Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 1 of 14 PageID #: 817
`
`Page 1
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISON
`
`Plaintiff,
`
`Civil Action No. 4:23-cv-750
`
`STELLAR, LLC,
`
`v.
`
`MOTOROLA SOLUTIONS, INC. and
`WATCHGUARD VIDEO, INC.
`
`JURY TRIAL DEMANDED
`
`Defendants.
`
`
`
`
`
`
`
`PLAINTIFF STELLAR, LLC’S REPLY CLAIM CONSTRUCTION BRIEF
`
`
`
`
`
`
`
`
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 2 of 14 PageID #: 818
`
`Page 2
`
`TABLE OF CONTENTS
`I. ARGUMENT........................................................................................................................... 1
`
`A. U.S. Patent No. 8,310,540.................................................................................................... 1
`
`1. “A method of storing discrete segments of imaged data in a camera, comprising” ........ 1
`
`2. “A method of storing discrete segments of imaged data in a camera, comprising: using a
`sensor in the camera to capture image data; providing a recorder coupled to the camera and
`having a memory; using multiple portions of the memory as a memory loop in which to
`record segments of the image data in approximately real time” ............................................. 2
`
`B. Means-Plus-Function Disputes ............................................................................................ 5
`
`1. The “computer processor” claims of the ’901 and ’910 Patents Are Not Means-Plus-
`Function .................................................................................................................................. 5
`
`2. The “hardware that executes an instruction set” claim of the ’752 Patent Is Not Means-
`Plus-Function .......................................................................................................................... 8
`
`II. CONCLUSION ..................................................................................................................... 10
`
`
`
`
`
`
`
`
`i
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 3 of 14 PageID #: 819
`
`Page 3
`
`TABLE OF AUTHORITIES
`
`Page(s)
`
`Cases
`
`Am. Med. Sys., Inc. v. Biolitec, Inc.,
`618 F.3d 1354 (Fed. Cir. 2010)................................................................................................... 1
`
`Apex Inc. v. Raritan Comput., Inc.,
`325 F.3d 1364 (Fed. Cir. 2003)................................................................................................... 5
`
`Cutsforth, Inc. v. Motivepower, Inc.,
`643 F. App’x 1008 (Fed. Cir. 2016) ........................................................................................... 3
`
`Dyfan, LLC v. Target Corp.,
`28 F.4th 1360 (Fed. Cir. 2022) ................................................................................................... 5
`
`Glob. Equity Mgmt. (SA) Pty. Ltd. v. Expedia, Inc.,
`2016 WL 7416132 (E.D. Tex. Dec. 22, 2016) ............................................................................ 2
`
`Haemonetics Corp. v. Baxter Healthcare Corp.,
`607 F.3d 776 (Fed. Cir. 2010)................................................................................................. 3, 5
`
`Linear Tech. Corp. v. Impala Linear Corp.,
`379 F.3d 1311 (Fed. Cir. 2004)................................................................................................... 9
`
`SyncPoint Imaging, LLC v. Nintendo of Am. Inc.,
`2016 U.S. Dist. LEXIS 677 (E.D. Tex. Jan. 5, 2016) ............................................................. 7, 9
`
`Synqor, Inc. v. Artesyn Techs., Inc.,
`709 F.3d 1365 (Fed. Cir. 2013)................................................................................................... 2
`
`WSOU Invs. LLC v. Google LLC,
`Nos. 2022-1063, 2022-1065,
`2023 U.S. App. LEXIS 27763 (Fed. Cir. Oct. 19, 2023) .................................................... 6, 8, 9
`
`Other Authorities
`
`IBM Dictionary of Computing and Webster’s New World Dictionary of Computing Terms ......... 7
`
`MPEP, 37 C.F.R § 1.84................................................................................................................... 4
`
`
`
`
`
`ii
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 4 of 14 PageID #: 820
`
`Page 4
`
`I.
