Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 1 of 14 PageID #: 2852
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`The following claim terms remain in dispute.
`
`NO.
`
`TERM
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`
`COURT’S CONSTRUCTION
`
`“characterizing
`quantities of the
`communication quality
`for each of the groups”
`(’139 Patent, Claims 1
`and 11)
`
`“a storage unit in
`which group
`information generated
`by classifying the
`plurality of base
`stations into groups”
`(’139 Patent, Claim 11)
`
`“combining” /
`“combined”
`(’292 Patent, Claims 1
`and 2)
`
`“GPS/cellular
`positioning results
`combining means for
`combining the GPS-
`based position result
`and the cellular-based
`position result with the
`
`1
`
`2
`
`
`3
`
`4
`
`
`
`TERMS FOR HUAWEI PATENTS
`
`“characteristics of the
`communication quality for each of
`the groups”
`
`“group scores derived from the
`indication of communication quality
`for each base station in a group”
`
`Not indefinite; plain and ordinary
`meaning
`
`
`Indefinite because the claim term
`does not inform those skilled in the
`art about the claim’s scope with
`reasonable certainty
`
`“a determination based on one or
`more inputs”
`
`“merging”/ “merged”
`
`Function: combining the GPS-
`based position result and the
`cellular-based position result with
`the GPS positioning reliability and
`the cellular positioning reliability
`Structure: GPS/cellular positioning
`results combining unit 400 and/or
`
`Function: combining the GPS
`based position result and the
`cellular-based position result with
`the GPS positioning reliability and
`the cellular positioning reliability
`Structure: GPS / Cellular
`Positioning Results Combining Unit
`
`A-1
`
`
`
`
`
`
`
`
`
`ZTE v. Maxell
`IPR2018-00235
`Maxell Ex. No. 2002
`
`Page 1 of 14
`
`

`

`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 2 of 14 PageID #: 2853
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`400 performing the weighted mean
`disclosed in Figure 3 and at col.
`4:49-56, block 606 in Fig. 2
`
`COURT’S CONSTRUCTION
`
`Function: (1) receiving GPS
`oriented signals and (2) generating
`received GPS signals
`Structure: GPS receiver 200, Block
`600 in Figure 2
`
`
`
`NO.
`
`TERM
`
`GPS positioning
`reliability and the
`cellular positioning
`reliability”
`(’292 Patent, Claim 1)
`
`5
`
`“GPS receiver means
`for receiving GPS-
`oriented signals and
`generating received
`GPS signals”
`(’292 Patent, Claim 1)
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`components within a mobile handset
`that perform processing functions,
`such as, a CPU programmed to
`execute processing in accordance
`with the algorithm set forth in the
`specification, a processor that
`combines GPS/cellular position as
`described in Fig. 2 (block 605) and
`corresponding recitations in the
`specification as provided herein, or
`equivalents thereof. See e.g., (4:42-
`56), (Fig. 3 at 400), (3:12-17), (5:3-
`7).
`
`Function: receiving GPS-oriented
`signals and generating received GPS
`signals
`Structure: A GPS receiver 200
`and/or components within a mobile
`handset that receive GPS signals,
`such as, an antenna and a
`transceiver or a processor that
`performs GPS receiving processes
`as described in Fig. 2 (block 600)
`and corresponding recitations in the
`specification as provided below or
`equivalents thereof. See e.g., (2:64-
`65; block 600 in Fig. 2), (3:24-32),
`(4:65-5:2), (2:53-57), (5:3-7).
`
`
`6
`
`“cellular receiver
`
`Function: receiving cellular-
`
`Function: (1) receiving cellular-
`
`
`
`
`
`A-2
`
`Page 2 of 14
`
`

