Case 2:23-cv-00083-RWS-RSP Document 83-1 Filed 08/02/24 Page 1 of 43 PageID #: 1001
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`
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`EXHIBIT A
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`Pursuant to Local Patent Rule 4-5(d), Slyde Analytics LLC and Defendants Samsung Electronics Co., Inc. and Samsung
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`Electronics America, Inc. hereby provide a Joint Claim Construction Chart containing the claim terms and phrases for the claims for
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`U.S. Patent Nos. 9,804,678; 10,198,085; 8,588,033; and 9,651,922. In addition, the parties hereby identify the claim number(s) where
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`the terms and phrases appear.
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`Claim Language
`8. The wristwatch of
`claim 1, wherein said
`several available
`cards are organized in
`a virtual closed loop
`row or in a virtual
`closed loop column
`[sic.].
`
`21. The method of
`claim 9, wherein said
`several available
`cards are organized in
`a virtual closed loop
`row or in a virtual
`closed loop column
`[sic.].
`
`22. The method of
`claim 9, wherein said
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`AGREED TERMS
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`Term
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`Patent/Claim(s)
`
`Agreed Construction
`
`Court’s Construction
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`’922 Patent;
`Claims 8, 21, 22,
`24
`
`
`
`Claims 8 and 21: The cards
`are organized in a row or
`column such that continuing
`to scroll beyond the last card
`in the row or column will
`lead back to the first one and
`vice-versa.
`Claims 22 and 24: The cards
`are organized in a row and
`column such that continuing
`to scroll beyond the last card
`in the row and column will
`lead back to the first one and
`vice versa.
`
`“wherein said several
`available cards are
`organized in a virtual
`closed loop row or in
`a virtual closed loop
`column” (’922 Patent,
`Claim 8)
`“wherein said several
`available cards are
`organized in a virtual
`closed loop row or in
`a virtual closed loop
`column” (’922 Patent,
`Claim 21)
`“wherein said several
`available cards are
`organized in a virtual
`closed loop row and in
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`1
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`

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`Term
`a virtual closed loop
`column” (’922 Patent,
`Claim 22)
`“wherein said several
`available cards are
`organized in a virtual
`closed loop row and in
`a virtual closed loop
`column” (’922 Patent,
`Claim 24)
`
`
`
`Claim Language
`several available
`cards are organized in
`a virtual closed loop
`row and in a virtual
`closed loop column
`[sic.].
`
`24. A wristwatch
`having:
`a digital matrix
`display;
`a sheet of touch-
`sensitive glass;
`a processing circuit
`specifically laid out
`so as to interpret the
`signals from the
`touch-sensitive glass,
`for selecting a card
`from several available
`cards depending on
`these signals and for
`displaying said card
`on the entire digital
`matrix display;
`wherein said touch-
`sensitive glass is a
`two-dimensional
`glass for detecting a
`movement of at least
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`AGREED TERMS
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`Patent/Claim(s)
`
`Agreed Construction
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`Court’s Construction
`
`2
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`

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`
`
`Claim Language
`one finger at any
`place on the touch-
`sensitive glass along
`at least two different
`directions;
`wherein said
`processing circuit is
`specifically laid out
`so as to cause cards to
`scroll past in order to
`lastingly replace the
`initially displayed
`card with a
`replacement card,
`wherein each card has
`a fixed or periodically
`refreshed image,
`wherein the size of
`the image
`corresponds to the
`size of said digital
`matrix display so that
`the displayed card
`occupies the whole of
`said digital matrix
`display
`wherein said
`processing circuit is
`further laid out so that
`the replacement card
`
`AGREED TERMS
`
`Term
`
`Patent/Claim(s)
`
`Agreed Construction
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`Court’s Construction
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`3
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`

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`AGREED TERMS
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`Term
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`Patent/Claim(s)
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`Agreed Construction
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`Court’s Construction
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`
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`Claim Language
`is dependent from the
`initially displayed
`card and from the
`direction of said
`movement and is
`independent from the
`starting point and end
`point of said
`movement on said
`digital matrix display;
`and
`wherein said several
`available cards are
`organized in a virtual
`closed loop row and
`in a virtual closed
`loop.
`
`
`
`
`
`4
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`

