https://www.docketalarm.

com/cases/International_Trade_Commission/337-837/Certain_Audiovisual_Components_and_Products_Con

EXHIBIT 51

Infringement Chart
Patent No. 5,870,087 (087 Patent)

Claim Language

Accused Instrumentality

1. An MPEG decoder system which includes a single memory for use by transport, decode and system controller functions, comprising:

The Accused Single Memory Products include an MPEG decoder system which includes a single memory for use by transport, decode and system controller functions. The Accused Single Memory Products include, without limitation, digital television, DVD player/recorder, Blu-ray disc player/recorder and other substantially similar audiovisual products in relevant part which contain integrated circuits (ICs) that utilize a single memory for the designated functions (single memory structure), and which are manufactured,

imported and/or distributed by or on behalf of Funais1 under brand names such as Philips, Magnavox, Funai,
Sylvania, Emerson, Symphonic, Sharp, and Denon. Specific non-limiting examples of ICs contained in the Accused Single Memory Products include MT5382, MT5391, MT5392, MT8551, MT8560, all of which have substantially or exactly the same structure in relevant part as those in MediaTek MT53xx family and MT5 8xx family.

MediaTek Chips As an example, the Philips 42PFL6704D Television product contains a MediaTek chip in the MT53xx family, MT5392. Ex. 50 [Philips 42PFL6704D/F 7 SVM] at 9-2. Chips in the MT5 3xx, MT5 8xx and similar families in relevant part include MPEG video and audio decoders. See, e. g., Ex. 89 [Philips 42PFL6704D/F7 User Manual] at 20 (supported video codecs include H.246, MPEG1, MPEG2, and supported audio codecs include MPEG1 L1/L2 and L3), see also, e. g., Ex. 142 [Vizio E420VO SVM] at 7-2 (listing MPEG2 video decoder and AC3/MPEG2 audio decoder as key features of MT5387 chipset) (available from: http://www.scribdcom/doc/52381651/E420VO-ServiceManual (last visited 03/09/2012).

MediaTek chips in the MT53xx, MT5 8xx and similar families in relevant part include a single memory for use b trans ort, decode and s stem controller functions. A block diaram of MT5392 chi set is shown below.

1 Funai refers collectively to Funai Corporation, Inc., P&F USA, Inc. and Funai Electric Company, Ltd, and any and all parties acting for, with or otherwise on
behalf of Funai Corporation, P&F USA and Funai Electric Co. 1 Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

The chipset is shown as including, in addition to other components, a TS Demux (transport logic), a Video Decoder (MPEG decoder), and an ARM1 1 controller (system controller). The DRAM (single memory) is controlled by the DRAM controller and shared by the transport logic, MPEG decoder, and system controller Via the DRAM Bus. See, e. g., EX. 91 [Philips LC9.2L Service Manual] at 43:

See also, e. g., EX. 50 [Philips 42PFL6704D SVM] at 10-5, 10-14 (showing a single DRAM (7B02) coupled to the main processor (7701)):

Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

A: -E.-*i1"1";*;":.;i"a2i"i" in Z
"??a~s** ".3------------iii:

gm$-a:3;s5ige.&E%f*3?m9i$:Sa%1IE

Similar structures in relevant part are found in other MediaTek chips. See, e. g., Ex. 142 [Vizio E420VO SVM] at 7-2, 7-3, 7-4, 7-30 (MT5387), Ex. 90 Global and China Flat-Panel TV IC Industry Report, 20092010 (MT5387). To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrine of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantially or exactly the same result. a channel receiver for receiving and MPEG encoded Kilpatrick Townsend 640179971 The MPEG decoder system in the Accused Single Memory Products includes a channel receiver (such as a tuner receiver or o tical disc receiver) for receivin an MPEG encoded stream.