`

`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 3 of 14 PageID #: 2854
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`COURT’S CONSTRUCTION
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`oriented signals and (2) generating
`received cellular signals
`Structure: cellular receiver 300,
`Block 603 in Fig. 2
`
`NO.
`
`TERM
`
`means for receiving
`cellular-oriented
`signals and generating
`received cellular
`signals”
`(’292 Patent, Claim 1)
`
`7
`
`“GPS position
`calculation means for
`calculating the mobile
`handset's position from
`the received GPS
`signals and outputting
`a GPS-based position
`result”
`(’292 Patent, Claim 1)
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`oriented signals and generating
`received cellular signals
`Structure: A cellular receiver 300
`and/or components within a mobile
`handset that receive and generate
`cellular signals, such as, an antenna,
`a transceiver, a processor that
`performs cellular receiving
`processes as described in Fig. 2
`(block 603) and corresponding
`recitations in the specification
`provided herein, or equivalents
`thereof. See e.g., (2:66-3:4), (3:10-
`11; see block 603 in Fig. 2), (4:4-9),
`(2:53-57), (5:3-7).
`
`Function: calculating the mobile
`handset's position from the received
`GPS signals and outputting a GPS-
`based position result
`Structure: At least one processor,
`for example, position calculation
`unit 201 and/or a mobile handset
`that perform processing functions or
`equivalents thereof. See e.g., (2:64-
`65; block 601 in Fig. 2), (3:24-38),
`(2:53-60), (5:3-7).
`
`Function: (1) calculating the mobile
`handset’s position from the received
`GPS signals and (2) outputting a
`GPS-based position result.
`Structure: position calculation unit
`for GPS 201, Block 601 in Fig. 2
`
`
`
`
`
`8
`
`“cellular position
`calculation means for
`calculating the mobile
`handset's position from
`
`Function: calculating the mobile
`handset's position from the received
`cellular signals and outputting a
`cellular-based position result
`
`Function: (1) calculating the mobile
`handset’s position from the received
`cellular signals and (2) outputting a
`cellular based position result.
`
`
`
`A-3
`
`Page 3 of 14
`
`

`

`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 4 of 14 PageID #: 2855
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`NO.
`
`TERM
`
`the received cellular
`signals and outputting
`a cellular-based
`position result”
`(’292 Patent, Claim 1)
`
`9
`
`“GPS reliability
`calculation means for
`calculating GPS
`positioning reliability
`based on the GPS-
`based position result”
`(’292 Patent, Claim 1)
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`Structure: A position calculation
`unit 301 and/or components within a
`mobile handset that perform
`processing functions, such as, a
`CPU programmed to execute
`processing in accordance with the
`algorithm set forth in the
`specification, or a processor that
`performs cellular position
`calculation processes as described in
`Fig. 2 (block 604) and
`corresponding recitations in the
`specification as provided herein, or
`equivalents thereof. See e.g., (1:23-
`27), (3:10-11; block 604 in Fig. 2),
`(4:4-16), (2:66-3:6), (5:3-7).
`
`Function: calculating GPS
`positioning reliability based on the
`GPS-based position result
`Structure: A GPS reliability
`calculation unit 204 and/or
`components within a mobile handset
`that perform processing functions,
`such as, a CPU programmed to
`execute processing in accordance
`with the algorithm set forth in the
`specification, a processor that
`performs GPS reliability calculation
`processes described in Fig. 2 (block
`602) and corresponding recitations
`in the specification as provided
`herein, or equivalents thereof. See
`
`COURT’S CONSTRUCTION
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`Structure: position calculation unit
`for cellular 301, which is
`insufficient structure because the
`specification does not disclose the
`necessary algorithm or flowchart,
`which renders the term indefinite
`
`
`
`Function: calculating GPS
`positioning reliability based on the
`GPS-based position result
`Structure: GPS reliability
`calculation unit 204, which is
`insufficient structure because the
`specification does not disclose the
`necessary algorithm or flowchart,
`which renders the term indefinite
`
`
`
`A-4
`
`Page 4 of 14
`
`