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`DISPUTED TERMS
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`Court’s Construction
`
`Plaintiff’s
`Construction
`
`Plain and ordinary
`meaning
`
`Defendants’
`Construction
`“A combination of
`two or more gears that
`transmit motion from
`one shaft to another”
`
`
`
`
`Claim Language
`
`Term
`
`Patent/Claims
`
`“gear train”
`
`’033 Patent;
`Claims 1, 17,
`18
`
`1. Wristwatch comprising:
`a watchcase;
`an electronic display in said
`watchcase;
`a quartz oscillator,
`a microcontroller being
`arranged for reproducing on
`said electronic display the
`simulation of a mechanical
`watch movement
`comprising a gear train,
`said simulation being visible
`so as to indicate the time,
`said microcontroller being
`further arranged for
`synchronizing the displayed
`time by said displayed
`mechanical movement with
`that of said quartz oscillator.
`
`16. Wristwatch comprising:
`a watchcase;
`an electronic display in said
`watchcase;
`a touch sensor associated
`with said display and
`enabling the displacement
`of at least one finger along
`
`5
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`

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`Claim Language
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`Term
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`Patent/Claims
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`Plaintiff’s
`Construction
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`Defendants’
`Construction
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`Court’s Construction
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`DISPUTED TERMS
`
`at least two different
`directions to be detected
`a quartz oscillator,
`a microcontroller being
`arranged for reproducing on
`said electronic display a
`simulation of a mechanical
`watch movement
`comprising a gear train
`visible so as to indicate the
`time and for synchronizing
`the displayed time by said
`displayed mechanical
`movement with that of said
`quartz oscillator, said
`microcontroller being
`further arranged for
`interpreting signals from the
`touch sensor, for selecting
`one screen from among
`several available screens
`depending on these signals,
`and for displaying this
`screen on the entirety of
`said display,
`said microcontroller being
`further specifically arranged
`so as to cause screens to
`scroll by in order to replace
`
`6
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`

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`Claim Language
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`Term
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`Patent/Claims
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`Plaintiff’s
`Construction
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`Defendants’
`Construction
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`Court’s Construction
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`DISPUTED TERMS
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`durably the screen displayed
`initially by another screen,
`with the orientation and the
`direction of scrolling
`depending on the orientation
`and direction of said
`displacement,
`wherein at least two of said
`screens correspond to two
`distinct mechanical
`movements that can be
`selected by the user.
`
`17. Method for displaying
`time in a wristwatch,
`comprising
`displaying on an electronic
`display of a simulated
`mechanical watch
`movement comprising a
`gear train and of time
`indicators so as to simulate
`a mechanical watch,
`said method comprising a
`step of modifying a position
`of at least one component of
`said mechanical movement
`by detecting displacement
`of a finger on that
`
`7
`
`

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`Claim Language
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`Term
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`Patent/Claims
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`Plaintiff’s
`Construction
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`Defendants’
`Construction
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`Court’s Construction
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`DISPUTED TERMS
`
`component with a touch
`sensor connected to said
`display.
`
`18. The method of claim 17,
`wherein:
`the angular position of at
`least one element of the
`gear train displayed on said
`display is modified by
`pressing on said
`element,
`a crown stem is displayed
`on said display opposite a
`crown on the outside of a
`case of the watch, the
`displayed position of said
`crown stem being modified
`when an actuation of said
`crown is detected, so as to
`simulate a direct action by
`said crown on said
`displayed crown stem;
`an element is displayed on
`said display opposite a
`pushbutton on the outside of
`the watchcase, the position
`of said element being
`modifiable by said
`
`8
`
`

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`Claim Language
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`Term
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`Patent/Claims
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`Plaintiff’s
`Construction
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`Defendants’
`Construction
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`Court’s Construction
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`DISPUTED TERMS
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`microcontroller when said
`microcontroller detects that
`said push-button
`has been actuated, so as to
`simulate a direct action by
`said push-button on said
`displayed element;
`the position of at least one
`element of said movement
`is modified according to the
`data from an accelerometer;
`the position of an oscillating
`mass displayed on the
`display depends on an
`output signal from said
`accelerometer;
`the position of a balance
`and/or tourbillon displayed
`on said display depends on
`an output signal from said
`accelerometer;
`the oscillations of a
`regulating organ displayed
`on said display are
`simulated taking into
`account the simulated mass
`of a simulated balance and
`the rigidity of a returning
`element displayed on said
`
`9
`
`

