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Case 3:06-cv-00019-MHP Document 131 Filed 07/13/2007 Page 1 of 58

Appendix B

Dockets.Justia.com
A. Claim Chart for Gremillet & Tescher for the ’995 Patent

Asserted U.S. Patent No. 4,963,995 Gremillet & Tescher


995-1. An audio/video transceiver apparatus comprising: Gremillet discloses a music on demand system for “the
teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .
[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-
68; 2:3-8; 3:5-10]

The distribution center has a television transmitter, either a


“transmitting antenna” or “a cable or optical fibres” that connect
with the subscriber’s equipment. [4:1-7]
[a] input means for receiving audio/visual source information; It is inherent in the Gremillet patent that the distribution center
receives the audio works for distribution. “[T]he distribution
center 10 comprises a bank 11 of musical recordings recorded at
a faster speed than normal.” [3:37-40]

This sound information is “obtained by writing [it] into a


memory and then reading from the memory at the accelerated
speed.” [3:42-44]

The Tescher patent describes the compression, encoding, and


buffering of time domain information signals “for subsequent
utilization, e.g.[,] transmission from a transmitting station to a
receiving station.” [2:43-44]. As illustrated in Fig. 1, the
system receives video source information through an analog
processor: “analog video signals are coupled to the input of an
analog processor unit 11 . . . and converted to multi-bit digital
samples.” [5:32-34]
[b] compression means, coupled to said input means, for Gremillet refers to the music it transmits as “compressed” but
compressing said audio/video source information into a time does not expressly describe a reduction in the number of bits
compressed representation thereof having an associated time used to represent the music: “the compression of the sound

GREMILLET ‘568 & TESCHER ‘012


period that is shorter than a time period associated with a real information can be obtained by writing into a memory and then
time representation of said audio/video source information; reading from the memory at the accelerated speed.” [3:42-45]

Gremillet describes the “information flow rate” of the musical


works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

It would also have been obvious to combine Gremillet with any


one of several known compression technologies, including those
disclosed in the U.S. Patent No. 4,541,012 (“the Tescher
Patent”), which discloses a lower bitrate for compressed video
than the rate disclosed for faster-than-real-time transmission of
audio in Gremillet.

The Tescher patent illustrates in Fig. 1 “a block diagram


illustrating an encoder incorporating the invention.” [5:7-8].
This encoder uses both intraframe and interframe compression.

Tescher uses an interframe compression technique of


“comparing corresponding blocks of time domain information
signals from successive fields.” [1:25-45]

The Tescher patent also describes using a type of intraframe


compression known as “transform domain encoding,” in which
“each field of information signals is divided into a number of
rectangular or square arrays of individual picture elements,”
rather than storing individual pixels. [1:59-66]

In addition, the Tescher patent employs a Huffman coding

GREMILLET ‘568 & TESCHER ‘012 -2-


technique, which was a well-known method for data
compression. [6:67-7:63]

These various compression techniques yield a compressed full-


motion video bit rate of “2.39 X 105 bits per second [or more
simply, 0.239 Mbits per second] which is 0.25 percent of the
standard uncompressed digital bit rate.” [11:61-12:1]

“The equivalent digital samples produced in analog processor


unit 11 are coupled to the input of an input digital processor 12
in which incoming field samples are merged with the
corresponding samples from the previous field.” [5:39-44]
[c] random access storage means, coupled to said compression The Gremillet patent discloses “recording support [which] can
means, for storing the time compressed representation of said be a video disk or a video recorder.” [3:40-42]
audio/video source information; and
This “information recording bank” can be formed from the audio
source information “by writing into a memory and then reading
from the memory at an accelerated speed.” [3:42-44]

The Tescher patent discloses the compression of an input video


stream “for subsequent utilization, e.g.[,] . . . recording on video
tape or other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a
random access storage means such as a hard disk for the purpose
of storing the compressed video.

[d] output means, coupled to said random access storage means, Gremillet explains that “[t]he information flow rate linked with
for receiving the time compressed audio/video source classical music is approximately 0.5 Mbits/s. However, the
information stored in said random access storage means for information flow rate of picture transmission channel used in
transmission away from said audio/video transceiver apparatus. television (either broadcast, or by optical fibres or cable) is well
above this value.” [2:1-8] This makes it possible to transmit
“music comparessed [sic] in a factor of 200,” meaning that “a
musical work lasting one hour can be transmitted in 18 seconds.”

GREMILLET ‘568 & TESCHER ‘012 -3-


[2:8-12]

Gremillet describes a “broadcasting means consisting of a


transmitter 31, a transmitting antenna 32, a receiving antenna 33,
or a cable or optical fibres 34,’ connecting the distribution center
with the subscriber equipment. [4:1-7]

Gremillet describes a “video recorder” which is “housed with the


requesting subscriber” and records the transmitted information:
“the writing phase continues until the work has been completely
recorded. However, as stated hereinbefore, this phase is of a
short duration, in view of the high compression level of the
recorder information (greater than 100).” [4:16-40; see also
Claim 1]

Gremillet describes the “information flow rate” of the musical


works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

It would also have been obvious to combine Gremillet with any


one of several known compression technologies, including those
disclosed in the U.S. Patent No. 4,541,012 (“the Tescher
Patent”), which discloses a lower bitrate for compressed video
than the rate disclosed for faster-than-real-time transmission of
audio in Gremillet.

The Tescher patent illustrates in Fig. 1 “a block diagram


illustrating an encoder incorporating the invention.” [5:7-8].
This encoder uses both intraframe and interframe compression.

GREMILLET ‘568 & TESCHER ‘012 -4-


Tescher describes the compression, encoding, and buffering of
time domain information signals “for subsequent utilization,
e.g.[,] transmission from a transmitting station to a receiving
station.” [2:43-44]. The described transfer from transmitting
to receiving station, “from an encoding site to a decoding site,”
discloses transmission of a compressed video stream to an
external device. [1:8-13]

995-2. An audio/video transceiver apparatus as in claim 1


further comprising editing means, coupled to said random access
storage means, for editing the time compressed representation of
said audio/video source information stored in said random
access storage means; and for restoring the edited time
compressed representation of said audio/video source
information in said random access storage means;
and wherein said output means is operative for receiving the
edited time compressed representation of said audio/video
source information stored in said random access storage means
for transmission away from said audio/video transceiver
apparatus.
-
995-3. An audio/video transceiver apparatus as in claim 2
further comprising monitor means for enabling the user to
selectively identify the time compressed representation of said
audio/video source information stored in said random access
storage means during editing.

995-7. An audio/video transceiver apparatus as in claim 1


wherein said random access storage means comprises a
semiconductor memory.

995-8. An audio/video transceiver apparatus as in claim 1

GREMILLET ‘568 & TESCHER ‘012 -5-


wherein:
said audio/video source information comprises analog In the Gremillet patent that the distribution center receives the
audio/video source information; audio works for distribution. “[T]he distribution center 10
comprises a bank 11 of musical recordings recorded at a faster
speed than normal.” [3:37-40] These works may be in analog
form and then converted by the transceiver. [5:7-9]

This sound information is “obtained by writing [it] into a


memory and then reading from the memory at the accelerated
speed.” [3:42-44]

The Tescher patent describes the compression, encoding, and


buffering of time domain information signals “for subsequent
utilization, e.g.[,] transmission from a transmitting station to a
receiving station.” [2:43-44]. As illustrated in Fig. 1, the
system receives video source information through an analog
processor: “analog video signals are coupled to the input of an
analog processor unit 11 . . . and converted to multi-bit digital
samples.” [5:32-37]
said audio/video transceiver apparatus further comprises analog Gremillet discloses the use of an analog to digital converter in
to digital converter means for converting said analog the transceiver. [5:7-9]
audio/video source information to corresponding digital
audio/video source information; The Tescher patent describes the compression, encoding, and
buffering of time domain information signals “for subsequent
utilization, e.g.[,] transmission from a transmitting station to a
receiving station.” [2:43-44]. As illustrated in Fig. 1, the
system receives video source information through an analog
processor: “analog video signals are coupled to the input of an
analog processor unit 11 . . . and converted to multi-bit digital
samples.” [5:32-37]
said compression means is operative for compressing said Gremillet refers to the music it transmits as “compressed” but
corresponding digital audio/video source information into a does not expressly describe a reduction in the number of bits
digital time compressed representation thereof having an used to represent the music: “the compression of the sound

GREMILLET ‘568 & TESCHER ‘012 -6-


associated time period that is shorter than a time period information can be obtained by writing into a memory and then
associated with a real time representation of said digital reading from the memory at the accelerated speed.” [3:42-45]
audio/video source information; and
Gremillet describes the “information flow rate” of the musical
works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

It would also have been obvious to combine Gremillet with any


one of several known compression technologies, including those
disclosed in the U.S. Patent No. 4,541,012 (“the Tescher
Patent”), which discloses a lower bitrate for compressed video
than the rate disclosed for faster-than-real-time transmission of
audio in Gremillet.

The Tescher patent illustrates in Fig. 1 “a block diagram


illustrating an encoder incorporating the invention.” [5:7-8].
This encoder uses both intraframe and interframe compression.

