Case 2:22-cv-00263-JRG-RSP Document 68-1 Filed 06/16/23 Page 1 of 11 PageID #: 2352
`Case 2:22-cv-00263-JRG-RSP Document 68-1 Filed 06/16/23 Page 1 of 11 PagelD #: 2352
`
`APPENDIX A
`APPENDIX A
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 68-1 Filed 06/16/23 Page 2 of 11 PageID #: 2353
`
`No. Claim Term/Phrase
`
`APPENDIX A: PROPOSED CONSTRUCTIONS
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Patent/
`Claims
`
`Governed by 35 U.S.C. §
`112(6)
`Function: “facilitating the
`transmission of electronic
`files between said PDA/cell
`phones in different location”
`
`Structure: “a PDA/cell phone
`programmed to implement
`transmission of a forced
`message alert using TCP/IP or
`another communications
`protocol, and equivalents
`thereof”
`
`Governed by 35 U.S.C. §
`112(6)
`Function: “attaching a forced
`message alert software packet
`to a voice or text message
`creating a forced message
`alert that is transmitted by
`said sender PDA/cell phone to
`the recipient PDA/cell phone,
`said forced message alert
`software packet containing a
`list of possible required
`responses and requiring the
`forced message alert software
`on said recipient PDA/cell
`
`Parties’ Proposed
`Construction Based on Prior
`Case Order
`Governed by 35 U.S.C.
`§ 112(6).1
`
`Function: “facilitating the
`transmission of electronic
`files between said PDA/cell
`phones in different
`locations”
`
`Structure: “communications
`network server using
`TCP/IP or other digital
`transmission means; and
`equivalents thereof”
`
`Governed by 35 U.S.C.
`§ 112(6).2
`
`Function: “attaching a
`forced message alert
`software packet to a voice or
`text message creating a
`forced message alert that is
`transmitted by said sender
`PDA/cell phone to the
`recipient PDA/cell phone,
`said forced message alert
`software packet containing a
`list of possible required
`responses and requiring the
`
`1.
`
`a data transmission means that
`facilitates the transmission of
`electronic files between said
`PDA/cell phones in different
`locations
`
`’970
`Patent:
`claim 2
`
`Governed by 35 U.S.C.
`§ 112(6).
`Function: “facilitating the
`transmission of electronic
`files between said PDA/cell
`phones in different
`locations”
`
`Structure: “communications
`network server using TCP/IP
`or other digital transmission
`means; and equivalents
`thereof”
`
`’970
`Patent:
`claim 2
`
`Governed by 35 U.S.C.
`§ 112(6).
`Function: “attaching a forced
`message alert software packet
`to a voice or text message
`creating a forced message alert
`that is transmitted by said
`sender PDA/cell phone to the
`recipient PDA/cell phone, said
`forced message alert software
`packet containing a list of
`possible required responses
`and requiring the forced
`message alert software on said
`recipient PDA/cell phone to
`
`2. means for attaching a forced
`message alert software packet
`to a voice or text message
`creating a forced message alert
`that is transmitted by said
`sender PDA/cell phone to the
`recipient PDA/cell phone, said
`forced message alert software
`packet containing a list of
`possible required responses
`and requiring the forced
`message alert software on said
`recipient PDA/cell phone to
`transmit an automatic
`acknowledgment to the sender
`
`1 AGIS Software Development LLC v. Google LLC, Case No. 2:19-cv-00361- JRG-RSP (Lead Case), Dkt No. 147 (“Google Claim Construction Order”).
`2 Google Claim Construction Order.
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 68-1 Filed 06/16/23 Page 3 of 11 PageID #: 2354
`
`APPENDIX A: PROPOSED CONSTRUCTIONS
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Patent/
`Claims
`
`No. Claim Term/Phrase
`
`PDA/cell phone as soon as
`said forced message alert is
`received by the recipient
`PDA/cell phone
`
`transmit an automatic
`acknowledgment to the sender
`PDA/cell phone as soon as said
`forced message alert is
`received by the recipient
`PDA/cell phone”
`
`Structure: “a PC or PDA/cell
`phone configured to implement
`the algorithm disclosed in the
`’970 Patent at 7:8–8:36; and
`equivalents thereof”
`
`phone to transmit an
`automatic acknowledgment to
`the sender PDA/cell phone as
`soon as said forced message
`alert is received by the
`recipient PDA/cell phone”
`
`Structure: “a PDA/cell phone
`configured to perform a
`portion of the forced-message
`alert software application
`program that allows a user to
`create a message, select
`recipients of that message,
`select a default or new
`response list to be sent with
`the message, and then send
`the message to the recipients.
