Motorola Mobility, Inc. v. Apple, Inc.

Filing 224

MOTION to Compel Responses to Interrogatories Regarding Set-Top Box Patents (Nos. 19-22) by Apple, Inc.. Responses due by 2/16/2012 (Attachments: # 1 Affidavit Declaration of Jill Ho, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C-SEALED, # 5 Exhibit D-SEALED, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Exhibit M, # 15 Exhibit N, # 16 Exhibit O, # 17 Exhibit P, # 18 Exhibit Q, # 19 Exhibit R, # 20 Exhibit S, # 21 Exhibit T, # 22 Exhibit U-SEALED, # 23 Exhibit V-SEALED, # 24 Exhibit W-SEALED, # 25 Exhibit X-SEALED, # 26 Exhibit Y-SEALED, # 27 Exhibit Z-SEALED, # 28 Exhibit AA-SEALED, # 29 Exhibit BB-SEALED, # 30 Exhibit CC-SEALED, # 31 Exhibit DD-SEALED, # 32 Text of Proposed Order)(Pace, Christopher)

EXHIBIT A

Exhibit A – U.S. Patent No. 5,583,560
Motorola directly and/or indirectly infringes at least claims 1, 2, 4-6, 8, 9, 11-13, 15-16 of the ’560 patent, either literally or
through the doctrine of equivalents. Motorola’s infringing products include set-top boxes and associated hardware, including but
not limited to remote control devices, that provide or operate in conjunction with an interactive user interface for managing or
selecting programs or services (e.g., TV programs or DVR functions), including but not limited to the: DCT700, DCT2500,
DCT3400, DCT3412, DCT3080, DCT6200, DCT6208, DCT6400, DCT6412, DCX700, DCX3200, DCX3200 P2, DCX3400,
DCH70, DCH100, DCH200, DCH3200, DCH3416, DCH6200, DCH6416, DTA100, QIP2500, QIP2708, QIP6200, QIP6416,
QIP7100, and QIP7216 (collectively, the “’560 Accused Products”).
In addition to Motorola’s direct infringement of the claims of the ’560 patent through its development, testing, manufacture
and use of its devices, Motorola also indirectly infringes at least claims 8, 9, 11, 12, 13, 15, 16 of the ’560 patent. Manufacturers,
retailers, distributors, end-users and others in the distribution channel of the ’560 Accused Products directly infringe this claim by
using, selling, offering for sale, and/or importing these devices into the United States. Motorola contributes to and induces the
infringement of asserted claims 8, 9, 11, 12, 13, 15, 16 through its promotion and provision of intentional marketing, sale and/or
technical support of the ’560 Accused Products and associated specialized components in the United States, and through the
intentional design, marketing, manufacture, sale, and/or technical support of the ’560 Accused Products abroad to induce direct
infringement in the United States. Motorola supplies ’560 Accused Products and actively encourages the use, sale, offer for sale,
and importation of the same in the United States through the promotion and provision of marketing literature and user guides, which
induces and results in direct infringement. Upon information and belief, Motorola has known or should have known that these
actions would cause direct infringement of the ’560 patent and did so with specific intent to encourage direct infringement.
Additionally, the ’560 Accused Products have no substantial non-infringing uses.
For purposes of this analysis, Apple will examine a representative set-top box, Motorola’s DCT3412 as used with Comcast
cable service. See, e.g., http://customer.comcast.com/Pages/FAQViewer.aspx?Guid=f39b3536-8ba2-4fbd-a359-644e00cd0a5a
(Comcast Cable Box User Manuals) (last visited May 18, 2011). All other ’560 Accused Products meet the limitations of the
asserted claims on the same bases as indicated for the Motorola DCT3412 unless otherwise stated.
These infringement contentions are preliminary and based only on publicly available information as to the ’560 Accused
Products. Motorola has provided little to no discovery as to its accused products and, in addition, Apple’s investigation of
Motorola's infringement is ongoing. Based on discovery and Apple’s continued investigations, Apple reserves the right to amend
these contentions to identify additional bases for infringement and additional accused products, including products that Motorola
may introduce in the future. Accordingly, Apple reserves its right to amend these contentions as discovery and its investigation
proceeds. Also, these disclosures are made based on information ascertained to date, and Apple expressly reserves the right to
1

modify or amend the disclosures contained herein based on the Court’s claim constructions or to reflect additional information that
becomes available to Apple.
U.S. Patent No. 5,583,560

