CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 1 of 21
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`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 1 of 21
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`
`Exhibit 10
`Exhibit 10
`
`Page 1
`
`OWTEx. 2139
`Tennant Company v. OWT
`IPR2021-00625
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 1 of 21
`
`
`Exhibit 10
`Exhibit 10
`
`Page 1
`
`OWTEx. 2139
`Tennant Company v. OWT
`IPR2021-00625
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 2 of 21
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF MINNESOTA
`
`
`
`
`
`
`
`
`
`
`Civil Case No. 20-cv-00358-ECT-HB
`
`
`OXYGENATOR WATER
`TECHNOLOGIES, INC.
`
`
`
`v.
`
`TENNANT COMPANY
`
`
`
`
`
`
`
`
`
`
`
`
`Plaintiff,
`
`Defendant.
`
`
`
`
`
`
`
`TENNANT’S AMENDED PROPOSED CLAIM TERMS
`FOR CONSTRUCTION AND EXTRINSIC EVIDENCE
`
`In accordance with the Court’s Pretrial Case Management Order (ECF 43) and
`
`Order granting Tennant’s Unopposed Motion to Supplement Invalidity Contentions and
`
`Amend the Pretrial Case Management Order (ECF 62), Defendant Tennant Company
`
`(“Tennant”) hereby provides its Preliminary Proposed Claim Constructions. Tennant
`
`makes this disclosure based on information presently known to it, without the benefit of
`
`full discovery. Tennant reserves the right to supplement or amend the information
`
`contained herein in response to any arguments, allegations, or evidence presented by
`
`Plaintiff, as information is discovered or confirmed during fact discovery, information is
`
`discovered, confirmed or provided by a party’s consultant or expert after the party’s
`
`contentions have been served, new products are launched or accused, amendments are
`
`made to the amended complaint and/or any counterclaims, information is learned from or
`
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 3 of 21
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`
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`positions are taken by another party during the exchange of contentions or the constructions
`
`process set forth in the Pretrial Case Management Order, rulings are made by the Court,
`
`amendments are made to infringement or validity contentions, or as otherwise permitted or
`
`required under the Federal Rules of Civil Procedure, the Local Rules, and the Court’s
`
`Pretrial Case Management Order. Further, Tennant reserves the right to change its position
`
`in response to Plaintiff’s identification of its preliminary claim constructions and
`
`supporting evidence, changes in the parties’ constructions, and as information is learned
`
`during the course of claim construction discovery.
`
`
`
`Tennant relies on the ‘415 Patent, the ‘415 Patent’s Prosecution History, the ‘092
`
`Patent, the ‘092 Patent’s Prosecution History, the ‘665 Patent, and the ‘665 Patent’s
`
`Prosecution History, including the file histories of related patents and applications.
`
`Further, Tennant identifies the following preliminary identification of extrinsic evidence1:
`
`- Dictionary definitions from Webster’s Third New International Dictionary,
`
`including the definitions of the following terms and phrases:
`
`o Aquarium
`
`o Aqueous
`
`o Axis
`
`o Composition
`
`o Concave
`
`
`1 Tennant has previously provided the definitions and references listed herein and incorporates
`its previous production herein.
`
`
`
`2
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 4 of 21
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`o Connected
`
`o Contain
`
`o Contained
`
`o Emit
`
`o Factor
`
`o Flow
`
`o Housing
`
`o Inlet
`
`o Outlet
`
`o Oxygenated
`
`o Oxygenated Water
`
`o Radial
`
`o Suspension
`
`o Tube
`
`o Tubular
`
`- Van London/pHoenix Co., Education Series Conductivity Guide, http://www.vl-
`
`pc.com/tasks/render/file/?fileid=10CA7CE7-B9B7-08EF-
`
`AD30B324EEF84B9D.
`
`- U.S. Patent No. 7,396,441 file history
`
`- Provisional App. No. 60/358,534
`
`- Expert Testimony from Mario Tremblay who may provide testimony through
`
`written declaration or live testimony to discuss the level of skill in the art, explain
`
`3
`
`
`
`
`
`
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`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 5 of 21
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`
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`how various terms and phrases would be understood by one of ordinary skill in
`
`the art, and present testimony regarding the indefiniteness of certain claim terms
`
`in the asserted patents.
`
`Subject to the foregoing, Tennant identifies the preliminary claim constructions and
`
`supporting evidence in the charts below.2 Where any construction for a term or phrase is
`
`given, Tennant incorporates that construction into its other proposed constructions, e.g.,
`
`where Tennant’s construction refers to “water,” such construction incorporates Tennant’s
`
`proposed construction of “water” as well. Tennant further submits the same terms or
`
`phrases should be construed in the same manner across all asserted claims and all asserted
`
`patents consistently.