`(See ’970 patent, 2:7– 16,
`7:8–20, 7:43–63, 8:25–30,
`FIG. 3A).”
`
`Governed by 35 U.S.C. §
`112(6)
`Function: “requiring a
`required manual response
`from the response list by the
`recipient in order to clear
`recipient’s response list from
`recipient’s cell phone display”
`
`
`3. means for requiring a required
`manual response from the
`response list by the recipient
`in order to clear recipient’s
`response list from recipient’s
`cell phone display
`
`’970
`Patent:
`claim 2
`
`Governed by 35 U.S.C.
`§ 112(6).
`Function: “requiring a
`required manual response
`from the response list by
`the recipient in order to
`clear recipient’s response
`list from recipient’s cell
`phone display”
`
`
`3 Google Claim Construction Order.
`
`Parties’ Proposed
`Construction Based on Prior
`Case Order
`forced message alert
`software on said recipient
`PDA/cell phone to transmit
`an automatic
`acknowledgment to the
`sender PDA/cell phone as
`soon as said forced message
`alert is received by the
`recipient PDA/cell phone”
`
`Structure: “a PC or
`PDA/cell phone configured
`to implement the algorithm
`disclosed in the ’970 Patent
`at 7:8–8:36; and equivalents
`thereof”
`
`Governed by 35 U.S.C.
`§ 112(6).3
`
`Function: “requiring a
`required manual response
`from the response list by the
`recipient in order to clear
`recipient’s response list
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 68-1 Filed 06/16/23 Page 4 of 11 PageID #: 2355
`
`No. Claim Term/Phrase
`
`APPENDIX A: PROPOSED CONSTRUCTIONS
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Patent/
`Claims
`
`
`Structure: “a PC or PDA/cell
`phone configured to
`implement the algorithm
`disclosed in the’970 Patent at
`8:37-57; and equivalents
`thereof”
`
`Governed by 35 U.S.C.
`§ 112(6).
`Function: “receiving and
`displaying a listing of which
`recipient PDA/cell phones
`have automatically
`acknowledged the forced
`message alert and which
`recipient PDA/cell phones
`have not automatically
`acknowledged the forced
`message alert”
`
`Structure: “PDA/cell phone
`hardware including display 16
`and a wireless receiver and/or
`
`
`Structure:
`“forced-message alert software-
`application program on the
`recipient PDA/cellular phone
`that causes the message and
`manual response list to be
`displayed on the screen of the
`recipient PDA/cellular phone
`and clears the forced alert text
`data when a response is
`selected from the manual
`response list. (See ’970 patent,
`8:39–46, FIG. 4).”
`
`Governed by 35 U.S.C. §
`112(6)
`Function: “receiving and
`displaying a listing of which
`recipient PDA/cell phones
`have automatically
`acknowledged the forced
`message alert and which
`recipient PDA/cell phones
`have not automatically
`acknowledged the forced
`message alert”
`
`Structure: “hardware on the
`sender’s PDA/cell phone
`including a display, such as
`
`’970
`Patent:
`claim 2
`
`4. means for receiving and
`displaying a listing of which
`recipient PDA/cell phones
`have automatically
`acknowledged the forced
`message alert and which
`recipient PDA/cell phones
`have not automatically
`acknowledged the forced
`message alert
`
`
`4 Google Claim Construction Order.
`
`Parties’ Proposed
`Construction Based on Prior
`Case Order
`from recipient’s cell phone
`display”
`
`Structure: “a PC or
`PDA/cell phone configured
`to implement the algorithm
`disclosed in the ’970 Patent
`at 8:37-57; and equivalents
`thereof”
`
`Governed by 35 U.S.C.