Tescher uses an interframe compression technique of


“comparing corresponding blocks of time domain information
signals from successive fields.” [1:25-45]

The Tescher patent also describes using a type of intraframe


compression known as “transform domain encoding,” in which
“each field of information signals is divided into a number of
rectangular or square arrays of individual picture elements,”
rather than storing individual pixels. [1:59-66]

In addition, the Tescher patent employs a Huffman coding

GREMILLET ‘568 & TESCHER ‘012 -7-


technique, which was a well-known method for data
compression. [6:67-7:63]

These various compression techniques yield a compressed full-


motion video bit rate of “2.39 X 105 bits per second [or more
simply, 0.239 Mbits per second] which is 0.25 percent of the
standard uncompressed digital bit rate.” [11:61-12:1]

“The equivalent digital samples produced in analog processor


unit 11 are coupled to the input of an input digital processor 12
in which incoming field samples are merged with the
corresponding samples from the previous field.” [5:39-44]
said random access storage means is operative for storing said The Gremillet patent discloses “recording support [which] can
digital time compressed representation of said corresponding be a video disk or a video recorder.” [3:40-42]
digital audio/video source information.
This “information recording bank” can be formed from the audio
source information “by writing into a memory and then reading
from the memory at an accelerated speed.” [3:42-44]

The Tescher patent discloses the compression of an input video


stream “for subsequent utilization, e.g.[,] . . . recording on video
tape or other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a
random access storage means such as a hard disk for the purpose
of storing the compressed video.

995-9. An audio/video transceiver apparatus as in claim 1


wherein:
said audio/video source information comprises digital
audio/video source information;
said compression means is operative for compressing said digital Gremillet refers to the music it transmits as “compressed” but
audio/video source information into a digital time compressed does not expressly describe a reduction in the number of bits

GREMILLET ‘568 & TESCHER ‘012 -8-


representation thereof having an associated time period that is used to represent the music: “the compression of the sound
shorter than a time period associated with a real time information can be obtained by writing into a memory and then
representation of said digital audio/video source information; reading from the memory at the accelerated speed.” [3:42-45]
and
Gremillet describes the “information flow rate” of the musical
works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

It would also have been obvious to combine Gremillet with any


one of several known compression technologies, including those
disclosed in the U.S. Patent No. 4,541,012 (“the Tescher
Patent”), which discloses a lower bitrate for compressed video
than the rate disclosed for faster-than-real-time transmission of
audio in Gremillet.

The Tescher patent illustrates in Fig. 1 “a block diagram


illustrating an encoder incorporating the invention.” [5:7-8].
This encoder uses both intraframe and interframe compression.

Tescher uses an interframe compression technique of


“comparing corresponding blocks of time domain information
signals from successive fields.” [1:25-45]

The Tescher patent also describes using a type of intraframe


compression known as “transform domain encoding,” in which
“each field of information signals is divided into a number of
rectangular or square arrays of individual picture elements,”
rather than storing individual pixels. [1:59-66]

GREMILLET ‘568 & TESCHER ‘012 -9-


In addition, the Tescher patent employs a Huffman coding
technique, which was a well-known method for data
compression. [6:67-7:63]

These various compression techniques yield a compressed full-


motion video bit rate of “2.39 X 105 bits per second [or more
simply, 0.239 Mbits per second] which is 0.25 percent of the
standard uncompressed digital bit rate.” [11:61-12:1]

“The equivalent digital samples produced in analog processor


unit 11 are coupled to the input of an input digital processor 12
in which incoming field samples are merged with the
corresponding samples from the previous field.” [5:39-44]
said random access storage means is operative for storing said The Gremillet patent discloses “recording support [which] can
digital time compressed representation of said digital be a video disk or a video recorder.” [3:40-42]
audio/video source information;
This “information recording bank” can be formed from the audio
source information “by writing into a memory and then reading
from the memory at an accelerated speed.” [3:42-44]

The Tescher patent discloses the compression of an input video


stream “for subsequent utilization, e.g.[,] . . . recording on video
tape or other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a
random access storage means such as a hard disk for the purpose
of storing the compressed video.

995-15. An audio/video transceiver apparatus is in claim 9


wherein said input means is coupled to an external computer and
said digital audio/video source information comprises
computer-generated audio/video information.

995-17. An audio/video transceiver apparatus comprising: Gremillet discloses a music on demand system for “the

GREMILLET ‘568 & TESCHER ‘012 - 10 -


teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .
[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-
68; 2:3-8; 3:5-10]

The distribution center has a television transmitter, either a


“transmitting antenna” or “a cable or optical fibres” that connect
with the subscriber’s equipment. [4:1-7]
[a] input means for receiving audio/video source information as It is inherent in the Gremillet patent that the distribution center
a time compressed representation thereof, said time compressed receives the audio works for distribution. “[T]he distribution
representation of said audio/video source information being center 10 comprises a bank 11 of musical recordings recorded at
received over an associated burst time period that is shorter than a faster speed than normal.” [3:37-40]
a real time period associated with said audio/video source
information; This sound information is “obtained by writing [it] into a
memory and then reading from the memory at the accelerated
speed.” [3:42-44]
[b] random access storage means, coupled to said input means, The Gremillet patent discloses “recording support [which] can
for storing the time compressed representation of said be a video disk or a video recorder.” [3:40-42]
audio/video source information received by said input means;
and This “information recording bank” can be formed from the audio
source information “by writing into a memory and then reading
from the memory at an accelerated speed.” [3:42-44]

Tescher discloses the compression of an input video stream “for


subsequent utilization, e.g.[,] . . . recording on video tape or
other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a
random access storage means such as a hard disk for the purpose
of storing the compressed video.
[c] output means, coupled to said random access storage means, Gremillet explains that “[t]he information flow rate linked with
for receiving the time compressed representation of said classical music is approximately 0.5 Mbits/s. However, the
audio/video source information stored in said random access information flow rate of picture transmission channel used in

GREMILLET ‘568 & TESCHER ‘012 - 11 -


storage means for transmission away from said audio/video television (either broadcast, or by optical fibres or cable) is well
transceiver apparatus above this value.” [2:1-8] This makes it possible to transmit
“music comparessed [sic] in a factor of 200,” meaning that “a
musical work lasting one hour can be transmitted in 18 seconds.”
[2:8-12]

Gremillet describes a “video recorder” which is “housed with the


requesting subscriber” and records the transmitted information:
“the writing phase continues until the work has been completely
recorded. However, as stated hereinbefore, this phase is of a
short duration, in view of the high compression level of the
recorder information (greater than 100).” [4:16-40; see also
Claim 1]

Gremillet describes the “information flow rate” of the musical


works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

Gremillet describes a “broadcasting means consisting of a


transmitter 31, a transmitting antenna 32, a receiving antenna 33,
or a cable or optical fibres 34,’ connecting the distribution center
with the subscriber equipment. [4:1-7]

This “recording can be kept on the video recorder for the


purpose of listening to it later.” [4:36-39] It would have been
obvious to copy the compressed musical works onto other tapes
in order to backup the information. See, e.g., U.S. Patent No.
4,768,110. Because these works are compressed, such copying
would be at a faster-than-real-time rate.

GREMILLET ‘568 & TESCHER ‘012 - 12 -


Tescher describes the compression, encoding, and buffering of
time domain information signals “for subsequent utilization,
e.g.[,] transmission from a transmitting station to a receiving
station.” [2:43-44]. The described transfer from transmitting
to receiving station, “from an encoding site to a decoding site,”
discloses transmission of a compressed video stream to an
external device. [1:8-13]

995-19. An audio/video transceiver apparatus as in claim 17 in In the Gremillet patent that the distribution center receives the
combination with a video library, coupled via a communication audio works for distribution. “[T]he distribution center 10
link with said audio/video transceiver apparatus, said video comprises a bank 11 of musical recordings recorded at a faster
library storing a multiplicity of items of audio/video source speed than normal.” [3:37-40] These works may be in analog
information in said time compressed representation for selective form and then converted by the transceiver. [5:7-9]
retrieval, in said associated burst time period over said
communication link. This sound information is “obtained by writing [it] into a
memory and then reading from the memory at the accelerated
speed.” [3:42-44]

The Tescher patent describes the compression, encoding, and


buffering of time domain information signals “for subsequent
utilization, e.g.[,] transmission from a transmitting station to a
receiving station.” [2:43-44]. As illustrated in Fig. 1, the
system receives video source information through an analog
processor: “analog video signals are coupled to the input of an
analog processor unit 11 . . . and converted to multi-bit digital
samples.” [5:32-37]

995-20. An audio/video transceiver apparatus as in claim 1 Gremillet discloses a music on demand system for “the
further comprising: teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .
[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-

GREMILLET ‘568 & TESCHER ‘012 - 13 -


68; 2:3-8; 3:5-10]
decompression means, coupled to said random access storage Gremillet describes the ability “to restore the normal speed to
means, for selectively decompressing said time compressed the information and finally a sound restoration chain 25
representation of said audio/video source information stored in connected to the rate converter,” which decompresses the
said random access storage means; and transmitted representation. [3:55-62]

Tescher discloses a decompression means, illustrated at Fig. 2,


that applies “essentially the inverse of the encoding process”:

“For each frame of encoded information, the first and second


control code signals are used to establish the initial minimum
quantization interval to be employed for inverse quantizing the
block replenishment code symbols. The received
replenishment code symbols are decoded using a parallel set of
inverse code tables, which are selected using the same predictive
mean algorithm as that employed in the encoding process. The
block address, quadrature chrominance and D.C. term codes are
coupled directly to a diagonal memory unit, while the coefficient
code terms are inverse quantized by multiplying each code term
by Dk, using the transmitted initial value of DK for the first block
of data, and the resulting coefficients are stored in the diagonal
memory unit. After the first block has been decoded, the
distortion constant Dk is recalculated and the newly calculated
value of Dk is used to inverse quantize the next block of data.
The coefficients stored in the diagonal memory unit are
then transformed to time domain digital samples using an
inverse discrete cosine transform, and the resulting samples are
stored in an output memory unit, replacing previous samples
representing the same block. The merged field samples stored
in the output memory unit, which replicate the merged field
samples stored in a corresponding reference memory unit at the
encoder stie [sic], are finally processed to provide video output
signals.” [4:24-52; see also 10:7-42]

GREMILLET ‘568 & TESCHER ‘012 - 14 -


editing means, coupled to said random access storage means and
decompression means, for editing said selectively decompressed
time compressed representation of said audio/video source
information, and for storing said edited selectively
decompressed time compressed representation of said
audio/video source information in said random access storage
means.

