`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`1
`
`Wireless Personal Area
`Network (WP AN)
`
`This term should be
`construed as "a network
`defined by, and co-located
`with, the wireless
`communication intelface."
`
`'904 Claims 1, 2, 10, 12-18, and
`20.
`
`'904 Patent Figures 1, 2-3, 7,
`and 8.
`
`'904 Patent at 2:57-3:3, 3:48-
`4:48, 6:49-59, and any
`referenced figures.
`
`2
`
`desired content is selected
`
`This term should be
`construed as "content is
`able to be selected."
`
`'904 Claim 1.
`
`'904 Patent Figure 5.
`
`'904 Patent at Abstract, 3:4-25,
`3:59-4:2, 4:38-48, 5:40-45, 6: 1-
`32, 6:60-7:9, 7:28-49, 7:66-8:16,
`and any referenced figures.
`
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`ro erl understood b
`
`1 Wherever a portion of Qurio's proposed claim construction appears elsewhere, Qurio incorporates by reference its construction relating to that
`portion and all support relating to that portion. Qurio also reserves the right to rely on any intrinsic or extrinsic evidence cited by Defendants.
`2 For each claim term, Qurio relies on the entire specification and file history of the patent, and reserves its right to rely on any other specific
`portion(s) of the patent specification or file history but provides the following specific and exemplary references for specific support for each term as
`a convenience to Defendants and to facilitate any possible agreement as to any claim construction.
`
`EXHIBIT C
`1
`
`DISH, Exh. 1011, p. 1
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`3
`
`desired content is selected
`from the content at the
`media device
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Claim 1.
`
`'904 Patent Figure 5.
`
`'904 Patent at Abstract, 3:4-25,
`3:59-4:2, 4:38-48, 5:40-45, 6: 1-
`32, 6:60-7:9, 7:28-49, 7:66-8:16,
`and any referenced figures.
`
`4
`
`adapted to update the
`information describing the
`content from the media
`device after leaving the
`WP AN associated with the
`media device and returning
`to the WP AN associated
`with the media device
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Claim 15.
`
`'904 Patent Figures 1-9.
`
`'904 Patent at 5:61-67, and any
`referenced figures.
`
`5
`
`communicate with the
`
`All terms are as construed
`
`'904 Claims 1 and 14.
`
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`
`Dr. Samuel H. Russ
`
`EXHIBIT C
`2
`
`DISH, Exh. 1011, p. 2
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`media device (when the
`mobile device is within a
`wireless personal area
`network (WP AN))
`
`herein or have their plain
`and ordinary meaning.
`
`'904 Patent Figures 1-9.
`
`'904 Patent at 1:27-52; 3:4-26;
`7:50-65, and any referenced
`figures.
`
`6
`
`content
`
`'904 Claims 1-4, 10, 12-18, and
`20.
`
`'904 Patent Figures 2, 4, 6, and
`9.
`
`'904 Patent at Abstract; 1:7-8;
`1:12-22; 1:26-27; 3:4-58; 5:22-
`45; 6:49-59; 7:10-34; 7:50-65.
`
`7
`
`content database
`
`All terms are as construed
`herein or have their plain
`and ordina
`
`'904 Claim 12.
`
`'904 Patent Figures 2, 4, 6, and
`9.
`
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meanin of "one of
`
`EXHIBIT C
`3
`
`DISH, Exh. 1011, p. 3
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`8
`
`control system
`
`'904 Patent at 3:27-4:2; 4:21-48;
`5:5-45; 5:61-6:48; 7:50-65;
`8:17-34, and any referenced
`figures.
`
`'904 Claims 1-4, 10, and 13-15.
`
`'904 Patent Figures 2, 4, 6, and
`9.
`
`'904 Patent at 1:30-46; 3:27-4:2;
`4:21-48; 5:5-45; 5:61-6:48;
`7:50-65; 8:17-34, and any
`referenced figures.
`
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`
`IEEE-The Authoritative
`Dictionary of IEEE
`Standards Terms(cid:173)
`Seventh Edition
`(December 2000)
`(hereinafter, "IEEE"),
`at p. 268 (defining
`"database").
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a erson of ordinar
`
`EXHIBIT C
`4
`
`DISH, Exh. 1011, p. 4
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`9
`
`digital content played by a
`plurality of media devices
`
`'904 Claims 1 and 16.