`§ 112(6).4
`
`Function: “receiving and
`displaying a listing of which
`recipient PDA/cell phones
`have automatically
`acknowledged the forced
`message alert and which
`recipient PDA/cell phones
`have not automatically
`acknowledged the forced
`message alert”
`
`Structure: “PDA/cell phone
`hardware including display
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 68-1 Filed 06/16/23 Page 5 of 11 PageID #: 2356
`
`No. Claim Term/Phrase
`
`APPENDIX A: PROPOSED CONSTRUCTIONS
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Patent/
`Claims
`
`5. means for periodically
`resending said forced message
`alert to said recipient
`PDA/cell phones that have not
`automatically acknowledged
`the forced message alert
`
`’970
`Patent:
`claim 2
`
`transceiver; and equivalents
`thereof”
`
`Governed by 35 U.S.C.
`§ 112(6).
`Function: “periodically
`resending said forced message
`alert to said recipient
`PDA/cell phones that have not
`automatically acknowledged
`the forced message alert”
`
`Structure: “a PC or PDA/cell
`phone configured to
`implement the algorithm
`disclosed in the ’970 Patent at
`7:64-67 and 8:6- 8; and
`equivalents thereof”
`
`6. means for receiving and
`displaying a listing of which
`recipient PDA/cell phones
`have transmitted a manual
`
`5 Google Claim Construction Order.
`6 Google Claim Construction Order.
`
`’970
`Patent:
`claim 2
`
`Governed by 35 U.S.C.
`§ 112(6).
`Function: “receiving and
`displaying a listing of which
`
`display 16, and a wireless
`receiver and/or transceiver
`that receives electronic
`transmissions with
`acknowledgement receipts.
`(See ’970 patent, 4:7–11, 8:1–
`5, 8:12–15, FIG. 1)”
`Governed by 35 U.S.C. §
`112(6)
`Function: “periodically
`resending said forced message
`alert to said recipient
`PDA/cell phones that have not
`automatically acknowledged
`the forced message alert”
`
`Structure: “the forced-
`message alert software-
`application program on the
`sender PDA/cell phone that
`will ‘periodically resend the
`forced message alert to the
`PDA/cell phone that have
`[sic] not acknowledged
`receipt.’ (’970 patent, 8:6–8,
`FIG. 3B).”
`Governed by 35 U.S.C. §
`112(6)
`Function: “receiving and
`displaying a listing of which
`
`Parties’ Proposed
`Construction Based on Prior
`Case Order
`16 and a wireless receiver
`and/or transceiver; and
`equivalents thereof”
`
`Governed by 35 U.S.C.
`§ 112(6).5
`
`Function: “periodically
`resending said forced
`message alert to said
`recipient PDA/cell phones
`that have not automatically
`acknowledged the forced
`message alert”
`
`Structure: “a PC or
`PDA/cell phone configured
`to implement the algorithm
`disclosed in the ’970 Patent
`at 7:64-67 and 8:6-8; and
`equivalents thereof”
`
`Governed by 35 U.S.C.
`§ 112(6).6
`
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 68-1 Filed 06/16/23 Page 6 of 11 PageID #: 2357
`
`APPENDIX A: PROPOSED CONSTRUCTIONS
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Patent/
`Claims
`
`No. Claim Term/Phrase
`
`response to said forced
`message alert and details the
`response from each recipient
`PDA/cell phone that
`responded
`
`recipient PDA/cell phones
`have transmitted a manual
`response to said forced
`message alert and details the
`response from each recipient
`PDA/cell phone that
`responded”
`
`Structure: “PDA/cell phone
`hardware including display 16
`and a wireless receiver and/or
`transreceiver; and equivalents
`thereof”
`
`Governed by 35 U.S.C.
`§ 112(6).
`Function: “transmitting the
`acknowledgement of receipt
`to said sender PDA/cellphone
`immediately upon receiving a
`forced message alert from the
`sender PDA/cellphone”
`
`Structure: “a PC or PDA/cell
`phone configured to
`
`recipient PDA/cell phones
`have transmitted a manual
`response to said forced
`message alert and details the
`response from each recipient
`PDA/cell phone that
`responded”
`
`Structure: “hardware on the
`sender’s PDA/cell phone
`including a display, such as
`display 16, and a wireless
`receiver and/or transceiver
`that receives electronic
`transmissions with manual
`responses and displays those
`responses on the sender’s
`PDA/cell phone. (See ‘970
`patent, 4:7– 11, 8:1–5, 8:12–
`15, FIG. 1)”
`Governed by 35 U.S.C. §
`112(6)
`Function: “transmitting the
`acknowledgment of receipt to
`said sender PDA/cellphone
`immediately upon receiving a
`forced message alert from the
`sender PDA/cellphone”
`
`Structure: “the forced
`message alert software on the
`
`7. means for transmitting the
`acknowledgment of receipt to
`said sender PDA/cell phone
`immediately upon receiving a
`forced message alert from the
`sender PDA/cell phone
`
`’970
`Patent:
`claim 2
`
`
`7 Google Claim Construction Order.