995-22. An audio/video transceiver apparatus as in claim 1 Gremillet discloses a music on demand system for “the
further comprising: teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .
[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-
68; 2:3-8; 3:5-10]
decompression means, coupled to said random access storage Tescher discloses a decompression means, illustrated at Fig. 2,
means, for selectively decompressing the time compressed that applies “essentially the inverse of the encoding process”:
representation of said audio/video source information stored in
said random access storage means; and “For each frame of encoded information, the first and second
control code signals are used to establish the initial minimum
quantization interval to be employed for inverse quantizing the
block replenishment code symbols. The received
replenishment code symbols are decoded using a parallel set of
inverse code tables, which are selected using the same predictive
mean algorithm as that employed in the encoding process. The
block address, quadrature chrominance and D.C. term codes are
coupled directly to a diagonal memory unit, while the coefficient
code terms are inverse quantized by multiplying each code term
by Dk, using the transmitted initial value of DK for the first block
of data, and the resulting coefficients are stored in the diagonal
memory unit. After the first block has been decoded, the
distortion constant Dk is recalculated and the newly calculated
value of Dk is used to inverse quantize the next block of data.
The coefficients stored in the diagonal memory unit are

GREMILLET ‘568 & TESCHER ‘012 - 15 -


then transformed to time domain digital samples using an
inverse discrete cosine transform, and the resulting samples are
stored in an output memory unit, replacing previous samples
representing the same block. The merged field samples stored
in the output memory unit, which replicate the merged field
samples stored in a corresponding reference memory unit at the
encoder stie [sic], are finally processed to provide video output
signals.” [4:24-52; see also 10:7-42]
monitor means for enabling the user to view the selectively
decompressed time compressed representation of said
audio/video source information.

995-23. An audio/video transceiver apparatus as in claim 8 Gremillet discloses a music on demand system for “the
further comprising: teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .
[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-
68; 2:3-8; 3:5-10]
decompression means, coupled to said random access storage Tescher discloses a decompression means, illustrated at Fig. 2,
means, for selectively decompressing the digital time that applies “essentially the inverse of the encoding process”:
compressed representation of said corresponding digital
audio/video source information stored in said random access “For each frame of encoded information, the first and second
storage means; and control code signals are used to establish the initial minimum
quantization interval to be employed for inverse quantizing the
block replenishment code symbols. The received
replenishment code symbols are decoded using a parallel set of
inverse code tables, which are selected using the same predictive
mean algorithm as that employed in the encoding process. The
block address, quadrature chrominance and D.C. term codes are
coupled directly to a diagonal memory unit, while the coefficient
code terms are inverse quantized by multiplying each code term
by Dk, using the transmitted initial value of DK for the first block
of data, and the resulting coefficients are stored in the diagonal

GREMILLET ‘568 & TESCHER ‘012 - 16 -


memory unit. After the first block has been decoded, the
distortion constant Dk is recalculated and the newly calculated
value of Dk is used to inverse quantize the next block of data.
The coefficients stored in the diagonal memory unit are
then transformed to time domain digital samples using an
inverse discrete cosine transform, and the resulting samples are
stored in an output memory unit, replacing previous samples
representing the same block. The merged field samples stored
in the output memory unit, which replicate the merged field
samples stored in a corresponding reference memory unit at the
encoder stie [sic], are finally processed to provide video output
signals.” [4:24-52; see also 10:7-42]
editing means, coupled to said random access storage means and
decompression means, for editing the decompressed digital time
compressed representation of said corresponding digital
audio/video source information and for then storing the edited
decompressed digital time compressed representation of said
corresponding digital audio/video source information in said
random access storage means.

995-44. An audio/video transceiver apparatus as in claim 1 Tescher discloses compression of video “for subsequent
further comprising recording means, including a removable utilization, e.g.[,] . . . recording on video tape or other magnetic
recording medium coupled to said random access storage means, media, etc.” [2:43-45]
for storing the time compressed representation of said
audio/video source information stored in said random access
storage means onto said removable recording medium.

995-47. An audio/video transceiver apparatus as in claim 17 The Gremillet patent discloses “recording support [which] can
further comprising recording means, including a removable be a video disk or a video recorder.” [3:40-42]
recording medium, coupled to said random access storage
means, for enabling user to selectively view the time compressed This “information recording bank” can be formed from the audio
representation of said audio/video source information stored in source information “by writing into a memory and then reading
said random access storage means onto said removable from the memory at an accelerated speed.” [3:42-44]

GREMILLET ‘568 & TESCHER ‘012 - 17 -


recording medium.
The Tescher patent discloses the compression of an input video
stream “for subsequent utilization, e.g.[,] . . . recording on video
tape or other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a
random access storage means such as a hard disk for the purpose
of storing the compressed video.

995-51. An audio/video transceiver apparatus as in claim 9


further comprising CD-ROM means for providing said digital
audio/video source information.

995-52. An audio/video transceiver apparatus as in claim 9


further comprising erasable optical disc means for providing said
digital audio/video source information.

995-80. An audio/video transceiver apparatus as in claim 1


further comprising editing means, coupled to said random access
storage means, for editing said time compressed representation
of said audio/video source information and for then storing the
edited time compressed representation of said audio/video
source information in said random access storage means.

GREMILLET ‘568 & TESCHER ‘012 - 18 -


B. Claim chart for Gremillet & Tescher for the ’839
Asserted U.S. Patent No. 5,164,839 Gremillet & Tescher
839-1. A method for handling audio/video source information, Gremillet discloses a music on demand system for “the
the method comprising: teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .
[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-
68; 2:3-8; 3:5-10]
[a] receiving audio/video source information; In the Gremillet patent that the distribution center receives the
audio works for distribution. “[T]he distribution center 10
comprises a bank 11 of musical recordings recorded at a faster
speed than normal.” [3:37-40] These works may be in analog
form and then converted by the transceiver. [5:7-9]

This sound information is “obtained by writing [it] into a


memory and then reading from the memory at the accelerated
speed.” [3:42-44]

The Tescher patent describes the compression, encoding, and


buffering of time domain information signals “for subsequent
utilization, e.g.[,] transmission from a transmitting station to a
receiving station.” [2:43-44]. As illustrated in Fig. 1, the
system receives video source information through an analog
processor: “analog video signals are coupled to the input of an
analog processor unit 11 . . . and converted to multi-bit digital
samples.” [5:32-37]
[b] compressing the received audio/video source information Gremillet refers to the music it transmits as “compressed” but
into a time compressed representation thereof having an does not expressly describe a reduction in the number of bits
associated burst time period that is shorter than a time period used to represent the music: “the compression of the sound
associated with a real time representation of the received information can be obtained by writing into a memory and then
audio/video source information; reading from the memory at the accelerated speed.” [3:42-45]

GREMILLET ‘568 & TESCHER ‘012 - 19 -


Gremillet describes the “information flow rate” of the musical
works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

It would also have been obvious to combine Gremillet with any


one of several known compression technologies, including those
disclosed in the U.S. Patent No. 4,541,012 (“the Tescher
Patent”), which discloses a lower bitrate for compressed video
than the rate disclosed for faster-than-real-time transmission of
audio in Gremillet.

The Tescher patent illustrates in Fig. 1 “a block diagram


illustrating an encoder incorporating the invention.” [5:7-8].
This encoder uses both intraframe and interframe compression.

Tescher uses an interframe compression technique of


“comparing corresponding blocks of time domain information
signals from successive fields.” [1:25-45]

The Tescher patent also describes using a type of intraframe


compression known as “transform domain encoding,” in which
“each field of information signals is divided into a number of
rectangular or square arrays of individual picture elements,”
rather than storing individual pixels. [1:59-66]

In addition, the Tescher patent employs a Huffman coding


technique, which was a well-known method for data
compression. [6:67-7:63]

GREMILLET ‘568 & TESCHER ‘012 - 20 -


These various compression techniques yield a compressed full-
motion video bit rate of “2.39 X 105 bits per second [or more
simply, 0.239 Mbits per second] which is 0.25 percent of the
standard uncompressed digital bit rate.” [11:61-12:1]

“The equivalent digital samples produced in analog processor


unit 11 are coupled to the input of an input digital processor 12
in which incoming field samples are merged with the
corresponding samples from the previous field.” [5:39-44]
[c] storing said time compressed representation of the received The Gremillet patent discloses “recording support [which] can
audio/video source information; and be a video disk or a video recorder.” [3:40-42]

This “information recording bank” can be formed from the audio


source information “by writing into a memory and then reading
from the memory at an accelerated speed.” [3:42-44]

Tescher discloses the compression of an input video stream “for


subsequent utilization, e.g.[,] . . . recording on video tape or
other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a
random access storage means such as a hard disk for the purpose
of storing the compressed video.
[d] transmitting, in said burst time period, the stored time Gremillet explains that “[t]he information flow rate linked with
compressed representation of the received audio/video source classical music is approximately 0.5 Mbits/s. However, the
information to a selected destination. information flow rate of picture transmission channel used in
television (either broadcast, or by optical fibres or cable) is well
above this value.” [2:1-8] This makes it possible to transmit
“music comparessed [sic] in a factor of 200,” meaning that “a
musical work lasting one hour can be transmitted in 18 seconds.”
[2:8-12]

Gremillet describes a “video recorder” which is “housed with the


requesting subscriber” and records the transmitted information:

GREMILLET ‘568 & TESCHER ‘012 - 21 -


“the writing phase continues until the work has been completely
recorded. However, as stated hereinbefore, this phase is of a
short duration, in view of the high compression level of the
recorder information (greater than 100).” [4:16-40; see also
Claim 1]

Gremillet describes the “information flow rate” of the musical


works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

Gremillet describes a “broadcasting means consisting of a


transmitter 31, a transmitting antenna 32, a receiving antenna 33,
or a cable or optical fibres 34,’ connecting the distribution center
with the subscriber equipment. [4:1-7]

Tescher describes the compression, encoding, and buffering of


time domain information signals “for subsequent utilization,
e.g.[,] transmission from a transmitting station to a receiving
station.” [2:43-44]. The described transfer from transmitting
to receiving station, “from an encoding site to a decoding site,”
discloses transmission of a compressed video stream to an
external device. [1:8-13]

839-2. A method as in claim 1 nps of:


editing the stored time compressed representation of said
audio/video source information; and
storing the edited time compressed representation of said
audio/video source information.

