick et al ., the video sources 112 must be manually controlled . Because the system is manually controlled, Fenwick et al . does not disclose a transmission system including identification encoding means for retrieving the information for the items from a library and for assigning a unique identification code to the retrieved information, as required in independent claim 1 .
FINN EUNOHENDERSON
FA1LA&OMY . CARRETT 6 DIrNNFR

Moreover, in Fenwick et al ., information is sent

directly from video sources 112 to the monitors 102 and is not stored prior to replay . Therefore, Fenwick et al . also does not - 1 1-

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disclose buffering received information at a remote location, as required in independent claim 18 or a storage device at the receiver, as required in independent claim 22 . 3. oulton, U .S . Patent No . 4,937 .821

The Boulton patent discloses an information delivery system for delivering reference information to a plurality of users . In

Boulton , information from data sources 12 is encoded in encoders 14 and mixed in mixers 16 and 18 for delivery over a cable 24 to a user . The information is neither transmitted nor received by the Boulton also does not show the

user in a compressed form .

requested information being stored prior to transmission to a user . Boulton therefore does not teach or suggest a transmission system including the preprocessing steps or compressed data storing means, as recited in independent claim 1, or the step of storing audio and video information in a compressed data form, as recited in independent claim 18 . Because Boulton also does not

show the requested information being stored at the receiving device of a user, Boulton does not teach or suggest storage means for storing compressed formatted data, as recited in independent claim 22 . 4. Ecimers et al . . U .S . Patent No . 4,920,432 The Eggers et al . patent discloses a system for random access to an audio video library with independent selection and display at each of a plurality of remote locations .
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The system in

Eggers et al . includes a video filer 2, which is a microprocessorcontrolled mechanical storage and retriever device, that transports discrete data record items, i .e ., video cartridges, - 1 2-

'

1

side, :between a rectangular array of storage sites 12 open on one l and an adjacent array of playback devices 11 . 36-40 . See col . 3, lines Video signal combiner 4 directs the outputs of all of the

signal sources, including players 11, to the user terminals 8 by way of a video cable 17 . Eggers et al . does not teach or suggest the identification

and encoding means for retrieving the information from the library for assigning a unique identification code to the retrieved material, as called for in independent claim 1 . receiving device prior to replay . Eggers et al . also does not teach storage of the requested material at the

Therefore, Eggers et al . does

independent not teach or suggest the buffering step set forth in does not teach the filer 2 to the user terminals 8, Eggers et al . claim 22 . or suggest the storage means called for in independent 5. Bestler et al . and 4 .755 .872 U.S . Patent Nos . 4,807,023 claim 18 . Moreover, because the material is sent directly from

pay per The Bestler et al . patents relate to an 'impulse view' system .

unscrambled at his specific cable program by requesting that it be causes the receiver . The user enters a password which thereby allowing him authorization code in his converter to change 14, lines 58-64 of 'to view the desired cable event . See col . Bestler_ et al . '872 . 023 and col . 4, lines 49-55 of Bestler et al .

a In the Bestler et al . system, a user can receive

FINTIECAN. HENDEMON FARADOW. GAAUTT B DUNNER '300 . 1-to. . ... .~.a*o . D C 70._ 000 -zar .00 "000

sent directly In the Bestler et al . patents, programming is Because the requested ito the viewer's cable television receiver . Bestler et al . programming is directly transmitted, neither of the -13-

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patents teaches buffering requested programming .

Therefore,

neither of the Bestler et al . patents teaches or suggests the preprocessing elements recited in independent claim 1, the buffering step required in independent claim 18, or the storage means called for in independent claim 22 . 6. ord on et al . .S . Patent No . 4 .763 .191 The Gordon et al . patent discloses a system providing an "800" dial-a-view program for ordering a selection through a telephone networking arrangement . The Gordon et al . system includes routing database 101 for directing a dial-a-view call received by a toll network switching office 102 to centralized network equipment 103 . Vendor equipment 104 supplies the requested subscription television programming to the calling customer television 105 at customer premises 122 via decoder 106 and coaxial cable 160 . See Fig . 1 and col . 5, lines 3-23 . Fig . 2 of Gordon et al . shows another embodiment of vendor equipment 104 . In this configuration, vendor equipment 104 Satellite facilities 202 and 203 provide Equipment 201 includes program includes local vendor equipment 201 to serve customer premises 122 via cable 160 . individual programming whereby information local vendor equipment 201 .

