Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 1 of 13 Page ID #:903
`
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`I.
`
`Proposed Constructions of Disputed Terms
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
`1. “charge cut-off voltage”
`
`5-7
`
`No construction is needed. If this
`term needs construction, it should be
`afforded its plain and ordinary
`meaning, which is the maximum
`voltage to which the battery is
`configured to be charged.
`
`Specification of the ’641 patent:
`
`Abstract; 1:36–2:67; 3:3–16; 3:55–
`6:67; 7:23–29; 9:49–55; Examples
`1–28; Tables 2-4.
`
`the voltage at which the charging
`changes from constant current
`charging to constant voltage
`charging
`
`Prosecution History of the ’641
`patent:
`
`• October 21, 2008 Applicant’s
`Remarks at 5-6
`• May 15, 2009 Applicant’s
`Remarks at 6
`• November 13, 2009
`Applicant’s Remarks at 8-11
`• Notice of Allowance of the
`’641 patent at 2-3
`
`Prosecution History of US Patent
`Application No. 12/817,028
`
`• February 9, 2011 Applicant’s
`Remarks at 4
`• August 25, 2011 Applicant’s
`Remarks at 4-7
`• February 26, 2013 Applicant’s
`Remarks at 4-6
`
`1
`
`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`’641 Patent at 2:38–41, 4:43–
`46, 5:62–6:34, 8:19–24.
`
`Dkt. 42 at 3.
`
`’641 Patent File History at
`Nov. 13, 2009 Amendment
`and Reply at 2–3.
`
`CNIPA Case No. 4W112700
`10/27/2022 Response and
`Supplemental Documents
`after Oral Hearing Proceeding
`at 26, 27, 29, 30, 49.
`
`CNIPA Case No. 4W107411
`08/07/2018 Response to
`Invalidation Request at 2-3.
`
`CNIPA Case No. 4W107411
`09/12/2018 Response to
`Supplemental Invalidation
`Request at 7.
`
`Linden, D. et al., Handbook
`of Batteries (3d ed. 2001).
`
`APPLE 1016
`
`

`

`Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 2 of 13 Page ID #:904
`
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`Graf, R., Modern Dictionary
`of Electronics (7th ed. 1999).
`
`Dr. Horn may offer expert
`testimony that a POSA would
`have understood this term to
`have Apple’s proposed
`construction.
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
`• November 27, 2013
`Applicant’s Pre-Appeal Brief
`Request for Review at 1-4
`
`Zou et al., Synthesis of High-
`Voltage (4.5V) Cycling Doped
`LiCoO2 for Use in Lithium
`Rechargeable Cells, Chemistry of
`Materials, Vol. 15, No. 25 (2003)
`
`The People’s Republic of China
`National Standard - General
`Specification of Lithium-Ion
`Battery for Cellular Phone (GB/T
`18287-2000)
`
`David Linden, Handbook of
`Batteries, McGraw-Hill
`Handbooks (2001)
`
`G.G. Amatucci et al., Cobalt
`dissolution in LiCoO2-based non-
`aqueous rechargeable batteris, 83
`Solid State Ionics, 167-173 (1996)
`
`K. Brandt, Historical development
`of secondary lithium batteries, 69
`Solid State Ionics 173-183 (1994)
`
`2
`
`

`

`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`
`Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 3 of 13 Page ID #:905
`
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
`B. Johnson et al., Characterization
`of commercially available lithium
`ion batteries, 70 J. Power Sources
`48-54 (1998)
`
`B. Johnson, An Examination of the
`Performance of the Lithium-Ion
`Battery System (1998) (Ph.D.
`dissertation, University of South
`Carolina)
`
`Kim et al., Effect of Capacity
`Ratios between Anode and
`Cathode on Electrochemical
`Properties for Lithium Polymer
`Batteries, 155 Electrochimica Acta
`431-36 (2015)
`
`Chen et al., Effect of N/P ratios on
`performance of
`LiNi0.8Co0.15Al0.05O2 ||
`SiOx/Graphite lithium-ion
`batteries, 439 J. Power Sources
`227056 (2019)
`
`Mayer et al., Cycle Life Testing of
`Lithium-Ion Batteries for Small
`Sattelite LEO Space Missions,
`Lawrence Livermore National
`Laboratory (1993)
`
`3
`
`