`
`'904 Patent Figures 2 and 6.
`
`'904 Patent at 3:27-4:2; 4:48-58,
`6:49-60, 7:10-34, and any
`referenced figures.
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`10
`
`included within a system
`further comprising the
`plurality of media devices
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Claim 12.
`
`'904 Patent Figures 1, 5, and 7-
`8.
`
`'904 Patent at 2:57-3:47, and
`any referenced figures.
`
`11
`
`information describing
`content residing at the
`media device
`
`All terms are as construed
`herein or have their plain
`and ordina
`
`'904 Claims 1 and 16.
`
`'904 Patent Fi ures 4 and 5.
`
`March 19, 2008
`Amendment, at
`
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`
`EXHIBIT C
`5
`
`DISH, Exh. 1011, p. 5
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`'904 Patent at 3:4-26, 4:21-48,
`5:5-21, 7:50-65, and any
`referenced figures.
`
`Q009544.
`
`November 5, 2008
`Amendment, at
`Q009505-06.
`
`12
`
`instruct the media device to
`play the desired content
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Claim 2.
`
`'904 Patent Figure 6.
`
`March 19, 2008
`Amendment, at
`Q009544.
`
`'904 Patent at 3:59-4:2, 4:21-48,
`and any referenced figures.
`
`13
`
`interact with a user such
`that the user selects the
`desired content to play at
`the media device from the
`media database
`
`All terms are as construed
`herein or have their plain
`and ordina
`
`'904 Claim 3.
`
`'904 Patent Figures 5 and 6.
`
`'904 Patent at 4:21-5:4, 6: 1-32,
`and any referenced figures.
`
`November 5, 2008
`Amendment, at
`Q009506.
`
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`osed claim
`
`EXHIBIT C
`6
`
`DISH, Exh. 1011, p. 6
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`14
`
`Last-played time-stamps
`
`'904 Claims 13 and 20.
`
`'904 Patent Figure 5.
`
`'904 Patent at 4:21-48, 5:22-45,
`6:33-48, and any referenced
`figures.
`
`15
`
`media database
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning. To
`the extent that the term
`"media database" requires
`construction, it should be
`construed as "a database
`of information describing
`the content."
`
`'904 Claims 1-3, 10, 13, 16-18,
`and 20.
`
`'904 Patent Figures 3-4, 6, and
`9.
`
`'904 Patent at Abstract, 4:21-48,
`5:5-45, 7:50-8:16, and any
`referenced figures.
`
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a erson of ordinar
`
`EXHIBIT C
`7
`
`DISH, Exh. 1011, p. 7
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`16
`
`media device( s)
`
`'904 Claims 1-3, 7, 10, 12-18,
`and 20.
`
`'904 Patent Figures 1, 2, 6, and
`7-9.
`
`'904 Patent at 1:13-22, 3:27-47,
`and any referenced figures.
`
`17
`
`media server
`
`'904 Claim 12.
`
`'904 Patent Figures 2-4, 6, and
`9.
`
`'904 Patent at 3:48-4:2, and any
`referenced figures.
`
`18
`
`mobile device
`
`'904 Claims 1 - 20.
`
`'904 Patent Fi ures 1 and 3-9.
`
`March 19, 2008
`Amendment, at
`
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`
`EXHIBIT C
`8
`
`DISH, Exh. 1011, p. 8
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`'904 Patent at 1:26-41, 3:4-25,
`4:3-20, and any referenced
`figures.
`
`19
`
`obtaining a passkey from a
`user associated with the
`mobile device and
`providing the passkey to
`the media device
`
`'904 Claim 14.
`
`'904 Patent Figure 4.
`
`'904 Patent at 4:49-5:4, and any
`referenced figures.
`
`March 19, 2008
`Amendment, at
`Q009544-45.
`
`20
`
`obtaining information
`describing content residing
`at the media device when a
`mobile device is within a
`wireless personal area
`network (WP AN)
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Claim 16.
`
`'904 Patent Figures 4-6 and 9.
`
`'904 Patent at Abstract, 3:4-25,
`4:21-48, 5:5-21, 6:61-67, 7:50-
`65, and an referenced fi ures.
`
`November 5, 2008
`Amendment, at
`Q009505.
`
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`osed claim
`
`EXHIBIT C
`9
`
`DISH, Exh. 1011, p. 9
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`21
`
`played at the media device
`I playing ... at the media
`device
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Claims 1 and 16.