Claim Language

Accused Instrumentality

For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips DTV 42PFL6704D/F7, include a DTD receiver which receives MPEG encoded streams from a digital tuner (such as an ATSC tuner):

,3,

1"

V gg, 4~I I. " . V n.4(.:13$ W rCEE:p::a ,,,mWiiiiiiiiiiii,WWWWWWWWWMiiiiiiiiiiiimamiiiiiiiiiiiiiiinn(

V 0II

Curaigsms @II

AE?EZ1"i 11%

Ex. 91 [Philips LC9.2L Service Manual] at 43, see also, e. g., EX. 142 [Vizio E420VO SVM] at 7-4 (noting that the transport demultiplexer [s]upports ATSC, MPEG-2 transport stream input), EX. 97 [ATSC Part 4MPEG2 Video System Characteristics] at 8, Section 6 (Source Coding Specification) (The DTV video compression algorithm shall conform to the Main Profile syntax of ISO/IEC 13818-2) [i.e., MPEG-2] (available from htt ://www.atsc.or/cms/standards/a53/a 53Part42009. df), EX. 98

Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

[http://wwwhdtvprimercom/ISSUES/what_is_ATSC.html] at l (ATSC employs MPEG-2....).

To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrine of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result. transport logic coupled to the channel receiver which The MPEG decoder system in the Accused Single Memory Products includes transport logic (such as a transport demultiplexer or a stream controller) coupled to the channel receiver which demultiplexes one or

demultiplexes one or more multimedia data streams from

the encoded stream,

more multimedia data streams from the encoded stream.

For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips DTV 42PFL6704D/F7 include a TS Demux or transport demultiplexer that is coupled to the channel receiver and which demultiplexes one or more multimedia data streams from the encoded stream:

*gEs!@_; _

LI

E51;:Iw1 P]I

, 53-

urra;;.vz2s::<uaa=s1 mw -

%%%l

tum-av

*I '

QQFQ

Kilpatrick Townsend 640 17997.1

Claim Language

Accused Instrumentality

Ex. 91 [Philips LC9.2L Service Manual] at 43, see also, e.g., Ex. 142 [Vizio E420VO SVM] at 7-3 (showing a TS Demux coupled to an ATSC tuner that receives MPEG2 streams), 7-4 (general features of Transport Multiplexer); Ex. 99 [ITU-T H.222.0 (2006)] at x, Section Intro. 8.1 (Demultiplexing) (On decoding, demultiplexing is required to reconstitute elementary streams from the multiplexed Program Stream or Transport Stream.), id. at 121, Figure 2-11 (showing Transport Stream demultiplexing), id. at 123, Figure 2-12 (showing Program Stream demultiplexing). To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrine of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result. a system controller coupled to the transport logic which controls operations within the MPEG decoder system, The MPEG decoder system in the Accused Single Memory Products includes a system controller (such as a CPU) coupled to the transport logic which controls operations within the MPEG decoder system. For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips DTV 42PFL6704D/F7, include an ARM 11 system controller (e. g. , an ARM 926 E] processor) which controls operation within the MPEG decoder system:

Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

B EH2 GE3fli'."ZIEl% 3

Ex. 91 [Philips LC9.2L Service Manual] at 43, see also, e.g., Ex. 142 [Vizio E420VO SVM] at 7-3 (similar block diagram for MT5387 in relevant part and listing the ARM chip, such as ARM 926E] as the Host CPU), Ex. 143 [Vizio GV42L_HTDV SVM] at 7-31, 7-32 (listing ARM 926E] as the host CPU for MT5351). The system controller is coupled to the transport logic. Ex. 142 at 7-4 (noting that the transport demultiplexer [s]upports a micro-processor for stream process and MPEG start code detection). To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrine of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result. an MPEG decoder coupled to receive one or more multimedia data streams Kilpatrick Townsend 640 17997.1 The Accused Single Memory Products include an MPEG decoder (e. g. an MPEG video or audio decoder) coupled to receive one or more multimedia data streams output from the transport logic (such as the transport demultiplexer or the stream controller), wherein the MPEG decoder operates to perform MPEG decoding on

Claim Language

Accused Instrumentality

output from the transport logic, wherein the MPEG decoder

the multimedia data streams.

operates to perform MPEG

decoding on the multimedia data streams;

For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips
DTV 42PFL6704D/F7, include a Video Decoder that is coupled to receive one or more multimedia data streams output from the transport logic via, for example, the system bus. The video decoder operates to perform MPEG decoding on the multimedia data streams:

0NI C355
7

vriamaara

giiflgfyim Haws
pm, sag;