`
`ARGUMENT
`
`Stellar submits this reply claim construction brief in response to the responsive claim
`
`construction brief filed by Motorola Solutions, Inc. and WatchGuard Video, Inc. (“Defendants”)
`
`on May 31, 2024. (Dkt. 37.)
`
`A.
`
`U.S. Patent No. 8,310,540
`
`1.
`
`“A method of storing discrete segments of imaged data in a camera,
`comprising”
`
`Defendants assert that “[t[he preamble of claim 1 is limiting because: 1) it provides
`
`antecedent basis for terms in the body of the claims; and (2) it does not merely state an intended
`
`use, but rather provides that the camera is where the discrete segments of imaged data are stored”
`
`and that “unlike Am. Medical Systems, the preamble provides the context that the imaged data of
`
`the claim is stored in a camera of the claim and is not merely duplicative of the limitations in the
`
`body of the claim.” (Dkt. 37 at 7-8 (citing Am. Med. Sys., Inc. v. Biolitec, Inc., 618 F.3d 1354,
`
`1360 (Fed. Cir. 2010).
`
`But providing a recorder coupled to the camera and having a memory and using that
`
`memory to record segments of image data, makes clear that the image data is stored in the
`
`camera, specifically within memory of a recorder coupled to (i.e., within the single unit of) the
`
`camera. Storing of discrete segments of imaged data in a camera is therefore duplicative of
`
`providing a recorder coupled to the camera and having a memory and using that memory to
`
`record segments of image data as recited in the body of the claim:
`
`1
`
`
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 5 of 14 PageID #: 821
`
`Page 5
`
` (Dkt. 1-3 (’540 patent), 8:19-26.) For similar reasons, Defendants fail to distinguish
`
`Global Equity. (Dkt. 37 at 8-9 (citing Glob. Equity Mgmt. (SA) Pty. Ltd. v. Expedia, Inc., 2016
`
`WL 7416132, *13 (E.D. Tex. Dec. 22, 2016)).)
`
`Defendants have failed to show that the preamble recites essential structure or steps or is
`
`necessary to give life, meaning, and vitality to the claim. Instead, the preamble is duplicative of
`
`the limitations in the body of the claim. The Court should therefore find that the preamble is not
`
`limiting.
`
`2.
`
`“A method of storing discrete segments of imaged data in a camera,
`comprising: using a sensor in the camera to capture image data;
`providing a recorder coupled to the camera and having a memory;
`using multiple portions of the memory as a memory loop in which to
`record segments of the image data in approximately real time”
`
`Defendants’ indefiniteness argument defies common sense. A lay person would easily
`
`understand that “a recorder coupled to the camera and having a memory” refers to a camera
`
`having sub-components, including a recorder having a memory. Importantly, the specification
`
`itself contemplates the sub-components all residing in a single device. “Recorder 120 comprises
`
`imager lens 220, memory 140, control buttons 230, microprocessor 240, power source 250,
`
`microphone 260 hard drive 270, transmitter 280, and optional display screen (not shown) as
`
`shown in FIG. 2.” (Dkt. 1-3 at 3:11-14.) “Typically, the recorder is a high performance digital
`
`camera . . . . The recorder’s electronics preferably are all on a unitary printed circuit board.” (Id.
`
`at 3:16-20.) Accepting Defendants’ interpretation would exclude embodiments disclosed in the
`
`specification. “A claim construction that ‘excludes the preferred embodiment is rarely, if ever,
`
`correct and would require highly persuasive evidentiary support.’” Synqor, Inc. v. Artesyn
`
`Techs., Inc., 709 F.3d 1365, 1378-79 (Fed. Cir. 2013).
`
`Further, “because claim construction frequently poses difficult questions over which
`
`reasonable minds may disagree, proof of indefiniteness must meet an exacting standard.”