`
`Parties’ Proposed
`Construction Based on Prior
`Case Order
`Function: “receiving and
`displaying a listing of which
`recipient PDA/cell phones
`have transmitted a manual
`response to said forced
`message alert and details the
`response from each recipient
`PDA/cell phone that
`responded”
`
`Structure: “PDA/cell phone
`hardware including display
`16 and a wireless receiver
`and/or transceiver; and
`equivalents thereof”
`
`Governed by 35 U.S.C.
`§ 112(6).7
`
`Function: “transmitting the
`acknowledgement of receipt
`to said sender
`PDA/cellphone immediately
`upon receiving a forced
`message alert from the
`sender PDA/cellphone”
`
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 68-1 Filed 06/16/23 Page 7 of 11 PageID #: 2358
`
`No. Claim Term/Phrase
`
`APPENDIX A: PROPOSED CONSTRUCTIONS
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Patent/
`Claims
`
`implement the algorithm
`disclosed in the ’970 Patent at
`8:20-30; and equivalents
`thereof”
`
`recipient PDA/cell phone.
`(See ’970 patent, 8:25–30,
`FIG. 4 at step 1)”
`
`
`Governed by 35 U.S.C. §
`112(6).
`
`Governed by 35 U.S.C. §
`112(6)
`
`Function: “controlling of
`the recipient
`PDA/cellphone upon
`transmitting said automatic
`acknowledgment and
`causing, in cases where the
`forced message alert is a
`text message, the text
`message and a response list
`to be shown on the display
`of the recipient
`PDA/cellphone or causes,
`in cases where the forced
`message alert is a voice
`message, the voice
`message being periodically
`repeated by the speakers of
`the recipient
`PDA/cellphone while said
`response list is shown on
`the display”
`
`Function: “control the
`recipient PDA/cell phone
`upon transmitting the
`automatic acknowledgment
`and cause, in cases where the
`forced message alert is a text
`message, the text message and
`a response list to be shown on
`the display of the recipient
`PDA/cell phone or cause, in
`cases where the forced
`message alert is a voice
`message, the voice message to
`be periodically repeated by
`the speakers of the recipient
`PDA/cell phone while the
`response list is shown on the
`display. (See ’970 patent,
`9:40–63 (claim 2)).”
`
`Structure: “the forced
`message alert software on the
`
`’970
`Patent:
`claim 2
`
`8. means for controlling of the
`recipient PDA/cell phone
`upon transmitting said
`automatic acknowledgment
`and causing, in cases where
`the force message alert is a
`text message, the text message
`and a response list to be
`shown on the display of the
`recipient PDA/cell phone or
`causes, in cases where the
`forced message alert is a voice
`message, the voice message
`being periodically repeated by
`the speakers of the recipient
`PDA/cell phone while said
`response list is shown on the
`display
`
`
`8 Google Claim Construction Order.
`
`Parties’ Proposed
`Construction Based on Prior
`Case Order
`Structure: “a PC or
`PDA/cell phone configured
`to implement the algorithm
`disclosed in the ’970 Patent
`at 8:20-30; and equivalents
`thereof”
`Governed by 35 U.S.C.
`§ 112(6).8
`
`Function: “controlling of the
`recipient PDA/cellphone
`upon transmitting said
`automatic acknowledgment
`and causing, in cases where
`the forced message alert is a
`text message, the text
`message and a response list
`to be shown on the display
`of the recipient
`PDA/cellphone or causes, in
`cases where the forced
`message alert is a voice
`message, the voice message
`being periodically repeated
`by the speakers of the
`recipient PDA/cellphone
`while said response list is
`shown on the display”
`
`Structure: “a PC or
`PDA/cell phone configured
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 68-1 Filed 06/16/23 Page 8 of 11 PageID #: 2359
`
`No. Claim Term/Phrase
`
`APPENDIX A: PROPOSED CONSTRUCTIONS
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Patent/
`Claims
`
`9. means for allowing a manual
`response to be manually
`selected from the response list
`or manually recorded and
`transmitting said manual
`response to the sender
`PDA/cell phone
`
`’970
`Patent:
`claim 2
`
`Structure: “a PC or PDA/cell
`phone configured to
`implement the algorithm
`disclosed in the ’970 Patent at
`8:37–44 and 8:46–51; and
`equivalents thereof”
`Governed by 35 U.S.C.
