Case 2:21-cv-00186-JRG-RSP Document 47-2 Filed 05/10/22 Page 1 of 5 PageID #: 613
`
`No.
`
`1
`
`2
`
`“acoustic noise”
`
`’072 Patent
`Claims 1, 2, and 9
`
`’091 Patent
`Claims 1, 10, 11
`and 17
`
`EXHIBIT B – Plaintiff Jawbone Innovations, LLC’s Proposed Constructions
`to Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`Claim Term/Phrase
`Patent/Claims
`Jawbone’s Preliminary
`Additional
`Construction
`Intrinsic Evidence
`“unwanted environmental
`’072 Patent, 3:36-
`acoustic noise”
`40, 13:64-67,
`14:19-23, 17:38-
`46; 18:22-34,
`19:45-47, 23:64-
`24:25, 24:40-56.
`
`’091 Patent,
`Abstract, 8:57-59,
`9:59-67, 10:49-67,
`11:25-39, 11:51-
`12:6, 12:58-13:3,
`13:12-20.
`
`
`’072 Patent,
`Abstract, FIGS. 6-
`10, 15, 2:38-48,
`3:23-26, 4:1-14,
`10:44-12:52,
`22:24-28:3.
`
`“virtual microphone array”
`
`’072 Patent
`Claim 1
`
`Plain and ordinary meaning.
`Alternatively: “group of two
`or more virtual
`microphones”
`
`Extrinsic Support
`
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`
`1
`
`
`
`No.
`
`1
`
`2
`
`“acoustic noise”
`
`’072 Patent
`Claims 1, 2, and 9
`
`’091 Patent
`Claims 1, 10, 11
`and 17
`
`EXHIBIT B – Plaintiff Jawbone Innovations, LLC’s Proposed Constructions
`to Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`Claim Term/Phrase
`Patent/Claims
`Jawbone’s Preliminary
`Additional
`Construction
`Intrinsic Evidence
`“unwanted environmental
`’072 Patent, 3:36-
`acoustic noise”
`40, 13:64-67,
`14:19-23, 17:38-
`46; 18:22-34,
`19:45-47, 23:64-
`24:25, 24:40-56.
`
`’091 Patent,
`Abstract, 8:57-59,
`9:59-67, 10:49-67,
`11:25-39, 11:51-
`12:6, 12:58-13:3,
`13:12-20.
`
`
`’072 Patent,
`Abstract, FIGS. 6-
`10, 15, 2:38-48,
`3:23-26, 4:1-14,
`10:44-12:52,
`22:24-28:3.
`
`“virtual microphone array”
`
`’072 Patent
`Claim 1
`
`Plain and ordinary meaning.
`Alternatively: “group of two
`or more virtual
`microphones”
`
`Extrinsic Support
`
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`
`1
`
`
`
`Case 2:21-cv-00186-JRG-RSP Document 47-2 Filed 05/10/22 Page 2 of 5 PageID #: 614
`
`Extrinsic Support
`
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`
`No.
`
`3
`
`EXHIBIT B – Plaintiff Jawbone Innovations, LLC’s Proposed Constructions
`to Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`Claim Term/Phrase
`Patent/Claims
`Jawbone’s Preliminary
`Additional
`Construction
`Intrinsic Evidence
`Plain and ordinary meaning
`’357 Patent at FIG.
`except for “transfer
`1, 6:11-8:61, 9:22-
`function”
`35, 16:47-17:62
`
`
`’357 Patent
`Claim 1
`
`“a signal processor coupled with
`the first and second microphone
`signals and operative … to apply
`a varying linear transfer function
`between the first and second
`microphone signals”
`
`4
`
`“a processing component …
`applying a varying linear transfer
`function between the acoustic
`signals”
`
`’080 Patent
`Claim 14
`
`Plain and ordinary meaning
`except for “transfer
`function”
`
`’080 Patent at
`FIGS. 1-2, 2:26-33,
`4:52-8:12, 15:48-
`16:45.
`
`2
`
`
`
`Case 2:21-cv-00186-JRG-RSP Document 47-2 Filed 05/10/22 Page 3 of 5 PageID #: 615
`
`No.