is

transmitted to the

distribution equipment 207 and a billing system 208 . In Gordon et al ., there is no provision for storage of requested programming before transmission to the user or for storage before the programming is played .
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Because there is no

storage, Gordon et al . does not teach or suggest the preprocessing step lements recited in independent claim 1, the buffering -14-

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required in independent claim 18, or the storage means called for in independent claim 22 . 7. thworth et al . U.S . Patent No . 4,400,717 The Southworth patent relates to a color slow-scan TV system and method . The system includes video compressor 25 which The output of the receives a color signal from a video input 27 . which indicates the image to be transmitted .

memory in video compressor 25 is displayed on a TV monitor 29 The memory is read See Fig . 1 and out slowly and transmitted over a transmission channel 31 to a

video expander 33 and displayed at TV monitor 35 . col . 2, lines 33-49 . Because Southworth, et

locations, as in video information from libraries to remote user the present invention . g. which The Lambert patent relates to a cable television system ambent . Patent No . 4,381,522

and it is not directed to reception and distribution of audio

al .

i s concerned with the slow scan,

viewers includes a minicomputer 11 that responds to signals from are sent only at remote receiving locations 18 . Desired programs channels . at specified times and only over specified cable In Lambert , the col . 2, line 49 through col . 3, line 18 . See

played subscriber has limited control over when a program will be

time for the because computer 11 assigns a channel, start and stop selected program .
INNEGAN. HENDERSO'I FAIUDO'i- GAARETT ; 0 h M NNF.
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Moreover, there is no provision for storage of

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requested data prior to transmission, or for storage at the receiving device of the user .

Accordingly, Lambert does not teach

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or suggest the preprocessing elements called for in independent - 1 5-

o

claim 1, the buffering step required in claim 18, or the storage means recited in claim 22 . 9. n U .S . Patent No . 4,122,299

The Cannon patent discloses a data output modifying system . The system places data from a television display into a format for acceptance by a general purpose communications printer . Cannon - is not concerned with a transmission, reception or distribution system responsive to user requests for information, as is the present invention . 10 . Stetten et al . . U .S . Patent No . 3 .746 .780

The Stetten et al . patent relates to a video display system including a transmission system whereby a subscriber 4 uses telephone 6 to select video display information stored in storage section 30 . The information is sent directly to TV receiver 34 .

There is no provision in Stetten et al . for storing requested information after selection and prior to transmission . Further,

Stetten et al . does not show the data sent to TV receiver 34 in a compressed format . Therefore, Stetten et al . does not teach or suggest a transmission system including the preprocessing elements recited in independent claim 1, or the step of storing audio and video information in a compressed data form, as recited in independent claim 18 . Also, there is no provision for storing the requested Accordingly,

information at the receiver of Stetten et al .
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Stetten et al . also does not teach or suggest storage means for storing compressed formatted data, as recited in the receiver system of independent claim 22 . - 1 6-

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EFER ENCES CITED IN THE SEARCH REPORT OF 6/19/90

1.

usic et al . . U.S . Patent So . 4,914,508

The Music et al . '508 patent relates to a method and system for compressing and statistically encoding color video data . Fig . 1 shows a diagram of the system and method for compressing color video data and Fig . 7 shows the system and method for decompressing color video data . Because Music et al . '508 relates

only to compression and decompression of color video data, Music et al . '508 is not concerned with a transmission, reception

or distribution system responsive to user requests for information, as is the present invention . 2. Okamura et al . . U .S . Patent No . 4,907,081 The object of Okamura et al . i s to

The Okamura et al . patent relates to a compression and coding device for video signals .

provide a coding device capable of suppressing signal deterioration (error propagation, etc .) accompanying the coding and of reducing the necessary average number of bits per sampled data . See col . 2, lines 12-16 . Okamura et al . i s not concerned with a transmission, reception or distribution system responsive to user requests for information, as is the present invention . 3. Golin et al ., U .S . Patent No . 4 .8 8,653 Particularly, Golin et al . i s directed to The Golin et al . patent relates to an adaptive digital video compression system . meeting the need for a compression system for providing a compressed digital video signal representative of a full motion
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color video signal which is suitable for recording or transmission using relatively narrow band media and which may be decompressed -17-