`§ 112(6).
`Function: “allowing a
`manual response to be
`manually selected from the
`response list or manually
`recorded and transmitting
`said manual response to the
`sender PDA/cell phone”
`
`Structure: “a PC or PDA/cell
`phone configured to implement
`the algorithm disclosed in the
`’970 Patent at 8:39-44 & 8:52-
`57; and equivalents thereof”
`
`recipient PDA/cell phone.
`(See ’970 patent, 8:37–44,
`8:46–50, FIG. 4 at step 2).”
`
`Governed by 35 U.S.C. §
`112(6)
`Function: “allowing a manual
`response to be manually
`selected from the response list
`or manually recorded and
`transmitting said manual
`response to the sender
`PDA/cell phone”
`
`Structure: “the forced
`message alert software on the
`recipient PDA/cell phone.
`(See ’970 patent, 8:52–57,
`FIG. 4 at step 3)”
`
`
`10. means for clearing the text
`message and a response list
`from the display of software
`on said recipient PDA/cell
`phone to transmit an
`automatic acknowledgment to
`the sender PDA/cell phone as
`
`9 Google Claim Construction Order.
`10 Google Claim Construction Order.
`
`’970
`Patent:
`claim 2
`
`Governed by 35 U.S.C. §
`112(6).
`Function: “clearing the text
`message and a response list
`from the display of the
`recipient PDA/cell phone or
`stopping the repeating voice
`
`Governed by 35 U.S.C. §
`112(6)
`Function: “clearing the text
`message and a response list
`from the display of the
`recipient PDA/cell phone or
`stopping the repeating voice
`
`Parties’ Proposed
`Construction Based on Prior
`Case Order
`to implement the algorithm
`disclosed in the ’970 Patent
`at 8:37–44 and 8:46–51; and
`equivalents thereof”
`
`Governed by 35 U.S.C.
`§ 112(6).9
`
`Function: “allowing a
`manual response to be
`manually selected from the
`response list or manually
`recorded and transmitting
`said manual response to the
`sender PDA/cell phone”
`
`Structure: “a PC or
`PDA/cell phone configured
`to implement the algorithm
`disclosed in the ’970 Patent
`at 8:39-44 & 8:52-57; and
`equivalents thereof”
`Governed by 35 U.S.C.
`§ 112(6).10
`
`Function: “clearing the text
`message and a response list
`from the display of the
`recipient PDA/cell phone or
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 68-1 Filed 06/16/23 Page 9 of 11 PageID #: 2360
`
`APPENDIX A: PROPOSED CONSTRUCTIONS
`
`Plaintiff’s Construction
`
`Defendants’ Construction
`
`Patent/
`Claims
`
`No. Claim Term/Phrase
`
`soon as said forced message
`alert is received by the
`recipient PDA/cell phone
`
`message and clearing the
`response list from the display
`of the recipient PDA/cell
`phone once the manual
`response is transmitted”
`
`Structure: “a PC or PDA/cell
`phone configured to
`implement the algorithm
`disclosed in the ’970 Patent at
`8:44–46 and 8:52–57; and
`equivalents thereof”
`
`message and clearing the
`response list from the display
`of the recipient PDA/cell
`phone once the manual
`response is transmitted”
`
`Structure: “the forced
`message alert software on the
`recipient PDA/cell phone.
`(See ’970 patent, 8:44–46,
`8:52–57, FIG. 4 at step 4)”
`
`Indefinite
`
`Antecedent basis for “the
`response list” is the “list of
`possible required responses”
`recited in the “means for
`attaching . . .” limitation
`
`Plain and ordinary meaning
`
`Indefinite
`
`Plain and ordinary meaning.