`
`2
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 6 of 14 PageID #: 822
`
`Page 6
`
`Haemonetics Corp. v. Baxter Healthcare Corp., 607 F.3d 776, 783 (Fed. Cir. 2010). The fact
`
`that the preamble refers to the memory storage capability of the overall camera without
`
`specifying that the memory storage capability resides within “a recorder” subcomponent of the
`
`camera does not change the definiteness of this claim. “A claim is not indefinite merely because
`
`parties disagree concerning its construction. An accused infringer must thus demonstrate by
`
`clear and convincing evidence that one of ordinary skill in the relevant art could not discern the
`
`boundaries of the claim based on the claim language, the specification, the prosecution history,
`
`and the knowledge in the relevant art.” Id. at 783 (internal quotations and citations omitted).
`
`Defendants’ argument also ignores the patentee’s use of the word “coupled” within the
`
`specification. The argument hinges on Defendants’ assertion that the plain meaning of “coupled
`
`to” does not allow for a structure to be “‘coupled’ to itself”. They cite Cutsforth, Inc. v.
`
`Motivepower, Inc., 643 F. App’x 1008, 1012 (Fed. Cir. 2016), to argue that the plain meaning of
`
`“couple to” indicates that one physical structure is “separate from” another physical structure.
`
`(Dkt. 37 at 10.) But this is not how the patentee uses “coupled”. For example, the ’540 patent
`
`recites: “This preferred embodiment is shown in FIGS. 3-7 and comprises a miniature solid state
`
`recording device 400 coupled with a head-mounted camera 410.” (Dkt. 1-3 at 6:15-17.) The
`
`following annotation of Figure 5 (with original numbers, lines and arrow from the patent) is an
`
`illustration of how these reference numbered items (recording device 400, and head-mounted
`
`camera 410) are part of the same structure—i.e., the camera recorder—yet are “coupled” with
`
`one another:
`
`
`
`3
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 7 of 14 PageID #: 823
`
`Page 7
`
`
`
`
`(Dkt. 1-3 at FIG. 5.)
`
`
`
`The USPTO’s Manual of Patent Examining Procedures (“MPEP”) also supports Stellar’s
`
`position. According to the MPEP, “arrows [as shown above with recording device 400] may be
`
`used at the ends of lines . . . as follows: (1) On a lead line, a freestanding arrow to indicate the
`
`entire section towards which it points[.]” See MPEP, 37 C.F.R § 1.84(r). Where arrows are not
`
`used, lead lines are understood as “those lines between the reference characters and the details
`
`referred to. . . . They must originate in the immediate proximity of the reference character and
`
`extend to the feature indicated.” Id. at subsection (q). Here, the arrow used with “recording
`
`device 400” reveals that this element refers to the entirety of the device. By contrast, a lead line
`
`without an arrow is used to show the location of “head-mounted camera 410”, revealing
`
`something less than the entirety of the device. Thus, in this instance, Figure 5 and the associated
`
`written description reveals that the word “coupled” is used to designate a camera substructure as
`
`a component within an entire recording device.
`
`Finally, Defendants’ reading of “coupled” ignores a commonly understood meaning of
`
`this term: “to come together to form a single unit.” See https://www.merriam-
`
`webster.com/thesaurus/coupled. As recited in claim 1, and consistent with the patentee’s use of
`
`“coupled” in the specification, the camera and recorder come together to form a single unit.
`
`4
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 8 of 14 PageID #: 824
`
`Page 8
`
`Nothing in Defendants’ arguments establishes by clear and convincing evidence that a
`
`POSITA could not discern the boundaries of the claim based on the claim language, the
`
`specification, the prosecution history, and the knowledge in the relevant art. Haemonetics Corp.,
`
`607 F.3d at 783. Accordingly, the Court should reject Defendants’ indefiniteness claim.
`
`B. Means-Plus-Function Disputes
`
`Defendants assert, in conclusory fashion, that the “computer processor” claim terms in
`
`the ’901 and ’910 patents and the “hardware that executes an instruction set” claim terms in the
`
`’752 patent are written in means-plus-function format and must be construed under § 112 ¶ 6.
`
`For the reasons set forth below, Defendants fail to rebut the presumption that § 112 ¶ 6 does not
`
`apply to the claims reciting the disputed terms.