`

`Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 4 of 13 Page ID #:906
`
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`
`5
`
`2. “ratio of positive
`electrode material to
`negative electrode material
`as calculated by a theoretic
`capacity with a charge cut-
`off voltage set at 4.2 V”
`
`No construction is needed. If this
`term needs construction, it should be
`afforded its plain and ordinary
`meaning: the ratio calculated as the
`product of the capacity of the
`cathode active material per mass unit
`and the amount of the cathode active
`material in the same mass unit
`divided by the product of the
`capacity of the anode active material
`per mass unit and the amount of the
`anode active material in the same
`mass unit, when the charge cutoff
`voltage is 4.2 V.
`
`RJ Technology’s expert may offer
`expert testimony, consistent with
`the intrinsic evidence and from the
`perspective of one of ordinary skill
`in the art at the time of the
`invention, that “charge cut-off
`voltage” as used in this patent has
`the meaning that Plaintiff
`proposes.
`Specification of the ’641 patent:
`
`Abstract; 1:36–44; 1:64–2:3; 3:7–
`12; 4:5–9; 4:27–42; 6:43–67; 7:1–
`8; 7:22–50; Examples 1–28
`
`Prosecution History of the ’641
`patent:
`
`• May 15, 2009 Applicant’s
`Remarks at 7
`• November 13, 2009
`Applicant’s Remarks at 8
`• Notice of Allowance of the
`’641 patent
`
`Prosecution History of US Patent
`Application No. 12/817,028
`
`4
`
`Indefinite.
`
`In the alternative, the ratio
`calculated as the product of the
`theoretic capacity of the cathode
`active material per mass unit and
`the amount of the cathode active
`material in the same mass unit
`divided by the product of the
`capacity of the anode active
`material per mass unit and the
`amount of the anode active
`material in the same mass unit,
`when the cell charge cutoff
`voltage is set at 4.2 V,
`
`wherein “theoretic capacity”
`means “theoretical, rather than
`actual, capacity that assumes all
`of the active substances
`
`’641 Patent at 1:24–30, 1:35–
`44, 1:64–67, 2:38–41, 3:7–12,
`4:5–9, 4:32–36, 4:43–46,
`6:50–53, 7:3–6, 8:4–24.
`
`’641 Patent File History at
`Nov. 13, 2009 Amendment
`and Reply at 7–8, 10–12.
`
`’641 Patent File History at
`Aug. 14, 2009 Office Action
`at 2–4.
`
`’641 Patent File History, Sept.
`4, 2009 Office Action at 2–4.
`
`’641 Patent File History at
`May 15, 2009 Amendment
`and Reply at 7.
`
`

`

`Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 5 of 13 Page ID #:907
`
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
`participate in the reaction of the
`battery”
`
`• February 9, 2011 Applicant’s
`Remarks at 4
`• August 25, 2011 Applicant’s
`Remarks at 4-7
`• February 26, 2013 Applicant’s
`Remarks at 4-6
`• November 27, 2013
`Applicant’s Pre-Appeal Brief
`Request for Review at 1-4
`
`David Linden, Handbook of
`Batteries, McGraw-Hill
`Handbooks (2001)
`
`K. Brandt, Historical development
`of secondary lithium batteries, 69
`Solid State Ionics 173-183 (1994)
`
`B. Johnson et al., Characterization
`of commercially available lithium
`ion batteries, 70 J. Power Sources
`48-54 (1998)
`
`B. Johnson, An Examination of the
`Performance of the Lithium-Ion
`Battery System (1998) (Ph.D.
`dissertation, University of South
`Carolina)
`
`5
`
`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`’641 Patent File History at
`Jan. 16, 2009 Office Action at
`3–4.
`
`’641 Patent File History at
`July 21, 2008 Office Action at
`2–4.
`
`U.S. Patent No. 5,260,148 at
`2:14–19, 2:20–24, 3:14–19,
`3:20–23, 9:15–16.
`
`U.S. Patent Pub. No. US
`2003/0113613 A1 at Abstract,
`[0003], [0005], [0006],
`[0012], [0014], [0016],
`[0018], [0019], [0027],
`[0031], [0033], [0034].
`
`CNIPA Case No. 4W112700
`11/15/2021 Response to
`Evidence and Opinions issued
`on September 24, 2021 at 4.
`
`CNIPA Case No. 4W107411
`09/12/2018 Response to
`Supplemental Invalidation
`Request at 8–9.
`
`