Tum:
an

:macsace=
.:sstmH

33:51:33 Wt

szfimri. 5 Ex. 91 [Philips LC9.2L Service Manual] at 43, see also, e.g., Ex. 89 [Philips 42PFL6704D/F7 User Manual] at 20 (supported video codecs include H.246, MPEG1, MPEG2, and supported audio codecs include MPEG1 L1/L2 and L3), Ex. 142 [Vizio E420VO SVM] at 7-3 (similar block diagram for MT5387 in relevant part), 74 (listing MPEG2 Decoder), Ex. 99 [ITU-T H.222.0 (2006)] at 13, Section 2.4.2.3 (Buffering) (Complete Transport Stream packets containing system information, for the program selected for decoding, enter the system transport buffer ...), id. at 52, Section 2.5.2.2 (Data from the Program Stream enters the system target decoder), id. at 121, Section 2.14.3.1 (The T-STD model includes a transport buffer TBn and a multiplex buffer MBn prior to buffer EBn for decoding of each ITU-T Rec. H.264 @I video elementary stream n), id. at 123, Section 2.14.3.2 (The P-STD model for the decodin of an ITU-T rec. H.264 I elementa stream Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

includes a multiplex buffer Bn and a decoder Dn followed by a buffer DPBn.). To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrine of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantially or exactly the same result. wherein the MPEG decoder is operable to access the memory during MPEG decoding operations; wherein the transport logic is operable to access the memory to store and retrieve data during demultiplexing operations; and wherein the system controller is operable to access the memory to retrieve code and data during system control functions. In the Accused Single Memory Products, the MPEG decoder is operable to access the memory during MPEG decoding operations, the transport logic is operable to access the memory to store and retrieve data during demultiplexing operations, and the system controller is operable to access the memory to retrieve code and data during system control functions. For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips DTV 42PFL6704D/F7, have a Video Decoder including the MPEG decoder, TS Demux (transport logic) and ARMl 1 (CPU or system controller) that are operable to access the single memory through the DRAM Bus.

Kilpatrick Townsend 640 17997.1

Claim Language

Accused Instrumentality

EX. 91 [Philips LC9.2L Service Manual] at 43, see also, e. g., EX. 142 [Vizio E420VO SVM] at 7-3 (similar block diagram for MT5387).

In both examples, the MPEG decoder accesses the memory during MPEG decoding operation; Transport logic, which typically requires buffering space on the memory (see e. g., EX. 99 [ITU-T H.222.0 (2006)] at 13, Section 2.4.2.3 (Buffering), at 53, Section 2.5.2.3 (Buffering)), accesses the memory to store and retrieve data during demultiplexing operations, the ARM CPU (such as ARM 926EJ or AM34-SMP) accesses the memory to retrieve code and data during system control functions. See, e. g., EX. 100 [ARM926EJ-S Technical Reference Manual] (available from http://infocenterarm.com/help/topic/com.arm.doc.ddi0198e/DDI0198E arm926eis r0p5 t1m.pdf (last visited (03/09/2012)) at 6-3, Section 6.2.1 (Memory Map) (The ARM926EJ-S processor is a cached processor with two AHB interfaces. It is a key system design issue that the D side must be able to access the same as the I side, with the same memo ma. This is reuired not onl to load code, but to enable access

Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

to PC-relative literal pools, and for SWI and emulated instruction handlers to work), To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrines of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantially or exactly the same result. 10. A method for performing video decoding in a MPEG decoder system As an example, Philips 42PFL6704D Television can decode MPEG-formatted video files. See, e. g., Ex. 89 [Philips 42PFL6704D/F 7 User Manual at 20 (supported video codecs include H.246, MPEG1, MPEG2). As another example Magnavox Blu-ray disc player MBP5220F can decode MPEG-2 and H.264 video files. See, e. g., Ex 93 [Magnavox MBP5220F SVM] at l-l l-3, l-l2-l2 (showing MPEG-2 and H.264 decoder): The operation of the Accused Single Memory Products (the Accused Single Memory Processes) involves methods for performing video decoding in an MPEG decoder system.

ll Kilpatrick Townsend 640 17997.1

Claim Language ll Imflflfi/Bl

Accused Instrumentality

~F-,Avme3umo _.g.12 wem.a.:9.:2: 5. V Pi?I 4 X-IJ.'1ASlw -4532 vrrzwzusn:

r E \r "H n n n n BI W3m=3 n n EE n n n n n n n n n . /E

To the extent that the Accused Single Memory Processes do not infringe literally, they infringe under the doctrines of equivalents because in the Accused Single Memory Processes and Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result. which includes a single memory for use by transport, decode and s stem controller In the Accused Single Memory Products, the MPEG decoder system includes a single memory for use by transport, decoder and system controller functions. Examples of ICs contained in the Accused Single Memory Products include, without limitation, MT5382, MT539l, MT5392, MT855 l, MT8560, MN2WSO06AAF, 12 Kilpatrick Townsend 640 17997.1

