Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 1 of 17 PageID #: 1169
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`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`
`
`
`
`
`Civil Action No.: 6:16-cv-01133-RWS-KNM
`
`
`
`Judge Robert W. Schroeder III
`
`
`
`
`)
`
`))))
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`)
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`)))))
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`
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`
`
`v.
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`MACROPOINT, LLC,
`
`
`
`
`
`RUIZ FOOD PRODUCTS, INC.,
`
`
`Plaintiff,
`
`Defendant.
`
`
`
`
`JOINT CLAIM CONSTRUCTION CHART
`
`
`Pursuant to Local Patent Rule (P.R.) 4-5(d) for the United States District Court for the
`
`Eastern District of Texas and the Court’s Docket Control Order, (Feb. 13, 2017, ECF No. 43),
`
`Plaintiff MacroPoint, LLC, (“MacroPoint”) and Defendant Ruiz Food Products, Inc. (“Ruiz
`
`Foods”) jointly submit this Joint Claim Construction Chart, attached hereto as Exhibit A.
`
`
`
`Page 1 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 2 of 17 PageID #: 1170
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`
`
`
`Dated: September 14, 2017
`
`Respectfully submitted,
`
`
`
`
`/s/ Arthur P. Licygiewicz
`Arthur P. Licygiewicz (OH #0068458)
`THOMPSON HINE LLP
`3900 Key Center
`127 Public Square
`Cleveland, Ohio 44114
`Telephone:
`(216) 566-5500
`Facsimile:
`(216) 566-5800
`Art.Licygiewicz@thompsonhine.com
`
`Jeffrey C. Metzcar (OH #0072648)
`THOMPSON HINE LLP
`10050 Innovation Drive
`Suite 400
`Miamisburg, Ohio 45342
`Telephone:
`(937) 443-6841
`Facsimile:
`(937) 443-6635
`Jeff.Metzcar@thompsonhine.com
`
`Michael C. Smith (TX #18650410)
`SIEBMAN, BURG, PHILLIPS & SMITH, LLP
`113 East Austin Street
`P.O. Box 1556
`Marshall, TX 75671
`Telephone:
`(903) 938-8900
`Facsimile:
`(972) 767-4620
`michaelsmith@siebman.com
`
`Attorneys for Plaintiff
`MacroPoint, LLC
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Mark Deming
`Gary E. Hood (IL # 6281580)
`Adam S. Weiss (IL # 6256842)
`Mark Deming (IL # 6299631)
`POLSINELLI PC
`150 N. Riverside Plaza
`Suite 3000
`Chicago, IL 60606
`Telephone:
`(312) 819-1900
`Facsimile:
`(312) 819-1910
`ghood@polsinelli.com
`aweiss@polsinelli.com
`mdeming@polsinelli.com
`
`E. Glenn Thames, Jr. (TX # 00785097)
`POTTER MINTON P.C.
`110 N. College Avenue, Suite 500
`Tyler, TX 75702
`Telephone:
`(903) 597-8311
`Facsimile:
`(903) 593-0846
`glennthames@potterminton.com
`
`
`
`
`
`
`
`Attorneys for Defendant
`Ruiz Food Products, Inc.
`
`
`
`2
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`Page 2 of 17
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`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 3 of 17 PageID #: 1171
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`MacroPoint’s
`Proposed Construction
`identifying the mobile
`device after the telephone
`connection with the
`mobile device is initiated
`and before the
`connection ends
`
`Ruiz Foods’
`Proposed Construction
`No construction
`necessary; plain and
`ordinary meaning
`
`
`
`Court’s Construction
`
`Disputed Claim
`Term / Phrase
`’358 Patent, Claim 1:
`A computer implemented method for receiving
`consent from a user of a mobile device to
`obtaining location information of the mobile
`device, the method comprising:
`participating in a telephone call with the
`mobile device;
`within the telephone call, identifying the
`mobile device at least in part by obtaining an
`identifier associated with the mobile device;
`transmitting to the mobile device during the
`telephone call an automated voice message
`communicating to the user of the mobile
`device at least one of:
`a notice including information indicating that
`consenting to the obtaining of the location
`information of the mobile device would
`result in the location information of the
`mobile device being disclosed, and
`a location at which to find the notice,
`wherein the location at which to find the
`notice is represented by a web address
`corresponding to a website where, during
`the telephone call, the user can find the
`notice indicating to the user that consenting
`to the obtaining of the location information
`of the mobile device would result in the
`location information of the mobile device
`being disclosed; and
`receiving from the mobile device during the
`telephone call a signal including data
`
`1
`
`Page 3 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 4 of 17 PageID #: 1172
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`Disputed Claim
`Term / Phrase
`indicating consent for obtaining the location
`information of the mobile device.