GREMILLET ‘568 & TESCHER ‘012 - 22 -


839-3. A method as in claim 2 further comprising the step of
monitoring the stored, time compressed representation of said
audio/video source information during editing.

839-9. A method as in claim 1 wherein:


said audio/video source information comprises digital
audio/video source information;
said step of compressing comprises compressing said digital Gremillet refers to the music it transmits as “compressed” but
audio/video source information into a digital time compressed does not expressly describe a reduction in the number of bits
representation thereof having an associated burst time period used to represent the music: “the compression of the sound
that is shorter than a time period associated with a real time information can be obtained by writing into a memory and then
representation of said digital audio/video source information; reading from the memory at the accelerated speed.” [3:42-45]
and
Gremillet describes the “information flow rate” of the musical
works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

It would also have been obvious to combine Gremillet with any


one of several known compression technologies, including those
disclosed in the U.S. Patent No. 4,541,012 (“the Tescher
Patent”), which discloses a lower bitrate for compressed video
than the rate disclosed for faster-than-real-time transmission of
audio in Gremillet.

The Tescher patent illustrates in Fig. 1 “a block diagram


illustrating an encoder incorporating the invention.” [5:7-8].
This encoder uses both intraframe and interframe compression.

Tescher uses an interframe compression technique of

GREMILLET ‘568 & TESCHER ‘012 - 23 -


“comparing corresponding blocks of time domain information
signals from successive fields.” [1:25-45]

The Tescher patent also describes using a type of intraframe


compression known as “transform domain encoding,” in which
“each field of information signals is divided into a number of
rectangular or square arrays of individual picture elements,”
rather than storing individual pixels. [1:59-66]

In addition, the Tescher patent employs a Huffman coding


technique, which was a well-known method for data
compression. [6:67-7:63]

These various compression techniques yield a compressed full-


motion video bit rate of “2.39 X 105 bits per second [or more
simply, 0.239 Mbits per second] which is 0.25 percent of the
standard uncompressed digital bit rate.” [11:61-12:1]

“The equivalent digital samples produced in analog processor


unit 11 are coupled to the input of an input digital processor 12
in which incoming field samples are merged with the
corresponding samples from the previous field.” [5:39-44]
said step of storing comprises storing said digital time The Gremillet patent discloses “recording support [which] can
compressed representation of said digital audio/video source be a video disk or a video recorder.” [3:40-42]
information.
This “information recording bank” can be formed from the audio
source information “by writing into a memory and then reading
from the memory at an accelerated speed.” [3:42-44]

The Tescher patent discloses the compression of an input video


stream “for subsequent utilization, e.g.[,] . . . recording on video
tape or other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a

GREMILLET ‘568 & TESCHER ‘012 - 24 -


random access storage means such as a hard disk for the purpose
of storing the compressed video.
839-15. A method as in claim 9 wherein said audio/video
source information comprises information received from a
computer.

839-17. A method for handling audio/video source information, Gremillet discloses a music on demand system for “the
the method comprising: teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .
[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-
68; 2:3-8; 3:5-10]

The distribution center has a television transmitter, either a


“transmitting antenna” or “a cable or optical fibres” that connect
with the subscriber’s equipment. [4:1-7]
[a] receiving audio/video source information as a time It is inherent in the Gremillet patent that the distribution center
compressed representation thereof, said time compressed receives the audio works for distribution. “[T]he distribution
representation of said audio/video source information being center 10 comprises a bank 11 of musical recordings recorded at
received over an associated burst time period that is shorter than a faster speed than normal.” [3:37-40]
a real time period associated with real time playback of said
audio/video source information; This sound information is “obtained by writing [it] into a
memory and then reading from the memory at the accelerated
speed.” [3:42-44]
[b] storing the time compressed representation of said received The Gremillet patent discloses “recording support [which] can
audio/video source information; and be a video disk or a video recorder.” [3:40-42]

This “information recording bank” can be formed from the audio


source information “by writing into a memory and then reading
from the memory at an accelerated speed.” [3:42-44]

Tescher discloses the compression of an input video stream “for


subsequent utilization, e.g.[,] . . . recording on video tape or

GREMILLET ‘568 & TESCHER ‘012 - 25 -


other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a
random access storage means such as a hard disk for the purpose
of storing the compressed video.
[c] transmitting, in said burst time period, the stored time Gremillet explains that “[t]he information flow rate linked with
compressed representation of said received audio/video source classical music is approximately 0.5 Mbits/s. However, the
information to a selected destination. information flow rate of picture transmission channel used in
television (either broadcast, or by optical fibres or cable) is well
above this value.” [2:1-8] This makes it possible to transmit
“music comparessed [sic] in a factor of 200,” meaning that “a
musical work lasting one hour can be transmitted in 18 seconds.”
[2:8-12]

Gremillet describes a “video recorder” which is “housed with the


requesting subscriber” and records the transmitted information:
“the writing phase continues until the work has been completely
recorded. However, as stated hereinbefore, this phase is of a
short duration, in view of the high compression level of the
recorder information (greater than 100).” [4:16-40; see also
Claim 1]

Gremillet describes the “information flow rate” of the musical


works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

Gremillet describes a “broadcasting means consisting of a


transmitter 31, a transmitting antenna 32, a receiving antenna 33,
or a cable or optical fibres 34,’ connecting the distribution center
with the subscriber equipment. [4:1-7]

GREMILLET ‘568 & TESCHER ‘012 - 26 -


Tescher describes the compression, encoding, and buffering of
time domain information signals “for subsequent utilization,
e.g.[,] transmission from a transmitting station to a receiving
station.” [2:43-44]. The described transfer from transmitting
to receiving station, “from an encoding site to a decoding site,”
discloses transmission of a compressed video stream to an
external device. [1:8-13]

839.19. A method as in claim 17 wherein said audio/video See citations above for claim 17.
source information comprises information received over a
communications link from a video library storing a multiplicity The Gremillet patent describes system that offers “to requesting
of programs of audio/video source information as time users, any piece of music of their choice (or any of the
compressed representations thereof for selective retrieval by a information referred to hereinbefore) and in a few seconds.”
user in an associated burst time period.
Gremillet was not limited to only songs, “[t]he scope of the
application relates to the teledistribution of musical works, such
as read literature works (novels, short stories, essays, plays, etc.).
musical works with commentaries, literary works read with
background effects, news, courses, conferences etc.” [1:11-16]

As such, it would have been obvious to combine the efficient


video compression techniques disclosed in U.S. Patent Number
4,541,012 (“the Tescher patent”) with the system for
compression, storage, and faster-than-real-time transmission of
media files disclosed in the Gremilet patent. The compression
techniques disclosed in the Tescher patent produce video files
that have one-half of the bitrate of the audio files already sent
faster-than-real-time as described in the Gremillet patent.
Specifically, the Gremillet patent discloses the storage and
faster-than-real-time transmission of compressed sound
recordings that have a bitrate of 0.5 Mbits per second. [2:3-4]
But using the compression techniques described in Tescher,

GREMILLET ‘568 & TESCHER ‘012 - 27 -


video programs can be compressed down to a bitrate of 0.239
Mbits per second. [Tescher Patent at 11:52-12:1] It would
have been obvious to combine the media compression, storage,
and transmission system disclosed in the Gremillet patent with
the video compression described in the Tescher patent to allow
the storage and distribution of video, because the signal bitrate in
Tescher is lower than the signal bitrate disclosed in Gremillet.

839-20. A method as in claim 1 further comprising the steps of:


selectively decompressing the stored time compressed Tescher discloses a decompression means, illustrated at Fig. 2,
representation of said audio/video source information; that applies “essentially the inverse of the encoding process”:

“For each frame of encoded information, the first and second


control code signals are used to establish the initial minimum
quantization interval to be employed for inverse quantizing the
block replenishment code symbols. The received
replenishment code symbols are decoded using a parallel set of
inverse code tables, which are selected using the same
predictive mean algorithm as that employed in the encoding
process. The block address, quadrature chrominance and D.C.
term codes are coupled directly to a diagonal memory unit,
while the coefficient code terms are inverse quantized by
multiplying each code term by Dk, using the transmitted initial
value of DK for the first block of data, and the resulting
coefficients are stored in the diagonal memory unit. After the
first block has been decoded, the distortion constant Dk is
recalculated and the newly calculated value of Dk is used to
inverse quantize the next block of data.
The coefficients stored in the diagonal memory unit are
then transformed to time domain digital samples using an
inverse discrete cosine transform, and the resulting samples are
stored in an output memory unit, replacing previous samples
representing the same block. The merged field samples stored

GREMILLET ‘568 & TESCHER ‘012 - 28 -


in the output memory unit, which replicate the merged field
samples stored in a corresponding reference memory unit at the
encoder stie [sic], are finally processed to provide video output
signals.” [4:24-52; see also 10:7-42]
editing the selectively decompressed time compressed
representation of said audio/video source information; and
storing the edited selectively decompressed time compressed
representation of said audio/video source information.