`

`Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 6 of 13 Page ID #:908
`
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
`Kim et al., Effect of Capacity
`Ratios between Anode and
`Cathode on Electrochemical
`Properties for Lithium Polymer
`Batteries, 155 Electrochimica Acta
`431-36 (2015)
`
`Chen et al., Effect of N/P ratios on
`performance of
`LiNi0.8Co0.15Al0.05O2 ||
`SiOx/Graphite lithium-ion
`batteries, 439 J. Power Sources
`227056 (2019)
`
`Luo et al., Examining Effects of
`Negative to Positive Capacity
`Ratios in Three-Electrode Lithium-
`Ion Cells with Layered Oxide
`Cathode and Si Anode, 5 Appl.
`Energy Mater. 5513-18 (2022)
`
`RJ Technology’s expert may offer
`expert testimony, consistent with
`the intrinsic evidence and from the
`perspective of one of ordinary skill
`in the art at the time of the
`invention, that “as calculated by a
`theoretic capacity with a charge
`cut-off voltage set at 4.2 V” as
`
`6
`
`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`CNIPA Case No. 4W112700
`10/27/2022 Response and
`Supplemental Documents
`after Oral Hearing Proceeding
`at 8, 14–15, 24.
`
`Dkt. 42 at 3, 7, 10–11, 14, 15.
`
`Linden, D. et al., Handbook
`of Batteries (3d ed. 2001).
`
`Graf, R., Modern Dictionary
`of Electronics (7th ed. 1999).
`
`Chambers, A. et al., Power
`Industry Dictionary (1996).
`
`Gibilisco, S., The Illustrated
`Dictionary of Electronics (7th
`ed. 1997).
`
`March 20, 2023 Hearing
`Transcript 22:6–23:14, 23:20–
`24:17, 25:2–25:10, 25:20–
`27:5, 27:18–28:8, 28:9–20,
`35:17–36:11.
`
`Dr. Horn may offer expert
`testimony that the ’641 Patent
`does not contain sufficient
`
`

`

`Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 7 of 13 Page ID #:909
`
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
`used in this patent has the meaning
`that Plaintiff proposes.
`
`3. “A secondary lithium ion
`cell or battery”
`
`5
`
`No construction is needed. See RJ
`Technology’s proposed construction
`for the term “as calculated by a
`theoretic capacity with a charge cut-
`off voltage set at 4.2 V”
`
`See RJ Technology’s evidence for
`the term “as calculated by a
`theoretic capacity with a charge
`cut-off voltage set at 4.2 V”
`
`A lithium ion battery, wherein
`the battery electrode materials
`must not be substantially
`changed from what was
`available in the art and made
`without substantially
`decomposing the electrolyte,
`which can be recharged to its
`original capacity, without any
`decreased capacity or cycle life
`at a charge cut-off voltage above
`4.2V
`
`7
`
`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`written description to
`demonstrate to a POSA that
`the inventor had possession of
`the invention at the time the
`application was filed. Dr.
`Horn may further offer expert
`testimony that a POSA would
`not understand how to make
`and use the invention. Dr.
`Horn may further offer expert
`testimony that, to the extent
`the term has any definite
`meaning within the context of
`the patent, a POSA would
`have understood this term to
`have Apple’s proposed
`construction.
`’641 Patent at 1:24–30, 1:64–
`67, 2:38–41, 3:7–12, 4:43–46,
`6:50–53, 7:3–6.
`
`’641 Patent File History at
`Nov. 13, 2009 Amendment
`and Reply at 7–8, 10–12.
`
`’641 Patent File History at
`Aug. 14, 2009 Office Action
`at 2–4.
`
`