Infringement Contentions

1. An audio-visual system
comprising:
a transceiver coupled to an
audio-visual (A/V) display for
receiving audio-visual signals
in an electronic signal
spectrum from a signal source,
said transceiver including an
interface generator for
displaying a listing interface on
said A/V display, said interface
generator including a list
generator for selectively
displaying listing information
related to audio-visual
programs which may be
viewed on said A/V display;

The ’560 Accused Products include a transceiver that connects to an audio-visual (A/V)
display, such as a TV, and receives audio-visual signals in an electronic signal spectrum
from a signal source.
•

By way of one example, the DCT3412 is a cable TV terminal or set-top box that
includes a transceiver and receives cable audio and video content, video-on-demand
content, and other information from a cable service provider, such as Comcast, for
display on the TV. See, e.g., Ex. A -1 [User Guide, DCT3400 Series High Definition
DVR Cable Terminal] at 3 (“The DCT3400 enables a direct digital connection to
consumer audio and video devices through IEEE-1394 DTV and HDMI interfaces.”);
Ex. A -2 [Motorola DCT3400 Specification Sheet]. See generally Ex. A -1 [User
Guide, DCT3400 Series High Definition DVR Cable Terminal] at 13-26 (illustrating
video connection options).

The transceiver of the ’560 Accused Products includes an interface generator for displaying
a listing interface on the A/V display.
•

By way of one example, the DCT3412 includes hardware and software that can display
a listing interface for listing TV content or for listing DVR content, such as an
interactive program guide. See, e.g., Ex. A -1 [User Guide, DCT3400 Series High
Definition DVR Cable Terminal] at 6 (describing “Interactive Program Guide”); id. at
12 (“The DCT3400 can generate on-screen graphics that overlay the video
programming or fill the entire television screen. Common examples include on-screen
menus (such as the User Setting menu), closed captions, and interactive program guides.
The cable terminal overlays these graphics whenever you display a menu, enable closed
captions, or scroll through a program grid.”). See also Ex. A -3 [Comcast, DVR
2

U.S. Patent No. 5,583,560

Infringement Contentions
Guide, Dual Tuner HD-Capable DVR] at 6 (showing listing of TV content); id. at 7
(showing list of DVR content); Ex. A -4 [Comcast Digital Cable Guide] at 6, 8, 11-12;
23-24.

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 6 (showing listing of TV content)

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 7 (showing listing of DVR content)

The ’560 Accused Products include a list generator for selectively displaying listing
information relating to audio-visual programs that may be viewed on the A/V display.
3

U.S. Patent No. 5,583,560
•

Infringement Contentions
By way of one example, the DCT3412 includes hardware and software that can
generate a list that selectively displays listing information for TV programs or DVR
content, such as an interactive program guide, that may be viewed on an A/V display,
such as a television screen. See, e.g., Ex. A -1 [User Guide, DCT3400 Series High
Definition DVR Cable Terminal] at 12 (“The DCT3400 can generate on-screen graphics
that overlay the video programming or fill the entire television screen. Common
examples include on-screen menus (such as the User Setting menu), closed captions,
and interactive program guides. The cable terminal overlays these graphics whenever
you display a menu, enable closed captions, or scroll through a program grid.”); Ex. A 3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 6-8; Ex. A -4 [Comcast
Digital Cable Guide] at 11 (explaining how to display more or less channels in the
listing information); Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at
6-8 (selecting items in listing interface to display select information about the item); Ex.
A -4 [Comcast Digital Cable Guide] at 5-17 (same).

Ex. A -4 [Comcast Digital Cable Guide] at 11 (selectively displaying TV listings)

a controller in communication
with said transceiver for
permitting a user viewing said
A/V display to selectively
display said listing information
on said A/V display;

The ’560 Accused Products use a controller in communication with the transceiver for
permitting a user viewing the A/V display to selectively display the listing information on
the A/V display.
•

By way of one example, users may use a remote control with the DCT3412 to navigate
and selectively display listing information on a TV screen. See, e.g., Ex. A -3
[Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 2, 6-8; Ex. A -4 [Comcast
4

U.S. Patent No. 5,583,560

Infringement Contentions
Digital Cable Guide] at 5-17.
•

By way of another example, users may use the control panel of the DCT3412 to
navigate and selectively display listing information on a TV screen. See, e.g., Ex. A -1
[User Guide, DCT3400 Series High Definition DVR Cable Terminal] at 4-5.

Ex. A -1 [User Guide, DCT3400 Series High Definition DVR Cable Terminal] at 4.