`
`
`Tennant notes that, in its invalidity contentions, Tennant identified two additional
`2
`phrases as unsupported by the specification: “flowing water at a flow rate no greater than
`12 gallons per minute” and “delivers a current to the electrodes at a ratio of 1.75 amps or
`less per 3 square inches of active electrode.” OWT has failed to suggest any construction
`for these terms is necessary. Tennant maintains that these terms are unsupported by the
`specification, regardless of construction.
`
`
`
`4
`
`
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`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 6 of 21
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`
`
`Dated: March 30, 2021
`
`
`
`
`
`72461070
`
`
`/s/ R. Scott Johnson
`Lora M. Friedemann (#0259615)
`FREDRIKSON & BYRON, P.A.
`200 South Sixth Street, Suite 4000
`Minneapolis, MN 55402-1425
`Telephone: 612.492.7000
`lfriedemann@fredlaw.com
`
`R. Scott Johnson (Admitted Pro Hac Vice)
`Cara S. Donels (Admitted Pro Hac Vice)
`FREDRIKSON & BYRON, P.A.
`111 E. Grand Avenue, Suite 301
`Des Moines, IA 50309
`Telephone: 515.242.8900
`rsjohnson@fredlaw.com
`cdonels@fredlaw.com.
`
`Attorneys for Defendant Tennant Company
`
`
`
`5
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 7 of 21
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`THE ‘415 PATENT
`I.
`Tennant’s
`Applicable
`Identified
`Claims
`Claim Term(s)
`“oxygenated
`aqueous
`composition”
`
`13
`
`A composition of water and
`oxygen.
`
`“water”
`
`13, 18, 20,
`21, 25, 27
`
`Senkiw acted as his own
`lexicographer. Therefore, the
`definition provided in the patent
`governs, as follows: “Water
`means any aqueous medium with
`resistance less than one ohm per
`square centimeter, that is, a
`medium that can support the
`electrolysis of water. In general,
`the lower limit of resistance for a
`medium that can support
`electrolysis is water containing
`more than 2000 ppm total
`dissolved solids.” Alternatively, in
`the event that the court determines
`that the definition contains an error
`and/or that it does not inform a
`POSITA of the scope of the
`invention with reasonable certainty,
`the definition is indefinite.
`
`
`6
`
`• Definition of oxygenated
`• Definition of oxygenated water
`• Definition of aqueous
`• Definition of composition
`
`• This construction may be supported
`by expert testimony from Mario
`Tremblay, who will testify as to the
`general knowledge in the art of the
`relationship between total dissolved
`solids, resistance and conductivity.
`Dr. Tremblay will also explain how
`this term would be understood by
`one of ordinary skill in the art. In
`particular, Tremblay will testify that
`the definition contains two
`sentences; that a POSITA would
`understand that both sentences must
`be given meaning; and that the
`second sentence requires more than
`2000 ppm total dissolved solids.
`Alternatively, in the event that the
`court determines that the definition
`contains errors and/or that it does
`not inform a POSITA of the scope
`of the invention with reasonable
`
`
`
`
`
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 8 of 21
`
`
`
`
`
`Tennant’s
`Identified
`Claim Term(s)
`
`Applicable
`Claims
`
`Tennant’s Proposed
`Construction
`
`“tubular
`housing”
`
`13, 26
`
`an enclosure shaped like a cylinder,
`hose, or tube
`
`“microbubbles” 13, 20, 21,
`22, 25
`
`“nanobubbles” 13, 20, 21,
`22, 25
`
`a bubble with a diameter less than
`50 microns
`
`Tennant maintains this term is
`indefinite and unsupported by the
`specification. Without waiving this
`position, to the extent any
`construction is possible, Tennant
`relies on the definition in the patent
`as follows: “Nanobubble means a
`bubble with a diameter less than
`that necessary to break the surface
`tension of water. Nanobubbles
`remain suspended in the water,
`giving the water an opalescent or
`milky appearance.”
`
`
`7
`
`Extrinsic Evidence
`
`
`
`certainty, Tremblay will testify that
`the definition is indefinite.
