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IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`THETA IP, LLC,
`Plaintiff
`
`-v-
`SAMSUNG ELECTRONICS CO.,
`LTD., SAMSUNG ELECTRONICS
`AMERICA, INC.,
`Defendants
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`W-20-CV-00160-ADA
`
`CLAIM CONSTRUCTION ORDER
`
`The Court held a Markman hearing on January 7, 2021. During that hearing, the Court
`
`provided its final constructions. The Court now enters those claim constructions.
`
`SIGNED this 7th day of January, 2020.
`
`ALAN D ALBRIGHT
`UNITED STATES DISTRICT JUDGE
`
`Petitioners Lenovo (United
`States) Inc. and Motorola
`Mobility LLC - Ex. 1009
`
`IPR2023-00697
`Theta EX2014
`
`

`

`Term
`
`“dynamically adjusting”
`(’202 Patent, Claims 1, 7, 19, 21)
`
`Group C terms:
`“dynamically decreasing”
`(’202 Patent, Claims 2, 5)
`
`“dynamically reducing”
`(’202 Patent, Claims 9, 20)
`
`“dynamically increased”
`(’202 Patent, Claim 13)
`
`Plaintiff’s Proposed
`Construction
`“adjusting during
`operation [but not by
`selecting between two
`predetermined modes in
`reliance on signal
`strength thresholds]”
`
`Or: Plain-and-ordinary
`meaning
`
`“[decreasing / reducing /
`increased] during
`operation [but not by
`selecting between two
`predetermined modes in
`reliance on signal
`strength thresholds]”
`
`Or: Plain and ordinary
`meaning.
`
`Defendants’ Proposed
`Construction
`“adjusting during operation
`without reliance upon a signal
`strength threshold”
`
`“[decreasing / reducing /
`increased] during operation
`without reliance upon a signal
`strength threshold”
`
`Court’s Final Construction
`
`Plain-and-ordinary-meaning,
`wherein the plain-and-
`ordinary meaning is
`“adjusting during operation
`based—at least in part—on
`information gained during
`operation”
`
`Plain-and-ordinary-meaning,
`wherein the plain-and-
`ordinary meaning is
`“[decreasing / reducing /
`increased] during operation
`based—at least in part—on
`information gained during
`operation”
`
`IPR2023-00697
`Theta EX2014
`
`

`

`Plaintiff’s Proposed
`Construction
`“decreased during
`operation [but not by
`selecting between two
`predetermined modes in
`reliance on signal
`strength thresholds]”
`
`Or: Plain and ordinary
`meaning.
`
`
`Plain-and-ordinary
`meaning
`
`
`Defendants’ Proposed
`Construction
`Indefinite as part of the phrase
`“dynamically decreased
`relative to the worst-case
`condition,” as discussed below
`with respect to Group E.
`
`Alternatively: “decreased
`during operation without
`reliance upon a signal strength
`threshold”
`
`“adjusting without reliance on
`any signal strength crossing a
`threshold [an impedance and a
`bias current / a bias current] …
`as the signal strength of the
`interferer signal and the signal
`strength of the desired signal
`vary”
`
`
`Court’s Final Construction
`
`Plain-and-ordinary-meaning,
`wherein the plain-and-
`ordinary meaning is
`“decreased during operation
`based—at least in part—on
`information gained during
`operation”
`
`
`Plain-and-ordinary meaning
`
`
`Term
`
`“dynamically decreased”
`(’202 Patent, Claim 11)
`
`
`Group B terms:
`“varying an impedance and a bias
`current…as the signal strength of the
`interferer signal and the signal
`strength of the desired signal vary”
`(’962 Patent, Claim 1)
`
`“causing a bias current to vary…as
`the signal strength of the interferer
`signal and the signal strength of the
`desired signal vary”
`(’825 Patent, Claims 1, 3)
`
`“causing a bias current and an
`impedance to vary…as the signal
`strength of the interferer signal and
`the signal strength of the desired
`signal vary”
`(’825 Patent, Claim 8)
`
`
`IPR2023-00697
`Theta EX2014
`
`

`

`Not indefinite. Plain-and-
`ordinary meaning.
`
`
`Indefinite.
`
`
`Not indefinite. Plain-and-
`ordinary meaning.
`
`
`Group D terms:
`“[signal / signal strength / strength of
`[[the/a]] … signal] is high” (’962
`Patent claim 1)
`(’202 Patent, Claims 1, 7, 11, 13, 19)
`
`“[signal / signal strength / strength of
`[[the/a]] … signal] is low” (’962
`Patent claim 1)
`(’202 Patent, Claims 1, 2, 5, 7, 9, 11,
`13, 19, 20)
`
`power
`a worst-case
`“wherein
`condition
`[from
`the
`dissipation
`battery] results when
`the signal
`strength of the desired signal is low
`and
`the signal strength of
`the
`interferer signal is high”
`(’825 Patent, Claims 1, 3, 8)
`
`“when the signal strength of the
`interferer signal is high and the signal
`strength of the desired signal is low,
`and the desired signal [has a signal
`strength that] is larger than in the
`power
`dissipation
`worst-case
`condition[s]”
`(’825 Patent, Claims 1, 3, 8)
`
`“[signal / signal strength] is weak”
`(’825 Patent, Claim 1)
`(’202 Patent, Claim 5)
`
`
`IPR2023-00697
`Theta EX2014
`
`

`

`Term
`
`Group E terms:
`“the bias current…is increased and
`the impedance…is reduced, resulting
`in a first current drain”
`(’962 Patent, Claim 1)
`
`“causing the bias current…to be
`reduced compared to the worst-case
`power dissipation condition”
`(’825 Patent, Claim 1)
`
`“causing the bias current…to be
`[reduced/decreased] compared to the
`power
`dissipation
`worst-case
`condition”
`(’825 Patent, Claims 1, 3)
`
`to be
`“causing a bias current
`dynamically decreased relative to the
`worst-case condition”
`(’202 Patent, Claim 11)
`
`“impedance”
`(’962 Patent, Claims 1, 6)
`(’825 Patent, Claim 8)
`(’202 Patent, Claims 1, 7, 19)
`
`
`
`
`Plaintiff’s Proposed
`Construction
`Not indefinite. Plain-and-
`ordinary meaning.
`
`
`Defendants’ Proposed
`Construction
`Indefinite.
`
`
`Court’s Final Construction
`
`Not indefinite. Plain-and-
`ordinary meaning.
`
`
`“opposition to the flow of
`alternating current”
`
`
`(i.e.,
`total opposition
`“the
`resistance and
`reactance) a
`circuit offers to the flow of
`alternating current at a given
`frequency
`
`
`Plain-and-ordinary meaning
`
`
`IPR2023-00697
`Theta EX2014
`
`

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