Claim Language

Accused Instrumentality

functions, the method comprising:

MN2WS0062AFF(B), MN2WS0062DFF, MN2WSOl50A3, MN2WS02l0A2, MN2WS0043DA, MN2WS0l2A, MN2WS0l2OA, MN2WS0l70, MN2DS00l9AA, MN2DS00l8VP, all of which have substantially the same structure as those in MediaTek MT53XX family and MT5 8);): family. As an example, the Philips 42PFL6704D Television product contains a MediaTek chip in the MT53XX family, MT5392. EX. 50 [Philips 42PFL6704D/F 7 SVM] at 9-2. MediaTek chips in the MT53XX, MT5 8):): and similar families in relevant part include a single memory for use by transport, decode and system controller functions. For example, a block diagram of MT5392 chipset is shown below. The chipset is shown as including, in addition to other components, a TS Demux (transport logic), a Video Decoder (MPEG decoder), and an ARMl 1 controller (system controller). The DRAM (single memory) is controlled by the DRAM controller and shared by the transport logic, MPEG decoder, and system controller via the DRAM Bus. See, e. g., EX. 91 [Philips LC9.2L Service Manual] at 43:

Ifarset

13 Kilpatrick Townsend 640 17997.1

Claim Language

Accused Instrumentality

See also, e. g., EX. 50 [Philips 42PFL6704D SVM] at 10-5, 10-14 (showing a single DRAM (7B02) coupled to the main processor (7701)):

Riiklvl "7E!s@2"

14 Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

Similar structures in relevant part are found in other MediaTek chips. See, e.g., Ex. 142 [Vizio E420VO SVM] at 7-2, 7-3, 7-4, 7-30 (MT5387), Ex. 90 Global and China Flat-Panel TV IC Industry Report, 20092010 (MT5373). To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrines of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result. receiving an MPEG encoded stream, The operation of the Accused Single Memory Products includes receiving an MPEG encoded stream. For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips DTV 42PFL6704D/F7, include a DTD receiver which receives MPEG encoded streams from a digital tuner (such as an ATSC tuner):

"cm!

063.39% C5-K}Fi3

Axum 35$? .I ErFm

sfirzstrg VS.
15 Kilpatrick Townsend 640 17997.1

Claim Language

Accused Instrumentality

Ex. 91 [Philips LC9.2L Service Manual] at 43, see also, e. g., Ex. 142 [Vizio E420VO SVM] at 7-4 (noting that the transport demultiplexer [s]upports ATSC, MPEG-2 transport stream input), Ex. 97 [ATSC Part 4MPEG2 Video System Characteristics] at 8, Section 6 (Source Coding Specification) (The DTV video compression algorithm shall conform to the Main Profile syntax of ISO/IEC 13818-2) [i.e. MPEG-2] To the extent that the Accused Single Memory Processes do not infringe literally, they infringe under the doctrines of equivalents because, in the Accused Single Memory Processes and Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantially or exactly the same result.

demultiplexing one or more

multimedia data streams from the encoded stream, wherein said demultiplexing one or more multimedia data streams from the encoded stream operates using a first unified memory,

The MPEG decoder system in the Accused Single Memory Products includes transport logic (such as a
transport demultiplexer or a stream controller) coupled to the channel receiver which demultiplexes one or more multimedia data streams from the encoded stream using a first unified memory. For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips DTV 42PFL6704D/F7 include a TS Demux or transport demultiplexer that is coupled to the channel receiver and which demultiplexes one or more multimedia data streams from the encoded stream:

16 Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality +I ~21:

p/I
`I mg;-rm.