`
`
`
`MacroPoint’s
`Proposed Construction
`
`Ruiz Foods’
`Proposed Construction
`
`Court’s Construction
`
`2
`
`Page 4 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 5 of 17 PageID #: 1173
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`Ruiz Foods’
`Proposed Construction
`No construction
`necessary; plain and
`ordinary meaning
`
`
`
`Court’s Construction
`
`MacroPoint’s
`Proposed Construction
`before the end of the
`telephone call, receiving
`from the mobile device
`one or more electrical or
`optical signals, analog or
`digital signals, data, one
`or more computer or
`processor instructions,
`messages, a bit or bit
`stream, or other means
`that can be received,
`transmitted or detected
`that signifies that consent
`to obtain the location
`information of the mobile
`device was granted
`
`Disputed Claim
`Term / Phrase
`’358 Patent, Claim 1:
`A computer implemented method for receiving
`consent from a user of a mobile device to
`obtaining location information of the mobile
`device, the method comprising:
`participating in a telephone call with the
`mobile device;
`within the telephone call, identifying the
`mobile device at least in part by obtaining an
`identifier associated with the mobile device;
`transmitting to the mobile device during the
`telephone call an automated voice message
`communicating to the user of the mobile
`device at least one of:
`a notice including information indicating that
`consenting to the obtaining of the location
`information of the mobile device would
`result in the location information of the
`mobile device being disclosed, and
`a location at which to find the notice,
`wherein the location at which to find the
`notice is represented by a web address
`corresponding to a website where, during
`the telephone call, the user can find the
`notice indicating to the user that consenting
`to the obtaining of the location information
`of the mobile device would result in the
`location information of the mobile device
`being disclosed; and
`receiving from the mobile device during the
`telephone call a signal including data
`
`3
`
`Page 5 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 6 of 17 PageID #: 1174
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`Disputed Claim
`Term / Phrase
`indicating consent for obtaining the
`location information of the mobile device.
`
`
`
`MacroPoint’s
`Proposed Construction
`
`Ruiz Foods’
`Proposed Construction
`
`Court’s Construction
`
`4
`
`Page 6 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 7 of 17 PageID #: 1175
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`Ruiz Foods’
`Proposed Construction
`No construction
`necessary; plain and
`ordinary meaning
`
`
`
`Court’s Construction
`
`MacroPoint’s
`Proposed Construction
`receive one or more
`electrical or optical
`signals, analog or digital
`signals, data, one or more
`computer or processor
`instructions, messages, a
`bit or bit stream, or other
`means that can be
`received, transmitted or
`detected that indicates
`that consent to send
`location information was
`given
`
`Disputed Claim
`Term / Phrase
`’659 Patent, Claim 2:
`A machine or group of machines for monitoring
`location of at least one of a vehicle or freight
`carried by the vehicle, comprising:
`a server comprising a central processing unit, a
`memory, a clock, and a server
`communication transceiver that receives
`location information of a mobile device, the
`mobile device comprising a GPS receiver, a
`microprocessor and a wireless
`communication transceiver coupled to the
`GPS receiver, the mobile device comprising
`the GPS receiver programmed to receive data
`sent by a plurality of GPS satellites, calculate
`location information of the mobile device
`comprising the GPS receiver and transmit the
`location information, the central processing
`unit programmed to:
`receive a request for information regarding the
`location of the vehicle or the freight carried
`by the vehicle;
`request location information of the mobile
`device comprising the GPS receiver from a
`location information provider;
`receive a signal that indicates that consent
`was given to transmission of location
`information;
`receive from the location information provider
`location information of the mobile device
`comprising the GPS receiver, wherein the
`location information of the mobile device
`
`5
`
`Page 7 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 8 of 17 PageID #: 1176
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`MacroPoint’s
`Proposed Construction
`
`Ruiz Foods’
`Proposed Construction
`
`Court’s Construction
`
`Disputed Claim
`Term / Phrase
`comprising the GPS receiver originated from
`a device other than the mobile device
`comprising the GPS receiver itself; and
`estimate the location of the vehicle or the
`freight carried by the vehicle based at least in
`part on the location information of the
`mobile device comprising the GPS receiver;
`and
`communicate the location of the vehicle or the
`freight carried by the vehicle to cause a
`representation of the location of the vehicle
`or the freight carried by the vehicle.
