`
`RUSS, AUGUST & KABAT
`Marc A. Fenster (CA Bar No. 181067)
`Benjamin T. Wang (CA Bar No. 228712)
`Neil A. Rubin (CA Bar No. 250761)
`Bahrad A. Sokhansanj (CA Bar No. 285185)
`James S. Tsuei (CA Bar No. 285530)
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, California 90025
`Telephone: (310) 826-7474
`Facsimile: (310) 826-6991
`mfenster@raklaw.com
`bwang@raklaw.com
`nrubin@raklaw.com
`bsokhansanj@raklaw.com
`jtsuei@raklaw.com
`
`Attorneys for Plaintiff
`Corephotonics, Ltd.
`
`COOLEY LLP
`Heidi Keefe (176960)
`(hkeefe@cooley.com)
`Lowell Mead (223989)
`(lmead@cooley.com)
`Priya B. Viswanath (238089)
`(pviswanath@cooley.com)
`3175 Hanover Street
`Palo Alto, California 94304
`Telephone:
`(650) 843-5000
`Facsimile:
`(650) 849-7400
`
`COOLEY LLP
`Stephen Smith (Pro Hac Vice)
`stephen.smith@cooley.com
`Phillip Morton (Pro Hac Vice)
`(pmorton@cooley.com)
`1299 Pennsylvania Avenue
`NW, Suite 700
`Washington, DC 20004-2400
`Telephone: (202) 842-7800
` Facsimile: (202) 842-7899
`
`Attorneys for Defendant
`Apple, Inc.
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`COREPHOTONICS, LTD.,
`
`Plaintiff,
`
`Case No. 5:17-cv-06457-LHK-PK (Lead
`Case)
`5:18-cv-02555-LHK-PK
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`JOINT CLAIM CONSTRUCTION AND
`PREHEARING STATEMENT
`
`Apple v. Corephotonics
`Exhibit 2003
`IPR2018-01133
`
`Exhibit 2003 Page 1 of 4
`
`
`
`Case 5:17-cv-06457-LHK Document 95 Filed 10/26/18 Page 2 of 4
`
`Pursuant to Patent Local Rule 4-3 and the Court’s Case Management Order (Dkt. 87), Plaintiff
`
`Corephotonics, Ltd. (“Corephotonics”) and Defendant Apple Inc. (“Apple”) hereby submit their Joint
`
`Claim Construction and Prehearing Statement for U.S. Patent Nos. 9,185,291 (“the ’291 patent”),
`
`9,402,032 (“the ’032 patent”), 9,538,152 (“the ’152 patent”), 9,568,712 (“the ’712 patent”), and
`
`9,857,568 (“the ’568 patent”) (collectively “the Asserted Patents”).
`
`
`
`I.
`
`AGREED UPON CONSTRUCTIONS
`
`The parties agree on the constructions of the following terms.
`
`Asserted
`Claims
`’291 cl. 1, 12
`
`
`
`
`
`Term or Phrase
`
`Agreed Construction
`
`smooth transition
`
`a transition between cameras or points of view that
`minimizes the jump effect
`
`
`II.
`
`PROPOSED CONSTRUCTIONS OF DISPUTED TERMS
`
`Pursuant to Patent Local Rule 4-2(b), the parties’ proposed constructions of the remaining
`
`terms in dispute, together with an identification of intrinsic references that support the constructions
`
`and extrinsic evidence on which the party intends to rely, are provided in Exhibit A.
`
`III.
`
`IDENTIFICATION OF SIGNIFICANT CLAIM TERMS
`
`Pursuant to Patent Local Rule 4-3(c), Corephotonics and Apple have met and conferred, and
`
`have identified the terms that remain in dispute, as identified in Exhibit A, which are potentially
`
`significant. The parties do not identify any of the remaining disputed terms as being case or claim
`
`dispositive.
`
`IV. ANTICIPATED LENGTH OF TIME NECESSARY FOR CLAIM CONSTRUCTION
`
`HEARING
`
`The parties respectfully request three hours for the claim construction hearing, with each party
`
`allotted ninety minutes.
`
`V. WITNESSES TO APPEAR AT CLAIM CONSTRUCTION HEARING
`
`The parties do not propose to call witnesses at the claim construction hearing.
`
`Apple v. Corephotonics
`Exhibit 2003
`IPR2018-01133
`
`Exhibit 2003 Page 2 of 4
`
`
`
`Case 5:17-cv-06457-LHK Document 95 Filed 10/26/18 Page 3 of 4
`
`VI.
`
`IDENTIFICATION OF FACTUAL FINDINGS REQUESTED FROM COURT
`
`The parties request that the Court make the factual findings that a person of ordinary skill in
`
`the art would understand that each of the disputed terms be construed as proposed by each of the
`
`respective parties as identified in Exhibit A.
`
`
`
`DATED: October 26, 2018
`
`Respectfully submitted,
`
`RUSS, AUGUST & KABAT
`
`
`By:
`
`/s/ Marc A. Fenster ________________
`Marc A. Fenster (CA Bar No. 181067)
`
`Attorneys for Plaintiff
`Corephotonics, Ltd.
`
`COOLEY LLP
`
`
`By:
`
`/s/ Heidi Keefe ____________________
`Heidi Keefe (176960)
`
`Attorneys for Defendant
`Apple Inc.
`
`
`Pursuant to Civil L.R. 5-1(i)(3), I attest that the concurrence in the filing of this document has
`
`ATTESTATION
`
`been obtained from the other signatories.
`
`
`
`DATED:
`
`October 26, 2018
`
`
`
`
`
`
`
`
`
`By: /s/ Bahrad A. Sokhansanj
`
`Apple v. Corephotonics
`Exhibit 2003
`IPR2018-01133
`
`Exhibit 2003 Page 3 of 4
`
`
`
`Case 5:17-cv-06457-LHK Document 95 Filed 10/26/18 Page 4 of 4
`
`CERTIFICATE OF SERVICE
`
`I certify that I caused the foregoing document to be electronically filed with the Clerk of the
`
`Court for the United States District Court for the Northern District of California using the CM/ECF
`
`System on October 26, 2018.
`
`I certify that all participants in the case are registered CM/ECF users and that service will be
`
`accomplished by the court’s CM/ECF system.
`
`
`
`DATED: October 26, 2018
`
`
`
`
`
`
`
`
`
`/s/ Bahrad A. Sokhansanj
`Bahrad A. Sokhansanj
`
`Apple v. Corephotonics
`Exhibit 2003
`IPR2018-01133
`
`Exhibit 2003 Page 4 of 4
`
`
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