`
`1.
`
`The “computer processor” claims of the ’901 and ’910 Patents Are
`Not Means-Plus-Function
`
`Because invoking § 112 ¶ 6 is a choice left to the claim drafter, in the absence of the term
`
`“means,” courts presume at the first step of the analysis that a claim limitation is not subject to §
`
`112 ¶ 6. Dyfan, LLC v. Target Corp., 28 F.4th 1360, 1365 (Fed. Cir. 2022). “In cases where it is
`
`clear that a claim term itself connotes some structure to a person of ordinary skill in the art, ‘the
`
`presumption that § 112, ¶ 6 does not apply is determinative’ in the absence of ‘more compelling
`
`evidence of the understanding of one of ordinary skill in the art.’” Id. at 1366 (citing Apex Inc. v.
`
`Raritan Comput., Inc., 325 F.3d 1364, 1373-74 (Fed. Cir. 2003)). In Apex, the defendant “relied
`
`on district court decisions addressing the definition of ‘circuit means’; expert testimony that the
`
`term ‘circuit’ would have been ‘understood by one of ordinary skill in the art as a very broad
`
`term’; and the description of preferred embodiments in the specification to establish that ‘circuit’
`
`did not connote sufficiently definite structure to a person of ordinary skill.’” Id. at 1373-74.
`
`Relying on a dictionary definition for the disputed term, the Federal Circuit disagreed, finding
`
`5
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 9 of 14 PageID #: 825
`
`Page 9
`
`that the evidence was not enough to rebut the § 112 ¶ 6 presumption because it failed to show
`
`that a POSITA would believe it did not recite sufficiently definite structure. Id. at 1374.
`
`That is where we find ourselves here. Relying primarily on WSOU Invs. LLC v. Google
`
`LLC, Nos. 2022-1063, 2022-1065, 2023 U.S. App. LEXIS 27763 (Fed. Cir. Oct. 19, 2023)
`
`(“WSOU II”), selected citations from the specification, and testimony from its expert, Defendants
`
`argue that the disputed terms of the ’901, ’910, and ’752 patents invoke § 112 ¶ 6.
`
`In support, Defendants offer WSOU II as though this decision created a categorical rule
`
`that the term “processor” is used “so broadly as to generically be any structure that manipulates
`
`data,” and thus invokes § 112 ¶ 6. (Dkt. 37 at 12-13.) In reality, the Federal Circuit explained:
`
`“there is no categorical rule regarding whether the term ‘processor’ connotes sufficient structure
`
`to avoid interpretation in means-plus-function format. Indeed, district courts have found some
`
`uses of ‘processor’ connote sufficient structure while others do not.” WSOU II, 2023 U.S. App.
`
`LEXIS 27763, at *8. Moreover, the Court need look no further than the second portion of
`
`WSOU II itself to understand when the use of “processor” connotes sufficient structure, which
`
`Defendants neglect to mention. Finding structure through the recitation of claim terms like
`
`“computer program code,” “memory,” and “processor,” the Federal Circuit reversed the district
`
`court’s finding of § 112 ¶ 6 applicability:
`
`The limitation at issue in the asserted claims of this patent is “at least one memory
`and the computer program code are configured, with the at least one processor, to
`cause the apparatus to” accomplish various functions. Like the previous claim
`limitation, this limitation receives the benefit of the presumption that it is not in
`means-plus-function format because it lacks the word “means.” Unlike the
`previous claim limitation, however, we conclude that Google has not rebutted the
`presumption. Google asserts that the collective “memory,” “computer program
`code,” and “processor” terms convey no “structural character” to a person of
`ordinary skill in the art and that they are understood “solely by the different
`functions they are assigned to perform.” We disagree.