`

`Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 8 of 13 Page ID #:910
`
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`’641 Patent File History at
`May 15, 2009 Amendment
`and Reply at 6–10.
`
`’641 Patent File History at
`Jan. 16, 2009 Office Action at
`3–4.
`
`’641 Patent File History at
`Oct. 21, 2008 Amendment
`and Reply at 5–6.
`
`’641 Patent File History at
`July 21, 2008 Office Action at
`2–4.
`
`Linden, D. et al., Handbook
`of Batteries (3d ed. 2001).
`
`Graf, R., Modern Dictionary
`of Electronics (7th ed. 1999).
`
`Chambers, A. et al., Power
`Industry Dictionary (1996).
`
`Gibilisco, S., The Illustrated
`Dictionary of Electronics (7th
`ed. 1997).
`
`8
`
`

`

`Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 9 of 13 Page ID #:911
`
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`U.S. Patent No. 5,260,148 at
`2:14–19, 2:20–24, 3:14–19,
`3:20–23, 9:15–16.
`
`U.S. Patent Pub. No. US
`2003/0113613 A1 at Abstract,
`[0003], [0005], [0006],
`[0012], [0014], [0016],
`[0018], [0019], [0027],
`[0031], [0033], [0034].
`
`CNIPA Case No. 4W112700
`11/15/2021 Response to the
`Invalidation Request at 5.
`
`Dkt. 42 at 3, 7, 10–11, 14, 15.
`
`March 20, 2023 Hearing
`Transcript 17:10–17:15,
`17:22–18:19, 19:1–3, 19:23–
`25, 20:4–7, 27:18–28:8,
`35:17–36:11.
`
`Dr. Horn may offer expert
`testimony that a POSA would
`have understood this term to
`have Apple’s proposed
`construction.
`
`9
`
`

`

`Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 10 of 13 Page ID
`#:912
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
`9, 10
`
`4. “overcharging protection
`voltage” /
`“overcharging protection
`release voltage” /
`“overcharge protection
`release voltage”
`
`No construction is needed. If this
`term needs construction,
`“overcharging protection voltage”
`should be afforded its plain and
`ordinary meaning, which is the
`voltage level at which the battery’s
`protection mechanism(s) engages to
`prevent the battery from being
`charged to a higher voltage.
`
`No construction is needed. If this
`term needs construction, it should be
`afforded its plain and ordinary
`meaning, which is the voltage level
`at which a battery’s protection
`mechanism(s) disengages or resets.
`
`Overcharging protection voltage
`/ release voltage, implemented in
`the secondary lithium ion cell or
`battery, and not in a protection
`circuit
`
`Specification of the ’641 patent:
`
`1:51–55; 3:34–44; 9:24–48; 16:7–
`10.
`
`David Linden, Handbook of
`Batteries, McGraw-Hill
`Handbooks (2001)
`
`B. Johnson et al., Characterization
`of commercially available lithium
`ion batteries, 70 J. Power Sources
`48-54 (1998)
`
`B. Johnson, An Examination of the
`Performance of the Lithium-Ion
`Battery System (1998) (Ph.D.
`dissertation, University of South
`Carolina)
`
`Kim et al., Effect of Capacity
`Ratios between Anode and
`Cathode on Electrochemical
`Properties for Lithium Polymer
`Batteries, 155 Electrochimica Acta
`431-36 (2015)
`
`Chen et al., Effect of N/P ratios on
`performance of
`LiNi0.8Co0.15Al0.05O2 ||
`
`10
`
`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`’641 Patent at 9:24–48.
`
`’641 Patent File History at
`Nov. 13, 2009 Amendment
`and Reply at 2–3.
`
`’641 Patent File History at
`Aug. 14, 2009 Office Action
`at 2–4.
`
`’641 Patent File History at
`Jan. 16, 2009 Office Action at
`4.
`
`’641 Patent File History at
`June 20, 2008 Response at 1.
`
`’641 Patent File History at
`May 23, 2008 Office Action
`at 2.
`
`Dkt. 42 at 7, 12.
`
`Dr. Horn may further offer
`expert testimony that a POSA
`would have understood this
`term to have Apple’s
`proposed construction.
`
`