`
`5
`
`6
`
`“response to
`[speech/noise]”/“linear response
`to [speech/noise]”
`
`’357 Patent
`Claims 1, 15, and
`17
`
`’080 Patent
`Claims 1 and 14
`
`’691 Patent
`Claims 1, 3, 4, 5,
`6, 7, 23, 24, 25,
`26, 27, 28, 29, 30,
`31, 32, 33, 34, 41,
`42, 43, 44, and 45
`
`EXHIBIT B – Plaintiff Jawbone Innovations, LLC’s Proposed Constructions
`to Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`Claim Term/Phrase
`Patent/Claims
`Jawbone’s Preliminary
`Additional
`Construction
`Intrinsic Evidence
`“output [in response to
`’357 Patent at
`speech/noise]”/“output of a
`Abstract, FIGS. 9-
`linear system [in response to
`22, 2:54-3:19,
`speech/noise]”
`3:24-42, 11:40-
`17:62.
`
`’080 Patent at
`Abstract, FIGS. 9-
`15, 2:52-3:11,
`8:54-57, 9:22-43,
`9:46-13:17.
`
`’691 Patent at
`Abstract, FIGS. 9-
`22, 2:41-67, 11:30-
`14:19.
`
`
`’080 Patent at FIG.
`1, 2:26-27, 4:52-
`7:16, 22:35-43,
`22:46-50, 24:34-
`39, 25:45-47,
`26:64-66, 27:42-
`44.
`
`“an adaptive noise removal
`application coupled to . . . and
`generating”
`
`’080 Patent
`Claim 1
`
`Plain and ordinary meaning
`
`Extrinsic Support
`
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`
`3
`
`
`
`Case 2:21-cv-00186-JRG-RSP Document 47-2 Filed 05/10/22 Page 4 of 5 PageID #: 616
`
`No.
`
`7
`
`8
`
`“an adaptive noise removal
`application . . . generating
`denoised output signals by
`forming a plurality of
`combinations . . . by filtering and
`summing the plurality of
`combinations . . . and by a
`varying linear transfer function
`between the plurality of
`combinations”
`“microphone”
`
`EXHIBIT B – Plaintiff Jawbone Innovations, LLC’s Proposed Constructions
`to Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`Claim Term/Phrase
`Patent/Claims
`Jawbone’s Preliminary
`Additional
`Construction
`Intrinsic Evidence
`Plain and ordinary meaning
`’080 Patent at FIG.
`except for “transfer
`1, 2:26-27, 3:49-
`function”
`67, 4:52-7:16,
`7:39-51, 7:66-8:12
`
`’080 Patent
`Claim 1
`
`’543 Patent
`Claims 1 and 26
`
`Plain and ordinary meaning
`
`’543 Patent at
`Abstract, FIGS. 1,
`1A, 1B, 2, 5:18-
`7:26, 9:13-60
`17:25-28.
`
`9
`
`“the one receiver”
`
`’058 Patent
`Claim 1
`
`Plain and ordinary meaning
`
`Alternatively, with respect
`to “receiver”: “microphone
`that receives the acoustic
`signals”
`
`’058 Patent at
`Abstract, Claim 1,
`FIGS. 1-4, 1:23-33,
`2:61-3:9, 5:46-
`8:31.
`
`4
`
`Extrinsic Support
`
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`
`
`
`Case 2:21-cv-00186-JRG-RSP Document 47-2 Filed 05/10/22 Page 5 of 5 PageID #: 617
`
`Extrinsic Support
`
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`Plaintiff may rely on the
`expert declaration or
`testimony of Dr. D.
`Richard Brown III in
`support of its proposed
`claim constructions, or
`to rebut and respond to
`Defendant's proposed
`constructions.
`
`No.
`
`10
`
`“the two receivers”
`
`EXHIBIT B – Plaintiff Jawbone Innovations, LLC’s Proposed Constructions
`to Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
`Claim Term/Phrase
`Patent/Claims
`Jawbone’s Preliminary
`Additional
`Construction
`Intrinsic Evidence
`Plain and ordinary meaning
`’058 Patent at
`
`Abstract, Claim 1,
`Alternatively, with respect
`FIGS. 1-4, 1:23-33,
`to “receiver”: “microphones
`2:61-3:9, 5:46-
`that receive the acoustic
`8:31.
`signals”
`
`’058 Patent
`Claim 1
`
`11
`
`“the VAD”
`
`’091 Patent
`Claims 1 and 2
`
`Plain and ordinary meaning
`
`’091 Patent at
`Abstract, FIGS. 1-
`2, 5-7B, 3:3-5:38,
`7:46-13:20.
`
`
`
`5
`
`
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