`Case 5:20-cv-09341-EJD Document 138-13 Filed 03/18/22 Page 1of5
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`EXHIBIT 10
`EXHIBIT 10
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`Case 5:20-cv-09341-EJD Document 138-13 Filed 03/18/22 Page 2 of 5
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`DEMARAY LLC,
`
`Plaintiff
`v.
`INTEL CORPORATION,
`Defendant.
`
`
`
`DEMARAY LLC,
`
`Plaintiff
`v.
`SAMSUNG ELECTRONICS CO., LTD (A
`KOREAN COMPANY), SAMSUNG
`ELECTRONICS AMERICA, INC.,
`SAMSUNG SEMICONDUCTOR, INC.,
`and SAMSUNG AUSTIN
`SEMICONDUCTOR, LLC,
`Defendants.
`
`
`
`Case No. 6:20-cv-00634-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`Case No. 6:20-cv-00636-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`PLAINTIFF DEMARAY LLC’S PROPOSED CONSTRUCTIONS
`
`
`
`10904025
`
`
`
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`Case 5:20-cv-09341-EJD Document 138-13 Filed 03/18/22 Page 3 of 5
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`Pursuant to the Court’s scheduling order, Plaintiff Demaray LLC (“Demaray”) hereby
`provides for exchange with the above-captioned Defendants (collectively, “Defendants”) a
`preliminary list of Demaray’s current proposed constructions of certain terms of U.S. Patent Nos.
`7,544,276 and 7,381,657.
`The inclusion of any claim terms, phrases, or clauses herein is not intended to mean, and
`should not be construed to mean, that any such terms, phrases, or clauses have a special or
`uncommon meaning. This disclosure is preliminary and Demaray expressly reserves the right to
`supplement, revise, modify, and/or otherwise finalize the below lists of proposed terms and
`associated proposed constructions based upon additional information or analyses, information
`learned through the course of discovery or otherwise, or in response to the terms, claim elements,
`and/or constructions proposed by Defendants. Demaray reserves the right to argue that
`Defendants’ proposed constructions are incorrect, to propose alternative constructions to any
`constructions proposed by Defendants, and/or to argue that any terms (either on Defendants’ or
`Demaray’s lists) should not be construed. Further, as discovery is ongoing, Demaray reserves the
`right to supplement and/or amend its proposed terms and/or preliminary claim constructions.
`Demaray expressly reserves the right to rely upon any and all intrinsic evidence in support
`of its preliminary claim constructions. Demaray further reserves the right to rely upon any and all
`extrinsic evidence, including, by way of example and without limitation, the right to rely upon the
`opinions and testimony of experts and/or the testimony of one or more of the individuals named
`as inventors of the respective patents. Demaray further reserves the right to rely upon any intrinsic
`or extrinsic evidence cited by Defendants in support of their claim construction positions.
`
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`10904025
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`- 2 -
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`Case 5:20-cv-09341-EJD Document 138-13 Filed 03/18/22 Page 4 of 5
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`
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`I.
`
`PROPOSED CONSTRUCTIONS
`Proposed Terms
`A method of depositing a film on an
`insulating substrate, comprising
`
`“pulsed DC power supply”
`
`“pulsed DC power”
`
`“narrow band-rejection filter”
`
`“reconditioning the target”
`
`“metallic mode”
`
`“poison mode”
`
`Proposed Constructions
`If limiting, plain and ordinary meaning
`
`or
`
`“A method of depositing a film on a
`substrate providing electrical insulation,
`comprising”
`
`Plain and ordinary meaning
`
`or
`
`“supply for providing direct current power
`that oscillates between positive and
`negative voltages”
`Plain and ordinary meaning
`
`or
`
`“direct current power that oscillates
`between positive and negative voltages”
`Plain and ordinary meaning
`
`or
`
`“filter that passes all of the frequencies of
`the power supply except within a narrow
`band”
`Plain and ordinary meaning
`
`or
`
`“cleaning and conditioning the target”
`“mode of operation in which the surface
`of the target is substantially metallic”
`“mode of operation in which the rate of
`the thin film formation on the surface of
`the target equals or exceeds the rate of
`sputter removal of the surface of the
`target”
`
`10904025
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`- 3 -
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`Case 5:20-cv-09341-EJD Document 138-13 Filed 03/18/22 Page 5 of 5
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`“substrate”
`
`
`
`Plain and ordinary meaning
`
`or
`
`“material that provides the surface on
`which something is deposited or
`inscribed, for example a silicon wafer
`used to manufacture integrated circuits”
`
`10904025
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`- 4 -
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`
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