`
`1
`
`
`TracBeam LLC v. Cisco Systems, Inc.
`Case No. 6:17-cv-525
`
`"mobile station location estimator"
`
`
`
`
`
`(' 484 patent, claim 49)
`
`Governed by 35 U.S.C. § 11216
`
`"location determiner"
`
`
`('327 patent, claim 1)
`
`"estimating mobile station location"
`
`
`
`Function:
`
`
`"location hypothesizing model
`Structure:
`
`
`(FOM) implemented on or by a location center
`
`or mobile base station"
`
`Governed by 35 U.S.C. § 112 16
`
`
`
`Function:
`location"
`
`"determining communication device
`
`"location hypothesizing model
`
`
`Structure:
`
`
`(FOM) implemented on or by a location center
`
`or mobile base station"
`
`
`Governed by 35 U.S.C. § 11216
`
`"location estimation determiner"
`
`('231 patent, claim 34)
`
`"determining mobile station
`
`
`
`"determining an estimate of mobile
`Function:
`
`station location"
`"location hypothesizing model
`
`
`Structure:
`
`
`(FOM) implemented on or by a location center
`
`or mobile base station"
`"mobile station location evaluator"
`
`
`
`
`Governed by 35 U.S.C. § 11216
`
`
`('484 patent, claims 25 and 57; '231 patent,
`
`
`Function:
`claim 30)
`location"
`"location hypothesizing model
`
`
`Structure:
`
`
`(FOM) implemented on or by a location center
`
`or mobile base station"
`
`
`
`"pattern recognizers for estimating a location
`
`Governed by 35 U.S.C. § 11216
`
`of one or more-of the mobile unit M"
`
`(' 525 patent, claim 1)
`
`"estimating a location of a mobile
`
`
`Function:
`
`
`unit M using a pattern recognition technique"
`
`
`"location hypothesizing model
`Structure:
`
`
`(FOM) that uses pattern recognition and is
`
`
`
`implemented on or by a location center or
`
`mobile base station"
`
`Governed by 35 U.S.C. § 11216
`"similarity determining computational
`
`
`
`
`machine that determines location related
`"determining location related
`
`
`Function:
`
`
`
`information for locating the mobile unit M"
`
`
`
`information for locating the mobile unit M
`
`(' 543 patent, claim 1)
`
`
`
`using a similarity in wireless signal data"
`
`1 These preliminary constructions are only meant to indicate where the Court stands after considering the claim
`
`
`
`
`
`
`
`
`
`
`construction briefing, and the Court may change its position based upon the parties' arguments.
`
`Cisco v. TracBeam / CSCO-1011
`Page 1 of 2
`
`
`
`Structure: "location center or mobile base
`
`
`
`
`
`
`
`station implementing a location hypothesizing
`
`
`
`model that determines a similarity or pattern in
`
`
`wireless signal data"
`
`
`"statistical based technique" (by agreement,
`"stochastic technique"
`
`
`('327 patent, claim 47; '231 claim 34) see Docket No. 81)
`
`no construction necessary
`
`"learning technique"
`('231 patent, claim 34)
`
`"deadreckoning process"
`
`('543 patent, claim 44)
`
`"location determining process that uses data
`
`
`
`
`indicating a change in the direction,
`
`
`
`acceleration, or position of the mobile unit"
`(by agreement)
`
`
`no construction necessary (by agreement)
`
`
`
`
`information"
`
`(' 484 patent, claim 25)
`
`
`
`
`as: only "multipath" "patterns in multipath for wireless signals construing
`
`communicated between: (a) one or more of "wireless signals propagated over multiple
`
`
`
`
`
`
`
`
`
`the communication stations, and (b) said paths due to objects or structures located
`
`mobile unit M"
`
`
`between the mobile unit M and one or more
`Or
`
`' communication stations"
`"multipath
`"
`
`(' 525 patent, claim 1)
`
`
`
`('231 patent, claim 34)
`
`"initiating a plurality ofrequests for
`
`necessary "location representation" no construction
`
`Page 2 of2
`
`Cisco v. TracBeam / CSCO-1011
`Page 2 of 2
`
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