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at speeds at least equal to conventional video frame rates . Col . 1, lines 44-50 . signal compression, Golin et al . i s not concerned with a

See

ecause Golin et al . i s concerned only with

transmission, reception or distribution system responsive to user requests for information, as is the present invention . 4. usic et al . .S . Patent No . _4 847,677 The Music et al . '677 patent relates to a video telecommunication system and method for compressing and decompressing digital color video data . Fig . 1 shows a diagram of the system and method for compressing color video data and Fig . 7 shows the system and method for decompressing color video data . Because Music et al . '677 relates only to compression and decompression of color video data, Music et al . '677 is not concerned with a transmission, reception or distribution system responsive to user requests for information, as is the present invention . 5. Hiras hima U .5 . Patent No . 4,833,710 The Hirashima patent is directed to a pay television system capable of effectively preventing illegal access to certain programming by being charge codes to indicate how much money a subscriber owes, and denying of access to the system unless the bill is paid . in Hirashima , requested programming is sent See Fig . 2 . it does not !directly to the television receiver 17 .

Because Hirashima directly transmits programming,
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disclose buffering and therefore does not teach or suggest the preprocessing elements recited in independent claim 1, the

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or the storage buffering step recited in independent claim 18, means recited in independent claim 22 . video The Keith et al . patent relates to a digital shows a system decompression system . Particularly, Keith et al . 6. eith et al . . Patent No . 4 .785 .349-

motion color digital video for compressing and formatting a full Because Keith et al . relates only to a decompression signal .

transmission, system, Keith et al . i s not concerned with a to user requests for reception or distribution system responsive information, as is the present invention . 7. kada et al . .S . ,Patent No . 4,734 .765

audio/video information The Okada et al . patent discloses an terminal 5 from transmission system which includes subscriber delivered to and received which information is requested and then 5 is coupled to suba TV receiver 52 . The subscriber terminal center 3 having audio and video center 6 which communicates with files 1 . is processed and the In Okada et al ., the subscriber request subscriber terminal . There is information is sent directly to the information prior to no provision for storage of the requested the receiver so that he transmission or for storage by the user at Therefore, Okada et al . does not for replay at a desired time . elements recited in independent teach or suggest the preprocessing claim 18, or the storage claim 1, the buffering step required in 22 . means called for in independent claim
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ile rs et al .

The Eilers et al . patent relates to a CATV transmission system for a CATV scrambled signal with compressed digital audio in the horizontal intervals . Because Eilers et al . i s only the steps o ¬ the distribution method set forth in independent 22 .

.s .

Patent No . 4,688,246

concerned with a transmission system, it does not teach or suggest

claim 18 or the receiving system set forth in independent claim Regarding the transmission system, Eilers et al . sends items Therefore, Eilers et al . does not

directly to users and does not provide for storage of compressed data prior to transmission .

teach or suggest a . transmission system including the preprocessing elements required in the transmission system recited in independent claim 1 . 9. atroe et al . . U.S . Patent No . 4,679 .079 The Catros et al . patent is concerned only with a method and system for bit-rate compression of digital data between a television transmitter and receiver . Catros et al . i s not concerned with a transmission, reception or distribution system responsive to user requests for information as in the present invention . 10 . Nakaiima et al ., U .S . Patent No . 4 .538 .176

The Nakaiima et al . patent discloses a video/audio transmission system for sending video and audio information from video and audio files of a center 4 to a subscriber terminal 7 .
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The arrangement includes a sub-center 8 which has a buffer memory 2 . See Fig . 2 . The information requested from center 4 is -20-

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sent to the sub-center 8 .