5, `I
gnpm

Emaa 63

Ex. 91 [Philips LC9.2L Service Manual] at 43, see also, e.g., Ex. 142 [Vizio E420VO SVM] at 7-3 (showing a TS Demux coupled to an ATSC tuner that receives MPEG2 streams), 7-4 (general features of Transport Multiplexer); Ex. 99 [ITU-T H.222.0 (2006)] at x, Section Intro. 8.] (Demultiplexing) (On decoding, demultiplexing is required to reconstitute elementary streams from the multiplexed Program Stream or Transport Stream.), id. at 121, Figure 2-11 (showing Transport Stream demultiplexing), id. at 123, Figure 2-12 (showing Program Stream demultiplexing). To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrine of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result. performing MPEG decoding on the multimedia data streams, wherein said The Accused Single Memory Products include an MPEG decoder (e. g. an MPEG video or audio decoder) which decodes the multimedia data streams using the first unified memory.

17 Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

performing MPEG decoding operates using said first unified memory;

For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips DTV 42PFL6704D/F7, include a Video Decoder that operates to perform MPEG decoding on the multimedia data streams using the first unified memory:

EX. 91 [Philips LC9.2L Service Manual] at 43, see also, e. g., EX. 89 [Philips 42PFL6704D/F7 User Manual] at 20 (supported video codecs include H.246, MPEG1, MPEG2, and supported audio codecs include MPEG1 L1/L2 and L3), EX. 142 [Vizio E420VO SVM] at 7-3 (similar block diagram for MT5387 in relevant part), 74 (listing MPEG2 Decoder), EX. 99 [ITU-T H.222.0 (2006)] at 13, Section 2.4.2.3 (Buffering) (Complete Transport Stream packets containing system information, for the program selected for decoding, enter the system transport buffer ...), id. at 52, Section 2.5.2.2 (Data from the Program Stream enters the system target decoder), id. at 121, Section 2.14.3.1 (The T-STD model includes a transport buffer TBn and a multiplex buffer MBn prior to buffer EBn for decoding of each ITU-T Rec. H.264 )I video elementary stream n), id. at 123, Section 2.14.3.2 (The P-STD model for the decoding of an ITU-T rec. H.264 P1I elementary stream includes a multi lex buffer Bn and a decoder Dn followed b a buffer DPBn.). Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrines of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result.

and a system controller

controlling operations within the MPEG decoder system, wherein said controlling

The Accused Single Memory Products include a system controller (such as a CPU) that control the operations
within the MPEG decoder system and accesses code and data from said first unified memory. For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips

operations accesses code and

data from said first unified memory

DTV 42PFL6704D/F7, include an ARM ll system controller (e.g., an ARM 926 E] processor) which
controls operation within the MPEG decoder system:

Wnea

V A . =2 fim'rip1:ssr1:'emI;

pp

'm

QVas
(C tmggaa:

rig?
Wm

:,_,jj;:Mj
gag;

3??-',3\_=.'i 3E_:'_z

SPEW 9%

Ex. 91 [Philips LC9.2L Service Manual] at 43, see also, e.g., Ex. 142 [Vizio E420VO SVM] at 7-3 (similar block diagram for MT5387 in relevant part and listing the ARM chip, such as ARM 926EJ as the Host Kilpatrick Townsend 640 17997.1

Claim Language

Accused Instrumentality

CPU), Ex. 143 [Vizio GV42L_HTDV SVM] at 7-31, 7-32 (listing ARM 926E] as the host CPU for MT5351). The system controller is coupled to the transport logic. Ex. 142 at 7-4 (noting that the transport demultiplexer [s]upports a micro-processor for stream process and MPEG start code detection). To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrines of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result. wherein said demultiplexing one or more multimedia data streams, said performing MPEG decoding, and said controlling operations each use said first unified memory. For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips DTV 42PFL6704D/F7, have a Video Decoder including the MPEG decoder, TS Demux (transport logic) and ARMl 1 (CPU or system controller) that are operable to access the single memory through the DRAM Bus. In the Accused Single Memory Products, the multiplexing of the data streams, the MPEG decoding and the controlling of operations each use the first unified memory.

20 Kilpatrick Townsend 640 17997.1

Claim Language

Accused Instrumentality

SF3mF'_ I338

EX. 91 [Philips LC9.2L Service Manual] at 43, see also, e. g., EX. 142 [Vizio E420VO SVM] at 7-3 (similar block diagram for MT5387).

