EXHIBIT 16CLAIM CHART SHOWING INFRINGEMENT OF THE 6,711,211 PATENT BY THEHTC ONE MOBILE PHONE
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Exhibit No. 16Claim Chart Showing Infringement of the 6,711,211 Patent by The HTC One MobilePhone
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Claims of the 211PatentHTC One Mobile Phone
26. A method for decoding encoded videoinformation, includingderiving predictionmotion coefficients for blocks within amacroblock of a videoframe being decodedfrom motion coefficientsof at least one prediction block that is a previouslydecoded macroblock or block within said videoframe, the methodcomprising:
The HTC One (hereafter referred to as the “device”) uses a method for decoding encodedvideo information, including deriving prediction motion coefficients for blocks within amacroblock of a video frame being decoded from motion coefficients of at least one prediction block that is a previously decoded macroblock or block within said video frame.The method is necessarily performed, for example, when an end-user of the device uses thedevice to view and play back VP8 encoded videos, as encouraged by HTC.
See, e.g.
,Exhibit 24 (HTC One User Guide) at pp. 46, 75, 83, 145-146. Moreover, the device runs theAndroid version 4.1.2 operating system.(Figure 1).All products running Android version 2.3 and above are capable of decoding encoded videoinformation by decoding encoded VP8 videos.
See
Exhibit 25(http://developer.android.com/about/versions/android-2.3-highlights.html) (“The platformnow offers built-in support for the VP8 open video compression format and the WebM opencontainer format”).Exhibit 50, titled “VP8 Data Format and Decoding Guide” describes the method for decoding the encoded VP8 video information.
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This claim chart is based on the information currently available to Nokia and is intended to be exemplaryin nature. Nokia reserves all rights to update and elaborate its infringement positions, including as Nokia obtainsadditional information during the course of discovery.
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Claims of the 211PatentHTC One Mobile Phone
1. Introduction
. . .
This document describes the VP8 compressed video data format, together with adiscussion of the decoding procedure for the format. It is intended to be used inconjunction with, and as a guide to, the reference decoder source code provided inAttachment One (Section 20).(Exhibit 50 at p. 4).
4. Overview of Compressed Data Format
The input to a VP8 decoder is a sequence of compressed frames whose order matchestheir order in time.(Exhibit 50 at p. 8).The following excerpts from Exhibit 50 illustrate that the device derives prediction motioncoefficients for blocks within a macroblock of a video frame
being decoded from motioncoefficients of at least one prediction block that is a previously decoded macroblock or block within said video frame
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2. Format Overview
. . .
Internally, VP8 decomposes each output frame into an array of macroblocks. Amacroblock is a square array of pixels whose Y dimensions are 16x16 and whose U andV dimensions are 8x8.
. . .
Macroblocks are further decomposed into 4x4 subblocks. Every macroblock has 16 Ysubblocks, 4 U subblocks, and 4 V subblocks.(Exhibit 50 at p. 6).
5. Overview of the Decoding Process
. . .
Inter-prediction is conceptually very simple. While, for reasons of efficiency, there areseveral methods of encoding the relationship between the current macroblock andcorresponding sections of the prediction frame, ultimately each of the sixteen Ysubblocks is related to a 4x4 subblock of the prediction frame, whose position in thatframe differs from the current subblock position by a (usually small) displacement.These two-dimensional displacements are called motion vectors.(Exhibit 50 at p. 12).
16.2 Inter-Predicted Macroblocks
. . .
the purpose of inter-mode decoding is to set a motion vector for each of the sixteen Ysubblocks of the current macroblock.
. . .
After the reference frame selector comes the mode (or motion vector reference) appliedto the macroblock as a whole, coded using the following enumeration and tree. . .