`
`FOR THE WESTERN DISTRICT OF TEXAS
`
`
`
`WACO DIVISION
`
`
`
`SYNKLOUD TECHNOLOGIES, LLC,
`
`PLAINTIFF,
`
`
`
`v.
`
`ADOBE, INC.,
`
`
`
`DEFENDANT.
`
`Civil Action No. 6:19-cv-00527-ADA
`
`
`
`JURY TRIAL DEMANDED
`
`
`
`
`PLAINTIFF SYNKLOUD TECHNOLOGIES, LLC’S
`REVISED CLAIM CONSTRUCTION CHART
`
`
`
`Pursuant to the CMC Order, Plaintiff SynKloud Technologies, LLC (“SynKloud” or
`
`“Plaintiff”) hereby submits this revised proposed claim construction chart in connection with
`
`disputed terms in the Patents-in-Suit. SynKloud does not contend that any claim terms of the
`
`asserted claims require construction by the Court. The constructions proposed herein are in
`
`response to the disputed claim construction terms proposed by Defendant. Plaintiff reserves the
`
`right to revise it further.
`
`No. Patent No. Claim Nos. Term
`1
`[allocating/allocate]
`8,606,880
`2, 11
`[…] a [first one of the]
`8,856,195
`15,
`storage space[s] of a
`8,868,690
`1, 9, 10, 14,
`predefined capacity
`16
`
`1,12
`configured with a
`storage space of a
`predefined capacity
`allocated
`
`
`
`
`9,239,686
`
`
`
`
`
`Plaintiff Proposed Construction
`[reserving/reserve] [….] a [first
`one of the] storage space[s] of a
`capacity defined in advance
`
`
`organized a storage space of a
`capacity defined in advance
`
`
`
`
`
`-1-
`
`Adobe - Exhibit 1034, page 1
`
`
`
`No. Patent No. Claim Nos. Term
`2
`download[ing] [a/the]
`9,219,780
`9, 10
`file [from a remote
`9,239,686
`1, 2, 13
`server] [across a
`10,015,254 9
`network] into the first
`one of the storage
`spaces
`
`the storing of the data
`including to download
`a file from a remote
`server into the first one
`of the storage spaces
`
`download a file from a
`remote server across a
`network into the first
`one of the storage
`spaces
`
`the storing of said data
`including to download
`a file from a remote
`server across a network
`into the first one of the
`storage spaces
`
`downloading a file
`from a remote server
`across a network into
`the first one of the
`storage spaces
`
`the storing data further
`comprises program
`instructions for the
`server downloading a
`file from a remote
`server across a network
`into the first one of the
`storage spaces
`
`[storing/store] …or
`[retrieving/retrieve]
`
`
`
`1, 10, 16
`8,868,690
`9, 15
`9,219,780
`1, 4, 12, 16
`9,239,686
`10,015,254 9, 15
`
`-2-
`
`
`9,219,780
`
`
`9
`
`
`9,239,686
`
`
`1, 13
`
`
`9,239,686
`
`
`1
`
`
`
`10,015,254 9
`
`
`
`10,015,254 9
`
`
`3
`
`
`4
`
`
`5
`
`
`6
`
`
`7
`
`
`8
`
`Plaintiff Proposed Construction
`Plain and ordinary meaning
`
`
`Plain and ordinary meaning
`
`
`Plain and ordinary meaning
`
`
`Plain and ordinary meaning
`
`
`Plain and ordinary meaning
`
`
`Plain and ordinary meaning
`
`
`Plain and ordinary meaning
`
`Adobe - Exhibit 1034, page 2
`
`
`
`No. Patent No. Claim Nos. Term
`
`
`
`
`9
`a server
`8,606,880
`2, 11
`8,856,195
`15
`8,868,690
`1, 10, 16
`9,219,780
`9
`9,239,686
`1, 12
`10,015,254 9
`
`
`8,606,880
`2, 7, 8, 10,
`11, 12, 13,
`14, 16, 17
`15, 16, 17,
`18, 19, 20
`1, 2, 4, 5, 6,
`8, 9, 10, 11,
`12, 14, 16,
`17, 19, 20
`9, 10, 11,
`12, 13, 14
`1, 2, 5, 6, 7,
`8, 9, 10, 12,
`13, 14, 15,
`17, 20
`10,015,254 9, 10, 11,
`12, 14, 15
`
`
`8,856,195
`
`8,868,690
`
`9,219,780
`
`9,239,686
`
`
`
`
`
`
`
`
`
`
`10
`
`
`wireless device
`
`Plaintiff Proposed Construction
`
`One or more servers
`
`
`Plain and ordinary meaning
`including a laptop, desktop or
`server computer
`
`
`
`-3-
`
`Adobe - Exhibit 1034, page 3
`
`
`
`Respectfully,
`
`/s/ Deepali Brahmbhatt _________
`Deepali Brahmbhatt (Pro Hac Vice)
`dbrahmbhatt@onellp.com
`ONE LLP
`4000 MacArthur Blvd.
`East Tower, Suite 500
`Newport Beach, CA 92660
`Telephone: (949) 502-2870
`Facsimile: (949) 258-5081
`
`Attorneys for Plaintiff
`SynKloud Technologies, LLC
`
`Dated: June 12, 2020
`
`Local Counsel:
`Kevin J. Terrazas (SBN 24060708)
`kterrazas@clevelandterrazas.com
`CLEVELAND TERRAZAS PLLC
`4611 Bee Cave Road, Suite 306B
`Austin, TX 78746
`Telephone: (512) 680-3257
`
`Of Counsel:
`John Lord (Pro Hac Vice)
`jlord@onellp.com
`ONE LLP
`9301 Wilshire Blvd.
`Penthouse Suite
`Beverly Hills, CA 90210
`Telephone: (310) 866-5157
`Facsimile: (310) 943-2085
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on June 12, 2020 all counsel of record who are deemed to
`
`have consented to electronic service are being served with a copy of this document via electronic
`
`mail.
`
`
`
`/s/ Deepali Brahmbhatt
`Deepali Brahmbhatt
`
`-4-
`
`Adobe - Exhibit 1034, page 4
`
`
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