In both examples, the MPEG decoder accesses the memory during MPEG decoding operation; Transport logic, which typically requires buffering space on the memory (see e. g., EX. 99 [ITU-T H.222.0 (2006)] at 13, Section 2.4.2.3 (Buffering), at 53, Section 2.5.2.3 (Buffering)), accesses the memory to store and retrieve data during demultiplexing operations. The ARM CPU (such as ARM 926EJ or AM34-SMP) accesses the memory to retrieve code and data during system control functions. See, e. g., EX. 100 [ARM926EJ-S Technical Reference Manual] (available from ht ://infocenter.armcom/hel /to ic/co1n.arm.doc.ddi0l98e/DDI0198E arm926e's r0 f trm. df (last visited (03/09/2012)) at 6-3, Section 6.2.1 (Memory Map) (The ARM926EJ-S processor is a cached processor with two AHB interfaces. It is a key system design issue that the D side must be able to access the same memory as the I side, with the same memory map. This is required not only to load code, but to enable access to PC-relative literal ools, and for SWI and emulated instruction handlers to work),

Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrines of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result. 16. A video decoder system which includes a single memory for use by transport, decode and system controller functions, comprising: The Accused Single Memory Products include a decoder system which includes a single memory for use by transport, decode and system controller functions. The Accused Single Memory Products include, without limitation, digital television, DVD player/recorder, Blu-ray disc player/recorder and other substantially similar audiovisual products in relevant part which contain integrated circuits (ICs) that utilize a single memory for the designated functions (single memory structure), and which are manufactured, imported and/or

distributed by or on behalf of Funais2 under brand names such as Philips, Magnavox, Funai, Sylvania,
Emerson, Symphonic, Sharp, and Denon. Specific non-limiting examples of ICs contained in the Accused Single Memory Products include MT5382, MT5391, MT5392, MT8551, MT8560, all of which have substantially or exactly the same structure in relevant part as those in MediaTek MT53xx family and MT5 8xx family. MediaTek Chips As an example, the Philips 42PFL6704D Television product contains a MediaTek chip in the MT53xx family, MT5392. Ex. 50 [Philips 42PFL6704D/F 7 SVM] at 9-2. Chips in the MT5 3xx, MT5 8xx and similar families in relevant part include MPEG video and audio decoders. See, e.g., Ex. 89 [Philips 42PFL6704D/F7 User Manual] at 20 (supported video codecs include H.246, MPEG1, MPEG2, and supported audio codecs include MPEG1 L1/L2 and L3), see also, e.g., Ex. 142 [Vizio E420VO SVM] at 7-2 (listing MPEG2 video decoder and AC3/MPEG2 audio decoder as key features of

MT5387 chipset) (available from h

03/09/2012).

:/XWWW.scribd.com/doc;52381651/E420VOServiceManual (last visited

MediaTek chips in the MT53xx, MT5 8xx and similar families in relevant part include a single memory for use b trans ort, decode and s stem controller functions. A block diaram of MT5392 chi set is shown below.

2 Funai refers collectively to Funai Corporation, Inc., P&F USA, Inc. and Funai Electric Company, Ltd, and any and all parties acting for, with or otherwise on
behalf of Funai Corporation, P&F USA and Funai Electric Co. 22 Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

The chipset is shown as including, in addition to other components, a TS Demux (transport logic), a Video Decoder (MPEG decoder), and an ARM1 1 controller (system controller). The DRAM (single memory) is controlled by the DRAM controller and shared by the transport logic, MPEG decoder, and system controller Via the DRAM Bus. See, e. g., EX. 91 [Philips LC9.2L Service Manual] at 43:

See also, e. g., EX. 50 [Philips 42PFL6704D SVM] at 10-5, 10-14 (showing a single DRAM (7B02) coupled to the main processor (7701)):

23 Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

A: -E,-*i1"1";*;":.;i"a2i7 in Z
"??a~s** ".3------------iii:

gm$-a:3;s5ige.&E,%f*3?mpi$:a%I1E

Similar structures in relevant part are found in other MediaTek chips. See, e. g., Ex. 142 [Vizio E420VO SVM] at 7-2, 7-3, 7-4, 7-30 (MT5387), Ex. 90 Global and China Flat-Panel TV IC Industry Report, 20092010 (MT5387). To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrines of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantially or exactly the same result. a channel receiver for receivin an encoded video Kilpatrick Townsend 640 17997.1 The MPEG decoder system in the Accused Single Memory Products includes a channel receiver (such as a tuner receiver or o tical disc receiver) for receivin an MPEG encoded stream.

