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FURTHER e.DIGITAL IDENTIFIED THAT BY LOOKING IN FOLLOWING HIGH LEVEL BLOCK DIAGRAM
RELATED TO CLAIMED CIRCUITY AND RELATED COMPONENTS FUNDAMENTAL TO PROCESSOR,
THEY ARE IN FACT THE PLATFORM OF FUNCTIONALITY THAT CLAIMED IN e.DIGITAL PATENTS,
AND SUPPORT HIGHLY THE INFRINGEMENT BY SAMSUNG.
FROM DOC 151
But, now that we are focusing on this website, to the extent that it has any relevance to
the pending dispute, it supports e.Digital’s position, not Samsung’s position.
Arguably, this
website: (a) buttresses e.Digital’s belief that Zoran provides processors that may be used in many
types of potentially infringing products, such as the mobile phones that are the subject of the
website article, and (b) confirms e.Digital’s belief that the claimed circuitry and related
components are fundamental to processors that perform the functionality claimed in the patents.
Based on the high level block diagram depicted in the website article at Fig. 10 (p. 16), this
media processor contains, at least, signal input circuitry, amplification circuitry, analog-to-digital
conversion circuitry, memory control circuitry, signal output circuitry and control logic circuitry
:

Zoran Corporation, incorporated in December 1981, is a provider of digital solutions in the digital entertainment and digital imaging market. Zoran has developed high-performance digital audio and video, imaging applications and Connect Share Entertain technologies for the digital home. The Company’s products consist of integrated circuits and related products used in digital versatile disc (DVD), players, movie and home theater systems, digital cameras and video editing systems. It provides integrated circuits (ICs), software and platforms for digital television applications that enable the delivery and display of digital video content through a set-top box or television, as well as digital imaging products consisting of semiconductor hardware and software that enable users to print, scan, process and transmit documents to computer peripherals that perform printing functions. Zoran also provides high-performance, low-power application processors, technology and products for the multimedia mobile phone market. The Company sells its products to original equipment manufacturers (OEMs) that incorporate them into products for consumer and commercial applications. In June 2008, the Company announced the completion of its acquisition of Let It Wave SA, a fabless semiconductor company.

The Company’s products are based on integrated application-specific ICs and system-on-a-chip (SoC) solutions. It also licenses software and other intellectual property. Zoran operates in two segments: Consumer group and Imaging group. The Consumer group provides products for use in DVD players, recordable DVD players, standard and high-definition digital television products, digital camera products and multimedia mobile phone products. The Imaging group provides products used in digital copiers, laser and inkjet printers, as well as multifunction peripherals. Zoran’s product offerings consist of four principal product families: DVD, digital television (DTV), mobile and digital imaging.

Mobile

The Company’s camera-on-a-chip (COACH) processors are integrated SoC solutions that include most of the electronics of a digital camera, which can be connected directly to a high-resolution charge-coupled device (CCD) or complementary metal-oxide semiconductor (CMOS) sensor. The COACH IC processes the video information in real time, compresses the captured image in real time, while interfacing to an liquid crystal display (LCD), television or micro display and to all types of flash memory. Among the capabilities of the COACH product is the ability to transfer in real time, over a USB bus, high-quality video to the personal computer (PC) and function as a PC video camera. The COACH products also allow for direct connection to a printer, including color correction and special effects, for the non-PC consumer environment. The COACH product is supplemented by digital camera reference designs, CamON and CamMini, products.

Zoran’s newest COACH processors utilize MPEG-4 and H.264 Codecs to incorporate basic digital camcorder capabilities for displaying video clips on a PC or television. Its mobile products division also offers mobile multimedia telephone products. The Company’s APPROACH media

processors support a variety of multimedia functions, including image signal processing (ISP), image quality, video play and record capabilities, multi-standard, end-to-end Mobile television decoding, integrated television-out, and high speed USB 2.0.

Zoran competes with Cheertek, ESS Technology Inc., LSI Corporation, Magnum Semiconductor, Matsushita, MediaTek, Renesas Technology, Samsung, Sunplus, Fujitsu, Novatech, Texas Instruments, Applied Micro Devices, Broadcom, M-Star, ST Microelectronics, Global Graphics, Marvell Semiconductor, Peerless Systems and Sigmatel Inc.

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