Case 1:16-cv-00455-RGA Document 143-1 Filed 06/14/17 Page 1 of 7 PageID #: 13781
`Case 1:16-cv-00455-RGA Document 143-1 Filed 06/14/17 Page 1 of 7 PagelD #: 13781
`
`EXHIBIT A
`EXHIBIT A
`
`
`Case 1:16-cv-00455-RGA Document 143-1 Filed 06/14/17 Page 1 of 7 PagelD #: 13781
`
`EXHIBIT A
`EXHIBIT A
`
`
`
`Case 1:16-cv-00455-RGA Document 143-1 Filed 06/14/17 Page 2 of 7 PageID #: 13782
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`EXHIBIT A – COMPARISON OF ACCELERATION BAY’S PROPOSED CLAIM CONSTRUCTIONS
`
`No.1 Terms for Construction
`
`Plaintiff's Proposed Constructions in the
`Joint Claim Construction Chart
`
`Plaintiff's Proposed Constructions in the
`Claim Construction Briefing/Declarations
`of Nenad Medvidović
`
`“m-regular”
`“m-regular network”
`
`a network where each participant has m
`neighbor participants in a steady state
`
`a network where each participant has m
`neighbor participants in a steady state
`
`“m”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`“m-connected”
`“m-connected network”
`
`a network that may be divided into
`disconnected sub-networks by the removal of
`m participants in a steady state
`
`a network that may be divided into
`disconnected sub-networks by the removal of
`m participants in a steady state
`
`“computer network”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`“network”
`
`plain and ordinary meaning
`
`plain and ordinary meaning
`
`17.
`
`16.
`
`18.
`
`9.
`
`10.
`
`1 The numbering for the terms corresponds with the numbering in the filed Joint Claim Construction Chart (D.I. 117-1) (“JCCC”).
`The terms are listed in the order they appeared in the Declaration of Nenad Medvidović (Ex. 13 to Defendants’ Motion to Strike). The
`chart does not included the means-plus-function terms for which there is no dispute, or claims 26 and 28 in the JCCC, which
`Acceleration Bay did not address in its briefing. For claim 27 in the JCCC, “computer readable medium,” in its Reply Claim
`Construction Brief, Acceleration Bay maintained its position in the JCCC of “No construction necessary: plain and ordinary
`meaning.” Acceleration Bay also argued that the Court should only partially adopt Defendants' proposed construction.
`
`
`
`Case 1:16-cv-00455-RGA Document 143-1 Filed 06/14/17 Page 3 of 7 PageID #: 13783
`
`No.1 Terms for Construction
`
`Plaintiff's Proposed Constructions in the
`Joint Claim Construction Chart
`
`Plaintiff's Proposed Constructions in the
`Claim Construction Briefing/Declarations
`of Nenad Medvidović
`
`11.
`
`12.
`
`13.
`
`14.
`
`15.
`
`19.
`
`“computer”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`“a plurality of participants”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`“participant”
`“participants”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`“connection”
`“connections”
`“connected”
`“connect”
`“connecting”
`“interconnections”
`“disconnecting”
`“neighbor”
`“neighbors”
`“neighboring”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`“thus resulting in a non-
`complete graph”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`“the network forms an
`incomplete graph”
`
`2
`
`
`
`Case 1:16-cv-00455-RGA Document 143-1 Filed 06/14/17 Page 4 of 7 PageID #: 13784
`
`No.1 Terms for Construction
`
`Plaintiff's Proposed Constructions in the
`Joint Claim Construction Chart
`
`Plaintiff's Proposed Constructions in the
`Claim Construction Briefing/Declarations
`of Nenad Medvidović
`
`20.
`
`21.
`
`22.
`
`23.
`
`24.
`
`25.
`
`“data”
`
`“peers”
`
`“peer-to-peer connections”
`“broadcast channel”
`
`“broadcast channels”
`
`“A non-routing table based
`computer network having a
`plurality of participants”
`
`“A non-routing table based
`computer-readable medium
`containing instructions for
`controlling communications
`of a participant of a broadcast
`channel within a network”
`“A computer-based, non-
`routing table based, non-
`switch based method for
`adding a participant to a
`network of participants”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`3
`
`
`
`Case 1:16-cv-00455-RGA Document 143-1 Filed 06/14/17 Page 5 of 7 PageID #: 13785
`
`No.1 Terms for Construction
`
`Plaintiff's Proposed Constructions in the
`Joint Claim Construction Chart
`
`Plaintiff's Proposed Constructions in the
`Claim Construction Briefing/Declarations
`of Nenad Medvidović
`
`“fully connected portal
`computer”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`29.
`
`30.
`
`31.
`
`32.
`
`33.
`
`34.
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`“located portal computer”
`
`“each participant being
`connected to three or more
`other participants”
`
`“sends an edge connection
`request to a number of
`randomly selected
`neighboring participants to
`which the seeking participant
`is to connect”
`“connection port search
`message”
`
`No construction necessary:
`plain and ordinary meaning
`
`“in order to maintain an m-
`regular graph”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`“list of neighbors”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`4
`
`
`
`Case 1:16-cv-00455-RGA Document 143-1 Filed 06/14/17 Page 6 of 7 PageID #: 13786
`
`No.1 Terms for Construction
`
`Plaintiff's Proposed Constructions in the
`Joint Claim Construction Chart
`
`Plaintiff's Proposed Constructions in the
`Claim Construction Briefing/Declarations
`of Nenad Medvidović
`
`35.
`
`36.
`
`37.
`
`38.
`
`39.
`
`“when the portal computer or
`the plurality of portal
`computers is in a state to
`coordinate the connection of
`the seeking computer to the
`network”
`“wherein the communications
`ports selected by the port
`ordering algorithm may be re-
`ordered”
`“port ordering algorithm”
`
`“wherein an originating
`participant sends data to the
`other participants by sending
`the data through each of its
`connections to its neighbor
`participants”
`“wherein each participant
`sends data that it receives
`from a neighbor participant to
`its other neighbor
`participants”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`5
`
`
`
`Case 1:16-cv-00455-RGA Document 143-1 Filed 06/14/17 Page 7 of 7 PageID #: 13787
`
`No.1 Terms for Construction
`
`Plaintiff's Proposed Constructions in the
`Joint Claim Construction Chart
`
`Plaintiff's Proposed Constructions in the
`Claim Construction Briefing/Declarations
`of Nenad Medvidović
`
`40.
`
`“wherein each participant
`sends data that it receives
`from a neighboring
`participant to its neighbor
`participants”
`
`No construction necessary:
`plain and ordinary meaning
`
`No construction necessary:
`plain and ordinary meaning
`
`6
`
`
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