`
`“a PDA/cell phone belonging
`to the recipient of a forced
`message alert, different from
`the sender”
`
`11.
`
`the response list
`
`12.
`
`a response list
`
`13.
`
`recipient PDA/cell phone
`
`’970
`Patent:
`claim 2
`
`’970
`Patent:
`claim 2
`’970
`Patent:
`claims
`2, 10
`
`
`11 Google Claim Construction Order.
`12 Google Claim Construction Order.
`13 Google Claim Construction Order.
`
`Parties’ Proposed
`Construction Based on Prior
`Case Order
`stopping the repeating voice
`message and clearing the
`response list from the
`display of the recipient
`PDA/cell phone once the
`manual response is
`transmitted”
`
`Structure: “a PC or
`PDA/cell phone configured
`to implement the algorithm
`disclosed in the ’970 Patent
`at 8:44–46 and 8:52–57; and
`equivalents thereof”
`The antecedent basis for
`“the response list” is the
`“list of possible required
`responses” recited in the
`“means for attaching . . .”
`limitation.11
`Plain and ordinary
`meaning12
`
`Plain and ordinary
`meaning13
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 68-1 Filed 06/16/23 Page 10 of 11 PageID #:
`2361
`APPENDIX A: PROPOSED CONSTRUCTIONS
`
`Plaintiff’s Construction
`
`No. Claim Term/Phrase
`
`Patent/
`Claims
`
`Defendants’ Construction
`
`Parties’ Proposed
`Construction Based on Prior
`Case Order
`Plain and ordinary
`meaning14
`
`“PDA/cellphone equipped
`with at least a CPU, a touch
`screen display, and
`memory”15
`Plain and ordinary
`meaning16
`
`“more than two participants
`associated together”17
`
`Plain and ordinary meaning.
`
`“a PDA/cell phone belonging
`to the sender of a forced
`message alert, different from
`the recipient”
`
`Plain and ordinary meaning.
`
`Indefinite
`
`Plain and ordinary meaning.
`
`“two or more participants
`associated together”
`
`“transmitting a selected
`manual response from the
`response list that is required to
`clear the required response list
`from the recipient’s cell phone
`display”
`“more than two participants
`associated together”
`
`14.
`
`sender PDA/ cell phone
`
`15.
`
`similarly equipped
`
`16.
`
`17.
`
`transmitting a selected
`required response from the
`response list in order to allow
`the message required response
`list to be cleared from the
`recipient’s cell phone display
`group
`
`’970
`Patent:
`claims
`2, 10,
`13
`’970
`Patent:
`claims
`2, 11
`’970
`Patent:
`claim
`10
`
`’838
`Patent:
`claims
`1, 19,
`54
`’829
`Patent:
`claims
`1, 34,
`35
`’123
`Patent:
`claims
`
`
`14 Google Claim Construction Order.
`15 AGIS Software Development LLC v. T-Mobile USA, Inc., et al., Case No. 2:21-cv-00072-JRG-RSP (Lead Case), Dkt. No. 213 (“T-Mobile Claim Construction Order”).
`16 T-Mobile Claim Construction Order.
`17 AGIS Software Development LLC v. Huawei Device USA Inc., et al., Case No. 2:17-cv-00513-JRG-RSP (Lead Case), Dkt No. 205 (“Huawei Claim Construction Order”).
`
`

`

`Case 2:22-cv-00263-JRG-RSP Document 68-1 Filed 06/16/23 Page 11 of 11 PageID #:
`2362
`APPENDIX A: PROPOSED CONSTRUCTIONS
`
`Plaintiff’s Construction
`
`No. Claim Term/Phrase
`
`Patent/
`Claims
`
`Defendants’ Construction
`
`Parties’ Proposed
`Construction Based on Prior
`Case Order
`
`“characters that together
`define a geographic position”
`
`“two or more numbers that
`together define a geographic
`position, such as latitude and
`longitude”
`
`“characters that together
`define a geographic
`position”18
`
`1, 8,
`14, 15,
`17, 23,
`36
`’838
`Patent:
`claims
`1, 54
`’829
`Patent:
`claims
`1, 34,
`35
`’123
`Patent:
`claims
`1, 14,
`23, 36
`
`18.
`
`spatial coordinates
`
`
`
`
`18 Google Claim Construction Order.
`
`