`
`
`Exhibit A
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`
`
`Case 6:17-cv-01217-EFM-ADM Document 99-1 Filed 06/12/20 Page 2 of 5
`
`Claim 1 –
`Disputed Terms Emphasized
`
`Court’s Construction
`
`LoganTree’s Proposed
`Construction of Disputed
`Terms
`
`Unrestrained movement in
`any direction – movement
`along multiple axes without
`restraint to the movement.
`
`Garmin’s Proposed
`Construction of Disputed
`Terms
`
`
`
`Unrestrained movement in
`any direction – This claim
`term is indefinite under §
`112, ¶ 2.
`
`
`
`1. A portable, self-contained device for
`monitoring movement of body parts
`during physical activity, said device
`comprising:
`
` a
`
` movement sensor capable of measuring
`data associated with unrestrained
`movement in any direction and
`generating signals indicative of said
`movement;
`
` a
`
` power source;
`
` a
`
` microprocessor connected to said
`movement sensor and to said power
`source, said microprocessor capable of
`receiving, interpreting, storing and
`responding to said movement data based
`on user-defined operational parameters,
`detecting a first user-defined based on the
`movement data and at least one of the
`
`
`
`Case 6:17-cv-01217-EFM-ADM Document 99-1 Filed 06/12/20 Page 3 of 5
`
`first time stamp information
`reflecting a time at which
`the movement data causing
`the first user-defined event
`occurred – First time stamp
`information reflecting a
`system time at which the
`movement data causing the
`first user-defined event
`occurred.
`
`
`angle – The space between
`two intersecting planes at the
`point where they meet.
`
`
`first time stamp information
`reflecting a time at which
`the movement data causing
`the first user-defined event
`occurred – LoganTree
`believes that no construction
`of this language is needed.
`To the extent the Court
`chooses to construe it,
`LoganTree believes that the
`following construction is
`appropriate:
`
`First time stamp information
`reflecting a system time
`associated with the
`movement data occurrence
`causing the first user-defined
`event.
`angle – LoganTree believes
`that no construction of this
`language is needed. To the
`extent the Court chooses to
`construe it, LoganTree
`believes that the following
`construction is appropriate:
`
` a
`
` measure of the amount of
`movement.
`
`user-defined operational parameters
`regarding the movement data, and storing
`first event information related to the
`detected first user-defined event along
`with first time stamp information
`reflecting a time at which the movement
`data causing the first user-defined event
`occurred;
`
`at least one user input connected to said
`microprocessor for controlling the
`operation of said device;
`
` a
`
` real-time clock connected to said
`microprocessor;
`
`memory for storing said movement data;
`and
`
`an output indicator connected to said
`microprocessor for signaling the
`occurrence of user-defined events;
`
`wherein said movement sensor measures
`the angle and velocity of said movement.
`
`
`
`
`Case 6:17-cv-01217-EFM-ADM Document 99-1 Filed 06/12/20 Page 4 of 5
`
`velocity – LoganTree
`believes that no construction
`of this language is needed.
`To the extent the Court
`chooses to construe it,
`LoganTree believes that the
`following construction is
`appropriate:
`
`rate of change of angular
`position.
`
`LoganTree’s Proposed
`Construction of Disputed
`Terms
`
`Unrestrained movement in
`any direction – movement
`along multiple axes without
`restraint to the movement.
`
`velocity – In its Reply,
`Garmin agreed to adopt
`LoganTree’s alternative
`proposal:
`
`rate of change of angular
`position.
`
`
`Garmin’s Proposed
`Construction of Disputed
`Terms
`
`Unrestrained movement in
`any direction – This claim
`term is indefinite under §
`112, ¶ 2.
`
`
`
`Court’s Construction
`
`
`
`Claim 20 –
`Disputed Terms Emphasized
`
`20. A method to monitor physical
`movement of a body part comprising the
`steps of:
`
`attaching a portable, self-contained
`movement measuring device to said body
`part for measuring unrestrained
`movement in any direction;
`
`measuring data associated with said
`physical movement;
`
`interpreting, using a microprocessor
`included in the portable, self-contained
`movement measuring device, said
`physical movement data based on user-
`
`
`
`Case 6:17-cv-01217-EFM-ADM Document 99-1 Filed 06/12/20 Page 5 of 5
`
`first time stamp information
`reflecting a time at which
`the movement data causing
`the first user-defined event
`occurred – First time stamp
`information reflecting a
`system time at which the
`movement data causing the
`first user-defined event
`occurred.
`
`defined operational parameters and a real-
`time clock;
`
`storing said data in memory;
`
`detecting, using the microprocessor, a first
`user-defined event based on the
`movement data and at least one of the
`user-defined operational parameters
`regarding the movement data; and
`
`storing, in said memory, first event
`information related to the detected first
`user-defined event along with first time
`stamp information reflecting a time at
`which the movement data causing the
`first user-defined event occurred.
`
`
`
`first time stamp information
`reflecting a time at which
`the movement data causing
`the first user-defined event
`occurred – LoganTree
`believes that no construction
`of this language is needed.
`To the extent the Court
`chooses to construe it,
`LoganTree believes that the
`following construction is
`appropriate:
`
`First time stamp information
`reflecting a system time
`associated with the
`movement data occurrence
`causing the first user-defined
`event.
`
`
`
`