`
`'904 Patent Figures 6.
`
`March 19, 2008
`Amendment, at
`Q009542-43.
`
`'904 Patent at Abstract, 3:4-25,
`5:5-17, 6:1-32, 7:50-65, and any
`referenced figures.
`
`22
`
`played at the media device
`when the mobile device is
`within the WPAN
`associated with the media
`device
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Claim 1.
`
`'904 Patent Figures 1 and 6-9.
`
`'904 Patent at Abstract, 3:48-58,
`4:21-5:4, 5:22-6:32, 6:49-59,
`and any referenced figures.
`
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a erson of ordinar
`
`EXHIBIT C
`10
`
`DISH, Exh. 1011, p. 10
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`23
`
`plurality of media devices
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning. To
`the extent that this phrase
`requires construction, it
`should be construed as
`"two or more media
`devices."
`
`'904 Claims 1, 7, 10, 12, 13, 16,
`18, and 20.
`
`'904 Patent Figures 1, 2, 6, and
`7-9.
`
`'904 Patent at 1:13-22, 3:27-47,
`and any referenced figures.
`
`24
`
`predetermined play list
`
`All terms are as construed
`herein or have their plain
`and ordina
`
`'904 Claim 7.
`
`'904 Patent Figure 5.
`
`'904 Patent at 6:27-32, and any
`referenced figures.
`
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`
`See e.g., In Re 55 Brake
`LLC, 2014-1554 (Fed.
`Cir. April 13, 2015)
`(defining plurality as
`"two or more").
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`
`EXHIBIT C
`11
`
`DISH, Exh. 1011, p. 11
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`25
`
`predetermined user
`preferences
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Claim 4.
`
`'904 Patent None.
`
`'904 Patent at 3:4-25, 4:21-48,
`6:1-32, and any referenced
`figures.
`
`26
`
`providing an instruction
`from the mobile device to
`the media device
`instructing the media
`device to play the desired
`content
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Claim 17.
`
`'904 Patent Figure 6.
`
`March 19, 2008
`Amendment, at
`Q009544.
`
`'904 Patent at 3:59-4:2, 4:21-48,
`and any referenced figures.
`
`27
`
`select desired content to
`
`All terms are as construed
`
`'904 Claim 10.
`
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`
`EXHIBIT C
`12
`
`DISH, Exh. 1011, p. 12
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`play for only the select
`media device from the
`media database and instruct
`only the select media
`device to play the desired
`content
`
`herein or have their plain
`and ordinary meaning.
`
`'904 Patent None.
`
`March 19, 2008
`Amendment, at
`Q009544.
`
`'904 Patent at 6:49-7:34 and any
`referenced figures.
`
`28
`
`select media device
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Claims 10 and 18.
`
`'904 Patent None.
`
`'904 Patent at 6:49-7:34 and any
`referenced figures.
`
`29
`
`selected
`
`Plain and ordinary
`meaning.
`
`'904 Claim 1.
`
`'904 Patent Figure 5.
`
`'904 Patent at Abstract, 3:4-25,
`
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinar skill in the art"
`
`EXHIBIT C
`13
`
`DISH, Exh. 1011, p. 13
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`30
`
`selecting
`
`Plain and ordinary
`meaning.
`
`3:59-4:2, 4:38-48, 5:40-45, 6: 1-
`32, 6:60-7:9, 7:28-49, 7:66-8:16,
`and any referenced figures.
`
`'904Claims 16, 17, 18, and20.
`
`'904 Patent Figure 5.
`
`'904 Patent at Abstract, 3:4-25,
`3:59-4:2, 4:38-48, 5:40-45, 6: 1-
`32, 6:60-7:9, 7:28-49, 7:66-8:16,
`and any referenced figures.
`
`31
`
`selects the desired content All terms are as construed
`based on the information
`herein or have their plain
`and the last-played time(cid:173)
`and ordinary meaning.
`stamps
`
`'904 Claim 13.
`
`'904 Patent Figure 5.
`
`'904 Patent at 1:53-67, 4:21-48,
`5:22-45, 6:33-48, 7:66-8:16, and
`any referenced figures.
`
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`
`EXHIBIT C
`14
`
`DISH, Exh. 1011, p. 14
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`32
`
`simultaneously within the
`WP AN associated with a
`first one of the plurality of
`media devices and the
`WP AN associated with a
`second one of the plurality
`of media devices
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Claims 10 and 18.
