Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 1 of 15 Page ID
` #:1960
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`
`United States Patent Nos.
`7,589,642, 8,004,389, and 9,911,325
`
`U.S. Patent
`
`
`
`Patent Terms
`
`Roku’s Construction
`
`Intrinsic and Extrinsic Evidence
`
`“key code signal”
`
`1.
`
`
`A signal, for controlling a specific type, brand,
`and model of consumer electronic device, and
`which contains a modulated key code. Excludes
`signals containing key codes to be stored on the
`remote control for later use in generating IR
`signals.
`
`‘642 Patent at Title, Abstract, Figs. 1-2, 4-6,
`1:23-25, 1:34-38, 2:2-15, 2:45-61, 4:35-5:5,
`5:37-49, 6:27-33, 6:43-58, 6:63-65, 7:21-26,
`7:1-9, 8:1-6; 9:58-59.1
`
`Prosecution of U.S. Patent Appl. No.
`10/737,029: July 28, 2006 Response to Office
`Action at 16-18, December 19, 2006
`Response to Office Action at 19-21, March
`24, 2007 Appeal Brief at 2-3, 21-23; June 11,
`2007 Amended Appeal Brief at 2-3, 22-24;
`January 2, 2008 Reply Brief at 5-6, 13.
`
`Expert declaration of Stu Lipoff. Mr. Lipoff
`will opine as to correctness of Roku’s
`proposed construction of “key code signal”,
`how one of ordinary skill in the art would
`interpret the related disclosures of the
`specifications and file history, what ordinary
`meaning(s) (if any) “key code signal” has in
`the field, the background of the technology,
`the level of ordinary skill in the art, the state
`of art at the time of the invention, and
`rebuttal opinions in response to UEI’s
`construction and supporting evidence for
`
`
`1 Citations to the specification of one of the asserted patents should be understood as also citing to the corresponding portions of each other asserted patent in the
`same family. Citations to the figures of a patent should be understood as citing to the corresponding portions of the written description and vice-versa.
`Page 1 of 15
`
`
`
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 2 of 15 Page ID
` #:1961
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`2. “key code generator
`device”
`
`This is a means-plus-function term subject to 35
`U.S.C. § 112(6).
`
`‘642 Patent at Abstract, Figs. 1-2, 2:2-6, 3:9-
`12, 3:27-35, 6:14-30.
`
`“key code signal” and rebuttal to any
`opinions or declarations offered by any
`witness on behalf of Plaintiff.
`
`The function is generate a key code.
`
`The structure is indefinite due to lack of
`sufficient corresponding structure.
`
`Page 2 of 15
`
`Prosecution of U.S. Patent Appl. No.
`10/737,029: July 28, 2006 Response to Office
`Action at 16-18, December 19, 2006
`Response to Office Action at 19-21, March
`24, 2007 Appeal Brief at 2-3, 21-23; June 11,
`2007 Amended Appeal Brief at 2-3, 22-24;
`January 2, 2008 Reply Brief at 5-6, 13.
`
`Expert declaration of Stu Lipoff. Mr. Lipoff
`will opine as to correctness of Roku’s
`proposed construction of “key code
`generator device”, how one of ordinary skill
`in the art would interpret the related
`disclosures of the specifications and file
`history, what ordinary meaning(s) (if any)
`“key code generator device” has in the field,
`to what extent “key code generator device”
`or alleged corresponding disclosures in the
`specification are structural, to what extent
`disclosures of the specification correspond
`to the recited function, the background of
`the technology, the level of ordinary skill in
`the art, the state of art at the time of the
`invention, and rebuttal opinions in response
`to UEI’s construction and supporting
`evidence for “key code generator device”
`
`
`
`
`
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 3 of 15 Page ID
` #:1962
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`3. “means for receiving a
`key code from said RF
`receiver and for sending
`said key code to said IR
`transmitter such that said
`key code is modulated
`onto an IR carrier signal”
`
`This is a means-plus-function term subject to 35
`U.S.C. § 112(6).