`
`
`
`6
`
`Page 8 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 9 of 17 PageID #: 1177
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`Ruiz Foods’
`Proposed Construction
`No construction
`necessary; plain and
`ordinary meaning
`
`
`
`Court’s Construction
`
`MacroPoint’s
`Proposed Construction
`Plain and ordinary
`meaning of “receive a
`sign or piece of
`information that consent
`to sending location
`information has been
`given.”
`
`Disputed Claim
`Term / Phrase
`’659 Patent, Claim 23:
`A machine or group of machines for monitoring
`location of at least one of a vehicle or freight
`carried by the vehicle, the machine or group of
`machines comprising:
`a server comprising a central processing unit, a
`memory, a clock, and a server
`communication transceiver that receives
`location information of a mobile device, the
`mobile device comprising a GPS receiver, a
`microprocessor and a wireless
`communication transceiver coupled to the
`GPS receiver, the mobile device comprising
`the GPS receiver programmed to receive data
`sent by a plurality of GPS satellites, calculate
`location information of the mobile device
`comprising the GPS receiver and transmit the
`location information, the central processing
`unit programmed to:
`receive a request for information regarding the
`location of the vehicle or the freight carried
`by the vehicle, and
`request location information of the vehicle or
`the freight carried by the vehicle from a
`location information provider;
`receive an indication that consent to
`transmission of location information has
`been given; and
`receive location information of the vehicle or
`the freight carried by the vehicle from the
`location information provider;
`
`7
`
`Page 9 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 10 of 17 PageID #: 1178
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`MacroPoint’s
`Proposed Construction
`
`Ruiz Foods’
`Proposed Construction
`
`Court’s Construction
`
`Disputed Claim
`Term / Phrase
`estimate the location of the vehicle or the
`freight carried by the vehicle from the
`location information received from the
`location information provider;
`communicate the location of the vehicle or the
`freight carried by the vehicle.
`
`
`
`8
`
`Page 10 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 11 of 17 PageID #: 1179
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`Court’s Construction
`
`
`
`Ruiz Foods’
`Proposed Construction
`To the extent the claims
`reciting this limitation
`are not invalid under 35
`U.S.C. § 101, it should
`be construed as follows:
`
`112, ¶ 6; Indefinite
`
`Function: participating in
`and transmitting and
`receiving during a
`telephone call according
`to an undisclosed
`algorithm
`
`Structure: no
`corresponding algorithm,
`structure, material, or
`acts disclosed for
`performing recited
`functions
`
`Disputed Claim
`Term / Phrase
`’358 Patent, Claim 19:
`A system for receiving user consent to obtaining
`location information of a mobile device, the
`system comprising:
`a communications interface configured to
`participate in a telephone call with the mobile
`device;
`a validation logic configured to, within the
`telephone call, identify the mobile device at
`least in part by obtaining an identifier
`associated with the mobile device; and
`a notification logic configured to communicate
`during the telephone call an automated voice
`message including at least one of:
`a notice including information indicating to
`the user of the mobile device that
`consenting to the obtaining of the location
`information of the mobile device would
`result in the location information of the
`mobile device being disclosed, and
`a location at which to find the notice,
`wherein the location at which to find the
`notice is represented by a web address
`corresponding to a website where, during
`the telephone call, the user of the mobile
`device can find the notice including
`information indicating to the user of the
`mobile device that consenting to the
`obtaining of the location information of the
`mobile device would result in the location
`information of the mobile device being
`
`MacroPoint’s
`Proposed Construction
`No construction is
`required.