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`1010
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`Claim Language
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`Term
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`Patent/Claims
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`Plaintiff’s
`Construction
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`Defendants’
`Construction
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`Court’s Construction
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`DISPUTED TERMS
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`display, with the time
`displayed being dependent
`on said simulation;
`the running of said
`displayed regulating
`element is modified
`according to the
`accelerations to which the
`watch is subjected;
`the running of a quartz
`oscillator is synchronized
`periodically or upon request
`from the user with the time
`displayed by said
`mechanical movement;
`said displayed mechanical
`movement is displayed on
`the entire surface of the
`electronic display so as to
`occupy the position and the
`dimensions of a real
`mechanical movement;
`the user selects the
`mechanical movement
`displayed on said display
`from among several
`available mechanical
`movements to be chosen
`from.
`
`10
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`

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`Case 2:23-cv-00083-RWS-RSP Document 83-1 Filed 08/02/24 Page 11 of 43 PageID #:
`1011
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`Claim Language
`
`Term
`
`Patent/Claims
`
`Plaintiff’s
`Construction
`
`Defendants’
`Construction
`
`Court’s Construction
`
`DISPUTED TERMS
`
`1. Wristwatch comprising:
`a watchcase;
`an electronic display in said
`watchcase;
`a quartz oscillator,
`a microcontroller being
`arranged for reproducing on
`said electronic display the
`simulation of a mechanical
`watch movement
`comprising a gear train,
`said simulation being
`visible so as to indicate the
`time, said microcontroller
`being further arranged for
`synchronizing the displayed
`time by said displayed
`mechanical movement with
`that of said quartz oscillator.
`17. Method for displaying
`time in a wristwatch,
`comprising
`displaying on an electronic
`display of a simulated
`mechanical watch
`movement comprising a
`gear train and of time
`indicators so as to
`
`“simulation of a
`mechanical watch
`movement
`comprising a gear
`train, said
`simulation being
`visible so as to
`indicate the time”
`
`“an electronic
`display of a
`simulated
`mechanical watch
`movement
`comprising a gear
`train and of time
`indicators so as to
`simulate a
`
`’033 Patent;
`Claim 1
`
`Plain and ordinary
`meaning
`
`’033 Patent;
`Claim 17
`
`Plain and ordinary
`meaning
`
`11
`
`
`
`
`
`“A simulation of a
`mechanical watch with
`a gear train where the
`positions of the
`internal components
`and the resulting time
`are calculated and
`displayed according to
`the components’
`interactions”
`
`“an electronic display
`of a simulation of a
`mechanical watch with
`a gear train where the
`positions
`of
`the
`internal
`components
`and the resulting time
`are
`calculated
`and
`displayed according to
`
`

`

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`1012
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`DISPUTED TERMS
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`Claim Language
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`Term
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`Patent/Claims
`
`mechanical
`watch”
`
`Plaintiff’s
`Construction
`
`Defendants’
`Construction
`components’
`the
`interactions”
`
`Court’s Construction
`
`simulate a mechanical
`watch,
`said method comprising a
`step of modifying a position
`of at least one component of
`said mechanical movement
`by detecting displacement
`of a finger on that
`component with a touch
`sensor connected to said
`display.
`
`1. Wristwatch comprising:
`a watchcase;
`an electronic display in said
`watchcase;
`a quartz oscillator,
`a microcontroller being
`arranged for reproducing on
`said electronic display the
`simulation of a mechanical
`watch movement
`comprising a gear train, said
`simulation being visible so
`as to indicate the time, said
`microcontroller being
`further arranged for
`synchronizing the displayed
`
`“mechanical
`watch”
`
`’033 Patent;
`Claims 1, 17
`
`Plain and ordinary
`meaning
`
`“Watch that keeps time
`by mechanical means”
`
`
`
`12
`
`

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`1013
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`Claim Language
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`Term
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`Patent/Claims
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`Plaintiff’s
`Construction
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`Defendants’
`Construction
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`Court’s Construction
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`DISPUTED TERMS
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`time by said displayed
`mechanical movement with
`that of said quartz oscillator.
`
`
`17. Method for displaying
`time in a wristwatch,
`comprising
`displaying on an electronic
`display of a simulated
`mechanical watch
`movement comprising a
`gear train and of time
`indicators so as to simulate
`a mechanical watch,
`said method comprising a
`step of modifying a position
`of at least one component of
`said mechanical movement
`by detecting displacement
`of a finger on that
`component with a touch
`sensor connected to said
`display.
`
`1. Wristwatch comprising:
`a watchcase;
`
`“synchronizing
`the displayed time
`
`’033 Patent;
`Claim 1
`
`Plain and ordinary
`meaning
`
`“adjusting the
`displayed time of the
`
`
`
`13
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`