`
`The function is receiving a key code from said
`RF receiver and sending said key code to said
`IR transmitter such that said key code is
`modulated onto an IR carrier signal.
`
`The structure is indefinite due to lack of
`sufficient corresponding structure.
`
`4. “autoscan functionality”
`
`Functionality for testing keycodes to determine
`the right keycode or codeset to control a
`particular device.
`
`Page 3 of 15
`
`and rebuttal to any opinions or declarations
`offered by any witness on behalf of Plaintiff.
`
`Specification lacks corresponding algorithm.
`See ’642 Patent at 3:66-4:3.
`
`Expert declaration of Stu Lipoff. Mr. Lipoff
`will opine as to correctness of Roku’s
`proposed construction of “means for
`receiving . . .”, how one of ordinary skill in
`the art would interpret the related
`disclosures of the specifications and file
`history, what ordinary meaning(s) (if any)
`“means for receiving . . .” has in the field, to
`what extent “means for receiving . . .” or
`alleged corresponding disclosures in the
`specification are structural, to what extent
`disclosures of the specification correspond
`to the recited function, the background of
`the technology, the level of ordinary skill in
`the art, the state of art at the time of the
`invention, and rebuttal opinions in response
`to UEI’s construction and supporting
`evidence for “means for receiving . . .” and
`rebuttal to any opinions or declarations
`offered by any witness on behalf of Plaintiff.
`
`‘642 Patent at 2:22-36, 7:4-8:18
`
`Expert declaration of Stu Lipoff. Mr. Lipoff
`will opine as to correctness of Roku’s
`proposed construction of “autoscan
`functionality”, how one of ordinary skill in
`
`
`
`
`
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 4 of 15 Page ID
` #:1963
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`
`
`
`
`
`5. “format … for
`transmission” /
`“formatted”
`
`Modulate / modulated
`
`Page 4 of 15
`
`the art would interpret the related disclosures
`of the specifications and file history, what
`ordinary meaning(s) (if any) “autoscan
`functionality” has in the field, the background
`of the technology, the level of ordinary skill
`in the art, the state of art at the time of the
`invention, and rebuttal opinions in response
`to UEI’s construction and supporting
`evidence for “autoscan functionality” and
`rebuttal to any opinions or declarations
`offered by any witness on behalf of Plaintiff
`
`‘642 Patent at Abstract, Figs. 2-6, 1:34-38;
`1:59-2:21; 5:53-63; 6:24-42.
`
`Expert declaration of Stu Lipoff. Mr. Lipoff
`will opine as to correctness of Roku’s
`proposed construction of “format ... for
`transmission” / “formatted”, how one of
`ordinary skill in the art would interpret the
`related disclosures of the specifications and
`file history, what ordinary meaning(s) (if any)
`“format ... for transmission” / “formatted”
`have in the field, the background of the
`technology, the level of ordinary skill in the
`art, the state of art at the time of the
`invention, and rebuttal opinions in response
`to UEI’s construction and supporting
`evidence for “format ... for transmission” /
`“formatted” and rebuttal to any opinions or
`declarations offered by any witness on behalf
`of Plaintiff.
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 5 of 15 Page ID
` #:1964
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`
`United States Patent No. 9,716,853
`
`U.S. Patent
`
`
`
`Patent Terms
`
`Roku’s Construction
`
`Intrinsic and Extrinsic Evidence
`
`1.
`
`
`“by using an identity
`associated with the
`intended target appliance
`to create a listing
`comprised of at least a
`first communication
`method and a second
`communication method
`different than the first
`communication method
`for use in controlling at
`least a first functional
`operation and a second
`functional operation of the
`intended target appliance”
`
`Create a listing by using an identity associated
`with the intended target appliance. The listing
`must contain at least two different
`communication methods, each of which can
`control and is associated with the same two or
`more functional operations of the same, single
`target appliance.
`
`Does not include selecting a communication
`protocol and thereafter using the selected
`communication protocol for any and all
`commands sent to the target appliance.