`
`
`
`6
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 10 of 14 PageID #: 826
`
`Page 10
`
`In light of the intrinsic record in this case, we conclude that a person of ordinary
`skill in the art would understand the structure of the claimed “computer program
`code,” “memory,” and “processor.” First, the claim language itself provides
`structural guidance. For example, the claim limitation at issue requires “at least
`one memory including computer program code,” which is configured “with the at
`least one processor” to perform various tasks. WSOU asserts that a person of
`ordinary skill in the art reading the claim in light of the specification would
`understand that the recited computer program code is stored in a memory
`structure and running on the processor. We agree. The disputed claim limitation
`recites multiple elements and their connections to one another. Though terms
`like “computer program code,” “memory,” and “processor” may be broad,
`the recited combination of these multiple broadly named structures informs
`the skilled artisan's relative understanding of what each structure is and
`what it is not, as well as how the various structures relate to one another.
`
`WSOU II, 2023 U.S. App. LEXIS 27763, at *11-12 (internal citations omitted; emphasis added).
`
`Similarly, as explained in Stellar’s Opening Brief (Dkt. 36), the claims at issue recite associated
`
`terms for the structure. For example, with respect to the ’901 and ’910 patents, the claims recite:
`
`(1) a sensor, (2) memory coupled to the sensor to store the sensor data, and (3) a computer
`
`processor configured to write-protect and store the sensor data in a particular manner while
`
`continuing to record sensor data in the memory. (Dkt. 36 at 12-13.)
`
`As in Apex with respect to the term “circuit”, here, technical dictionaries confirm the
`
`structure of the term “processor” consisting of at least an instruction control unit and an
`
`arithmetic and logic unit” and “the central processing unit of a computer.” SyncPoint Imaging,
`
`LLC v. Nintendo of Am. Inc., 2016 U.S. Dist. LEXIS 677, at *59-60 (E.D. Tex. Jan. 5, 2016)
`
`(citing IBM Dictionary of Computing and Webster’s New World Dictionary of Computing
`
`Terms) (internal quotations omitted). One of the dictionaries cited by Defendants’ own expert
`
`confirms this structure defining “central processor” as “[t]he main part of a computer consisting
`
`of an arithmetic logic unit and a control unit.” (Dkt. 37-3 at 4.)
`
`The holding in WSOU II and the dictionary definition of “processor” each alone support
`
`the finding of sufficient structure to avoid the application of § 112 ¶ 6. Taken together, they
`
`clearly demonstrate the fallacy of Defendants’ argument. Accordingly, the Court should find
`
`7
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 11 of 14 PageID #: 827
`
`Page 11
`
`that § 112 ¶ 6 does not apply. Because § 112 ¶ 6 does not apply, the Court need not address
`
`Defendants’ arguments regarding function and corresponding structure.
`
`2.
`
`The “hardware that executes an instruction set” claim of the ’752
`Patent Is Not Means-Plus-Function
`
` For similar reasons to their “computer processor” argument, Defendants assert that the
`
`term “hardware that executes an instruction set” invokes § 112 ¶ 6. And for similar reasons as
`
`outlined above, Defendants fail to rebut the presumption against the application of § 112 ¶ 6.
`
`The extrinsic evidence confirms the inapplicability of § 112 ¶ 6. First, technical
`
`dictionaries relied upon by other courts, as well as at least one relied upon by Defendants’ expert,
`
`confirm that the phrase “hardware that executes an instruction set” would be understood to
`
`connote actual physical structure, specifically “mechanical, electrical and electronic components
`
`of a computer system,” as opposed to a non-structural element. (Dkt. 37-3 at 5; see also, Dkt.
`
`36-2 at 5.) This is further supported by the primary case Defendants rely upon, the
`
`aforementioned WSOU II decision by the Federal Circuit. WSOU II expressly refers to
`
`“hardware that runs the computer program code,” as a way to a describe physical structure for an
`
`associated function, thus avoiding application of § 112 ¶ 6. WSOU II, 2023 U.S. App. LEXIS
`
`27763, at *14.
