`Marc A. Fenster (CA SBN 181067)
`Reza Mirzaie (CA SBN 246953)
`Jeffrey Z.Y. Liao (CA SBN 288994)
`Christian Conkle (CA SBN 306374)
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, California 90025
`Telephone: (310) 826-7474
`Facsimile: (310) 826-6991
`
`Attorneys for Plaintiff
`FastVDO LLC
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF CALIFORNIA
`
` Case No. 3:16-cv-00385-H-WVG
`LEAD CASE
`
`Member Cases:
`16-cv-386-H (WVG)
`16-cv-389-H (WVG)
`16-cv-390-H (WVG)
`16-cv-394-H (WVG)
`16-cv-395-H (WVG)
`16-cv-396-H (WVG)
`
`
`
`FASTVDO LLC,
`Plaintiff,
` v.
`
`AT&T MOBILITY LLC,
`AT&T SERVICES, INC., and
`APPLE, INC.,
`
`
`
`Defendants
`
`PLAINTIFF’S PRELIMINARY CLAIM CONSTRUCTIONS AND
`PRELIMINARY IDENTIFICATION OF EXTRINSIC EVIDENCE
`Pursuant to Paragraph 7 of the Court’s Case Management Schedule, Plaintiff
`hereby provides its preliminary proposed construction of each claim term, phrase,
`or clause that it has identified for claim construction purposes. Plaintiff does not
`contend that any term is governed by 35 U.S.C. § 112(6). Plaintiff notes that these
`identifications are preliminary, and reserves all rights to amend or alter its claim
`construction positions.
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`16cv0385
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`RUSS, AUGUST & KABAT
`
`Page 1 of 3
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`I.
`
`
`
`Asserted Claim
`
`PRELIMINARY PROPOSED CONSTRUCTIONS
`
`Claim Term or Element
`
`1, 7, 12, 22, 28
`
`information within the first
`portion that is
`representative of a
`predetermined characteristic
`of the associated second
`portion
`
`Preliminary Proposed
`Construction
`information within the first
`portion that, if the first
`portion is decoded correctly,
`enables a predetermined
`characteristic of the
`associated second portion to
`be known.
`
`II.
`
`IDENTIFICATION
`
`OF
`
`EXTRINSIC
`
`PRELIMINARY
`EVIDENCE
`Plaintiff identifies, on a preliminary basis, the following extrinsic evidence
`supporting its claim constructions: The testimony of its expert witness, Branimir
`Vojcic. Dr. Vojcic will testify to the following subject matter: How a person of
`ordinary skill in the art would understand this term/phrase in view of the intrinsic
`evidence.
`
`DATED: May 27, 2016
`
`By: /s/ Christian W. Conkle
`Christian W. Conkle
`
`Marc A. Fenster (CA SBN 181067)
`Reza Mirzaie (CA SBN 246953)
`Jeffrey Z.Y. Liao (CA SBN 288994)
`Christian W. Conkle (CA SBN 306374)
`
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, California 90025
`Telephone: (310) 826-7474
`Facsimile: (310) 826-6991
`mfenster@raklaw.com
`rmirzaie@raklaw.com
`jliao@raklaw.com
`cconkle@raklaw.com
`Attorneys for Plaintiff FastVDO LLC
`
`
`
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`2
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`16cv0385
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`RUSS, AUGUST & KABAT
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`Page 2 of 3
`
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`
`
`CERTIFICATE OF SERVICE
`
`I certify that counsel of record is being served on May 27, 2016, with a copy of
`this document via Electronic Mail and on this date.
`/s/ Christian W. Conkle
`
`
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`RUSS, AUGUST & KABAT
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`Page 3 of 3
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