`
`‘853 Patent, cl. 1, Figs. 7, 9, 10, 8:49-11:9,
`11:40-12:43, 14:6-24.
`
`13/657,176 File History, May 14, 2015
`Response at 6
`
`13/933877 File History, April 28, 2015
`Response at 6; 14/948,927 File History
`January 31, 2017 Response at 3
`
`Expert declaration of Stu Lipoff. Mr. Lipoff
`will opine as to correctness of Roku’s
`proposed construction of “by using ...”, how
`one of ordinary skill in the art would
`interpret the related disclosures of the
`specifications and file history, what ordinary
`meaning(s) (if any) “by using ...” has in the
`field, the background of the technology, the
`level of ordinary skill in the art, the state of
`art at the time of the invention, and rebuttal
`opinions in response to UEI’s construction
`and supporting evidence for “by using ...”
`and rebuttal to any opinions or declarations
`offered by any witness on behalf of Plaintiff
`
`2. “universal control engine”
`
`Indefinite
`
`‘853 Patent at 2:4-55
`
`Expert declaration of Stu Lipoff. Mr. Lipoff
`will opine as to correctness of Roku’s
`proposed construction of “universal control
`
`Page 5 of 15
`
`
`
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 6 of 15 Page ID
` #:1965
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`engine”, how one of ordinary skill in the art
`would interpret the related disclosures of the
`specifications and file history, what ordinary
`meaning(s) (if any) “universal control
`engine” has in the field, the background of
`the technology, the level of ordinary skill in
`the art, the state of art at the time of the
`invention, and rebuttal opinions in response
`to UEI’s construction and supporting
`evidence for “universal control engine” and
`rebuttal to any opinions or declarations
`offered by any witness on behalf of Plaintiff.
`
`3. “causing a one of the first
`and second
`communication methods
`in the listing of
`communication methods
`that has been associated
`with the requested one of
`the first and second
`functional operations to be
`used to transmit”
`
`Transmitting using one of the listed
`communication methods associated with the
`requested functional operation.
`
`‘853 Patent, cl. 1, Abstract, Figs. 7, 9, 10,
`2:29-45, 3:51-58, 6:62-7:52, 8:49-11:9,
`11:40-12:43, 14:6-24.
`
`Does not include selecting the communication
`method based on the characteristic of the data to
`be transmitted without regard for the identity of
`the intended target device.
`
`14/948,927 File History, January 1, 31 2017
`Response at 3
`
`Expert declaration of Stu Lipoff. Mr. Lipoff
`will opine as to correctness of Roku’s
`proposed construction of “causing a one ...”,
`how one of ordinary skill in the art would
`interpret the related disclosures of the
`specifications and file history, what ordinary
`meaning(s) (if any) “causing a one ...” has in
`the field, the background of the technology,
`the level of ordinary skill in the art, the state
`of art at the time of the invention, and
`rebuttal opinions in response to UEI’s
`construction and supporting evidence for
`“causing a one ...” and rebuttal to any
`
`Page 6 of 15
`
`
`
`
`
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 7 of 15 Page ID
` #:1966
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`
`
`opinions or declarations offered by any
`witness on behalf of Plaintiff.
`
`Page 7 of 15
`
`
`
`
`
`
`
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 8 of 15 Page ID
` #:1967
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`
`United States Patent Nos.
`7,782,309, 7,821,504, and 7,821,505
`
`U.S. Patent
`
`
`
`Patent Terms
`
`Roku’s Construction
`
`Intrinsic and Extrinsic Evidence
`
`1.
`
`
`“universal controlling
`device”
`
`A controlling device capable of commanding
`the operation of multiple classes of appliances
`from multiple manufacturers
`
`2. “second input type
`indicative of a motion
`made across the touch-
`sensitive surface” /
`“second input type
`indicative of a moving
`touch made across the
`touch-sensitive surface”
`
`
`
`
`Plain and ordinary meaning.