`
`'904 Patent Figures 7-8.
`
`March 19, 2008
`Amendment, at
`Q009543-44.
`
`'904 Patent at 6:49-59 and any
`referenced figures.
`
`33
`
`store
`
`'904 Claims 1 and 13.
`
`'904 Patent Figures 2-4.
`
`'904 Patent at 3:48-58 and any
`referenced figures.
`
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`
`EXHIBIT C
`15
`
`DISH, Exh. 1011, p. 15
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`34
`
`storing
`
`35
`
`the content from the media
`device
`
`'904 Claims 12, 16, and 20.
`
`'904 Patent Figures 2-4.
`
`'904 Patent at 3:48-58 and any
`referenced figures.
`
`'904 Claim 15.
`
`'904 Patent Figures 3-4, 6, and
`9.
`
`'904 Patent at Abstract, 1: 12-22,
`3:4-4:2; 4:21-48; 5:5-45; 5:61-
`6:48; 7:50-65; 8:17-34and any
`referenced figures.
`
`"store").
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`
`IEEE at 1113 (defining
`"store").
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a erson of ordinar
`
`EXHIBIT C
`16
`
`DISH, Exh. 1011, p. 16
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`36
`
`update the information
`describing the content from
`the media device after
`leaving the WP AN
`associated with the media
`device and returning to the
`WP AN associated with the
`media device
`
`37
`
`wireless communication
`interface
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Claim 15.
`
`'904 Patent Figure 6.
`
`'904 Patent at 5:61-67, 6:33-48,
`8:17-29, and any referenced
`figures.
`
`Plain and ordinary
`meaning. To the extent
`that this phrase requires
`construction, it should be
`construed as "conduit for
`wireless communication
`between one or more
`media devices and one or
`more mobile devices."
`
`'904 Claims 1 and 12.
`
`'904 Patent Figures 2 and 3.
`
`'904 Patent at 2:57-3:3, 3:26-46,
`4:3-20, 4:49-5:4 and any
`referenced figures.
`
`38
`
`wireless communication
`interface for
`communicatin with the
`
`All terms are as construed
`herein or have their plain
`and ordina
`
`'904 Claim 12.
`
`'904 Patent Fi ures 2 and 3.
`
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`
`EXHIBIT C
`17
`
`DISH, Exh. 1011, p. 17
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`mobile device
`
`39
`
`wireless communication
`interface for
`communicating with the
`plurality of media devices
`
`All terms are as construed
`herein or have their plain
`and ordinary meaning.
`
`'904 Patent at 2:57-3:3, 3:26-46,
`4:3-20, 4:49-5:4 and any
`referenced figures.
`
`'904 Claim 1.
`
`'904 Patent Figures 2 and 3.
`
`'904 Patent at 2:57-3:3, 3:26-46,
`4:3-20, 4:49-5:4 and any
`referenced figures.
`
`40
`
`within a wireless personal
`area network (WP AN)
`associated with the media
`device I a wireless personal
`area network (WP AN)
`associated with a
`first/second one of the
`
`Plain and ordinary
`meaning. To the extent
`that the phrase "associated
`with" requires
`construction, it should be
`construed as "capable of
`bein used b ."
`
`'904 Claims 1, 2, 10, 12-18, and
`20.
`
`'904 Patent Figures 1 and 7-8.
`
`'904 Patent at 1:27-52; 3:4-26;
`6:49-59, 7:50-65, and an
`
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`proposed claim
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`Dr. Samuel H. Russ
`will provide testimony
`regarding the proper
`meaning of "one of
`ordinary skill in the art"
`and supporting Qurio's
`osed claim
`
`EXHIBIT C
`18
`
`DISH, Exh. 1011, p. 18
`
`
`
`REDACTED I NON-CONFIDENTIAL CHART
`
`QURIO'S PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS AND DISCLOSURE OF SUPPORTING EVIDENCE
`PURSUANT TO PATENT L.R. 4-31
`Preliminary Proposed
`Construction
`
`plurality of media devices
`
`referenced figures.
`
`construction of this
`term as stated herein as
`properly understood by
`a person of ordinary
`skill in the art.
`
`EXHIBIT C
`19
`
`DISH, Exh. 1011, p. 19