`
`• Definition of tubular
`• Definition of housing
`• U.S. Patent No. 7,396,441 file
`history, Figure 7, page 293
`• Provisional App. No. 60/358,534,
`All Figures and Disclosures
`
`
`
`• This construction may be supported
`by expert testimony from Mario
`Tremblay, who will discuss the
`indefiniteness issues associated with
`this claim and explain how this
`phrase would be understood by one
`of ordinary skill in the art.
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 9 of 21
`
`Applicable
`Claims
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`
`
`“the distance separating the anode
`and cathode at which evolved
`oxygen forms microbubbles and
`nanobubbles.”
`
`Voltage maximum of
`approximately 28.3 volts
`
`
`
`The portion of the tubular housing
`through which water enters and
`which is not connected to any other
`tubing.
`
`The portion of the tubular housing
`through which water exits and
`which is not connected to any other
`tubing.
`
`A straight line defining a path
`through which water flows through
`the tubular housing and extending
`from the inlet to the outlet.
`
`Tennant maintains this term is
`indefinite and unsupported by the
`specification. Without waiving this
`8
`
`• Definition of inlet
`
`
`• Definition of outlet
`
`
`• Definition of axis
`• Definition of tubular
`
`• This construction may be supported
`by expert testimony from Mario
`
`Tennant’s
`Identified
`Claim Term(s)
`“critical
`distance”
`
`“a voltage no
`greater than
`about 28.3
`volts”
`
`“inlet”
`
`13
`
`13
`
`13, 18
`
`“outlet”
`
`13
`
`“tubular flow
`axis from the
`inlet to the
`outlet”
`
`“conductivity
`produced by
`the presence of
`
`13
`
`13
`
`
`
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 10 of 21
`
`Applicable
`Claims
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`position, to the extent any
`construction is possible, Tennant
`relies on the definition provided by
`the applicant wherein he defined
`how conductivity is produced by
`the presence of dissolved solids
`such that the water supports plant
`or animal life as water that can
`support electrolysis is “water
`containing more than 2000 ppm
`total dissolved solids.”
`
`
`The method uses water temperature
`to determine whether or not a
`suspension can be formed
`
`Tremblay, who will discuss the
`indefiniteness issues associated with
`this claim and explain how this
`phrase would be understood by one
`of ordinary skill in the art. Dr.
`Tremblay will explain the types and
`quantities of dissolved solids that
`are often present in different kinds
`of water, including salt in marine
`water, and chlorine and fluoride in
`tap water. Dr. Tremblay will testify
`that this term fails to inform those
`skilled in the art about the scope of
`the patent with reasonable certainty
`of the quantity of dissolved solids
`needed to support plant or animal
`life in a particular context.
`
`• Definition of factor
`
`Where the microbubbles and the
`nanobubbles remain in water for
`any time period up to several hours.
`
`
`
`9
`
`Tennant’s
`Identified
`Claim Term(s)
`dissolved
`solids such that
`the water
`supports plant
`or animal life”
`
`18
`
`20
`
`“the water
`temperature is
`a factor for
`formation of
`the suspension”
`
`“wherein the
`microbubbles
`and
`nanobubbles
`
`
`
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 11 of 21
`
`Applicable
`Claims
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`Tennant’s
`Identified
`Claim Term(s)
`remain in the
`water at least in
`part for a
`period up to
`several hours”
`
`“containing the
`water with
`microbubbles
`and
`nanobubbles in
`a two and one
`half gallon
`aquarium
`reservoir
`container”
`
`20
`
`In its infringement contentions,
`OWT failed to specifically indicate
`where this element was present in
`any Tennant accused product or
`method of using the same and
`relied on future potential fact or
`expert discovery to assert that this
`element was present. Because
`OWT has failed to identify any
`such evidence, Tennant is uncertain
`what OWT is alleging this phrase
`means. To the extent that this
`element is not indefinite,
`“aquarium reservoir container”
`should be construed as “a container
`designed for keeping fish or other
`live aquatic creatures”
`
`“oxygen at a higher concentration
`than normal calculated oxygen
`solubility at a particular
`temperature and pressure.”
`
`10
`
`• Definition of aquarium
`
`
`
`“supersaturate” 21
`
`
`
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 12 of 21
`
`Tennant’s
`Identified
`Claim Term(s)
`
`Applicable
`Claims
`
`22
`
`25
`
`“bubble
`diameter is less
`than 0.0006
`inches”
`
`“incapable of
`breaking the
`surface tension
`of the water”
`
`
`
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`
`Plain and ordinary meaning
`
`
`
`containing nanobubbles
`
`•
`
`This construction will be supported
`by testimony of Mario Tremblay
`that a POSITA would understand
`that “incapable of breaking the
`surface tension of the water” means
`“contains nanobubbles” because of
`the express definition of nanobubble
`provided in the ’415 patent.