839-28. A method as in claim 9 further comprising the steps of:


selectively decompressing the stored digital time compressed Tescher discloses a decompression means, illustrated at Fig. 2,
representation of said digital audio/video source information; and that applies “essentially the inverse of the encoding process”:

“For each frame of encoded information, the first and second


control code signals are used to establish the initial minimum
quantization interval to be employed for inverse quantizing the
block replenishment code symbols. The received
replenishment code symbols are decoded using a parallel set of
inverse code tables, which are selected using the same
predictive mean algorithm as that employed in the encoding
process. The block address, quadrature chrominance and D.C.
term codes are coupled directly to a diagonal memory unit,
while the coefficient code terms are inverse quantized by
multiplying each code term by Dk, using the transmitted initial
value of DK for the first block of data, and the resulting
coefficients are stored in the diagonal memory unit. After the
first block has been decoded, the distortion constant Dk is
recalculated and the newly calculated value of Dk is used to
inverse quantize the next block of data.
The coefficients stored in the diagonal memory unit are
then transformed to time domain digital samples using an
inverse discrete cosine transform, and the resulting samples are
stored in an output memory unit, replacing previous samples

GREMILLET ‘568 & TESCHER ‘012 - 29 -


representing the same block. The merged field samples stored
in the output memory unit, which replicate the merged field
samples stored in a corresponding reference memory unit at the
encoder stie [sic], are finally processed to provide video output
signals.” [4:24-52; see also 10:7-42]
visually displaying the selectively decompressed digital time
compressed representation of said digital audio/video source
information for selective viewing by a user.

839-44. A method as in claim 1 further comprising the step of Tescher discloses compression of video “for subsequent
recording the stored time compressed representation of said utilization, e.g.[,] . . . recording on video tape or other magnetic
audio/video source information onto a removable recording media, etc.” [2:43-45]
medium.

839-45. A method as in claim 2 further comprising the step of


recording the edited time compressed representation of said
audio/video source information onto a removable recording
medium.

839.47. A method as in claim 17 further comprising the step of Tescher discloses compression of video “for subsequent
recording the time compressed representation of said audio/video utilization, e.g.[,] . . . recording on video tape or other magnetic
source information onto a removable recording medium. media, etc.” [2:43-45]

839-51. A method as in claim 9 wherein said digital audio/video


source information is received from a CD-ROM.

839-76. A method for handling audio/video source Gremillet discloses a music on demand system for “the
information, the method comprising: teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .
[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-
68; 2:3-8; 3:5-10]
[a] receiving audio/video source information comprising a It is inherent in the Gremillet patent that the distribution center

GREMILLET ‘568 & TESCHER ‘012 - 30 -


multiplicity of video frames in the form of one or more full receives the audio works for distribution. “[T]he distribution
motion video programs; center 10 comprises a bank 11 of musical recordings recorded at
a faster speed than normal.” [3:37-40]

This sound information is “obtained by writing [it] into a


memory and then reading from the memory at the accelerated
speed.” [3:42-44]

It would have been obvious to combine the efficient video


compression techniques disclosed in U.S. Patent Number
4,541,012 (“the Tescher patent”) with the system for
compression, storage, and faster-than-real-time transmission of
media files disclosed in the Gremilet patent. The compression
techniques disclosed in the Tescher patent produce video files
that have one-half of the bitrate of the audio files already sent
faster-than-real-time as described in the Gremillet patent.
Specifically, the Gremillet patent discloses the storage and
faster-than-real-time transmission of compressed sound
recordings that have a bitrate of 0.5 Mbits per second. [2:3-4]
But using the compression techniques described in Tescher,
video programs can be compressed down to a bitrate of 0.239
Mbits per second. [Tescher Patent at 11:52-12:1] It would
have been obvious to combine the media compression, storage,
and transmission system disclosed in the Gremillet patent with
the video compression described in the Tescher patent to allow
the storage and distribution of video, because the signal bitrate in
Tescher is lower than the signal bitrate disclosed in Gremillet.

As illustrated in Fig. 1, the system receives video source


information through an analog processor: “analog video
signals are coupled to the input of an analog processor unit
11 . . . and converted to multi-bit digital samples.” [5:32-34]
[b] compressing said received audio/video source information Gremillet refers to the music it transmits as “compressed” but

GREMILLET ‘568 & TESCHER ‘012 - 31 -


into a time compressed representation thereof having an does not expressly describe a reduction in the number of bits
associated burst time period that is shorter than a time period used to represent the music: “the compression of the sound
associated with a real time representation of said received information can be obtained by writing into a memory and then
audio/video source information; reading from the memory at the accelerated speed.” [3:42-45]

Gremillet describes the “information flow rate” of the musical


works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

It would also have been obvious to combine Gremillet with any


one of several known compression technologies, including those
disclosed in the U.S. Patent No. 4,541,012 (“the Tescher
Patent”), which discloses a lower bitrate for compressed video
than the rate disclosed for faster-than-real-time transmission of
audio in Gremillet.

The Tescher patent illustrates in Fig. 1 “a block diagram


illustrating an encoder incorporating the invention.” [5:7-8].
This encoder uses both intraframe and interframe compression.

Tescher uses an interframe compression technique of


“comparing corresponding blocks of time domain information
signals from successive fields.” [1:25-45]

The Tescher patent also describes using a type of intraframe


compression known as “transform domain encoding,” in which
“each field of information signals is divided into a number of
rectangular or square arrays of individual picture elements,”
rather than storing individual pixels. [1:59-66]

GREMILLET ‘568 & TESCHER ‘012 - 32 -


In addition, the Tescher patent employs a Huffman coding
technique, which was a well-known method for data
compression. [6:67-7:63]

These various compression techniques yield a compressed full-


motion video bit rate of “2.39 X 105 bits per second [or more
simply, 0.239 Mbits per second] which is 0.25 percent of the
standard uncompressed digital bit rate.” [11:61-12:1]

“The equivalent digital samples produced in analog processor


unit 11 are coupled to the input of an input digital processor 12
in which incoming field samples are merged with the
corresponding samples from the previous field.” [5:39-44]
[c] storing the time compressed representation of said received The Gremillet patent discloses “recording support [which] can
audio/video source information on one or more magnetic disks; be a video disk or a video recorder.” [3:40-42]
and
This “information recording bank” can be formed from the audio
source information “by writing into a memory and then reading
from the memory at an accelerated speed.” [3:42-44]

It would have been obvious to combine the Gremillet patent with


references disclosing different storage mediums. For example,
at Gremillet describes the video recorder at the user station
recording transmitted works using a magnetoscope. [4:23-
25] It would have been obvious to store the audio works on
hard disk. [See, e.g., “Peripheral Storage: Who’s Got What”
at APBU 714-725]

Tescher discloses the compression of an input video stream “for


subsequent utilization, e.g.[,] . . . recording on video tape or
other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a

GREMILLET ‘568 & TESCHER ‘012 - 33 -


random access storage means such as a hard disk for the purpose
of storing the compressed video.
[d] transmitting, in said burst time period, the stored time Gremillet explains that “[t]he information flow rate linked with
compressed representation of said received audio/video source classical music is approximately 0.5 Mbits/s. However, the
information to a selected destination. information flow rate of picture transmission channel used in
television (either broadcast, or by optical fibres or cable) is well
above this value.” [2:1-8] This makes it possible to transmit
“music comparessed [sic] in a factor of 200,” meaning that “a
musical work lasting one hour can be transmitted in 18 seconds.”
[2:8-12]

Gremillet describes a “video recorder” which is “housed with the


requesting subscriber” and records the transmitted information:
“the writing phase continues until the work has been completely
recorded. However, as stated hereinbefore, this phase is of a
short duration, in view of the high compression level of the
recorder information (greater than 100).” [4:16-40; see also
Claim 1]

Gremillet describes the “information flow rate” of the musical


works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

Gremillet describes a “broadcasting means consisting of a


transmitter 31, a transmitting antenna 32, a receiving antenna 33,
or a cable or optical fibres 34,’ connecting the distribution center
with the subscriber equipment. [4:1-7]

Tescher describes the compression, encoding, and buffering of

GREMILLET ‘568 & TESCHER ‘012 - 34 -


time domain information signals “for subsequent utilization,
e.g.[,] transmission from a transmitting station to a receiving
station.” [2:43-44]. The described transfer from transmitting
to receiving station, “from an encoding site to a decoding site,”
discloses transmission of a compressed video stream to an
external device. [1:8-13]

839-77. A method for handling audio/video source information, Gremillet discloses a music on demand system for “the
the method comprising: teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .
[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-
68; 2:3-8; 3:5-10]

This makes it possible to transmit “music comparessed [sic] in a


factor of 200,” meaning that “a musical work lasting one hour
can be transmitted in 18 seconds.” [2:8-12]
receiving audio/video source information as a time compressed In the Gremillet patent that the distribution center receives the
digital representation thereof, said audio/video source audio works for distribution. “[T]he distribution center 10
information comprising a multiplicity of video frames in the form comprises a bank 11 of musical recordings recorded at a faster
of one or more full motion video programs selected from a video speed than normal.” [3:37-40] These works may be in
library storing a multiplicity of full motion video programs in a analog form and then converted by the transceiver. [5:7-9]
time compressed digital representation thereof for selective
retrieval, said time compressed digital representation of the This sound information is “obtained by writing [it] into a
received audio/video source information being received in an memory and then reading from the memory at the accelerated
associated burst time period that is shorter than a time period speed.” [3:42-44]
associated in an associated burst time period that is shorter than a
time period associated with a real time representation of said The Tescher patent describes the compression, encoding, and
received audio/video source information; buffering of time domain information signals “for subsequent
utilization, e.g.[,] transmission from a transmitting station to a
receiving station.” [2:43-44]. As illustrated in Fig. 1, the
system receives video source information through an analog
processor: “analog video signals are coupled to the input of an