`
`Again, Defendants do not appear to appreciate the teaching of WSOU II, which explains
`
`that § 112 ¶ 6 may apply even in the absence of “means for” language where the use of the
`
`disputed term is so generic that it could refer “to hardware, software, or essentially anything else
`
`that could perform the claimed functions.” Id. at *7; see also, id. at * 9 and *14 (“[i]n other
`
`words, the [’045 patent] specification teaches that the processor could be software, hardware, or
`
`a combination of the two. Other references to the ‘processor’ in the specification describe it only
`
`in terms of its function,” but “[i]n contrast to the ’045 patent, the [’825 patent] specification here
`
`describes the ‘processor’ as hardware that runs the computer program code.”)
`
`8
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 12 of 14 PageID #: 828
`
`Page 12
`
`In the context of the specification and associated words of the claims in the ’752 patent, a
`
`POSITA would understand the term “hardware that executes an instruction set” refers to a
`
`known physical structure with a known functional purpose, and therefore connotes sufficient
`
`structure to a POSITA for the same reasons as discussed in Section I.B.1, above. And when
`
`combined with a description of the operation and objectives of the recited hardware, the term
`
`conveys sufficient structural meaning to a POSITA and § 112 ¶ 6 does not apply. SyncPoint,
`
`2016 U.S. Dist. LEXIS 677, at * 59 (quoting Linear Tech. Corp. v. Impala Linear Corp., 379
`
`F.3d 1311, 1319-21(Fed. Cir. 2004).
`
`Moreover, like the ’901 and ’910 patents, the ’752 patent confirms a structural
`
`meaning—as was emphasized in WSOU II—because the associated elements within the claim
`
`recite interrelated structures. For example, claim 1 of the ’752 patent recites: (1) a camera to
`
`convert images into data streams, (2) a memory to store the converted images, and (3) hardware
`
`that executes an instruction set (processor) that protects and stores a segment of a data stream in
`
`a particular manner while continuing to record another data stream in the memory without
`
`overwriting the protected segment. See WSOU II, 2023 U.S. App. LEXIS 27763, at *11-12
`
`(“The disputed claim limitation recites multiple elements and their connections to one another.
`
`Though terms like ‘computer program code,’ ‘memory,’ and ‘processor’ may be broad, the
`
`recited combination of these multiple broadly named structures informs the skilled artisan's
`
`relative understanding of what each structure is and what it is not, as well as how the various
`
`structures relate to one another.”).
`
`The term “hardware that executes and instruction set”, especially when combined with
`
`the other elements, connotes sufficient structure to a POSITA. Defendants have not presented
`
`any contrary, more compelling evidence to rebut the presumption that this claim limitation is not
`
`9
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 13 of 14 PageID #: 829
`
`Page 13
`
`in means-plus-function format. Because the term is not governed by § 112 ¶ 6, the Court need
`
`not reach Defendants’ indefiniteness argument.
`
`II.
`
`CONCLUSION
`
`For the reasons set forth above, Stellar requests that the Court find that Defendants have
`
`failed to meet their burden of establishing that ’540 patent, claim 1 is indefinite. Stellar further
`
`asks that the Court find that none of the disputed terms invoke § 112 ¶ 6 because Defendants
`
`have failed to meet their burden of showing otherwise. To the extent the Court does find that a
`
`term invokes § 112 ¶ 6, Stellar submits that there is sufficient structure disclosed to support the
`
`recited function and requests that the Court adopt Stellar’s identification of the recited function
`
`and corresponding structure for each term.
`
`
`
`Dated: June 7, 2024
`
`
`
`
`
`/s/ Robert Kiddie
`Timothy Devlin
`tdevlin@devlinlawfirm.com
`Jim Lennon
`jlennon@devlinlawfirm.com
`Robert Kiddie
`rkiddie@devlinlawfirm.com
`1526 Gilpin Avenue
`Wilmington, Delaware 19806
`Telephone: (302) 449-9010
`Facsimile: (302) 353-4251
`
`Attorneys for Plaintiff
`Stellar, LLC
`
`
`
`
`
`
`
`
`
`
`
`
`10
`
`

`

`Case 4:23-cv-00750-SDJ Document 38 Filed 06/07/24 Page 14 of 14 PageID #: 830
`
`Page 14
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on June 7, 2024 I caused the foregoing to be electronically filed with
`
`the Clerk of the Court using CM/ECF, which will send notification of such filing to all registered
`
`participants.