`

`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 5 of 14 PageID #: 2856
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`NO.
`
`TERM
`
`10
`
`“cellular reliability
`calculation means for
`calculating cellular
`positioning reliability
`based on the cellular-
`based position result”
`(’292 Patent, Claim 1)
`
`“still pictures encoded
`by a second encoding
`method, and second
`pictures corresponding
`to the still pictures and
`having a smaller
`number of pixels than
`the still pictures are
`recorded”
`
`11
`
`
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`e.g., (2:60-65; block 602 in Fig. 2),
`(3:38-4:3), (5:3-7).
`
`Function: calculating cellular
`positioning reliability based on the
`cellular-based position result
`Structure: A cellular reliability
`calculation unit 304 and/or
`components within a mobile handset
`that perform processing functions,
`such as, a CPU programmed to
`execute processing in accordance
`with the algorithm set forth in the
`specification, , a processor that
`performs cellular reliability
`calculation processes as described in
`Fig. 2 (block 605) and
`corresponding recitations in the
`specification as provided herein, or
`equivalents thereof. See e.g., (3:10-
`11; block 605 in Fig. 2), (4:15-42),
`(3:6-11), (5:3-7).
`
`Plain and ordinary meaning
`
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`
`COURT’S CONSTRUCTION
`
`
`
`
`
`Function: calculating cellular
`positioning reliability based on the
`cellular-based position result
`Structure: cellular reliability
`calculation unit 304, which is
`insufficient structure because the
`specification does not disclose the
`necessary algorithm or flowchart,
`which renders the term indefinite
`
`“still pictures encoded by the first
`encoding method and by a second
`encoding method, and second
`pictures corresponding to the still
`pictures and having a smaller
`number of pixels than the still
`pictures are recorded”
`
`A-5
`
`Page 5 of 14
`
`

`

`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 6 of 14 PageID #: 2857
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`NO.
`
`TERM
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`
`COURT’S CONSTRUCTION
`
`(’440 Patent, Claims 1,
`3, 5, 7)
`
`“first encoding
`method”
`(’760 Patent, Claims 1,
`3, 4, 6, 7, 9, 10, 12, 13,
`and 15)
`
`“selection switching
`determination unit for
`selecting one from said
`first and second
`physical interfaces to
`switch to a selected
`physical interface”
`(’517 Patent, Claim 1)
`
`“wherein said selection
`switching
`determination unit
`makes a selection
`switching based on the
`communication
`availability determined
`by said communication
`determination unit, the
`moving speed
`determined by said
`movement
`determination unit, and
`
`12
`
`13
`
`
`
`
`
`
`
`Plain and ordinary meaning
`
`“moving picture encoding method”
`
`Not means-plus-function terms;
`plain and ordinary meaning
`
`
`Function: selecting one from said
`first and second physical interfaces
`to switch to a selected physical
`interface, wherein said selection
`switching determination unit makes
`a selection switching based on the
`communication availability
`determined by said communication
`determination unit, the moving
`speed determined by said movement
`determination unit, and the position
`detected by said position detection
`unit and wherein said selection
`switching determination unit waits a
`longer time until switching of said
`physical interface when said
`movement determination unit
`determines the moving speed being
`faster
`Structure: Switching determination
`unit 108 and the algorithms in FIGs.
`4, 6, and 9, which is insufficient
`structure because the specification
`
`A-6
`
`Page 6 of 14
`
`

`

`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 7 of 14 PageID #: 2858
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`NO.
`
`TERM
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`does not disclose the necessary
`algorithm or flowchart, which
`renders the term indefinite.
`
`COURT’S CONSTRUCTION
`
`the position detected by
`said position detection
`unit”
`(’517 Patent, Claim 1)
`
`“wherein said selection
`switching
`determination unit
`waits a longer time
`until switching of said
`physical interface when
`said movement
`determination unit
`determines the
`movement speed being
`faster”
`(’517 Patent, Claim 1)
`
`“waits a longer time
`until switching”
`(’517 Patent, Claim 1)
`
`“when any change
`occurs in the video
`signal inputted to the
`input portion”
`
`“when the change of
`the video signal does
`not occur and when the
`
`14
`
`15
`
`
`
`Plain and ordinary meaning
`
`Plain and ordinary meaning
`
`
`
`
`
`sets a longer period of time to wait
`before determining whether to
`switch
`
`“in response to any change
`occurring in the video signal
`inputted to the input portion”
`“in response to the change of the
`video signal not occurring and the
`illumination detected by the
`illumination sensor being above a
`predetermined value”
`
`A-7
`
`Page 7 of 14
`
`