`
`This claim term is not a
`means-plus-function term
`governed by 35 U.S.C.
`§ 112(f). To the extent an
`identification of function
`and corresponding
`structure is required:
`
`Function: participate in a
`telephone call with a
`mobile device
`
`Structure: a card;
`hardware, firmware,
`software or combinations
`of each, a “logic,” a
`software controlled
`microprocessor, discrete
`logic like an application
`specific integrated circuit
`(ASIC), a programmed
`logic device, or a
`memory device
`containing instructions
`
`9
`
`Page 11 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 12 of 17 PageID #: 1180
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`Disputed Claim
`Term / Phrase
`
`disclosed;
`wherein the communications interface is
`configured to transmit during the telephone
`call the automated voice message to the
`mobile device, and
`wherein the communications interface is
`further configured to, during the telephone
`call, receive from the mobile device data
`indicating the user consent for obtaining the
`location information of the mobile device.
`
`
`
`MacroPoint’s
`Proposed Construction
`
`Ruiz Foods’
`Proposed Construction
`
`Court’s Construction
`
`10
`
`Page 12 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 13 of 17 PageID #: 1181
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`Court’s Construction
`
`
`
`Ruiz Foods’
`Proposed Construction
`To the extent the claims
`reciting this limitation
`are not invalid under 35
`U.S.C. § 101, it should
`be construed as follows:
`
`112, ¶ 6; Indefinite
`
`Function: identifying a
`mobile device according
`to an undisclosed
`algorithm
`
`Structure: no
`corresponding algorithm,
`structure, material, or
`acts disclosed for
`performing recited
`functions
`
`Disputed Claim
`Term / Phrase
`’358 Patent, Claim 19:
`A system for receiving user consent to obtaining
`location information of a mobile device, the
`system comprising:
`a communications interface configured to
`participate in a telephone call with the mobile
`device;
`a validation logic configured to, within the
`telephone call, identify the mobile device at
`least in part by obtaining an identifier
`associated with the mobile device; and
`a notification logic configured to communicate
`during the telephone call an automated voice
`message including at least one of:
`a notice including information indicating to
`the user of the mobile device that
`consenting to the obtaining of the location
`information of the mobile device would
`result in the location information of the
`mobile device being disclosed, and
`a location at which to find the notice,
`wherein the location at which to find the
`notice is represented by a web address
`corresponding to a website where, during
`the telephone call, the user of the mobile
`device can find the notice including
`information indicating to the user of the
`mobile device that consenting to the
`obtaining of the location information of the
`mobile device would result in the location
`information of the mobile device being
`
`MacroPoint’s
`Proposed Construction
`To the extent a
`construction is required,
`this term should be
`construed as “hardware,
`firmware, software or
`combinations of each that
`performs or causes a
`validation action to be
`performed”
`
`This claim term is not a
`means-plus-function term
`governed by 35 U.S.C.
`§ 112(f). To the extent an
`identification of function
`and corresponding
`structure is required:
`
`Function: identifying a
`mobile device
`
`Structure: hardware,
`firmware, software or
`combinations of each, a
`“logic,” a software
`controlled
`microprocessor, discrete
`logic like an application
`specific integrated circuit
`(ASIC), a programmed
`logic device, a memory
`
`11
`
`Page 13 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 14 of 17 PageID #: 1182
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`Disputed Claim
`Term / Phrase
`
`disclosed;
`wherein the communications interface is
`configured to transmit during the telephone
`call the automated voice message to the
`mobile device, and
`wherein the communications interface is
`further configured to, during the telephone
`call, receive from the mobile device data
`indicating the user consent for obtaining the
`location information of the mobile device.