`
`
`
`/s/Robert Kiddie
`Robert Kiddie
`
`
`
`
`
`
`
`11
`
`

`

`Page 15
`
`CourtAlert® Case Management
`From:                              txedCM@txed.uscourts.gov
`Sent:                               6/7/2024 2:40:45 PM
`To:                                   txedcmcc@txed.uscourts.gov
`Subject:                          Activity in Case 4:23-cv-00750-SDJ STELLAR, LLC v. Motorola Solutions,
`Inc. et al Reply to Claim Construction Brief
`
`This Message Is From an External Sender
`If you are concerned about the message’s content, highlight the email in your inbox and click “Report Suspicious” in
`the Outlook ribbon -or- contact 6Help.
`
` 
`
`This is an automatic e-mail message generated by the CM/ECF system. Please DO NOT
`RESPOND to this e-mail because the mail box is unattended.
`***NOTE TO PUBLIC ACCESS USERS*** Judicial Conference of the United States
`policy permits attorneys of record and parties in a case (including pro se litigants) to
`receive one free electronic copy of all documents filed electronically, if receipt is required
`by law or directed by the filer. PACER access fees apply to all other users. To avoid later
`charges, download a copy of each document during this first viewing. However, if the
`referenced document is a transcript, the free copy and 30 page limit do not apply.
`
`U.S. District Court
`
`Eastern District of TEXAS [LIVE]
`
`Notice of Electronic Filing
`
`The following transaction was entered by Kiddie, Robert on 6/7/2024 at 1:40 PM CDT and filed
`on 6/7/2024
`Case Name:
`STELLAR, LLC v. Motorola Solutions, Inc. et al
`Case Number:
`4:23-cv-00750-SDJ
`Filer:
`STELLAR, LLC
`Document Number: 38
`
`Docket Text:
`REPLY to [37] Claim Construction Brief, filed by STELLAR, LLC. (Kiddie, Robert)
`
`4:23-cv-00750-SDJ Notice has been electronically mailed to:
`
`Christopher Alan Buxton     cbuxton@jonesday.com, Courtalert@jonesday.com,
`docketcentral@jonesday.com, poppert@jonesday.com
`
`Hilda Contreras Galvan     hcgalvan@jonesday.com, sfoster@jonesday.com
`
`

`

`Page 16
`
`James M Lennon     jlennon@devlinlawfirm.com, dlflitparas@devlinlawfirm.com,
`fxu@devlinlawfirm.com
`
`John A Marlott     jamarlott@jonesday.com, edoehring@jonesday.com
`
`Kristina N Hendricks     khendricks@jonesday.com, aciraci@jonesday.com
`
`Maeve Dineen     mdineen@jonesday.com
`
`Robert Dean Kiddie , Jr     rkiddie@devlinlawfirm.com, ecfdocketing@devlinlawfirm.com,
`fxu@devlinlawfirm.com, mmcclain@devlinlawfirm.com, tdevlin@devlinlawfirm.com
`
`Timothy Devlin     tdevlin@devlinlawfirm.com, dlflitparas@devlinlawfirm.com,
`mmcclain@devlinlawfirm.com, Stellar-DLF_Intl@devlinlawfirm.com
`
`4:23-cv-00750-SDJ Notice will not be electronically mailed to:
`
`The following document(s) are associated with this transaction:
`
`Document description:Main Document
`Original filename:n/a
`Electronic document Stamp:
`[STAMP dcecfStamp_ID=1041545818 [Date=6/7/2024] [FileNumber=14680542-0
`] [bb06ef6cf94d6cd7a2ddc8c6824bf490b5c1d3de152778edbddc5eea725a1382da1
`04b86c948d867886e82d0ab7b556274e821890718f4b8cc952129cc681f00]]
`
`