5

U.S. Patent No. 5,583,560

Wherein said controller
includes a control having an
activator for activating said list
generator in said transceiver,
the activation of said list
generator resulting in said
listing interface being
displayed on said A/V display;
and

Infringement Contentions
Ex. A -1 [User Guide, DCT3400 Series High Definition DVR Cable Terminal] at 5.
The controllers of the ’560 Accused Products include a control having an activator for
activating the list generator in the transceiver.
•

By way of one example, the remote control used with the DCT3412 includes controls
with an activator that activates the interactive program guide. See, e.g., Ex. A -3
[Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 2, 6-8 (explaining buttons to
press to enter on-screen guide menus or DVR menus); Ex. A -4 [Comcast Digital Cable
Guide] at 5-17 (same).

•

By way of another example, the control panel of the DCT3412 includes controls with an
activator that activates the interactive program guide. See, e.g., Ex. A -1 [User Guide,
DCT3400 Series High Definition DVR Cable Terminal] at 4-5.

Ex. A -1 [User Guide, DCT3400 Series High Definition DVR Cable Terminal] at 4.

6

U.S. Patent No. 5,583,560

Infringement Contentions

Ex. A -1 [User Guide, DCT3400 Series High Definition DVR Cable Terminal] at 5.
•

Using either a remote control or the control panel of the DCT3412, the activation
thereof results in displaying the interactive program guide on the display device or TV
screen, as below.

See, e.g., Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 3

7

U.S. Patent No. 5,583,560
wherein said listing interface
includes a picture in a picture
(PIP) window in which an
audio-visual program viewed
by said user prior to said
activation of said list generator
is displayed in said PIP
window.

Infringement Contentions
The listing interface of the ’560 Accused Products includes a picture in a picture (PIP)
window that displays the audio-visual program that was viewed by the user prior to the
activation of the list generator.
•

In either case of the DVR or TV listing, the DCT3412 allows for the display of the
program that the user was viewing before the activation of the list generator in a picturein-picture window, as below.

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 6 (showing picture-in-picture display of
program that user was viewing while also displaying TV listings)

8

U.S. Patent No. 5,583,560

Infringement Contentions

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 7 (showing picture-in-picture display of
program that user was viewing while also displaying DVR listings)

(Screenshot of DCT3412 program guide with Comcast cable service)

2. The audio-visual system as

The ’560 Accused Products provide that, upon the activation of the list generator, a listing
9

U.S. Patent No. 5,583,560
defined by claim 1 wherein
upon said activation of said list
generator a listing for the
audio-visual program
displayed in said PIP window
is displayed and highlighted.

Infringement Contentions
for the audio-visual program displayed in the PIP window is displayed and highlighted.
•

By way of one example, upon entering the display of TV listings, the DCT3412 allows
for listing information of the program being displayed in the picture-in-picture window
to be displayed and highlighted, as below.

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 6

4. An audio-visual system
comprising:
a transceiver coupled to an
audio-visual (A/V) display for
receiving audio-visual signals
in an electronic signal
spectrum from a signal source,
said transceiver including an
interface generator for
displaying a listing interface on
said A/V display, said interface
generator including a list
generator for selectively

The ’560 Accused Products include a transceiver that connects to an audio-visual (A/V)
display, such as a TV, and receives audio-visual signals in an electronic signal spectrum
from a signal source.
•

By way of one example, the DCT3412 is a cable TV terminal or set-top box that
includes a transceiver and receives cable audio and video content, video-on-demand
content, and other information from a cable service provider, such as Comcast, for
display on the TV. See, e.g., Ex. A -1 [User Guide, DCT3400 Series High Definition
DVR Cable Terminal] at 3 (“The DCT3400 enables a direct digital connection to
consumer audio and video devices through IEEE-1394 DTV and HDMI interfaces.”);
Ex. A -2 [Motorola DCT3400 Specification Sheet]. See generally Ex. A -1 [User
10

U.S. Patent No. 5,583,560
displaying listing information
related to audio-visual
programs which may be
viewed on said A/V display;

Infringement Contentions
Guide, DCT3400 Series High Definition DVR Cable Terminal] at 13-26 (illustrating
video connection options).
The ’560 Accused Products include an interface generator for displaying a listing interface
on the A/V display.
•

By way of one example, the DCT3412 includes hardware and software that can display
a listing interface for listing TV content or for listing DVR content, such as an
interactive program guide. See, e.g., Ex. A -1 [User Guide, DCT3400 Series High
Definition DVR Cable Terminal] at 6 (describing “Interactive Program Guide”); id. at
12 (“The DCT3400 can generate on-screen graphics that overlay the video
programming or fill the entire television screen. Common examples include on-screen
menus (such as the User Setting menu), closed captions, and interactive program guides.
The cable terminal overlays these graphics whenever you display a menu, enable closed
captions, or scroll through a program grid.”). See also Ex. A -3 [Comcast, DVR
Guide, Dual Tuner HD-Capable DVR] at 6 (showing listing of TV content); id. at 7
(showing list of DVR content); Ex. A -4 [Comcast Digital Cable Guide] at 6, 8, 11-12,
23-24.