`

`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 8 of 14 PageID #: 2859
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`NO.
`
`TERM
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`
`COURT’S CONSTRUCTION
`
`illumination detected
`by the illumination
`sensor is above a
`predetermined value”
`
`(’901 Patent, Claim 1)
`
`“an input entered by a
`user”
`(’438 Patent, Claim 1)
`
`“a detecting means for
`detecting whether a
`user associated
`medium at least
`approaches at least
`part of a housing of
`said apparatus”
`(’443 Patent, Claim 1)
`
`16
`
`17
`
`
`
`
`
`
`
`Plain and ordinary meaning
`
`“data entered by a user, such as a
`user ID and password, that validates
`the user”
`
`TERM FOR OVERLAPPING ‘443 PATENT
`
`Function: detecting whether a user
`associated medium at least
`approaches at least part of a housing
`of said apparatus
`Structure: A sensor, a touch-
`sensitive surface, or a tablet
`configured to detect proximity
`and/or contact using one or more of
`an electromagnetic induction
`system, a capacitance system , a
`capacitive coupling system, a
`pressure-sensitive resistance system,
`a transmission pen type ultrasonic
`system, a surface acoustic wave type
`ultrasonic system, an optical system,
`an image sensor, a camera, a
`microphone, or a temperature
`sensor, as well as equivalents
`
`This term is written as a means-
`plus-function
`Function: for detecting whether a
`user-associated medium at least
`approaches at least a part of a
`housing of said apparatus
`Structure: Electromagnetic
`induction systems, electrostatic
`coupling system, and Optical
`system, listed in Table 1;
`“microphone” (18:8); “temperature
`sensor” (19:12); “cameras” (Figs. 14
`and 15)
`
`A-8
`
`Page 8 of 14
`
`

`

`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 9 of 14 PageID #: 2860
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`NO.
`
`TERM
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`
`COURT’S CONSTRUCTION
`
`thereof
`
`TERMS FOR ZTE PATENTS
`
`18
`
`“controller means for
`detecting change in
`said method of
`compression and
`encoding, and for
`transferring the
`decoding program code
`corresponding to the
`method of the
`compression and
`encoding after being
`changed, from said
`read-only memory to
`said first memory”
`(’491 Patent, Claim 1)
`
`Function: detecting change in said
`method of compression and
`encoding, and for transferring the
`decoding program code
`corresponding to the method of the
`compression and encoding after
`being changed, from said read-only
`memory to said first memory
`Structure: At least one processor –
`such as a CPU –programmed to
`execute processing in accordance
`with the algorithm set forth in
`flowcharts of Fig. 4 (including steps
`S3, S5-S9), Fig. 9 (including steps
`S3-S14) and corresponding citations
`in the specification at 5:60-64, 6:30-
`7:54, 9:13-18, 9:28-44, and FIGS. 1,
`4-6, and 9, as well as equivalents
`thereof
`
`
`
`This is a means-plus-function
`element to be construed in
`accordance with 35 U.S.C. § 112, ¶
`6.
`Function: Claim 1: “for detecting
`change in said method of
`compression and encoding, and for
`transferring the decoding program
`code corresponding to the method of
`the compression and encoding after
`being changed, from said read-only
`memory to said first memory”
`Claim 2: “for transferring said plural
`decoding program codes from said
`read only memory to said second
`memory in advance, as well as for
`detecting change in said method of
`compression and encoding, and for
`transferring the decoding program
`code corresponding to the method of
`the compression and encoding after
`being changed, from said read only
`memory to said first memory”
`Structure: Claims 1 &2 : an external
`CPU (FIG 1) connected via a bus
`between a read only memory and
`the first memory, running the
`algorithm of Figs. 4 and 5. (6:30–
`
`
`
`A-9
`
`Page 9 of 14
`
`