`

`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`
`Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 11 of 13 Page ID
`#:913
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
`SiOx/Graphite lithium-ion
`batteries, 439 J. Power Sources
`227056 (2019)
`
`Luo et al., Examining Effects of
`Negative to Positive Capacity
`Ratios in Three-Electrode Lithium-
`Ion Cells with Layered Oxide
`Cathode and Si Anode, 5 Appl.
`Energy Mater. 5513-18 (2022)
`
`RJ Technology’s expert may offer
`expert testimony, consistent with
`the intrinsic evidence and from the
`perspective of one of ordinary skill
`in the art at the time of the
`invention, that “overcharging
`protection voltage” and
`“overcharging protection release
`voltage” as used in this patent has
`the meaning that Plaintiff
`proposes.
`
`5. “maintains at least 7500
`of capacity after 400
`cycles”; “maintain at least
`75% of capacity after 400
`cycles”; “maintains at least
`75.83% of capacity after
`
`11-14
`
`No construction is needed. If this
`term needs construction, it should be
`afforded its plain and ordinary
`meaning, which means “maintains at
`least 75%/75.83%/80%/80.72% of
`
`Specification of the ’641 patent:
`
`Indefinite
`
`3:2–7; 5:13–15; Examples 1–28
`
`Prosecution History of the ’641
`patent:
`
`Dr. Horn may offer expert
`testimony that the ’641 Patent
`does not contain sufficient
`written description to
`demonstrate to a POSA that
`the inventor had possession of
`
`11
`
`

`

`Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 12 of 13 Page ID
`#:914
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`the invention at the time the
`application was filed. Dr.
`Horn may further offer expert
`testimony that a POSA would
`not understand how to make
`and use the invention.
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
`400 cycles”; “maintains at
`least 80% of capacity after
`400 cycles”; “maintains at
`least 80.72% of capacity
`after 400 cycles”
`
`capacity after 400 complete charge
`and discharge cycles of the battery”
`
`• May 15, 2009 Applicant’s
`Remarks at 10–11
`• November 13, 2009
`Applicant’s Remarks at 8–12
`
`David Linden, Handbook of
`Batteries, McGraw-Hill
`Handbooks (2001)
`
`B. Johnson et al., Characterization
`of commercially available lithium
`ion batteries, 70 J. Power Sources
`48-54 (1998)
`
`B. Johnson, An Examination of the
`Performance of the Lithium-Ion
`Battery System (1998) (Ph.D.
`dissertation, University of South
`Carolina)
`
`Kim et al., Effect of Capacity
`Ratios between Anode and
`Cathode on Electrochemical
`Properties for Lithium Polymer
`Batteries, 155 Electrochimica Acta
`431-36 (2015)
`
`Chen et al., Effect of N/P ratios on
`performance of
`
`12
`
`

`

`Apple’s Identification of
`Intrinsic and Extrinsic
`Evidence
`
`Case 8:22-cv-01874-JVS-JDE Document 67-1 Filed 05/31/23 Page 13 of 13 Page ID
`#:915
`EXHIBIT A TO THE PARTIES’ JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT
`
`Term
`
`Claim(s)
`
`RJ Technology’s Proposed
`Construction
`
`RJ Technology’s Identification of
`Intrinsic and Extrinsic Evidence
`
`Apple’s Proposed Construction
`
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`
`Luo et al., Examining Effects of
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`RJ Technology’s expert may offer
`expert testimony, consistent with
`the intrinsic evidence and from the
`perspective of one of ordinary skill
`in the art at the time of the
`invention, that these terms as used
`in this patent have the meaning
`that Plaintiff proposes.
`
`13
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