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 6 (showing listing of TV content)

11

U.S. Patent No. 5,583,560

Infringement Contentions

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 7 (showing listing of DVR content)

The ’560 Accused Products include a list generator for selectively displaying listing
information relating to audio-visual programs that may be viewed on the A/V display.
•

By way of one example, the DCT3412 includes hardware and software that can generate
a list that selectively displays listing information for TV programs or DVR content, such
as an interactive program guide, that may be viewed on an A/V display, such as a
television screen. See, e.g., Ex. A -1 [User Guide, DCT3400 Series High Definition
DVR Cable Terminal] at 12 (“The DCT3400 can generate on-screen graphics that
overlay the video programming or fill the entire television screen. Common examples
include on-screen menus (such as the User Setting menu), closed captions, and
interactive program guides. The cable terminal overlays these graphics whenever you
display a menu, enable closed captions, or scroll through a program grid.”); Ex. A -3
[Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 6-8; Ex. A -4 [Comcast
Digital Cable Guide] at 11 (explaining how to display more or less channels in the
listing information); Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at
6-8 (selecting items in listing interface to display select information about the item); Ex.
A -4 [Comcast Digital Cable Guide] at 5-17 (same).

12

U.S. Patent No. 5,583,560

Infringement Contentions

Ex. A -4 [Comcast Digital Cable Guide] at 11 (selectively displaying TV listings)

a controller in communication
with said transceiver for
permitting a user viewing said
A/V display to selectively
display said listing information
on said A/V display;

The ’560 Accused Products use a controller in communication with the transceiver for
permitting a user viewing the A/V display to selectively display the listing information on
the A/V display.
•

By way of one example, users may use a remote control with the DCT3412 to navigate
and selectively display listing information on a TV screen. See, e.g., Ex. A -3
[Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 2, 6-8; Ex. A -4 [Comcast
Digital Cable Guide] at 5-17.

•

By way of another example, users may use the control panel of the DCT3412 to
navigate and selectively display listing information on a TV screen. See, e.g., Ex. A -1
[User Guide, DCT3400 Series High Definition DVR Cable Terminal] at 4-5.

13

U.S. Patent No. 5,583,560

Infringement Contentions

Ex. A -1 [User Guide, DCT3400 Series High Definition DVR Cable Terminal] at 4.

Ex. A -1 [User Guide, DCT3400 Series High Definition DVR Cable Terminal] at 5.
wherein said controller
includes a control having an

The controllers of the ’560 Accused Products include a control having an activator for
activating the list generator in the transceiver.
14

U.S. Patent No. 5,583,560
activator for activating said list
generator in said transceiver,
the activation of said list
generator resulting in said
listing interface being
displayed on said A/V display;

•

•

Infringement Contentions
By way of one example, the remote control used with the DCT3412 includes controls
with an activator that activates the interactive program guide. See, e.g., Ex. A -3
[Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 2, 6-8 (explaining buttons to
press to enter on-screen guide menus or DVR menus); Ex. A -4 [Comcast Digital Cable
Guide] at 5-17 (same).
By way of another example, the control panel of the DCT3412 includes controls with an
activator that activates the interactive program guide. See, e.g., Ex. A -1 [User Guide,
DCT3400 Series High Definition DVR Cable Terminal] at 4-5.

Ex. A -1 [User Guide, DCT3400 Series High Definition DVR Cable Terminal] at 4.

15

U.S. Patent No. 5,583,560

Infringement Contentions

Ex. A -1 [User Guide, DCT3400 Series High Definition DVR Cable Terminal] at 5.
•

Using either the remote control or the control panel of the DCT3412, the activation
thereof results in displaying the interactive program guide on the display device or TV
screen, as below.