`
`Page 8 of 15
`
`’309 patent at 6:57-59; see also 1:16-34.
`
`Declaration of Robert Dezmelyk. Mr.
`Dezmelyk will opine as to correctness of
`Roku’s proposed construction of “universal
`controlling device”, how one of ordinary
`skill in the art would interpret the related
`disclosures of the specifications and file
`history, what ordinary meaning(s) (if any)
`“universal controlling device” has in the
`field, the background of the technology, the
`level of ordinary skill in the art, the state of
`art at the time of the invention, and rebuttal
`opinions in response to UEI’s construction
`and supporting evidence for “universal
`controlling device” and rebuttal to any
`opinions or declarations offered by any
`witness on behalf of Plaintiff.
`
`Declaration of Robert Dezmelyk. Mr.
`Dezmelyk will opine as to correctness of
`Roku’s proposed construction of “second
`input type ...”, how one of ordinary skill in
`the art would interpret the related
`disclosures of the specifications and file
`history, what ordinary meaning(s) (if any)
`“second input type ...” has in the field, the
`background of the technology, the level of
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 9 of 15 Page ID
` #:1968
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`3. “automatically toggle(s)” Toggle without user interaction
`
`’309 patent at 3:32-36; 5:14-6:47
`
`ordinary skill in the art, the state of art at the
`time of the invention, and rebuttal opinions
`in response to UEI’s construction and
`supporting evidence for “second input type
`...” and rebuttal to any opinions or
`declarations offered by any witness on
`behalf of Plaintiff.
`
`American Heritage College Dictionary (4th
`ed. 2002), at 96 (definition of automatic—
`“Acting or operating in a manner essentially
`independent of external influence or
`conscious control”)
`
`Declaration of Robert Dezmelyk. Mr.
`Dezmelyk will opine as to correctness of
`Roku’s proposed construction of
`“automatically toggle(s)”, how one of
`ordinary skill in the art would interpret the
`related disclosures of the specifications and
`file history, what ordinary meaning(s) (if
`any) “automatically toggle(s)” has in the
`field, the background of the technology, the
`level of ordinary skill in the art, the state of
`art at the time of the invention, and rebuttal
`opinions in response to UEI’s construction
`and supporting evidence for “automatically
`toggle(s)” and rebuttal to any opinions or
`declarations offered by any witness on
`behalf of Plaintiff.
`
`Page 9 of 15
`
`
`
`
`
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 10 of 15 Page ID
` #:1969
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`4. “second data
`representative of the
`motion made across the
`touch-sensitive interface”
`
`Plain and ordinary meaning.
`
`Declaration of Robert Dezmelyk. Mr.
`Dezmelyk will opine as to correctness of
`Roku’s proposed construction of “second data
`...”, how one of ordinary skill in the art would
`interpret the related disclosures of the
`specifications and file history, what ordinary
`meaning(s) (if any) “second data ...” has in
`the field, the background of the technology,
`the level of ordinary skill in the art, the state
`of art at the time of the invention, and rebuttal
`opinions in response to UEI’s construction
`and supporting evidence for “second data ...”
`and rebuttal to any opinions or declarations
`offered by any witness on behalf of Plaintiff.
`
`5. “static touch”
`
`“a stationary touch at one location”
`
`’309 patent at 2:12-15; 3:32-43; 5:14-32
`
`Declaration of Robert Dezmelyk. Mr.
`Dezmelyk will opine as to correctness of
`Roku’s proposed construction of “static
`touch”, how one of ordinary skill in the art
`would interpret the related disclosures of the
`specifications and file history, what ordinary
`meaning(s) (if any) “static touch” has in the
`field, the background of the technology, the
`level of ordinary skill in the art, the state of
`art at the time of the invention, and rebuttal
`opinions in response to UEI’s construction
`and supporting evidence for “static touch”
`and rebuttal to any opinions or declarations
`offered by any witness on behalf of Plaintiff.