`
`
`
`MacroPoint’s
`Proposed Construction
`device containing
`instructions
`
`Ruiz Foods’
`Proposed Construction
`
`Court’s Construction
`
`12
`
`Page 14 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 15 of 17 PageID #: 1183
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`Court’s Construction
`
`
`
`Ruiz Foods’
`Proposed Construction
`To the extent the claims
`reciting this limitation
`are not invalid under 35
`U.S.C. § 101, it should
`be construed as follows:
`
`112, ¶ 6; Indefinite
`
`Function: communicating
`an automatic voice
`message during a
`telephone call according
`to an undisclosed
`algorithm
`
`Structure: no
`corresponding algorithm,
`structure, material, or
`acts disclosed for
`performing recited
`functions
`
`Disputed Claim
`Term / Phrase
`’358 Patent, Claim 19:
`A system for receiving user consent to obtaining
`location information of a mobile device, the
`system comprising:
`a communications interface configured to
`participate in a telephone call with the mobile
`device;
`a validation logic configured to, within the
`telephone call, identify the mobile device at
`least in part by obtaining an identifier
`associated with the mobile device; and
`a notification logic configured to
`communicate during the telephone call an
`automated voice message including at least
`one of:
`a notice including information indicating to
`the user of the mobile device that
`consenting to the obtaining of the location
`information of the mobile device would
`result in the location information of the
`mobile device being disclosed, and
`a location at which to find the notice,
`wherein the location at which to find the
`notice is represented by a web address
`corresponding to a website where, during
`the telephone call, the user of the mobile
`device can find the notice including
`information indicating to the user of the
`mobile device that consenting to the
`obtaining of the location information of the
`mobile device would result in the location
`
`MacroPoint’s
`Proposed Construction
`To the extent a
`construction is required,
`this term should be
`construed as “hardware,
`firmware, software or
`combinations of each that
`performs or causes a
`notification action to be
`performed”
`
`This claim term is not a
`means-plus-function term
`governed by 35 U.S.C.
`§ 112(f). To the extent an
`identification of function
`and corresponding
`structure is required:
`
`Function: communicating
`information
`
`Structure: hardware,
`firmware, software or
`combinations of each, a
`“logic,” a software
`controlled
`microprocessor, discrete
`logic like an application
`specific integrated circuit
`(ASIC), a programmed
`logic device, a memory
`
`13
`
`Page 15 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 16 of 17 PageID #: 1184
`Exhibit A – Joint Claim Construction Chart under P.R. 4-5(d)
`
` U.S. Pat. Nos. 8,275,358 and 9,429,659
`
`MacroPoint’s
`Proposed Construction
`device containing
`instructions
`
`Ruiz Foods’
`Proposed Construction
`
`Court’s Construction
`
`Disputed Claim
`Term / Phrase
`information of the mobile device being
`disclosed;
`wherein the communications interface is
`configured to transmit during the telephone
`call the automated voice message to the
`mobile device, and
`wherein the communications interface is
`further configured to, during the telephone
`call, receive from the mobile device data
`indicating the user consent for obtaining the
`location information of the mobile device.
`
`
`
`14
`
`Page 16 of 17
`
`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
`
`

`

`Case 6:16-cv-01133-RWS-KNM Document 63 Filed 09/14/17 Page 17 of 17 PageID #: 1185
`
`
`CERTIFICATE OF SERVICE
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` certify that all counsel of record who are deemed to have consented to electronic service
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` I
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`are being served with a copy of the foregoing Joint Claim Construction Chart through the
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`Court’s CM/ECF system in accordance with Local Rule CV-5(a)(3) on September 14, 2017, and
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`that a copy of the Joint Claim Construction Chart (including Exhibit A thereto) in Word format
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`is being provided on computer disk to the Court.
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`By:
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`/s/ James T. Fisher
`James T. Fisher
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`An Attorney for Plaintiffs
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`Page 17 of 17
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`RUIZ FOOD PRODUCTS, INC.
`Exhibit 1021
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