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 3

16

U.S. Patent No. 5,583,560
wherein said interface
generator includes a reminder
mechanism for identifying
audio-visual programs
represented in said listing
information which said user
desires to be reminded of; and

Infringement Contentions
The interface generator of the ’560 Accused Products includes a reminder mechanism for
identifying audio-visual programs represented in the TV listing that the user wants to be
reminded of.
•

By way of one example, the DCT3412 allows for the interface generator to set
reminders of a show displayed in the TV listings. See, e.g., Ex. A -4 [Comcast Digital
Cable Guide] at 12 (explaining how to set reminders for TV programs from the TV
listings).

See, e.g., Ex. A -4 [Comcast Digital Cable Guide] at 17

wherein said reminder
mechanism is activated by said
user selecting a selected audiovisual program represented in
said listing information using
first or second buttons and then
activating a mark button on
said controller.

The reminder mechanism of the ’560 Accused Products is activated by the user selecting an
audio-visual program in the listing information displayed using first or second buttons and
then activating a mark button the controller.
•

By way of one example, the reminder mechanism of the DCT3412 is activated by a user
choosing the program from the TV listings using a the up or down keys and then
pressing the “info” button on the remote control. By way of further example, the user
presses a series of buttons, either on the remote control or the control panel of the
DCT3412, to select a reminder icon in the interactive program guide displayed by the
DCT3412, and activates the reminder mechanism by pressing the OK button.

See, e.g., Ex. A -4 [Comcast Digital Cable Guide] at 11 (explaining how to choose a program in the TV

17

U.S. Patent No. 5,583,560

Infringement Contentions
listings using directional arrow buttons on the remote control)

See, e.g., Ex. A -4 [Comcast Digital Cable Guide] at 12 (explaining the buttons needed to set a reminder)

5. The audio-visual system as
defined by claim 4 wherein
upon said user activating said
mark button, said list generator
displays a reminder mark
adjacent to the listing
information corresponding to
said selected audio-visual
program

Upon activating the button for the reminder mechanism, the ’560 Accused Products allow
for the display of a reminder mark adjacent to the listing information corresponding to the
selected audio-visual program.
•

By way of one example, the DCT3412 can display a reminder icon in the shape of a
bell next to the selected audio-visual program on the A/V display.

(Screenshot of DCT3412 program guide with Comcast cable service)

18

U.S. Patent No. 5,583,560
6. The audio-visual system as
defined by claim 4 wherein
said list generator displays a
reminder at a predefined
location on said audio-visual
display, on the date and at the
time said selected audio-visual
program is received by said
transceiver.

Infringement Contentions
The list generator of the ’560 Accused Products displays a reminder at a predefined location
on the audio-visual or TV display, on the date and at the time that the selected audio-visual
program to be reminded of is received by the transceiver.
•

By way of one example, after setting a reminder for a program, a reminder is displayed at
the bottom of the screen on the date and time that the program is received by the
DCT3412.

(Screenshot of DCT3412 program guide with Comcast cable service)

8. A method for generating and
displaying a listing interface on
an audio-visual (A/V) system,
comprising the steps of:

The ’560 Accused Products, such as the DCT3412, allow for the generating and displaying
of a listing interface on an audio-visual system, such as on a TV screen, as explained
below:
19

U.S. Patent No. 5,583,560
receiving audio-visual signals
in an electronic signal
spectrum using a transceiver
coupled to an A/V display,
said transceiver including an
interface generator for
displaying said listing interface
on said A/V display, said
interface generator including a
list generator for selectively
displaying listing information
related to audio-visual
programs which may be
viewed on said A/V display;
and

Infringement Contentions
The ’560 Accused Products include a transceiver that connects to an audio-visual (A/V)
display, such as a TV, and receives audio-visual signals in an electronic signal spectrum
from a signal source.
•

By way of one example, the DCT3412 is a cable TV terminal or set-top box that
includes a transceiver and receives cable audio and video content, video-on-demand
content, and other information from a cable service provider, such as Comcast, for
display on the TV. See, e.g., Ex. A -1 [User Guide, DCT3400 Series High Definition
DVR Cable Terminal] at 3 (“The DCT3400 enables a direct digital connection to
consumer audio and video devices through IEEE-1394 DTV and HDMI interfaces.”);
Ex. A -2 [Motorola DCT3400 Specification Sheet]. See generally Ex. A -1 [User
Guide, DCT3400 Series High Definition DVR Cable Terminal] at 13-26 (illustrating
video connection options).