In sub-center 8, the video is separated Audio is decompressed in

from audio and sent to buffer 25 .

changeover/output unit 24 and combined with video in combining and output unit 26 . The decompressed information is then sent to See Figs . 3 and 6A and col . subscriber terminal 7b over line 5 . 4, line 50 through col . 5, line 6 . In Nakaiima et al ., the subscriber request is processed and the information is sent directly to the subscriber terminal . There is no provision for storage of the requested information prior to transmission to the user or storage by the user so that to replay at a desired time . Therefore, Nakaiima et al . does not

teach or suggest the preprocessing elements recited in independent claim 1, the buffering step required in claim 18, or the storage means called for in claim 22 . 11 . iemann et al ., U .S . Patent No . _ 4_, 5_3_3 .9_36_

The Tiemann et al . patent relates to a system for encoding and decoding video signals to reduce the bandwidth required for transmission thereof over a transmission channel, a broadcast channel or a storage medium . See col . 1, lines 5--9 . Because

Tiemann et al . i s concerned solely with encoding and decoding video signals, that reference is not related to the transmission, reception or distribution system responsive to user requests for information of the present invention . 12 . -, ., . .. Lovett, U .S . Patent No . 4,450 477 _

The Lovett patent discloses a television information system wherein a control station 140 sends a unique modulated carrier frequency signal to the subscriber terminal 129 of a user . - 2 1-

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carrier frequency Privacy is guaranteed by dedicating a different storage of the to each subscriber . There is no provision for so that requested information prior to transmission or by the user he or she can replay it at a desired time . Therefore, Lovett does recited in not teach or suggest the preprocessing elements

independent claim 1, the buffering step required in independent U .S . Patent No . 4,009,346

claim 22 . claim 18, or the storage means called for in independent 13 . activity The Parker et al . patent relates to distributional compression . Particularly, Parker et al . concerns a modular switching hierarchical approach to time division multiplex (TDM) Parker et al .

(TDMA) facilities, relative to time division multiplex access Parker et al ., particularly earth satellite TD14A facilities . reception or however does not relate to the transmission, for information of distribution system responsive to user requests the present invention . 14 . Flemmin .S . Patent No . 4,009,_344 Specifically,

switching, The Flemming patent relates to interrelated activity compression and demand assignment . Flemmin station apparatus concerns an access method and modular relative to a TDMA link, for switching voice and data signals 3-5 . Flemmin is not especially a satellite . See col . 3, lines or distribution system related to the transmission, reception of the present responsive to user requests for information invention .

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15 .

ackson et al . . U.S . Patent_ No .

599,178

The Jackson et al . patent relates to a method of storing information on and retrieving information from a magnetic drum . Jackson et al . employs selective mapping of information on a magnetic drum to permit rapid access and retrieval . Because Jackson et al , is concerned only with the storage of information, Jackson et al . does not relate to the transmission, reception or distribution system responsive to user requests for information of the present invention . D. 1. THER REFERENCES ohen . U .S . Patent No . 4,949 .187

The Cohen patent relates to a video communication system having a remotely controlled central source of video and audio data . Cohen shows a block diagram of the remotely-controlled Disks 12, 14, 16, 18, 20, The disks are Movies central source of video and audio data .

22, 24, and 26 store frequently accessed movies .

read by drives controlled by a disk controller 28, 30 .

that are only accessed infrequently are archived on a tape archival system 32 which is controlled by tape driver 34 . The distribution system CPU 36 controls the bidirectional flow of data from disks 12-26 and tape archival system 32 . 1-l8 . In order to output a plurality of movies simultaneously, several controllers 42, 44, 46, and 48 are used which output signals to multiplexor 58 for transmission over telephone line 60 .
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See col . 1, lines

See Fig . 4 and col . 4, lines 30-46 .

Cohen does not teach that the

information transmitted over telephone line 60 is compressed, and -23-

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therefore does not teach or suggest compression means for compressing formatted and sequenced data or the compressed data storage means for storing as a file the compressed, sequenced data, as recited in the transmission system of independent claim 1. Cohen also does not teach or suggest the step of storing audio and video information in a compressed data form, as recited in the distribution method of independent claim 18 . Figs . 1-3 of Cohen show the receiving device . Incoming serial data on phone line 112 is processed by modem 110 and is forwarded by central processing unit 104 to the disk storage system 114 via disk controller 116 . Cohen does not indicate that Because the incoming signals are received in a compressed format .