GREMILLET ‘568 & TESCHER ‘012 - 35 -


analog processor unit 11 . . . and converted to multi-bit digital
samples.” [5:32-37]
storing the time compressed digital representation of said The Gremillet patent discloses “recording support [which] can
received audio/video source information; and be a video disk or a video recorder.” [3:40-42]

This “information recording bank” can be formed from the


audio source information “by writing into a memory and then
reading from the memory at an accelerated speed.” [3:42-44]

The Tescher patent discloses the compression of an input video


stream “for subsequent utilization, e.g.[,] . . . recording on video
tape or other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a
random access storage means such as a hard disk for the
purpose of storing the compressed video.

transmitting, in said burst time period, the stored time Gremillet explains that “[t]he information flow rate linked with
compressed digital representation of said received audio/video classical music is approximately 0.5 Mbits/s. However, the
source information to a selected destination. information flow rate of picture transmission channel used in
television (either broadcast, or by optical fibres or cable) is well
above this value.” [2:1-8] This makes it possible to transmit
“music comparessed [sic] in a factor of 200,” meaning that “a
musical work lasting one hour can be transmitted in 18
seconds.” [2:8-12]

Gremillet describes a “video recorder” which is “housed with


the requesting subscriber” and records the transmitted
information: “the writing phase continues until the work has
been completely recorded. However, as stated hereinbefore,
this phase is of a short duration, in view of the high compression
level of the recorder information (greater than 100).” [4:16-
40; see also Claim 1]

GREMILLET ‘568 & TESCHER ‘012 - 36 -


Gremillet describes the “information flow rate” of the musical
works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

Gremillet describes a “broadcasting means consisting of a


transmitter 31, a transmitting antenna 32, a receiving antenna
33, or a cable or optical fibres 34,’ connecting the distribution
center with the subscriber equipment. [4:1-7]

Tescher describes the compression, encoding, and buffering of


time domain information signals “for subsequent utilization,
e.g.[,] transmission from a transmitting station to a receiving
station.” [2:43-44]. The described transfer from transmitting
to receiving station, “from an encoding site to a decoding site,”
discloses transmission of a compressed video stream to an
external device. [1:8-13]

GREMILLET ‘568 & TESCHER ‘012 - 37 -


C. Claim chart for Gremillet & Tescher for the ’932 Patent

Asserted U.S. Patent No. 5,057,932 Gremillet & Tescher


932-4. An audio/video transceiver apparatus comprising: Gremillet discloses a music on demand system for “the
teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .
[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-
68; 2:3-8; 3:5-10]

This makes it possible to transmit “music comparessed [sic] in a


factor of 200,” meaning that “a musical work lasting one hour
can be transmitted in 18 seconds.” [2:8-12]

The distribution center has a television transmitter, either a


“transmitting antenna” or “a cable or optical fibres” that connect
with the subscriber’s equipment. [4:1-7]

Tescher discloses a video compression/decompression system


that receives video input, achieves “signal compression of a
magnitude substantially greater than that available with known
systems,” and transmits that compressed data “for subsequent
utilization, e.g.[,] transmission from a transmitting station to a
receiving station, recording on video tape or other magnetic
media, etc.” [2:29-39; 2:43-45]

“This invention relates to information signal processing in


general, and in particular to the field of processing time
sequential information signals (such as video signals) for the
purpose of compressing the amount of information to be
transferred from an encoding site to a decoding site.” [1:8-13;
see also Abstract; 2:25-26]
[a] input means for receiving audio/video source information, It is inherent in the Gremillet patent that the distribution center

GREMILLET ‘568 & TESCHER ‘012 - 38 -


said audio/video source information comprising a multiplicity of receives the audio works for distribution. “[T]he distribution
video frames in the form of one or more full motion video center 10 comprises a bank 11 of musical recordings recorded at
programs; a faster speed than normal.” [3:37-40]

This sound information is “obtained by writing [it] into a


memory and then reading from the memory at the accelerated
speed.” [3:42-44]

It would have been obvious to combine the efficient video


compression techniques disclosed in U.S. Patent Number
4,541,012 (“the Tescher patent”) with the system for
compression, storage, and faster-than-real-time transmission of
media files disclosed in the Gremilet patent. The compression
techniques disclosed in the Tescher patent produce video files
that have one-half of the bitrate of the audio files already sent
faster-than-real-time as described in the Gremillet patent.
Specifically, the Gremillet patent discloses the storage and
faster-than-real-time transmission of compressed sound
recordings that have a bitrate of 0.5 Mbits per second. [2:3-4]
But using the compression techniques described in Tescher,
video programs can be compressed down to a bitrate of 0.239
Mbits per second. [Tescher Patent at 11:52-12:1] It would
have been obvious to combine the media compression, storage,
and transmission system disclosed in the Gremillet patent with
the video compression described in the Tescher patent to allow
the storage and distribution of video, because the signal bitrate in
Tescher is lower than the signal bitrate disclosed in Gremillet.

Tescher discloses the process for comparing each video frame of


the input video program against the previous frame: “The
equivalent digital samples produced in analog processor unit 11
are coupled to the input of an input digital processor 12 in which
incoming field samples are merged with the corresponding

GREMILLET ‘568 & TESCHER ‘012 - 39 -


samples from the previous field in the manner described below.”
[5:39-44]

As illustrated in Fig. 1 of Tescher, the system receives video


source information through the input means of an analog
processor: “analog video signals are coupled to the input of an
analog processor unit 11 . . . and converted to multi-bit digital
samples.” [5:32-34]
[b] compression means, coupled to said input means, for Gremillet refers to the music it transmits as “compressed” but
compressing said audio/video source information into a time does not expressly describe a reduction in the number of bits
compressed representation thereof having an associated time used to represent the music: “the compression of the sound
period that is shorter than a time period associated with a real information can be obtained by writing into a memory and then
time representation of said audio/video source information; reading from the memory at the accelerated speed.” [3:42-45]

Gremillet describes the “information flow rate” of the musical


works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

It would also have been obvious to combine Gremillet with any


one of several known compression technologies, including those
disclosed in the U.S. Patent No. 4,541,012 (“the Tescher
Patent”), which discloses a lower bitrate for compressed video
than the rate disclosed for faster-than-real-time transmission of
audio in Gremillet.

The Tescher patent illustrates in Fig. 1 “a block diagram


illustrating an encoder incorporating the invention.” [5:7-8].
This encoder uses both intraframe and interframe compression.

GREMILLET ‘568 & TESCHER ‘012 - 40 -


Tescher uses an interframe compression technique of
“comparing corresponding blocks of time domain information
signals from successive fields.” [1:25-45]

The Tescher patent also describes using a type of intraframe


compression known as “transform domain encoding,” in which
“each field of information signals is divided into a number of
rectangular or square arrays of individual picture elements,”
rather than storing individual pixels. [1:59-66]

In addition, the Tescher patent employs a Huffman coding


technique, which was a well-known method for data
compression. [6:67-7:63]

These various compression techniques yield a compressed full-


motion video bit rate of “2.39 X 105 bits per second [or more
simply, 0.239 Mbits per second] which is 0.25 percent of the
standard uncompressed digital bit rate.” [11:61-12:1]

“The equivalent digital samples produced in analog processor


unit 11 are coupled to the input of an input digital processor 12
in which incoming field samples are merged with the
corresponding samples from the previous field.” [5:39-44]
[c] random access storage means, coupled to said compression The Gremillet patent discloses “recording support [which] can
means, for storing the time compressed representation of said be a video disk or a video recorder.” [3:40-42]
audio/video source information, said random access storage
means comprising one or [more] magnetic disks; and This “information recording bank” can be formed from the audio
source information “by writing into a memory and then reading
from the memory at an accelerated speed.” [3:42-44]

It would have been obvious to combine the Gremillet patent with


references disclosing different storage mediums. For example,
at Gremillet describes the video recorder at the user station

GREMILLET ‘568 & TESCHER ‘012 - 41 -


recording transmitted works using a magnetoscope. [4:23-
25] It would have been obvious to store the audio works on
hard disk. [See, e.g., “Peripheral Storage: Who’s Got What”
at APBU 714-725]

Tescher discloses the compression of an input video stream “for


subsequent utilization, e.g.[,] . . . recording on video tape or
other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a
random access storage means such as a hard disk for the purpose
of storing the compressed video.
[d] output means, coupled to said random access storage means, Gremillet explains that “[t]he information flow rate linked with
for receiving the time compressed audio/video source classical music is approximately 0.5 Mbits/s. However, the
information stored in said random access storage means for information flow rate of picture transmission channel used in
transmission away from said audio/video transceiver apparatus. television (either broadcast, or by optical fibres or cable) is well
above this value.” [2:1-8] This makes it possible to transmit
“music comparessed [sic] in a factor of 200,” meaning that “a
musical work lasting one hour can be transmitted in 18 seconds.”
[2:8-12]

Gremillet describes a “video recorder” which is “housed with the


requesting subscriber” and records the transmitted information:
“the writing phase continues until the work has been completely
recorded. However, as stated hereinbefore, this phase is of a
short duration, in view of the high compression level of the
recorder information (greater than 100).” [4:16-40; see also
Claim 1]

Gremillet describes the “information flow rate” of the musical


works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also

GREMILLET ‘568 & TESCHER ‘012 - 42 -


been compressed in a manner that reduces the number of bits
used to represent the music.