`

`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 10 of 14 PageID #: 2861
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`NO.
`
`TERM
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`
`COURT’S CONSTRUCTION
`
`“a demultiplexer for
`inputting one audio
`data sequence which is
`compressed and
`encoded, being selected
`from a plurality of
`audio data sequences
`which are multiplexed”
`(’491 Patent, Claims 7
`and 8)
`
`“walking navigation”
`(’317 Patent, Claims 1,
`10, 15, 16, 17, and 20)
`
`“said device connected
`to said server
`outputting said location
`information and said
`direction information
`and receiving retrieved
`information based on
`said outputted
`information at said
`server”
`(’317 Patent, Claim 6)
`
`19
`
`20
`
`21
`
`
`
`Not a means-plus-function term;
`plain and ordinary meaning
`
`“information to navigate a user who
`is walking”
`
`Plain and ordinary meaning
`
`
`
`
`
`
`
`7:54)
`
`Indefinite
`Alternative if not indefinite: a
`demultiplexer that outputs one data
`sequence, which is compressed and
`encoded, to the input of a frame
`sync. The demultiplexer itself does
`this inputting and also extracts the
`method of compression and
`encoding.
`
`“display of information to assist a
`user in walking, not driving, in a
`system that is not usable in an object
`car that is running on a road”
`
`Indefinite
`This is a means-plus-function
`element to be construed in
`accordance with 35 U.S.C. § 112, ¶
`6.
`Function: outputting said location
`information and said direction
`information and receiving retrieved
`information based on said outputted
`information at said server
`Structure: insufficient corresponding
`structure is disclosed
`
`A-10
`
`Page 10 of 14
`
`

`

`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 11 of 14 PageID #: 2862
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`TERM
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`
`COURT’S CONSTRUCTION
`
`NO.
`
`22
`
`Plain and ordinary meaning
`
`“an image sensing
`device having an array
`of pixels arranged
`vertically and
`horizontally in a grid
`pattern”
`(’729 Patent, Claim 1)
`
`
`
`
`
`This is a means-plus-function
`element to be construed in
`accordance with 35 U.S.C. § 112, ¶
`6.
`Function: “for image sensing”
`Structure: a solid state image
`sensing device with a light receiving
`sensor having an array of pixels
`arranged vertically and horizontally
`in a grid pattern and having an equal
`number of color sensitive filter
`elements arranged such that each
`color forms a vertical line.
`See “a solid-state image sensing
`device with a light receiving sensor
`having an array of pixels arranged
`vertically and horizontally in a grid
`pattern, in an N number of vertically
`arranged pixel lines” (2:59)
`See also FIGs. 10, 13A, and 13B;
`[6:17-22]; [15:23-35]
`
`Indefinite
`This is a means-plus-function
`element to be construed in
`accordance with 35 U.S.C. § 112, ¶
`6.
`Function: “detecting an image-
`instability of the electric camera”
`
`23
`
`“an image-instability
`detector” (’729 Patent,
`Claim 1)
`
`“a device, such as a gyroscopic
`sensor or the like, capable of
`detecting an image instability of the
`electric camera”
`
`
`
`A-11
`
`Page 11 of 14
`
`

