`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`FUTURE LINK SYSTEMS, LLC,
`
`Plaintiff,
`
`v.
`
`APPLE, INC.,
`
`Defendant.
`
` Case No. 6:21-cv-0263-ADA
`
`JURY TRIAL DEMANDED
`
`PLAINTIFF FUTURE LINK SYSTEMS, LLC’S
`PRELIMINARY PROPOSED CLAIM CONSTRUCTIONS
`
`Pursuant to the Court’s Scheduling Order, Plaintiff Future Link Systems, LLC (“Future
`
`Link”) hereby discloses to Defendant in the above-captioned action its preliminary proposed
`
`construction for the claim terms, phrases, or clauses from the patents-in-suit (set forth in Exhibit
`
`A), which the parties collectively have identified for claim construction purposes.
`
`Future Link has not yet completed its investigation, collection of information, discovery,
`
`and analysis relating to this action. Further discovery and investigation may require Future Link
`
`to supplement, modify, or alter the preliminary claim constructions, including, for example, in
`
`view of any developments that arise during the meet and confer process. Accordingly, Future Link
`
`expressly reserves the right to supplement, modify, or alter its preliminary proposed claim
`
`constructions. Future Link reserves all of its rights and does not waive any proposed construction,
`
`defense, or position by the submission of this disclosure.
`
`IPR2022-00208
`Apple EX1006 Page 1
`
`
`
`Dated: October 12, 2021
`
`
`
`
`
`
`
`
`
`
`/s/ James Milkey. _
`Reza Mirzaie (CA SBN 246953)
`rmirzaie@raklaw.com
`Marc A. Fenster (CA SBN 181067)
`mfenster@raklaw.com
`Brian D. Ledahl (CA SBN 186579)
`bledahl@raklaw.com
`James Milkey (CA SBN 281283)
`jmilkey@raklaw.com
`Christian W. Conkle (CA SBN 306374)
`cconkle@raklaw.com
`Jonathan Ma (CA SBN 312773)
`jma@raklaw.com
`Minna Y. Chan (CA SBN 305941)
`mchan@raklaw.com
`RUSS AUGUST & KABAT
`12424 Wilshire Blvd., 12th Floor
`Los Angeles, California 90025
`Telephone: (310) 826-7474
`Facsimile: (310) 826-6991
`
`Attorneys for Plaintiff
`Future Link Systems, LLC
`
`2
`
`
`
`
`
`
`IPR2022-00208
`Apple EX1006 Page 2
`
`
`
`CERTIFICATE OF SERVICE
`
`
`I certify that this document is being served upon counsel of record for Defendant identified
`
`in the above caption on October 12, 2021 via e-mail.
`
`
`
`
`
`
`/s/ James Milkey
`James Milkey
`
`
`
`3
`
`IPR2022-00208
`Apple EX1006 Page 3
`
`
`
`
`
`
`
`
`Exhibit A
`Exhibit A
`
`
`
`
`
`4
`
`IPR2022-00208
`Apple EX1006 Page 4
`
`IPR2022-00208
`Apple EX1006 Page 4
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`
`
`Future Link’s Preliminary Claim Constructions
`
`
`Preliminary proposed construction
`Plain and ordinary meaning
`
`“a port that transfers bits, characters, or data units
`sequentially” – see Intel Corp. v. Future Link Sys.,
`LLC, C.A. No. 1-14-cv-00377-LPS, Dkt. 378 at 15-16
`(D. Del. Aug, 2, 2016) / plural of “serial port,” as
`construed
`Plain and ordinary meaning
`
`Plain and ordinary meaning
`
`USPN 6,317,804
`
`Claim term of ’804 Patent
`“functional block” / “functional blocks”
`
`“serial port” / “serial ports”
`
`“serial command, data and clock interconnects”
`
`“selectively couple”
`
`
`
`USPN 7,917,680
`
`“packet”
`
`Claim term of ’680 Patent
`
`Preliminary proposed construction
`Plain and ordinary meaning
`
`“packet-based communications” / “communicating packet data” /
`“communicate the packets”
`
`Plain and ordinary meaning
`
`5
`
`IPR2022-00208
`Apple EX1006 Page 5
`
`
`
`Claim term of ’680 Patent
`“performance-based communications order” / “order . . . as a function of
`the communications priority and performance rules” / “order to the packets
`based upon the generated protocol-based ordering data and performance-
`based rules”
`“CPU-based link”
`
`Preliminary proposed construction
`Plain and ordinary meaning
`
`Plain and ordinary meaning
`
`
`
`USPN 6,622,1081
`
`Claim term of ’108 Patent
`“low complexity memory” (claims 1 and 11)
`
`Whether the preamble of asserted claim 11 is limiting
`
`
`
`
`Preliminary proposed construction
`“memory with less complex initialization processes or
`access protocols than the main unit”
`The preamble to claim 11 is limiting.
`
`
`1 Both “low complexity memory” and whether the preamble to claim 11 is limiting are issues that may be resolved by the Court in the Markman proceedings in
`Future Link Systems v. Advanced Micro Devices, Case No. 6:20-cv-01176-ADA. If the Court resolves these issues in the AMD Markman, FLS understands that
`the Court will adopt the construction from the AMD case. See July 16, 2021 email from Laura Degnan to Hannah Santasawatkul.
`
`6
`
`IPR2022-00208
`Apple EX1006 Page 6
`
`
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