Gremillet describes a “broadcasting means consisting of a


transmitter 31, a transmitting antenna 32, a receiving antenna 33,
or a cable or optical fibres 34,’ connecting the distribution center
with the subscriber equipment. [4:1-7]

Tescher describes the compression, encoding, and buffering of


time domain information signals “for subsequent utilization,
e.g.[,] transmission from a transmitting station to a receiving
station.” [2:43-44]. The described transfer from transmitting
to receiving station, “from an encoding site to a decoding site,”
discloses transmission of a compressed video stream to an
external device. [1:8-13]

GREMILLET ‘568 & TESCHER ‘012 - 43 -


D. Claim Chart for Gremillet & Tescher for the ’705 Patent

Asserted U.S. Patent No. 5,995,705 Gremillet & Tescher


705-1. An audio/video transceiver apparatus comprising: Gremillet discloses a music on demand system for “the
teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .
[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-
68; 2:3-8; 3:5-10]

This makes it possible to transmit “music comparessed [sic] in a


factor of 200,” meaning that “a musical work lasting one hour
can be transmitted in 18 seconds.” [2:8-12]

Tescher discloses a video compression/decompression system


that receives video input, achieves “signal compression of a
magnitude substantially greater than that available with known
systems,” and transmits that compressed data “for subsequent
utilization, e.g.[,] transmission from a transmitting station to a
receiving station, recording on video tape or other magnetic
media, etc.” [2:29-39; 2:43-45]

“This invention relates to information signal processing in


general, and in particular to the field of processing time
sequential information signals (such as video signals) for the
purpose of compressing the amount of information to be
transferred from an encoding site to a decoding site.” [1:8-13;
see also Abstract; 2:25-26]
input means for receiving audio/video source information, said In the Gremillet patent that the distribution center receives the
audio/video source information comprising a multiplicity of audio works for distribution. “[T]he distribution center 10
video frames collectively representing at least one full motion comprises a bank 11 of musical recordings recorded at a faster
video program; speed than normal.” [3:37-40] These works may be in analog
form and then converted by the transceiver. [5:7-9]

GREMILLET ‘568 & TESCHER ‘012 - 44 -


This sound information is “obtained by writing [it] into a
memory and then reading from the memory at the accelerated
speed.” [3:42-44]

The Tescher patent describes the compression, encoding, and


buffering of time domain information signals “for subsequent
utilization, e.g.[,] transmission from a transmitting station to a
receiving station.” [2:43-44]. As illustrated in Fig. 1, the
system receives video source information through an analog
processor: “analog video signals are coupled to the input of an
analog processor unit 11 . . . and converted to multi-bit digital
samples.” [5:32-37]
compression means, coupled to said input means, for Gremillet refers to the music it transmits as “compressed” but
compressing said audio/video source information into a digital does not expressly describe a reduction in the number of bits
time compressed representation thereof, wherein said digital used to represent the music: “the compression of the sound
time compressed representation of said audio/video source information can be obtained by writing into a memory and then
information is capable of being transmitted in a burst reading from the memory at the accelerated speed.” [3:42-45]
transmission time period that is substantially shorter than a time
period associated with real time viewing by a receiver of said Gremillet describes the “information flow rate” of the musical
audio/video source information; works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

It would also have been obvious to combine Gremillet with any


one of several known compression technologies, including those
disclosed in the U.S. Patent No. 4,541,012 (“the Tescher
Patent”), which discloses a lower bitrate for compressed video
than the rate disclosed for faster-than-real-time transmission of
audio in Gremillet.

GREMILLET ‘568 & TESCHER ‘012 - 45 -


The Tescher patent illustrates in Fig. 1 “a block diagram
illustrating an encoder incorporating the invention.” [5:7-8].
This encoder uses both intraframe and interframe compression.

Tescher uses an interframe compression technique of


“comparing corresponding blocks of time domain information
signals from successive fields.” [1:25-45]

The Tescher patent also describes using a type of intraframe


compression known as “transform domain encoding,” in which
“each field of information signals is divided into a number of
rectangular or square arrays of individual picture elements,”
rather than storing individual pixels. [1:59-66]

In addition, the Tescher patent employs a Huffman coding


technique, which was a well-known method for data
compression. [6:67-7:63]

These various compression techniques yield a compressed full-


motion video bit rate of “2.39 X 105 bits per second [or more
simply, 0.239 Mbits per second] which is 0.25 percent of the
standard uncompressed digital bit rate.” [11:61-12:1]

“The equivalent digital samples produced in analog processor


unit 11 are coupled to the input of an input digital processor 12
in which incoming field samples are merged with the
corresponding samples from the previous field.” [5:39-44]
storage means, coupled to said compression means, for storing The Gremillet patent discloses “recording support [which] can
said digital time compressed representation of said audio/video be a video disk or a video recorder.” [3:40-42]
source information; and
This “information recording bank” can be formed from the audio
source information “by writing into a memory and then reading

GREMILLET ‘568 & TESCHER ‘012 - 46 -


from the memory at an accelerated speed.” [3:42-44]

The Tescher patent discloses the compression of an input video


stream “for subsequent utilization, e.g.[,] . . . recording on video
tape or other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a
random access storage means such as a hard disk for the purpose
of storing the compressed video.
transmission means, coupled to said storage means, for Gremillet explains that “[t]he information flow rate linked with
transmitting said digital time compressed representation of said classical music is approximately 0.5 Mbits/s. However, the
audio/video source information away from said audio/video information flow rate of picture transmission channel used in
transceiver apparatus in said burst transmission time period. television (either broadcast, or by optical fibres or cable) is well
above this value.” [2:1-8] This makes it possible to transmit
“music comparessed [sic] in a factor of 200,” meaning that “a
musical work lasting one hour can be transmitted in 18 seconds.”
[2:8-12]

Gremillet describes a “video recorder” which is “housed with the


requesting subscriber” and records the transmitted information:
“the writing phase continues until the work has been completely
recorded. However, as stated hereinbefore, this phase is of a
short duration, in view of the high compression level of the
recorder information (greater than 100).” [4:16-40; see also
Claim 1]

Gremillet describes the “information flow rate” of the musical


works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

GREMILLET ‘568 & TESCHER ‘012 - 47 -


Gremillet describes a “broadcasting means consisting of a
transmitter 31, a transmitting antenna 32, a receiving antenna 33,
or a cable or optical fibres 34,’ connecting the distribution center
with the subscriber equipment. [4:1-7]

Tescher describes the compression, encoding, and buffering of


time domain information signals “for subsequent utilization,
e.g.[,] transmission from a transmitting station to a receiving
station.” [2:43-44]. The described transfer from transmitting
to receiving station, “from an encoding site to a decoding site,”
discloses transmission of a compressed video stream to an
external device. [1:8-13]

705-2. The audio/video transceiver apparatus of claim 1,


further comprising editing means, coupled to said storage means,
for editing the digital time compressed representation of said
audio/video source information stored in said storage means and
for storing the edited digital time compressed representation of
said audio/video source information in said storage means.

705-3. The audio/video transceiver apparatus of claim 2,


wherein said transmission means is configured to receive the
edited digital time compressed representation of said audio/video
source information and to transmit the edited digital time
compressed representation of said audio/video source
information away from said audio/video transceiver apparatus in
said burst transmission time period.

705-12. A method for handling audio/video source Gremillet discloses a music on demand system for “the
information, the method comprising the steps of: teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .
[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-

GREMILLET ‘568 & TESCHER ‘012 - 48 -


68; 2:3-8; 3:5-10]

This makes it possible to transmit “music comparessed [sic] in a


factor of 200,” meaning that “a musical work lasting one hour
can be transmitted in 18 seconds.” [2:8-12]
receiving audio/video source information, said audio/video In the Gremillet patent that the distribution center receives the
source information comprising a multiplicity of video frames audio works for distribution. “[T]he distribution center 10
collectively constituting at least one full motion video program; comprises a bank 11 of musical recordings recorded at a faster
speed than normal.” [3:37-40] These works may be in analog
form and then converted by the transceiver. [5:7-9]

This sound information is “obtained by writing [it] into a


memory and then reading from the memory at the accelerated
speed.” [3:42-44]

The Tescher patent describes the compression, encoding, and


buffering of time domain information signals “for subsequent
utilization, e.g.[,] transmission from a transmitting station to a
receiving station.” [2:43-44]. As illustrated in Fig. 1, the
system receives video source information through an analog
processor: “analog video signals are coupled to the input of an
analog processor unit 11 . . . and converted to multi-bit digital
samples.” [5:32-37]
compressing the received audio/video source information into a Gremillet refers to the music it transmits as “compressed” but
digital time compressed representation thereof, the digital time does not expressly describe a reduction in the number of bits
compressed representation of said audio/video source used to represent the music: “the compression of the sound
information having an associated burst transmission time period information can be obtained by writing into a memory and then
that is substantially shorter than a time period associated with reading from the memory at the accelerated speed.” [3:42-45]
real time viewing by a receiver of said audio/video source
information; Gremillet describes the “information flow rate” of the musical
works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which

GREMILLET ‘568 & TESCHER ‘012 - 49 -


suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

It would also have been obvious to combine Gremillet with any


one of several known compression technologies, including those
disclosed in the U.S. Patent No. 4,541,012 (“the Tescher
Patent”), which discloses a lower bitrate for compressed video
than the rate disclosed for faster-than-real-time transmission of
audio in Gremillet.

The Tescher patent illustrates in Fig. 1 “a block diagram


illustrating an encoder incorporating the invention.” [5:7-8].
This encoder uses both intraframe and interframe compression.