`
`11
`
`
`
`
`
`
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 13 of 21
`
`Applicable
`Claim(s)
`
`13
`
`OWT’s
`Identified
`Claim Term(s)
`“flowing water
`. . . through an
`electrolysis
`emitter”
`
`“an electrical
`power source”
`
`“an anode
`electrode and a
`cathode
`electrode
`contained in a
`tubular
`housing”
`
`“a suspension” 13
`
`13
`
`13
`
`13
`
`“the water
`temperature is
`a factor for
`formation of
`the suspension”
`
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`Placing the emitting device in the
`fluid to be treated as opposed to
`using a pipe system
`
`• Definition of emit
`• Definition of flow
`• Definition of electrolysis
`
`Plain and ordinary meaning
`
`
`
`An anode electrode and a cathode
`electrode located within a tubular
`housing.
`
`• Definition of tubular
`• Definition of contained
`
`A mixture of water and oxygen
`gas wherein the oxygen gas is
`mixed with the water.
`
`The method uses water
`temperature to determine whether
`or not a suspension can be formed.
`
`• Definition of suspension
`
`• Definition of factor
`
`
`12
`
`
`
`
`
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 14 of 21
`
`Applicable
`Claim(s)
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`19
`
`Where the microbubbles and the
`nanobubbles remain in water for
`any period of time up to several
`hours.
`
`
`
`
`
`13
`
`OWT’s
`Identified
`Claim Term(s)
`“the
`microbubbles
`and
`nanobubbles
`remain in the
`water at least in
`part for a
`period up to
`several hours”
`
`
`
`
`
`
`
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 15 of 21
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`
`
`
`
`II. THE ‘092 PATENT3
`Tennant’s
`Applicable
`Identified
`Claims
`Claim Term
`“water”
`
`13, 27, 60 Senkiw acted as his own
`lexicographer. Therefore, the
`definition provided in the patent
`governs, as follows: “Water
`means any aqueous medium
`with resistance less than one
`ohm per square centimeter, that
`is, a medium that can support
`the electrolysis of water. In
`general, the lower limit of
`resistance for a medium that can
`support electrolysis is water
`containing more than 2000 ppm
`total dissolved solids.”
`Alternatively, in the event that the
`court determines that the definition
`contains an error and/or that it
`does not inform a POSITA of the
`scope of the invention with
`reasonable certainty, the definition
`is indefinite.
`
`
`•
`
`This construction may be supported
`by expert testimony from Mario
`Tremblay, who will testify as to the
`general knowledge in the art of the
`relationship between total dissolved
`solids, resistance and conductivity.
`Dr. Tremblay will also explain how
`this term would be understood by
`one of ordinary skill in the art. In
`particular, Tremblay will testify that
`the definition contains two sentences;
`that a POSITA would understand that
`both sentences must be given
`meaning; and that the second
`sentence requires more than 2000
`ppm total dissolved solids.
`Alternatively, in the event that the
`court determines that the definition
`contains errors and/or that it does not
`inform a POSITA of the scope of the
`invention with reasonable certainty,
`Tremblay will testify that the
`definition is indefinite.
`
`
`3 Upon further consideration, we removed “unobstructed passageway” as a term that requires construction.
`14
`
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 16 of 21
`
`Applicable
`Claims
`
`Tennant’s Proposed
`Construction
`
`13, 27
`
`Voltage maximum of
`approximately 28.3 volts.
`
`Extrinsic Evidence
`
`• Definition of inlet
`
`• Definition of outlet
`
`• This construction may be supported
`by expert testimony from Mario
`Tremblay, who will discuss the
`indefiniteness issues associated with
`this claim and explain how this term
`would be understood by one of
`ordinary skill in the art.
`
`
`
`
`
`
`
`
`
`
`
`The portion of the tubular housing
`through which water enters and
`which is not connected to any
`other tubing.
`
`The portion of the tubular housing
`through which water exits and
`which is not connected to any
`other tubing.
`
`a bubble with a diameter less than
`50 microns
`
`Tennant maintains this term is
`indefinite and unsupported by the
`specification. Without waiving
`this position, to the extent any
`construction is possible, Tennant
`relies on the definition in the
`patent as follows: “Nanobubble
`means a bubble with a diameter
`less than that necessary to break
`the surface tension of water.
