Case 2:16-cv-00741-RWS Document 202-1 Filed 07/11/17 Page 1 of 6 PageID #: 3204
`Case 2:16-cv-00741-RWS Document 202-1 Filed 07/11/17 Page 1 of 6 PageID #: 3204
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`EXHIBIT A
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`EXHIBIT A
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`Case 2:16-cv-00741-RWS Document 202-1 Filed 07/11/17 Page 1 of 6 PageID #: 3204
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`EXHIBIT A
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`EXHIBIT A
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`Case 2:16-cv-00741-RWS Document 202-1 Filed 07/11/17 Page 2 of 6 PageID #: 3205
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`EXHIBIT A
`The parties have yet to reach agreement as to the construction of the following claim terms/phrases recited in one or more of
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`TERMS AND PHRASES UNILOC’S PROPOSED
`CONSTRUCTION
`code associated with
`performing function for a
`user
`
`“application program(s) /
`application(s)”
`
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`DEFENDANTS’ PROPOSED
`CONSTRUCTION1
`application level software program code
`for underlying application level functions
`that executes locally at the client as a
`separate application from the browser
`
`the patents-in-suit:
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`1.
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`CLAIMS
`
`’466 patent
`claims 1-4, 8-9,
`13, 15-19, 23-24,
`28, 30-32, 36-37,
`41
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`’578 patent
`claims 1, 2, 4, 5,
`7, 11-18, 20, 21,
`23, 27-33, 35, 36,
`38, 42-46
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`’293 patent
`claims 1, 12, 17
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`’766 patent
`claims 1-3, 7-9,
`13-15
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`1 Defendants’ proposed claim constructions are based on the claims asserted by Uniloc. Should Uniloc assert additional claims, defendants may
`seek to pursue construction of terms from those additional claims.
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`1
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`Case 2:16-cv-00741-RWS Document 202-1 Filed 07/11/17 Page 3 of 6 PageID #: 3206
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`CLAIMS
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`’466 patent
`claims 1, 14, 15,
`16, 19, 28, 41
`’578 patent
`claims 15-17, 31-
`32, 46
`’766 patent
`claims 3, 9, 15
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`’466 patent
`claims 3, 6, 10,
`18, 21, 25, 31, 34,
`38
`’578 patent
`claims 1, 4-5, 11-
`17, 20-21, 27-32,
`35-36, 42-46
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`’766 patent
`claims 2, 8, 14
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`2.
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`3.
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`“an instance” / “an
`instance of the application
`program” / “an instance of
`the selected one of the
`plurality of application
`programs”
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`TERMS AND PHRASES UNILOC’S PROPOSED
`CONSTRUCTION
`“A program is a sequence
`of instructions that indicates
`which operations the
`computer should perform
`on a set of data. An
`instance of a program is a
`copy of a program that is
`understandable by a
`computer’s central
`processing unit and that is
`ready to run as soon it is
`copied from storage into
`memory.”
`a program distributed to a
`client to initially populate a
`user desktop and to request
`execution of the application
`program
`
`“application launcher
`program” / “application
`launcher program
`associated with the
`application program” /
`“application launcher
`programs associated with
`each of the set of the
`plurality of application
`programs”
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`DEFENDANTS’ PROPOSED
`CONSTRUCTION1
`Kaspersky Labs:
`“a copy of an executable version of the
`program that has been written to the
`computer’s memory.”
`
`All other Defendants:
`plain and ordinary meaning; or, in the
`alternative, “a copy” / “a copy of the
`application program” / “a selected copy of
`the application program”
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`Kaspersky Labs:
`a program distributed to a client to
`initially populate a user desktop and to
`request execution of the application
`program
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`All other Defendants:
`a program distributed to a client to
`initially populate a user desktop and to
`request the application program from a
`server
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`2
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`Case 2:16-cv-00741-RWS Document 202-1 Filed 07/11/17 Page 4 of 6 PageID #: 3207
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`CLAIMS
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`’293 patent
`claims 1, 12, 17
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`’578 patent
`claims 15, 16, 17,
`32, 46
`’466 patent
`claims 1, 15, 16
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`4.
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`5.
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`“registration operations”
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`TERMS AND PHRASES UNILOC’S PROPOSED
`CONSTRUCTION
`registration of the
`application program at the
`target on-demand server so
`that it will be available to
`users from client computers
`“provide” – plain and
`ordinary meaning
`“instance” – see above
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`“provid[e]/[ing] an
`instance of the application
`program” / “providing an
`instance of the selected
`one of the plurality of
`application programs to
`the client for execution”
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`DEFENDANTS’ PROPOSED
`CONSTRUCTION1
`registration of the application program at
`the on-demand server(s) so that it will be
`available for access and download
`responsive to user requests from client
`computers
`Kaspersky Labs, Ubisoft, and Square
`Enix:
`plain and ordinary meaning
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`All other Defendants:
`“download[ing] an instance of the
`application program from the server to the
`client” / “downloading an instance of the
`selected one of the plurality of application
`programs from the server to the client for
`execution”
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`3
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`Case 2:16-cv-00741-RWS Document 202-1 Filed 07/11/17 Page 5 of 6 PageID #: 3208
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`6.
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`CLAIMS
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`’578 patent
`claims 6, 8
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`7.
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`’578 patent
`claims 20, 22, 24,
`35, 37, 39
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`“the initiating execution
`step”
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`TERMS AND PHRASES UNILOC’S PROPOSED
`CONSTRUCTION
`Claim 6 adds to claim 1 two
`limitations: A) storing a
`user set and an
`administrator set on a
`storage device before
`initiating the execution, and
`B) retrieving the stored sets
`in initiating the execution..
`Claim 8 adds to claim 1 the
`limitation: obtaining default
`preference values in
`initiating the execution.
`[Representative] Claim 35
`adds to claim 32 the
`limitation: code that
`actually executes the
`application program.
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`“the computer readable
`program code means for
`executing the application
`program” / “the computer
`readable program code
`means for initiating
`execution” / “the means
`for executing the
`application program” /
`“the means for initiating
`execution”
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`DEFENDANTS’ PROPOSED
`CONSTRUCTION1
`Indefinite
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`Indefinite
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`4
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`Case 2:16-cv-00741-RWS Document 202-1 Filed 07/11/17 Page 6 of 6 PageID #: 3209
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`8.
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`CLAIMS
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`‘466 Patent – 9,
`10, 24, 25, 37, 38
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`‘766 Patent – 1, 7,
`13
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`TERMS AND PHRASES UNILOC’S PROPOSED
`CONSTRUCTION
`determination that a user
`can be issued a license to
`the selected application
`program
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`“license availability” / “a
`license availability for the
`selected one of the
`plurality of application
`programs for the user”
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`9.
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`‘293 patent
`claims 1, 12, 17
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`“make the application
`program available for use”
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`make the application
`program available for use
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`DEFENDANTS’ PROPOSED
`CONSTRUCTION1
`ADP and Zendesk:
`“determination that a user can be issued a
`license to the selected application
`program, distinct from any determination
`that the user is authorized to access the
`selected application program”
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`All other Defendants:
`“determination that a user can be issued a
`license to the selected application
`program.”
`Kaspersky Labs:
`make the application program available
`for use
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`All other Defendants:
`make the application available for access
`and download, responsive to user requests
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`5
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