`
`Page 10 of 15
`
`
`
`
`
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 11 of 15 Page ID
` #:1970
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`
`
`
`United States Patent Nos. 7,895,532
`
`U.S. Patent
`
`
`
`Patent Terms
`
`Roku’s Construction
`
`Intrinsic and Extrinsic Evidence
`
`“automatically created”
`
`Plain and ordinary meaning
`
`1.
`
`
`
`
`
`Page 11 of 15
`
`’532 patent, 11:43-12:13, 17:36-67, 23:65-
`24:16
`
`American Heritage College Dictionary (4th
`ed. 2002), at 96 (definition of automatic—
`“Acting or operating in a manner essentially
`independent of external influence or
`conscious control”)
`
`Expert declaration of Robert Dezmelyk. Mr.
`Dezmelyk will opine as to correctness of
`Roku’s proposed construction of
`“automatically created”, how one of
`ordinary skill in the art would interpret the
`related disclosures of the specifications and
`file history, what ordinary meaning(s) (if
`any) “automatically created” has in the field,
`the background of the technology, the level
`of ordinary skill in the art, the state of art at
`the time of the invention, and rebuttal
`opinions in response to UEI’s construction
`and supporting evidence for “automatically
`created” and rebuttal to any opinions or
`declarations offered by any witness on
`behalf of Plaintiff.
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 12 of 15 Page ID
` #:1971
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`2. “sequence of instructions” A macro
`
`Indefinite
`
`3. “presenting to a user a
`graphical user interface
`including a
`representations of at least
`one appliance controllable
`by the controlling device”
`
`Page 12 of 15
`
`
`
`
`
`
`’532 patent, 10:39-67, 11:43-12:13, 17:36-
`67, 23:65-24:16, 29:65-30:20, Figs. 11,
`16(g), 18, 22(g)
`
`Expert declaration of Robert Dezmelyk. Mr.
`Dezmelyk will opine as to correctness of
`Roku’s proposed construction of “sequence
`of instructions”, how one of ordinary skill in
`the art would interpret the related
`disclosures of the specifications and file
`history, what ordinary meaning(s) (if any)
`“sequence of instructions” has in the field,
`the background of the technology, the level
`of ordinary skill in the art, the state of art at
`the time of the invention, and rebuttal
`opinions in response to UEI’s construction
`and supporting evidence for “sequence of
`instructions” and rebuttal to any opinions or
`declarations offered by any witness on
`behalf of Plaintiff.
`
`’532 patent, 10:39-67, 11:43-12:13, 17:36-67,
`23:65-24:16, Figs. 11, 16(g), 18, 22(g)
`
`Expert declaration of Robert Dezmelyk. Mr.
`Dezmelyk will opine as to correctness of
`Roku’s proposed construction of “present to
`a user ...”, how one of ordinary skill in the
`art would interpret the related disclosures of
`the specifications and file history, what
`ordinary meaning(s) (if any) “present to a
`user ...” has in the field, the background of
`the technology, the level of ordinary skill in
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 13 of 15 Page ID
` #:1972
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`
`
`
`
`
`
`
`4. “causing the automatically
`created sequence of
`instructions to be executed
`by the controlling device
`in response to a selection
`of a user input element of
`the controlling device”
`
`(1) This step is performed after the sequence of
`instructions has been created;
`(2) The “selection of a user input element of the
`controlling device” is separate and distinct from
`the “one or more interactions by the user with
`the representations of the at least one
`appliance”;
`(3) No further construction of the claim
`language is needed.
`
`
`
`Page 13 of 15
`
`the art, the state of art at the time of the
`invention, and rebuttal opinions in response
`to UEI’s construction and supporting
`evidence for “present to a user ...” and
`rebuttal to any opinions or declarations
`offered by any witness on behalf of Plaintiff
`
`’532 patent, 10:39-67, 11:43-12:13, 17:36-67,
`23:65-24:16, Figs. 11, 16(g), 18, 22(g)
`
`Expert declaration of Robert Dezmelyk. Mr.