The ’560 Accused Products include an interface generator for displaying a listing interface
on the A/V display.
•

By way of one example, the DCT3412 includes hardware and software that can display
a listing interface for listing TV content or for listing DVR content, such as an
interactive program guide. See, e.g., Ex. A -1 [User Guide, DCT3400 Series High
Definition DVR Cable Terminal] at 6 (describing “Interactive Program Guide”); id. at
12 (“The DCT3400 can generate on-screen graphics that overlay the video
programming or fill the entire television screen. Common examples include on-screen
menus (such as the User Setting menu), closed captions, and interactive program guides.
The cable terminal overlays these graphics whenever you display a menu, enable closed
captions, or scroll through a program grid.”). See also Ex. A -3 [Comcast, DVR
Guide, Dual Tuner HD-Capable DVR] at 6 (showing listing of TV content); id. at 7
(showing list of DVR content); Ex. A -4 [Comcast Digital Cable Guide] at 6, 8, 11-12;
23-24.

20

U.S. Patent No. 5,583,560

Infringement Contentions

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 6 (showing listing of TV content)

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 7 (showing listing of DVR content)

The ’560 Accused Products include a list generator for selectively displaying listing
information relating to audio-visual programs that may be viewed on the A/V display.
•

By way of one example, the DCT3412 includes hardware and software that can generate
a list that selectively displays listing information for TV programs or DVR content, such
as an interactive program guide, that may be viewed on an A/V display, such as a
21

U.S. Patent No. 5,583,560

Infringement Contentions
television screen. See, e.g., Ex. A -1 [User Guide, DCT3400 Series High Definition
DVR Cable Terminal] at 12 (“The DCT3400 can generate on-screen graphics that
overlay the video programming or fill the entire television screen. Common examples
include on-screen menus (such as the User Setting menu), closed captions, and
interactive program guides. The cable terminal overlays these graphics whenever you
display a menu, enable closed captions, or scroll through a program grid.”); Ex. A -3
[Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 6-8; Ex. A -4 [Comcast
Digital Cable Guide] at 11 (explaining how to display more or less channels in the
listing information); Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at
6-8 (selecting items in listing interface to display select information about the item); Ex.
A -4 [Comcast Digital Cable Guide] at 5-17 (same).

Ex. A -4 [Comcast Digital Cable Guide] at 11 (selectively displaying TV listings)

a user selectively displaying
said listing information on said
A/V display using a controller
in communication with said
transceiver;

Users of the ’560 Accused Products can use a controller in communication with the
transceiver to selectively display the listing information on the A/V display.
•

By way of one example, users can use a remote control with the DCT3412 to navigate
and selectively display listing information on a TV screen. See, e.g., Ex. A -3
[Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 2, 6-8; Ex. A -4 [Comcast
Digital Cable Guide] at 5-17.
22

U.S. Patent No. 5,583,560
activating said list generator in
said transceiver, the activation
of said list generator resulting
in said listing interface being
displayed on said A/V display;
and

Infringement Contentions
The list generator of the ’560 Accused Products can be activated to result in a listing
interface being displayed on an A/V display.
•

By way of one example, the list generator of the the DCT3412 is activated, which
results in TV listings or DVR listings being displayed on a TV screen. See, e.g., Ex. A
-3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 2, 6-8 (explaining buttons
to press to enter on-screen guide menus or DVR menus); Ex. A -4 [Comcast Digital
Cable Guide] at 5-17 (same). The activation thereof results in displaying the
interactive program guide on the display device or TV screen, as below.

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 3

displaying in said listing
interface a picture in a picture
(PIP) window in which an
audio-visual program viewed
by said user prior to said
activation of said list

The listing interface of the ’560 Accused Products includes a picture in a picture (PIP)
window that displays the audio-visual program that was viewed by the user prior to the
activation of the list generator.
•

In either case of the DVR or TV listing, the DCT3412 allows for the display of the
program that the user was viewing before the activation of the list generator in a picturein-picture window, as below.

generator is displayed.

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U.S. Patent No. 5,583,560

Infringement Contentions

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 6 (showing picture-in-picture display of
program that user was viewing while also displaying TV listings)

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 7 (showing picture-in-picture display of
program that user was viewing while also displaying DVR listings

9. The method as defined by
claim 8 wherein upon said
activation of said list generator
a listing in said listing

The ’560 Accused Products provide that, upon the activation of the list generator, a listing
for the audio-visual program displayed in the PIP window is displayed and highlighted.
•

By way of one example, upon entering the display of TV listings, the DCT3412 allows
for listing information of the program being displayed in the picture-in-picture window
24

U.S. Patent No. 5,583,560
information for the audiovisual program displayed in
said PIP window is
highlighted.

Infringement Contentions
to be displayed and highlighted, as below.

