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UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`NAVBLAZER, LLC,
`
`Plaintiff,
`
`v.
`
`SAMSUNG ELECTRONICS CO., LTD. AND
`SAMSUNG ELECTRONICS AMERICA, INC.,
`
`Defendants.
`
`NAVBLAZER, LLC,
`
`Plaintiff,
`
`v.
`
`LG ELECTRONICS INC. AND LG
`ELECTRONICS MOBILECOMM U.S.A., INC.,
`
`Defendants.
`
`NAVBLAZER, LLC,
`
`Plaintiff,
`
`v.
`
`MOTOROLA MOBILITY LLC,
`
`Defendant.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`Civil Case No. 6:20-cv-00089-ADA
`
`JURY TRIAL DEMANDED
`
`Civil Case No. 6:20-cv-00095-ADA
`
`JURY TRIAL DEMANDED
`
`Civil Case No. 6:20-cv-100-ADA
`
`JURY TRIAL DEMANDED
`
`DEFENDANTS’ PROPOSED CLAIM CONSTRUCTIONS
`
`Pursuant to the Court’s Scheduling Order (Dkt. 311) and the Court’s Order Governing
`
`Proceedings – Patent Case (Dkt. 23), Defendants Samsung Electronics Co., Ltd. and Samsung
`
`Electronics America, Inc. (collectively, “Samsung”), LG Electronics Inc. and LG Electronics
`
`1 All docket number references are from NavBlazer, LLC v. Samsung Electronics Co., Ltd. et al., Case No.
`6:20-cv-00089-ADA, unless otherwise noted.
`
`1
`
`Google Ex. 1011
`
`

`

`U.S.A., Inc. (collectively, “LG”), and Motorola Mobility LLC (“Motorola”) (collectively,
`
`“Defendants”), by their attorneys, serve on Plaintiff NavBlazer, LLC. (“NavBlazer” or
`
`“Plaintiff”) the following preliminary proposed claim constructions for U.S. Patent No.
`
`9,075,136 (“’136 patent”) and U.S. Patent No. 9,885,782 (“’782 patent”).
`
`Defendants reserve the right to supplement, modify, and/or amend its preliminary
`
`constructions for any reason, including in light of further claim construction discovery, as a
`
`result of the parties’ meet-and-confer, in response to NavBlazer’s or any other Defendants’
`
`proposed constructions, or upon receiving materials that have not yet been produced.
`
`Defendants note that they allege that the asserted claims are invalid, including for failing to
`
`comply with 35 U.S.C. § 112. Defendants proposed constructions for terms, phrases, or clauses
`
`with respect to claims and limitations should in no way be read to imply that the claims satisfy
`
`35 U.S.C. § 112. The presence of a claim term, phrase, or clause in the table below should be
`
`interpreted as applying to all occurrences of the same or similar item and of its grammatical
`
`variants throughout the asserted claims of the asserted patents, regardless of the number of times
`
`each term, phrase, or clause expressly appears in the table below; the citations to the patent
`
`claims below are provided for convenience only, and should not be construed to be limited in
`
`any way.
`
`Defendants will identify at a later date, consistent with the Court’s Scheduling Order, the
`
`evidence supporting its claim constructions, including but not limited to the specification, the
`
`prosecution history, related patents and applications, and the cited references on the face of, or
`
`identified in, the specification or prosecution history of the asserted patents. Subject to the above
`
`reservations of rights, Defendants propose the following constructions for the proposed claim
`
`terms in the asserted patents that have been currently identified:
`
`2
`
`Google Ex. 1011
`
`

`

`No.
`1.
`
`2.
`
`3.
`
`4.
`
`5.
`6.
`
`7.
`
`8.
`
`Claim Term/Phrase
`“wherein the processing device processes
`information regarding the position or the
`location of the vehicle and information
`regarding a destination” / “wherein the
`processing device processes information
`regarding the location of the apparatus or the
`location of the vehicle and information
`regarding a destination”
`(e.g., claim 55 of the ’136 patent; claim 1 of
`the ’782 patent)
`“wherein the processing device determines or
`identifies a travel route to the destination”
`(e.g., claim 55 of the ’136 patent; claim 1 of
`the ’782 patent)
`“traffic information or information regarding a
`traffic condition”
`(e.g., claim 55 of the ’136 patent; claim 1 of
`the ’782 patent)
`“information regarding the travel route”
`(e.g., claim 55 of the ’136 patent; claim 1 of
`the ’782 patent)
`“a location remote from the vehicle”
`(e.g., claim 55 of the ’136 patent)
`“maintenance information associated with [the
`travel route / a second travel route]”
`(e.g., claim 61 of the ’136 patent; claim 7 of
`the ’782 patent)
`“receiver”
`(e.g., claim 55 of the ’136 patent; claim 1 of
`the ’782 patent)
`“on at least one of . . . and” (e.g., claim 55 of
`the ’136 patent)
`
`Proposed Construction
`Plain and ordinary meaning
`
`“wherein the processing device computes a travel route
`to the destination”
`
`“information about traffic pertinent to the location of the
`computer, transmitter, or device [from which the
`information was received]”
`
`“information received from cameras or devices stationed
`at locations on the travel route” or otherwise indefinite
`
`Plain and ordinary meaning
`
`“information about maintenance services received from
`cameras or devices stationed at locations on the travel
`route / a second travel route”
`
`Plain and ordinary meaning
`
`Plain and ordinary meaning
`
`3
`
`Google Ex. 1011
`
`