Claim Language

Accused Instrumentality

For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips DTV 42PFL6704D/F7, include a DTD receiver which receives MPEG encoded streams from a digital tuner (such as an ATSC tuner):

,3,

1"

V gg, @ I. " . V n.4(.:13$ W rCEE:p::a ,,,mWiiiiiiiiiiii,WWWWWWWWWMiiiiiiiiiiiimamiiiiiiiiiiiiiiinn(

Curaigsms

AE?EZ1"i 11%

Ex. 91 [Philips LC9.2L Service Manual] at 43, see also, e. g., EX. 142 [Vizio E420VO SVM] at 7-4 (noting that the transport demultiplexer [s]upports ATSC, MPEG-2 transport stream input), EX. 97 [ATSC Part 4MPEG2 Video System Characteristics] at 8, Section 6 (Source Coding Specification) (The DTV video compression algorithm shall conform to the Main Profile syntax of ISO/IEC 13818-2) [i.e. MPEG-2] (available from htt ://www.atsc.or/cms/standards/a53/a 53Part42009. df), EX. 98 25 Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

[http://wwwhdtvprimercom/ISSUES/what_is_ATSC.html] at l (ATSC employs MPEG-2....).

To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrines of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result. transport logic coupled to the channel receiver which The MPEG decoder system in the Accused Single Memory Products includes transport logic (such as a transport demultiplexer or a stream controller) coupled to the channel receiver which demultiplexes one or

demultiplexes one or more multimedia data streams from

the encoded stream,

more multimedia data streams from the encoded stream.

For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips DTV 42PFL6704D/F7 include a TS Demux or transport demultiplexer that is coupled to the channel receiver and which demultiplexes one or more multimedia data streams from the encoded stream:

*gEs!@_; _

E51;:Iw1 @

, 53-

urra;;.vz2s::<uaa=s1 mw -

%%%l

tum-av

p! '

QQFQ

26 Kilpatrick Townsend 640 17997.1

Claim Language

Accused Instrumentality

Ex. 91 [Philips LC9.2L Service Manual] at 43, see also, e.g., Ex. 142 [Vizio E420VO SVM] at 7-3 (showing a TS Demux coupled to an ATSC tuner that receives MPEG2 streams), 7-4 (general features of Transport Multiplexer); Ex. 99 [ITU-T H.222.0 (2006)] at x, Section Intro. 8.1 (Demultiplexing) (On decoding, demultiplexing is required to reconstitute elementary streams from the multiplexed Program Stream or Transport Stream.), id. at 121, Figure 2-11 (showing Transport Stream demultiplexing), id. at 123, Figure 2-12 (showing Program Stream demultiplexing). To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrines of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result. a system controller coupled to the transport logic which controls operations within the video decoder system, For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips DTV 42PFL6704D/F7, include an ARM 11 system controller (e.g., an ARM 926 E] processor) which controls operation within the MPEG decoder system: The MPEG decoder system in the Accused Single Memory Products includes a system controller (such as a CPU) coupled to the transport logic which controls operations within the MPEG decoder system.

27 Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

B EH2 GE3fli'."ZIEl% 3

psKI I[I

Ex. 91 [Philips LC9.2L Service Manual] at 43, see also, e.g., Ex. 142 [Vizio E420VO SVM] at 7-3 (similar block diagram for MT5387 in relevant part and listing the ARM chip, such as ARM 926E] as the Host CPU), Ex. 143 [Vizio GV42L_HTDV SVM] at 7-31, 7-32 (listing ARM 926E] as the host CPU for MT5351). The system controller is coupled to the transport logic. See Ex. 142 (noting that the transport demultiplexer [s]upports a micro-processor for stream process and MPEG start code detection). To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrines of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result. a video decoder coupled to receive one or more multimedia data streams Kilpatrick Townsend 640 17997.1 The Accused Single Memory Products include an MPEG decoder (e. g. an MPEG video or audio decoder) coupled to receive one or more multimedia data streams output from the transport logic (such as the transport demultiplexer or the stream controller), wherein the MPEG decoder operates to perform MPEG decoding on

Claim Language

Accused Instrumentality

output from the transport logic, wherein the video decoder

the multimedia data streams.

operates to perform video

decoding on the multimedia data streams;