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 6

11. A method for generating
and displaying a listing
interface on an audio-visual
(A/V) system, comprising the
steps of:

The ’560 Accused Products, such as the DCT3412, include an audio-visual system for
generating and displaying a listing interface, as explained below:

25

U.S. Patent No. 5,583,560
receiving audio-visual signals
in an electronic signal
spectrum using a transceiver
coupled to an A/V display,
said transceiver including an
interface generator for
displaying said listing interface
on said A/V display, said
interface generator including a
list generator for selectively
displaying listing information
related to audio-visual
programs which may be
viewed on said A/V display;

Infringement Contentions
The ’560 Accused Products include a transceiver that connects to an audio-visual (A/V)
display, such as a TV, and receives audio-visual signals in an electronic signal spectrum
from a signal source.
•

By way of one example, the DCT3412 is a cable TV terminal or set-top box that
includes a transceiver and receives cable audio and video content, video-on-demand
content, and other information from a cable service provider, such as Comcast, for
display on the TV. See, e.g., Ex. A -1 [User Guide, DCT3400 Series High Definition
DVR Cable Terminal] at 3 (“The DCT3400 enables a direct digital connection to
consumer audio and video devices through IEEE-1394 DTV and HDMI interfaces.”);
Ex. A -2 [Motorola DCT3400 Specification Sheet]. See generally Ex. A -1 [User
Guide, DCT3400 Series High Definition DVR Cable Terminal] at 13-26 (illustrating
video connection options).

The ’560 Accused Products include an interface generator for displaying a listing interface
on the A/V display.
•

By way of one example, the DCT3412 includes hardware and software that can display
a listing interface for listing TV content or for listing DVR content, such as an
interactive program guide. See, e.g., Ex. A -1 [User Guide, DCT3400 Series High
Definition DVR Cable Terminal] at 6 (describing “Interactive Program Guide”); id. at
12 (“The DCT3400 can generate on-screen graphics that overlay the video
programming or fill the entire television screen. Common examples include on-screen
menus (such as the User Setting menu), closed captions, and interactive program guides.
The cable terminal overlays these graphics whenever you display a menu, enable closed
captions, or scroll through a program grid.”). See also Ex. A -3 [Comcast, DVR
Guide, Dual Tuner HD-Capable DVR] at 6 (showing listing of TV content); id. at 7
(showing list of DVR content); Ex. A -4 [Comcast Digital Cable Guide] at 6, 8, 11-12,
23-24.

26

U.S. Patent No. 5,583,560

Infringement Contentions

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 6 (showing listing of TV content)

Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 7 (showing listing of DVR content)

The ’560 Accused Products include a list generator for selectively displaying listing
information relating to audio-visual programs that may be viewed on the A/V display.
•

By way of one example, the DCT3412 includes hardware and software that can generate
a list that selectively displays listing information for TV programs or DVR content, such
as an interactive program guide, that may be viewed on an A/V display, such as a
27

U.S. Patent No. 5,583,560

Infringement Contentions
television screen. See, e.g., Ex. A -1 [User Guide, DCT3400 Series High Definition
DVR Cable Terminal] at 12 (“The DCT3400 can generate on-screen graphics that
overlay the video programming or fill the entire television screen. Common examples
include on-screen menus (such as the User Setting menu), closed captions, and
interactive program guides. The cable terminal overlays these graphics whenever you
display a menu, enable closed captions, or scroll through a program grid.”); Ex. A -3
[Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 6-8; Ex. A -4 [Comcast
Digital Cable Guide] at 11 (explaining how to display more or less channels in the
listing information); Ex. A -3 [Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at
6-8 (selecting items in listing interface to display select information about the item); Ex.
A -4 [Comcast Digital Cable Guide] at 5-17 (same).

Ex. A -4 [Comcast Digital Cable Guide] at 11 (selectively displaying TV listings)

.
a user selectively displaying
said listing information on said
A/V display using a controller
in communication with said
transceiver;

Users of the ’560 Accused Products can use a controller in communication with the
transceiver to selectively display the listing information on the A/V display.

wherein said interface

The interface generator of the ’560 Accused Products includes a reminder mechanism for

•

By way of one example, users can use a remote control with the DCT3412 to navigate
and selectively display listing information on a TV screen. See, e.g., Ex. A -3
[Comcast, DVR Guide, Dual Tuner HD-Capable DVR] at 2, 6-8; Ex. A -4 [Comcast
Digital Cable Guide] at 5-17.