`15
`
`Tennant’s
`Identified
`Claim Term
`“the voltage
`being less than
`or equal to 28.3
`volts”
`
`“inlet”
`
`13, 27
`
`“outlet”
`
`13, 27
`
`“microbubbles”
`
`“nanobubbles”
`
`23
`
`26
`
`
`
`
`
`
`
`Tennant’s
`Identified
`Claim Term
`
`“concave”
`
`“radial
`direction”
`
`64
`
`65
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 17 of 21
`
`Applicable
`Claims
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`Nanobubbles remain suspended in
`the water, giving the water an
`opalescent or milky appearance.”
`
`Shaped like a curved recess
`
`Radiating outwardly as a ray and
`developing uniformly around a
`center axis
`
`
`• Definition of concave
`• Definition of radial
`
`OWT’s
`Identified
`Claim Term(s)
`“a flow-
`through
`oxygenator”
`
`“a power
`source”
`
`“passing water
`through the
`tubular
`housing”
`
`
`Applicable
`Claim(s)
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`13
`
`Placing the emitting device in the
`fluid to be treated as opposed to
`using a pipe system
`
`13, 27
`
`Plain and ordinary meaning
`
`
`
`
`
`13
`
`Plain and ordinary meaning
`
`
`
`
`
`16
`
`
`
`
`
`
`
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 18 of 21
`
`
`
`
`
`III. THE ‘665 PATENT4
`Tennant’s
`Applicable
`Identified
`Claims
`Claim Term
`“water”
`
`13, 55
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`Senkiw acted as his own
`lexicographer. Therefore, the
`definition provided in the patent
`governs, as follows: “Water
`means any aqueous medium
`with resistance less than one
`ohm per square centimeter, that
`is, a medium that can support
`the electrolysis of water. In
`general, the lower limit of
`resistance for a medium that can
`support electrolysis is water
`containing more than 2000 ppm
`total dissolved solids.”
`Alternatively, in the event that the
`court determines that the definition
`contains an error and/or that it
`does not inform a POSITA of the
`scope of the invention with
`reasonable certainty, the definition
`is indefinite.
`
`
`• This construction may be supported
`by expert testimony from Mario
`Tremblay, who will testify as to the
`general knowledge in the art of the
`relationship between total dissolved
`solids, resistance and conductivity.
`Dr. Tremblay will also explain how
`this term would be understood by one
`of ordinary skill in the art. In
`particular, Tremblay will testify that
`the definition contains two sentences;
`that a POSITA would understand that
`both sentences must be given
`meaning; and that the second
`sentence requires more than 2000
`ppm total dissolved solids.
`Alternatively, in the event that the
`court determines that the definition
`contains errors and/or that it does not
`inform a POSITA of the scope of the
`invention with reasonable certainty,
`Tremblay will testify that the
`definition is indefinite.
`
`
`4 Upon further consideration, we removed “unobstructed passageway” as a term that requires construction.
`17
`
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 19 of 21
`
`Applicable
`Claims
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`13
`
`Voltage maximum of
`approximately 28.3 volts
`
`Tennant’s
`Identified
`Claim Term
`
`“the voltage
`being less than
`or equal to 28.3
`volts”
`
`“inlet”
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`• Definition of inlet
`
`• Definition of outlet
`
`• Definition of aqueous
`• Definition of medium
`
`13, 55
`
`“outlet”
`
`13, 55
`
`55
`
`61
`
`“aqueous
`medium”
`
`“a first anode
`electrode
`portion that is
`non- parallel to
`a second anode
`electrode
`portion”
`
`
`The portion of the tubular housing
`through which water enters and
`which is not connected to any
`other tubing.
`
`The portion of the tubular housing
`through which water exits and
`which is not connected to any
`other tubing.
`
`A mixture made with water
`
`A first anode and a second anode
`with planar surfaces that are not
`orientated in the same direction.
`
`18
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 20 of 21
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 20 of 21
`
`19
`
`
`
`
`
`
`
`
`
`
`CASE 0:20-cv-00358-ECT-HB Doc. 80-8 Filed 06/10/21 Page 21 of 21
`
`Applicable
`Claim(s)
`
`Tennant’s Proposed
`Construction
`
`Extrinsic Evidence
`
`13
`
`13
`
`Plain and ordinary meaning
`
`Delivering electrical current to the
`electrodes while lf
`
`
`
`
`
`20
`
`OWT’s
`Identified
`Claim Term(s)
`“a power
`source”
`
`“deliver
`electrical
`current to the
`electrodes
`while water
`flows through
`the tubular
`housing”
`
`
`
`
`
`
`
`
`
`
`
`
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