Cohen does not receive the signals in a compressed format, Cohen also does not teach or suggest the decompressing means for decompressing the compressed formatted data, as recited in the receiving system of independent claim 22 . 2. abiki et al ., U .S . Patent No . 4-518_ .989 Yabiki et al .

The Yabiki et al . patent is commonly assigned to the assignee of the Okada et al . and Nak,aiima et al . patents .

shows a plurality of repeaters 6 between center 4 and sub-center 8 and between sub-center 8 and subscriber terminal 7 . In

Yabiki et al ., a subscriber request is processed and the information is sent directly to the subscriber terminal . There is

no provision for storage of the requested information prior to
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transmission or by the user so that he or she can replay it at a desired time . Therefore, Yabiki et al . does not teach or suggest

zo :

the preprocessing elements recited in independent claim 1, the -24-

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means called for in independent claim 22 . 3. braham

buffering step required in independent claim 1B, or the storage . Patent No . 4,567,512 In this system, subscribers communicate The

communication system .

The Abraham '512 patent discloses a recorded program

with a library computer 28 via a telephone connection . subscriber enters his or her choices .

-telephone system 12 is coupled to a command unit 24 from which the 24, the subscriber has access to information in the library station 18 and provides billing information to the billing station 27 . See col . 4, lines 45-49 . By using command unit 24, the subscriber enters selection data obtained from a printed program guide which identifies each program in the library and its associated program number . available time segments for the selected program . lines 24-32 and Fig . 3 . Based on the same program guide, the subscriber selects one of the See col . 7, with the system in Abraham '512, the This With command terminal unit

subscriber may not change the time a program can be viewed . is because there is no provision for storage of the requested program prior to transmission or for storage at the receiving device of the user .

Therefore, Abraham does not teach or suggest

the preprocessing elemetns recited in independent claim 1, the buffering step required in independent claim 18, or the storage means called for in independent claim 22 . 4.
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braham

U .S . Patent No . 4,521,806

Abraham 1 806 relates to a method of generating and processing audio/video broadcast signals in a subscription communication -25-

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system .

In Abraham '806, as with Abraham '512 and '516, the

requested information is not stored prior to transmission and the subscriber cannot store the requested information at his or her station . Therefore, the subscriber can only receive information Because

substantially simultaneously to the request for it .

requested information is not stored prior to transmission or at the user's receiving device, Abraham '806 does not teach or suggest the preprocessing elements recited in independent claim the buffering step required in independent claim 18, or the storage means called for in independent claim 22 . 5. ushnell et al ., U .S . Patent No . 4,071,697 The Bushnell et al . patent relates to an interactive video/ telephone transmission system wherein a user can view merchandise information at home . The system includes a capability of calling The user does not particular stores offering the viewed merchandise to registering a request to purchase selected merchandise . purchase selected merchandise . receive anything at his receiver 12 in response to his request to Rather, in Bushnell et al ., the user simply views merchandise and then calls a store to order that merchandise . 6. eidler et al . . U .S . Patent No . 4 .062 .043 The Zeidler et al . patent relates to a light wave transmission and distribution system in which at least one optical transmitter is used to distribute television programming to a plurality of receivers through light conducting fibers .
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Ohrenstein

with .a The Qhrenstein article describes a data storage system high performance parallel interface (HPPI) . B. orreale et al . The Morreale et al . article discusses metropolitan-area networks (MAN) . CONCLUSION None of the references renders the pending claims invalid under 35 U .S .C . S 103 . Furthermore, there is no reasonable combination of references which can be combined under of ordinary skill .

a person 35 U .S .C . S 103 to render the pending claims obvious to met, The requirements of M .P .E .P . S70B .02 (VIII) having been

references, and the pending claims being allowable over the Special be granted Applicants request that this Petition to Make to issue as and that claims 1-32 of this application be passed quickly as possible . Respectfully submitted, . FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER

By :

c ~s nQi .:. Doris ,T.' Johnson Reg . No . 34,529

Dated : June 17, 1991

FINwr-AN, HENDMON FA1ABOW. C,AAAET7 6 DUNNER ']00 1 STNE~. w w.5r.w0+or, an 20005 -202 .08- "000

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