`

`Dated: October 2, 2020
`
`By: /s/ Sasha Mayergoyz
`Sasha Mayergoyz
`
`JONES DAY
`Tharan Gregory Lanier (Admitted pro hac vice)
`CA State Bar No. 138784
`Email: tglanier@jonesday.com
`Michael C. Hendershot (Admitted pro hac vice)
`CA State Bar No. 211830
`Email: mhendershot@jonesday.com
`Evan M. McLean (Admitted pro hac vice)
`CA State Bar No. 280660
`Email: emclean@jonesday.com
`1755 Embarcadero Road
`Palo Alto, CA 94303
`Telephone: (650) 739-3939
`Facsimile:
`(650) 739-3900
`Sasha Mayergoyz (Admitted pro hac vice)
`IL State Bar No. 6271800
`Email: smayergoyz@jonesday.com
`77 West Wacker, Suite 3500
`Chicago, IL 60602
`Telephone: (312) 782-3939
`Facsimile:
`(312) 782-8585
`Emily J. Tait (Admitted pro hac vice)
`MI State Bar No. P74708
`Email: etait@jonesday.com
`150 West Jefferson, Suite 2100
`Detroit, MI 48226
`Telephone: (313) 733-3939
`Facsimile:
`(313) 230-7997
`NAMAN HOWELL SMITH & LEE, PLLC
`John P. Palmer
`State Bar No. 15430600
`400 Austin Avenue, 8th Floor
`P.O. Box 1470
`Waco, TX 76701
`Telephone:
` (254) 755-4100
`Facsimile:
` (254) 754-6331
`Email: palmer@namanhowell.com
`Attorneys for Defendants
`
`4
`
`Google Ex. 1011
`
`

`

`CERTIFICATE OF SERVICE
`
`I declare that I am employed with the law firm of Jones Day, whose address is 1755
`
`Embarcadero Road, Palo Alto, California 94303. I am over the age of eighteen years and not a party
`
`to the within-entitled action.
`
`On October 2, 2020, I served a copy of:
`
` DEFENDANTS’ PROPOSED CLAIM CONSTRUCTIONS
`
`BY ELECTRONIC SERVICE [Fed. R. Civ. P. 5(b)] by electronically mailing a true and correct
`
`copy through Jones Day’s electronic mail system to the e-mail addresses set forth below:
`
`Thomas Fasone III
`tfasone@ghiplaw.com
`M. Scott Fuller
`sfuller@ghiplaw.com
`René A. Vazquez
`rvazquez@ghiplaw.com
`Randall T. Garteiser
`rgarteiser@ghiplaw.com
`Christopher A. Honea
`chonea@ghiplaw.com
`GARTEISER HONEA, PLLC
`119 W. Ferguson Street
`Tyler, Texas 75702
`Telephone: (903) 705-7420
`
`Raymond W. Mort, III
`raymort@austinlaw.com
`THE MORT LAW FIRM, PLLC
`100 Congress Ave, Suite 2000
`Austin, Texas 78701
`Telephone: (512) 865-7950
`
`John P. Palmer
`palmer@namanhowell.com
`NAMAN HOWELL SMITH & LEE, PLLC
`400 Austin Avenue, 8th Floor
`P.O. Box 1470
`Waco, TX 76701
`Telephone: (254) 755-4100
`
`I declare under penalty of perjury under the laws of the State of California and the United States
`
`of America that the foregoing is true and correct.
`
`Executed this 2nd day of October, 2020, at San Jose, California.
`
`/s/ Lori Murray
`Lori Murray
`
`5
`
`Google Ex. 1011
`
`

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