`Dezmelyk will opine as to correctness of
`Roku’s proposed construction of “causing the
`automatically created ...”, how one of
`ordinary skill in the art would interpret the
`related disclosures of the specifications and
`file history, what ordinary meaning(s) (if any)
`“causing the automatically created ...” has in
`the field, the background of the technology,
`the level of ordinary skill in the art, the state
`of art at the time of the invention, and rebuttal
`opinions in response to UEI’s construction
`and supporting evidence for “causing the
`automatically created ...” and rebuttal to any
`opinions or declarations offered by any
`witness on behalf of Plaintiff.
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 14 of 15 Page ID
` #:1973
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`
`United States Patent Nos. 8,015,446
`
`U.S. Patent
`
`
`
`Patent Terms
`
`Roku’s Construction
`
`Intrinsic and Extrinsic Evidence
`
`Indefinite
`
`1.
`
`
`“the data being
`representative of a user
`interaction with a user
`interface element of the
`controlling device
`resulting from the user
`interaction with the user
`interface element of the
`controlling device”
`
`2. “whereby the uploaded
`captured data is available
`for use in debugging the
`remote control application
`of the controlling device”
`
`Indefinite
`
`
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`Page 14 of 15
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`’446 Patent, 6:25-35, 10:25-34, 30:41-55,
`36:22-46
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`Expert declaration of Robert Dezmelyk.
`Mr. Dezmelyk will opine as to correctness
`of Roku’s proposed construction of “the
`data being representative ...”, how one of
`ordinary skill in the art would interpret the
`related disclosures of the specifications and
`file history, what ordinary meaning(s) (if
`any) “the data being representative ...” has
`in the field, the background of the
`technology, the level of ordinary skill in the
`art, the state of art at the time of the
`invention, and rebuttal opinions in response
`to UEI’s construction and supporting
`evidence for “the data being representative
`...” and rebuttal to any opinions or
`declarations offered by any witness on
`behalf of Plaintiff.
`
`’446 Patent, 6:25-35, 10:25-34, 30:41-55,
`36:22-46
`
`Expert declaration of Robert Dezmelyk.
`Mr. Dezmelyk will opine as to correctness
`of Roku’s proposed construction of
`“whereby the uploaded captured data ...”,
`how one of ordinary skill in the art would
`
`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`

`

`Case 8:18-cv-01580-JVS-ADS Document 70-2 Filed 04/19/19 Page 15 of 15 Page ID
` #:1974
`Exhibit B to Parties’ Joint Claim Construction Chart – Roku’s Proposed Constructions and Supporting Evidence
`
`3. “event journal”
`
`A log of events
`
`interpret the related disclosures of the
`specifications and file history, what ordinary
`meaning(s) (if any) “whereby the uploaded
`captured data ...” has in the field, the
`background of the technology, the level of
`ordinary skill in the art, the state of art at the
`time of the invention, and rebuttal opinions
`in response to UEI’s construction and
`supporting evidence for “whereby the
`uploaded captured data ...” and rebuttal to
`any opinions or declarations offered by any
`witness on behalf of Plaintiff.
`
`’446 Patent, 6:25-35, 10:25-34, 30:41-55,
`36:22-46
`
`Expert declaration of Robert Dezmelyk. Mr.
`Dezmelyk will opine as to correctness of
`Roku’s proposed construction of “event
`journal”, how one of ordinary skill in the art
`would interpret the related disclosures of the
`specifications and file history, what ordinary
`meaning(s) (if any) “event journal” has in
`the field, the background of the technology,
`the level of ordinary skill in the art, the state
`of art at the time of the invention, and
`rebuttal opinions in response to UEI’s
`construction and supporting evidence for
`“event journal” and rebuttal to any opinions
`or declarations offered by any witness on
`behalf of Plaintiff.
`
`Page 15 of 15
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`Universal Electronics Inc., Exhibit 2001
`Roku, Inc. v. Universal Electronics Inc., IPR2020-00951
`
`