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U.S. Patent No. 5,583,560
generator includes a reminder
mechanism for identifying
audio-visual programs
represented in said listing
information which said user
desires to be reminded of; and

Infringement Contentions
identifying audio-visual programs represented in the TV listing that the user wants to be
reminded of.
•

By way of one example, the DCT3412 allows for the interface generator to set
reminders of a show displayed in the TV listings. See, e.g., Ex. A -4 [Comcast Digital
Cable Guide] at 12 (explaining how to set reminders for TV programs from the TV
listings).

See, e.g., Ex. A -4 [Comcast Digital Cable Guide] at 17

activating said reminder
mechanism by said user
selecting an audio-visual
program represented in said
listing information using said
first or second buttons and then
activating a mark button on
said controller.

The reminder mechanism of the ’560 Accused Products is activated by the user selecting an
audio-visual program in the listing information displayed using first or second buttons and
then activating a mark button the controller.
•

By way of one example, the reminder mechanism of the DCT3412 is activated by a user
choosing the program from the TV listings using a the up or down keys and then
pressing the “info” button on the remote control. By way of further example, the user
presses a series of buttons, either on the remote control or the control panel of the
DCT3412, to select a reminder icon in the interactive program guide displayed by the
DCT3412, and activates the reminder mechanism by pressing the OK or Select button.

See, e.g., Ex. A -4 [Comcast Digital Cable Guide] at 11 (explaining how to choose a program in the TV
listings using directional arrow buttons on the remote control)

29

U.S. Patent No. 5,583,560

Infringement Contentions

See, e.g., Ex. A -4 [Comcast Digital Cable Guide] at 12 (explaining the buttons needed to set a reminder)

12. The method as defined by
claim 11 wherein upon said
user activating said mark
button, said list generator
displays a reminder mark
adjacent to said listing
information corresponding to
said audio-visual program.

Upon activating the button for the reminder mechanism, the ’560 Accused Products allow
for the display of a reminder mark adjacent to the listing information corresponding to the
selected audio-visual program.
•

By way of one example, the DCT3412 can display a reminder icon in the shape of a bell
next to the selected audio-visual program on the A/V display.

(Screenshot of DCT3412 program guide with Comcast cable service)

13. The method as defined by

The list generator of the ’560 Accused Products displays a reminder at a predefined location
30

U.S. Patent No. 5,583,560
claim 12 wherein said list
generator displays a reminder
at a predefined location on said
A/V display, on the date and at
the time said audiovisual
program is received by said
transceiver.

Infringement Contentions
on the audio-visual or TV display, on the date and at the time that the selected audio-visual
program to be reminded of is received by the transceiver.
•

By way of one example, after setting a reminder for a program, a reminder is displayed at
the bottom of the screen on the date and time that the program is received by the
DCT3412.

(Screenshot of DCT3412 program guide with Comcast cable service)

15. The method as defined by
claim 11 wherein said list
generator further includes a
record mechanism for
recording selected audio-visual
programs on a storage device
coupled to said transceiver.

The list generator of the ’560 Accused Products further includes a record mechanism for
recording selected audio-visual programs on a storage device coupled to said transceiver.
•

By way of one example, the DCT3412 includes a hard drive for digital video recording
functionality coupled to the tranceiver. See, e.g., Ex. A-1 [Comcast DCT3400 User
Manual] at 3.

•

By way of another example, the DCT3412 includes a mechanism for recording audio31

U.S. Patent No. 5,583,560

16. The method as defined by
claim 15 wherein said record
mechanism is activated by said
user selecting an audio-visual
program represented in said
listing information using said
first or second buttons and then
activating a record button on
said controller.

Infringement Contentions
visual programs to a VCR or other device coupled to the transceiver of the DCT3412.
See, e.g., Ex. A-1 [Comcast DCT3400 User Manual] at 28-29.
The record mechanism of the ’560 Accused Products is activated by the user selecting an
audio-visual program represented in the listing information using first or second buttons and
then activating a record button on said controller.
•

By way of one example, the record mechanism of the DCT3412 is activated by a user
choosing the program from the TV listings using a the up or down keys and then
pressing the “record” button on the remote control or selecting the record icon using the
control panel. See, e.g., Ex. A -4 [Comcast Digital Cable Guide] at 1.

See, e.g., Ex. A -4 [Comcast Digital Cable Guide] at 11 (explaining how to choose a program in the TV
listings using directional arrow buttons on the remote control)

See, e.g., Ex. A -4 [Comcast Digital Cable Guide] at 18 (explaining how to record programs through DVR
service)

32