For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips
DTV 42PFL6704D/F7, include a Video Decoder that is coupled to receive one or more multimedia data streams output from the transport logic via, for example, the system bus. The video decoder operates to perform MPEG decoding on the multimedia data streams:

II C355
7

vriamaara

giiflgfyim Haws
pm, sag;

Tum:
an

:macsace=
.:sstmH

33:51:33 Wt

EX. 91 [Philips LC9.2L Service Manual] at 43, see also, e. g., EX. 89 [Philips 42PFL6704D/F7 User Manual] at 20 (supported video codecs include H.246, MPEG1, MPEG2, and supported audio codecs include MPEG1 L1/L2 and L3), EX. 142 [Vizio E420VO SVM] at 7-3 (similar block diagram for MT5387 in relevant part), 74 (listing MPEG2 Decoder), EX. 99 [ITU-T H.222.0 (2006)] at 13, Section 2.4.2.3 (Buffering) (Complete Transport Stream packets containing system information, for the program selected for decoding, enter the system transport buffer `III ), id. at 52, Section 2.5.2.2 (Data from the Program Stream enters the system target decoder), id. at 121, Section 2.14.3.1 (The T-STD model includes a transort buffer TBn and a multilex Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality buffer MBn prior to buffer EBn for decoding of each ITU-T Rec. H.264 0I video elementary stream n), id. at 123, Section 2.14.3.2 (The P-STD model for the decoding of an ITU-T rec. H.264 pjI elementary stream includes a multiplex buffer Bn and a decoder Dn followed by a buffer DPBn.). To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrines of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result.

and a memory coupled to the video decoder, wherein the memory is used by the video decoder during video decoding operations, wherein the memory stores code and data useable by the system controller which enables the system controller to perform control functions within the video decoder system, wherein the memory is used by the transport logic for demultiplexing operations; wherein the video decoder is operable to access the memory during video decoding operations, wherein the transport logic is operable to access the memory to store and retrieve data during demultiplexing operations, and wherein the system controller is operable to access the to retrieve code and

In the Accused Single Memory Products, the MPEG decoder is operable to access the memory during MPEG decoding operations, the transport logic is operable to access the memory to store and retrieve data during demultiplexing operations, and the system controller is operable to access the memory to retrieve code and data during system control functions. For example, chips in the MediaTek family and similar families in relevant part, such as MT5392 in Philips DTV 42PFL6704D/F7, have a Video Decoder including the MPEG decoder, TS Demux (transport logic) and ARMl 1 (CPU or system controller) that are operable to access the single memory through the DRAM Bus.

30 Kilpatrick Townsend 640 17997.1

Claim Language

Accused Instrumentality

data during system control functions.

SF3mF'_ I338

EX. 91 [Philips LC9.2L Service Manual] at 43, see also, e. g., EX. 142 [Vizio E420VO SVM] at 7-3 (similar block diagram for MT5387).

In both examples, the MPEG decoder accesses the memory during MPEG decoding operation; Transport logic, which typically requires buffering space on the memory (see e. g., EX. 99 [ITU-T H.222.0 (2006)] at 13, Section 2.4.2.3 (Buffering), at 53, Section 2.5.2.3 (Buffering)), accesses the memory to store and retrieve data during demultiplexing operations. The ARM CPU (such as ARM 926EJ or AM34-SMP) accesses the memory to retrieve code and data during system control functions. See, e. g., EX. 100 [ARM926EJ-S Technical Reference Manual] (available from ht ://infocenter.armcom/hel /to ic/co1n.arrn.doc.ddi0l98e/DDI0198E arm926e's r0 f trrn. df (last visited (03/09/2012)) at 6-3, Section 6.2.1 (Memory Map) (The ARM926EJ-S processor is a cached processor with two AHB interfaces. It is a key system design issue that the D side must be able to access the same memory as the I side, with the same memory map. This is required not only to load code, but to enable access to PC-relative literal ools, and for SWI and emulated instruction handlers to work),

Kilpatrick Townsend 640179971

Claim Language

Accused Instrumentality

To the extent that the Accused Single Memory Products do not infringe literally, they infringe under the doctrines of equivalents because, in the Accused Single Memory Products, the claimed and identified features perform substantially or exactly the same function, in substantially or exactly the same way, to achieve substantiall or exactl the same result.

32 Kilpatrick Townsend 640 17997.1