`

`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 12 of 14 PageID #: 2863
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`NO.
`
`TERM
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`Structure: insufficient
`corresponding structure disclosed
`
`COURT’S CONSTRUCTION
`
`“an amount of image-
`instability of the
`camera”
`(’729 Patent, Claim 1)
`
`“to change a position of
`the second effective set
`of pixels according to
`the amount of image-
`instability detected by
`the image-instability
`detector, in order to
`correct the image-
`instability”
`(’729 Patent, Claim 1)
`
`“a display unit
`configured to display
`an image
`corresponding to the
`image signals formed
`by the signal processing
`unit”
`(’729 Patent, Claim 1)
`
`24
`
`25
`
`26
`
`
`
`
`
`
`
`
`
`“an amount of instability caused by
`vertical and/or horizontal movement
`of the electric camera”
`
`Indefinite
`
`“based on the converted pixel
`numbers, the position of an
`extracted area (effective pixel area)
`on the light receiving surface is
`shifted, in order to correct the
`image-instability”
`
`“Based on the converted pixel
`numbers, the position of an
`extracted area (effective pixel area)
`on the light receiving surface is
`shifted in a direction that cancels the
`image-instability.”
`
`Plain and ordinary meaning
`
`This is a means-plus-function
`element to be construed in
`accordance with 35 U.S.C. § 112, ¶
`6.
`Function: “for displaying an image
`corresponding to the image signals
`formed by the signal processing
`unit”
`Structure: “display screen of a
`television system” (3:22-23) or
`other screen compatible with NTSC
`or PAL format (1:35–36; 10:19–21)
`
`A-12
`
`Page 12 of 14
`
`

`

`NO.
`
`27
`
`28
`
`29
`
`“A cellular telephone
`adapted to be used in a
`CDMA system,
`comprising”
`(’193 Patent, all asserted
`claims)
`
`“variable amplitude
`amplifier”
`(’193 Patent, Claims 1
`and 7)
`
`“function device(s)”
`(’794 Patent, Claims 1
`and 9)
`
`“component device” /
`“component devices for
`performing different
`functions in the device”
`(’794 Patent, Claim 9)
`
`The preambles are not limiting.
`
`Preambles are limiting
`
`Plain and ordinary meaning
`
`“hardware, software, or a
`combination of the two that
`consumes power and implements
`one or more functions of the
`information processing device”
`
`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 13 of 14 PageID #: 2864
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`TERM
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`
`COURT’S CONSTRUCTION
`
`
`
`
`
`
`
`
`
`“device that includes a first-stage
`amplifier, two filters, an up-
`converter, and a second-stage
`amplifier”
`
`Indefinite
`This is a means-plus-function
`element to be construed in
`accordance with 35 U.S.C. § 112, ¶
`6.
`Function: “modem functions”
`(1:20); “audio communication
`function (function device A) and a
`videophone function (function
`device B)” (1:31-32); no function
`otherwise disclosed
`Structure: insufficient
`corresponding structure disclosed
`
`This is a means-plus-function
`element to be construed in
`accordance with 35 U.S.C. § 112, ¶
`6.
`
`30
`
`“a controller for
`receiving a method of
`compression and
`encoding from said
`
`Not a means-plus-function term;
`plain and ordinary meaning.
`
`
`
`A-13
`
`Page 13 of 14
`
`

`

`Case 5:16-cv-00178-RWS Document 108-1 Filed 11/03/17 Page 14 of 14 PageID #: 2865
`EXHIBIT A:
`DISPUTED CLAIM TERMS
`
`PLAINTIFF’S PROPOSED
`CONSTRUCTION
`
`NO.
`
`TERM
`
`demultiplexer . . .”
`(’695 Patent, Claims 1
`and 4)
`
`
`
`
`
`COURT’S CONSTRUCTION
`
`DEFENDANTS’ PROPOSED
`CONSTRUCTION
`Function: “for receiving a method
`of compression and encoding from
`said demultiplexer, for detecting
`whether said method of compression
`and encoding changes to another
`method of compression and
`encoding or not, and if said method
`of compression and encoding
`changes, for downloading the
`decoding program code
`corresponding to said another
`method of compression and
`encoding to said memory from
`outside said memory”
`Structure: an external CPU (FIG 1)
`connected via a bus between a read
`only memory and the memory,
`running the algorithm of Figs. 4 and
`5. (6:30–7:54)
`
`A-14
`
`Page 14 of 14
`
`