`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 16-453 (RGA)
`
`C.A. No. 16-454 (RGA)
`
`C.A. No. 16-455 (RGA)
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`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`v.
`
`ACTIVISION BLIZZARD, INC.,
`
`Defendant.
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`v.
`
`ELECTRONIC ARTS INC.,
`
`Defendant.
`ACCELERATION BAY LLC,
`
`Plaintiff,
`
`v.
`
`TAKE-TWO INTERACTIVE SOFTWARE,
`INC., ROCKSTAR GAMES, INC., and 2K
`SPORTS, INC.,
`
`Defendants.
`
`[PROPOSED] SUPPLEMENTAL CLAIM CONSTRUCTION ORDER
`
`The Court, having considered the parties’ briefing on claim construction (D.I. 281 and
`
`321)1, and in accordance with the reasoning set forth in the Court’s Memorandum Opinions (D.I.
`
`386 and 387), IT IS HEREBY ORDERED that the terms of U.S. Patent Nos. 6,701,344 (the
`
`“’344 Patent”), 6,714,966 (the “’966 Patent”), 6,829,634 (the “’634 Patent”), 6,910,069 (the
`
`1 Citation to “D.I. __” refer to the docket in C.A. No. 16-453, unless otherwise noted.
`
`
`
`Case 1:16-cv-00455-RGA Document 353 Filed 12/27/17 Page 2 of 4 PageID #: 24300
`
`“’069 Patent”), 6,732,147 (the “’147 Patent”), and 6,920,497 (the “’497 Patent”) set forth below
`
`are construed as follows:
`
`Term
`No.
`14
`
`Claim Term
`
`“connection”
`
`15
`
`[1] “neighbor”;
`[2] “neighbors”;
`[3] “neighboring”
`
`Patent(s)
`
`Construction
`
`’344/ 12, 13, 14,
`15;
`
`’966/ 12, 13;
`
`’634/ 19, 22;
`
`’069/ 1, 11;
`’147/ 1, 11, 15,
`16;
`
`’497 9. 16
`’344/ 12, 13, 14,
`15;
`
`’966/ 12, 13;
`
`’634/ 19, 22;
`
`’069/ 1
`
`’147/ 1, 11, 15,
`16
`
`“connection between two participants,
`with no other participants in between,
`through which data can be sent a
`received”
`
`“connection between two computers,
`with no other computers in between,
`through which data can be sent a
`received”
`[1] “a neighbor of a participant is another
`participant that has a connection to the
`first participant, with no other
`participants in between”
`
`[2] “the neighbors of a participant are
`additional participants that each have a
`connection to the first participant, with
`no other participants in between the first
`participant and each additional
`participant”
`
`[3] “being a neighbor of”
`[1] “a neighbor of a computer is another
`computer that has a connection to the
`first computer, with no other computers
`in between”
`
`[2] “the neighbors of a computer are
`additional computers that each have a
`connection to the first computer, with no
`other computer in between the first
`computer and each additional computer”
`
`[3] “being a neighbor of”
`
`2
`
`
`
`Case 1:16-cv-00455-RGA Document 353 Filed 12/27/17 Page 3 of 4 PageID #: 24301
`
`Term
`No.
`19
`
`Claim Term
`
`Patent(s)
`
`Construction
`
`“thus resulting in non-
`complete graph”
`
`’344/ 12, 13, 14,
`15;
`
`“thus the graph is configured to maintain
`a non-complete state”
`
`20
`
`“data”
`
`22
`
`“broadcast channel(s)”
`
`27
`
`29
`
`30
`
`31
`
`“computer readable
`medium”
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`[1] “fully connected
`portal computer”
`
`[2] “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”
`
`’966/ 12, 13;
`
`’634/ 19, 22
`’344/ 12, 13. 14.
`15;
`
`’966/ 12, 13;
`
`’634/ 22
`’344/ 12, 13, 14,
`15;
`
`’966/ 12, 13;
`
`’634/ 19, 22
`’147/ 1, 11, 15,
`16
`
`‘634/ 19, 22;
`
`’147/ 11, 14, 15,
`16
`
`[1] ’634/ 19, 22;
`
`[2] ’069/ 1, 11
`
`’069/ 1, 11
`
`’069/ 1, 11
`
`3
`
`plain and ordinary meaning
`
`“communications network consisting of
`interconnected participants where each
`participant receives all data broadcasted
`on that communications network”
`
`“communications network of
`interconnected computers where each
`computer receives all data broadcasted on
`that communications network”
`“any medium for storing or transporting
`computer readable instructions, including
`memory, storage device, carrier waves,
`and communications links”
`
`“connected to exactly m neighboring
`participants”
`
`“each participant being connected to the
`same number of other participants in the
`network, where the number is three or
`more”
`“sends a message through a number of
`randomly selected connections until fully
`connected participants are identified to
`which the seeking participant is to
`connect”
`
`
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`Case 1:16-cv-00455-RGA Document 353 Filed 12/27/17 Page 4 of 4 PageID #: 24302
`
`Term
`No.
`32
`
`33
`
`34
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`38
`
`39
`
`40
`
`Claim Term
`
`Patent(s)
`
`Construction
`
`“connection port search
`message”
`“in order to maintain an
`m-regular graph”
`
`’147/ 1, 11
`
`’147/ 1, 11
`
`“list of neighbors”
`
`’147/ 1, 11
`
`“a message sent to locate a computer with
`less than m neighbors”
`“in order to maintain the broadcast
`channel as m-regular following
`disconnection”
`plain and ordinary meaning
`
`“wherein an originating
`participant send 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”
`“wherein each
`participant sends data
`that it receives from a
`neighboring participant
`to its neighbor
`participants”
`
`’344/ 12, 13, 14,
`15;
`
`’634/ 1;
`
`’966/ 1, 13.
`
`’344/ 12;
`
`’966/ 12
`
`“data is sent from an originating
`participant to the other participants by
`broadcasting data through each of its
`connections to its neighbor participants”
`
`“each participant receives data from a
`neighboring participant and rebroadcasts
`the received data to its other neighbor
`participants”
`
`’344/ 13, 14, 15;
`
`’966/ 13
`
`“each participant receives data from a
`neighboring participant and rebroadcasts
`the received data to its other neighbor
`participants”
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`IT IS SO ORDERED this _______ day of December, 2017
`
`United States District Judge
`
`5594860
`
`4
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`