`FOR THE DISTRICT OF DELAWARE
`
`
`EVOLVED WIRELESS, LLC,
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`
`
`
`
`C.A. No. 1:15–cv-00547–SLR
`
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`)
`)
`)
`)
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`Plaintiff,
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`v.
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`MICROSOFT CORPORATION,
`MICROSOFT MOBILE OY and
`NOKIA INC.,
`
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`
`
`
`Defendants.
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`EVOLVED WIRELESS’S IDENTIFICATION OF
`CLAIM TERMS AND PROPOSED CONSTRUCTIONS
`
`Pursuant to the Court’s Scheduling Order and as amended by agreement of the parties,
`
`Evolved Wireless identifies the following terms in the patents-in-suit in need of construction and
`
`the proposed constructions.
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`
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`
`
`’916 Patent Claim terms
`All terms in the ’916 Patent should be
`given their plain and ordinary meaning.
`
`Proposed construction
`
`
`
`
`
`
`’965 Patent Claim terms
` All terms in the ’965 Patent should be
`given their plain and ordinary meaning.
`
`Proposed construction
`
`
`
`
`’373 Patent Claim terms
`1. “handover”
`
`2. “target base station”
`
`Proposed construction
`a process to transfer a telecommunication
`link by establishing radio connection with the
`target base station after radio connection with
`the source base station has ceased
`the base station to which the source base
`station determines the mobile terminal will
`be transferred
`
`PETITIONERS 1073-0001
`IPR2016-00758
`
`
`
`
`
`
`
`
`
`’373 Patent Claim terms
`3. Claim 17:
`“the measurement report is used to
`determine”
`
`Proposed construction
`the measurement report is used by the source
`base station to determine
`
`
`
`
`’236 Patent Claim terms
` All terms in the ’236 Patent should be
`given their plain and ordinary meaning.
`
`
`Proposed construction
`
`
`’481 Patent Claim terms
` All terms in the ’481 Patent should be
`given their plain and ordinary meaning.
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`Discovery is at an early stage and expert discovery has not been completed. Evolved
`
`Proposed construction
`
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`Wireless reserves the right to propose additional terms and amend its proposed constructions as
`
`the case moves forward and disputes or disagreements emerge between the parties, including
`
`from the claim terms and proposed constructions identified by the defendants in connection with
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`the joint claim construction statement to be filed with the Court on May 17, 2016.
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`
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`PETITIONERS 1073-0002
`IPR2016-00758
`
`
`
`
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`Dated: April 26, 2016
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`
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`
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`Respectfully submitted,
`
`/s/ Ryan M. Schultz
`
`PHILLIPS GOLDMAN MCLAUHLIN &
`HALL, P.A.
`John C. Phillips, Jr. (Bar No. 110)
`David A. Bilson (Bar No. 4986)
`1200 North Broom Street
`Wilmington, Delaware 19806
`(302) 655-4200
`jcp@pgmhlaw.com
`dab@pgmhlaw.com
`
`Christopher K. Larus (admitted pro hac vice)
`Ryan M. Schultz (admitted pro hac vice)
`Andrew D. Hedden (admitted pro hac vice)
`Benjamen C. Linden (admitted pro hac vice)
`Ryan E. Dornberger (admitted pro hac vice)
`Anthony F. Schlehuber (admitted pro hac vice)
`ROBINS KAPLAN LLP
`800 LaSalle Avenue, Suite 2800
`Minneapolis, Minnesota 55402
`Telephone: (612) 349-8500
`Facsimile: (612) 339-4181
`clarus@robinskaplan.com
`rschultz@robinskaplan.com
`ahedden@robinskaplan.com
`blinden@robinskaplan.com
`rdornberger@robinskaplan.com
`aschlehuber@robinskaplan.com
`
`Andrea L. Gothing (admitted pro hac vice)
`ROBINS KAPLAN LLP
`2440 W. El Camino Real, Suite 100
`Mountain View, CA 94040
`Telephone: (650) 784-4040
`Facsimile: (650) 784-4041
`agothing@robinskaplan.com
`
`Counsel For Plaintiff Evolved Wireless, LLC
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`PETITIONERS 1073-0003
`IPR2016-00758
`
`
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