Tescher uses an interframe compression technique of


“comparing corresponding blocks of time domain information
signals from successive fields.” [1:25-45]

The Tescher patent also describes using a type of intraframe


compression known as “transform domain encoding,” in which
“each field of information signals is divided into a number of
rectangular or square arrays of individual picture elements,”
rather than storing individual pixels. [1:59-66]

In addition, the Tescher patent employs a Huffman coding


technique, which was a well-known method for data
compression. [6:67-7:63]

These various compression techniques yield a compressed full-


motion video bit rate of “2.39 X 105 bits per second [or more
simply, 0.239 Mbits per second] which is 0.25 percent of the
standard uncompressed digital bit rate.” [11:61-12:1]

GREMILLET ‘568 & TESCHER ‘012 - 50 -


“The equivalent digital samples produced in analog processor
unit 11 are coupled to the input of an input digital processor 12
in which incoming field samples are merged with the
corresponding samples from the previous field.” [5:39-44]
storing the digital time compressed representation of said The Gremillet patent discloses “recording support [which] can
audio/video source information; and be a video disk or a video recorder.” [3:40-42]

This “information recording bank” can be formed from the audio


source information “by writing into a memory and then reading
from the memory at an accelerated speed.” [3:42-44]

The Tescher patent discloses the compression of an input video


stream “for subsequent utilization, e.g.[,] . . . recording on video
tape or other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a
random access storage means such as a hard disk for the purpose
of storing the compressed video.
transmitting, in said burst transmission time period, the stored Gremillet explains that “[t]he information flow rate linked with
digital time compressed representation of said audio/video classical music is approximately 0.5 Mbits/s. However, the
source information to a selected destination. information flow rate of picture transmission channel used in
television (either broadcast, or by optical fibres or cable) is well
above this value.” [2:1-8] This makes it possible to transmit
“music comparessed [sic] in a factor of 200,” meaning that “a
musical work lasting one hour can be transmitted in 18 seconds.”
[2:8-12]

Gremillet describes a “video recorder” which is “housed with the


requesting subscriber” and records the transmitted information:
“the writing phase continues until the work has been completely
recorded. However, as stated hereinbefore, this phase is of a
short duration, in view of the high compression level of the
recorder information (greater than 100).” [4:16-40; see also

GREMILLET ‘568 & TESCHER ‘012 - 51 -


Claim 1]

Gremillet describes the “information flow rate” of the musical


works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

Gremillet describes a “broadcasting means consisting of a


transmitter 31, a transmitting antenna 32, a receiving antenna 33,
or a cable or optical fibres 34,’ connecting the distribution center
with the subscriber equipment. [4:1-7]

Tescher describes the compression, encoding, and buffering of


time domain information signals “for subsequent utilization,
e.g.[,] transmission from a transmitting station to a receiving
station.” [2:43-44]. The described transfer from transmitting
to receiving station, “from an encoding site to a decoding site,”
discloses transmission of a compressed video stream to an
external device. [1:8-13]

705-13. The method of claim 12, further comprising the steps


of:
editing the stored time compressed representation of said
audio/video source information; and
storing the edited time compressed representation of said
audio/video source information.

705-21. A method for handling audio/video source Gremillet discloses a music on demand system for “the
information, the method comprising the steps of: teledistribution of recorded information” that “offers[s], to
requesting users, any piece of music of their choice . . .

GREMILLET ‘568 & TESCHER ‘012 - 52 -


[transmitted] in a few seconds” from a distribution center using
the “transmission channels used in television.” [1:47-50; 1:64-
68; 2:3-8; 3:5-10]

“in a more detailed manner, the distribution centre 10 comprises


a bank 11 of musical recordings recorded at a faster speed than
normal (100-200 times faster.” [3:38-40]

This makes it possible to transmit “music comparessed [sic] in a


factor of 200,” meaning that “a musical work lasting one hour
can be transmitted in 18 seconds.” [2:8-12]
[a] receiving audio/video source information as a digital time It is inherent in the Gremillet patent that the distribution center
compressed representation thereof, said audio/video source receives the audio works for distribution. “[T]he distribution
information comprising a multiplicity of video frames center 10 comprises a bank 11 of musical recordings recorded at
collectively constituting at least one full motion video program a faster speed than normal.” [3:37-40]
selected from a video library storing a plurality of video
programs in a digital time compressed representation thereof for This sound information is “obtained by writing [it] into a
selective retrieval; memory and then reading from the memory at the accelerated
speed.” [3:42-44]

It would have been obvious to combine the efficient video


compression techniques disclosed in U.S. Patent Number
4,541,012 (“the Tescher patent”) with the system for
compression, storage, and faster-than-real-time transmission of
media files disclosed in the Gremilet patent. The compression
techniques disclosed in the Tescher patent produce video files
that have one-half of the bitrate of the audio files already sent
faster-than-real-time as described in the Gremillet patent.
Specifically, the Gremillet patent discloses the storage and
faster-than-real-time transmission of compressed sound
recordings that have a bitrate of 0.5 Mbits per second. [2:3-4]
But using the compression techniques described in Tescher,
video programs can be compressed down to a bitrate of 0.239

GREMILLET ‘568 & TESCHER ‘012 - 53 -


Mbits per second. [Tescher Patent at 11:52-12:1] It would
have been obvious to combine the media compression, storage,
and transmission system disclosed in the Gremillet patent with
the video compression described in the Tescher patent to allow
the storage and distribution of video, because the signal bitrate in
Tescher is lower than the signal bitrate disclosed in Gremillet.

As illustrated in Fig. 1 of Tescher, the system receives video


source information through an analog processor: “analog video
signals are coupled to the input of an analog processor unit
11 . . .” [5:32-34]
[b] said at least one video program being received by a receiver It is inherent in the Gremillet patent that the distribution center
in a burst transmission time period that is substantially shorter receives the audio works for distribution. “[T]he distribution
than a time period associated with real-time viewing by a center 10 comprises a bank 11 of musical recordings recorded at
receiver of said at least one video program; a faster speed than normal.” [3:37-40]

This sound information is “obtained by writing [it] into a


memory and then reading from the memory at the accelerated
speed.” [3:42-44]

It would have been obvious to combine the efficient video


compression techniques disclosed in U.S. Patent Number
4,541,012 (“the Tescher patent”) with the system for
compression, storage, and faster-than-real-time transmission of
media files disclosed in the Gremilet patent. The compression
techniques disclosed in the Tescher patent produce video files
that have one-half of the bitrate of the audio files already sent
faster-than-real-time as described in the Gremillet patent.
Specifically, the Gremillet patent discloses the storage and
faster-than-real-time transmission of compressed sound
recordings that have a bitrate of 0.5 Mbits per second. [2:3-4]
But using the compression techniques described in Tescher,
video programs can be compressed down to a bitrate of 0.239

GREMILLET ‘568 & TESCHER ‘012 - 54 -


Mbits per second. [Tescher Patent at 11:52-12:1] It would
have been obvious to combine the media compression, storage,
and transmission system disclosed in the Gremillet patent with
the video compression described in the Tescher patent to allow
the storage and distribution of video, because the signal bitrate in
Tescher is lower than the signal bitrate disclosed in Gremillet.

As illustrated in Fig. 1, the system receives video source


information through an analog processor: “analog video
signals are coupled to the input of an analog processor unit
11 . . .” [5:32-34]
[c] storing the digital time compressed representation of said The Gremillet patent discloses “recording support [which] can
audio/video source information; and be a video disk or a video recorder.” [3:40-42]

This “information recording bank” can be formed from the audio


source information “by writing into a memory and then reading
from the memory at an accelerated speed.” [3:42-44]

It would have been obvious to combine the Gremillet patent with


references disclosing different storage mediums. For example,
at Gremillet describes the video recorder at the user station
recording transmitted works using a magnetoscope. [4:23-
25] It would have been obvious to store the audio works on
hard disk. [See, e.g., “Peripheral Storage: Who’s Got What”
at APBU 714-725]

Tescher discloses the compression of an input video stream “for


subsequent utilization, e.g.[,] . . . recording on video tape or
other magnetic media, etc.” [2:43-45] Tescher thus
anticipates coupling the output of the compression means to a
random access storage means such as a hard disk for the purpose
of storing the compressed video.
[d] transmitting, in said burst transmission time period, the Gremillet explains that “[t]he information flow rate linked with

GREMILLET ‘568 & TESCHER ‘012 - 55 -


stored digital time compressed representation of said audio/video classical music is approximately 0.5 Mbits/s. However, the
source information to a selected destination. information flow rate of picture transmission channel used in
television (either broadcast, or by optical fibres or cable) is well
above this value.” [2:1-8] This makes it possible to transmit
“music comparessed [sic] in a factor of 200,” meaning that “a
musical work lasting one hour can be transmitted in 18 seconds.”
[2:8-12]

Gremillet describes a “video recorder” which is “housed with the


requesting subscriber” and records the transmitted information:
“the writing phase continues until the work has been completely
recorded. However, as stated hereinbefore, this phase is of a
short duration, in view of the high compression level of the
recorder information (greater than 100).” [4:16-40; see also
Claim 1]

Gremillet describes the “information flow rate” of the musical


works it transmits as “approximately 0.5 Mbit/s.” This is less
than the data rate of an uncompressed wideband audio signal
(e.g. CD audio) which is approximately 0.7 Mbit/s, which
suggests that the audio information Gremillet transmits has also
been compressed in a manner that reduces the number of bits
used to represent the music.

Gremillet describes a “broadcasting means consisting of a


transmitter 31, a transmitting antenna 32, a receiving antenna 33,
or a cable or optical fibres 34,’ connecting the distribution center
with the subscriber equipment. [4:1-7]

This “recording can be kept on the video recorder for the


purpose of listening to it later.” [4:36-39] It would have been
obvious to copy the compressed musical works onto other tapes
in order to backup the information. See, e.g., U.S. Patent No.

GREMILLET ‘568 & TESCHER ‘012 - 56 -


4,768,110. Because these works are compressed, such copying
would be at a faster-than-real-time rate.

Tescher describes the compression, encoding, and buffering of


time domain information signals “for subsequent utilization,
e.g.[,] transmission from a transmitting station to a receiving
station.” [2:43-44]. The described transfer from transmitting
to receiving station, “from an encoding site to a decoding site,”
discloses transmission of a compressed video stream to an
external device. [1:8-13]

GREMILLET ‘568 & TESCHER ‘012 - 57 -

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