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`1014
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`Claim Language
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`Term
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`Patent/Claims
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`Plaintiff’s
`Construction
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`DISPUTED TERMS
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`by said displayed
`mechanical
`movement with
`that of said quartz
`oscillator”
`
`Court’s Construction
`
`Defendants’
`Construction
`simulated mechanical
`watch movement to
`show the time
`determined by the
`quartz oscillator”
`
`an electronic display in said
`watchcase;
`a quartz oscillator,
`a microcontroller being
`arranged for reproducing on
`said electronic display the
`simulation of a mechanical
`watch movement
`comprising a gear train, said
`simulation being visible so
`as to indicate the time, said
`microcontroller being
`further arranged for
`synchronizing the
`displayed time by said
`displayed mechanical
`movement with that of
`said quartz oscillator.
`
`
`1. A wristwatch having:
`a digital matrix display;
`a sheet of touch-sensitive
`glass;
`a processing circuit
`specifically laid out so as to
`interpret the signals from
`the touch-sensitive glass, for
`
`“cause said
`several available
`cards to scroll
`past”
`
`’922 Patent;
`Claim 1
`
`Plain and ordinary
`meaning
`
`
`
`“to scroll more than
`one card across the
`display in response to
`one movement of at
`least one finger”
`
`14
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`

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`Claim Language
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`Term
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`Patent/Claims
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`Plaintiff’s
`Construction
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`Defendants’
`Construction
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`Court’s Construction
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`DISPUTED TERMS
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`selecting a card from
`several available cards
`depending on these signals
`and for displaying said card
`on the entire digital matrix
`display;
`wherein said touch-sensitive
`glass is a two-dimensional
`glass for detecting a
`movement of at least one
`finger at any place on the
`touch-sensitive glass along
`at least two different
`directions;
`wherein said processing
`circuit is specifically laid
`out so as to cause said
`several available cards to
`scroll past in order to
`lastingly replace the initially
`displayed card with a
`replacement card selected
`between said several
`available cards, wherein
`each card of said several
`available cards has a distinct
`fixed or periodically
`refreshed image,
`
`15
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`

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`Claim Language
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`Term
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`Plaintiff’s
`Construction
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`Defendants’
`Construction
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`Court’s Construction
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`DISPUTED TERMS
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`wherein the size of the
`image corresponds to the
`size of said digital matrix
`display so that the displayed
`card occupies the whole of
`said digital matrix display;
`wherein one card of said
`several available cards and
`occupying the entire digital
`matrix display is
`immediately and without
`further user intervention
`replaced after the scrolling
`by a different card of said
`several available cards that
`occupies the entire digital
`matrix display;
`wherein said processing
`circuit is further laid out so
`that the replacement card is
`dependent from the initially
`displayed card and from the
`direction of said movement
`and is independent from the
`starting point and end point
`of said movement on said
`digital matrix display.
`
`
`
`16
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`

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`Claim Language
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`Term
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`Patent/Claims
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`Plaintiff’s
`Construction
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`Defendants’
`Construction
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`Court’s Construction
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`DISPUTED TERMS
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`“scrolling on a
`digital matrix
`display of several
`available cards”
`
`’922 Patent;
`Claim 9
`
`Plain and ordinary
`meaning
`
`
`
`“scrolling more than
`one card across the
`display in response to
`one movement of at
`least one finger”
`
`9. A method for replacing
`an initially displayed card
`displayed by a wristwatch
`by a replacement card, the
`method having the
`following steps:
`detecting a direction of a
`movement of at least one
`finger at any place and
`along at least two different
`directions on a two-
`dimensional touch-sensitive
`glass;
`scrolling on a digital
`matrix display of several
`available cards so as for
`said scrolling to stop of
`itself so as to align an edge
`of the replacement card with
`an edge of the matrix
`display, wherein one card of
`said several available cards
`and occupying the entire
`digital matrix display is
`replaced after the scrolling,
`immediately and without
`further user intervention, by
`a different card selected
`between said several
`
`17
`
`

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`Claim Language
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`Term
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`Patent/Claims
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`Plaintiff’s
`Construction
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`Defendants’
`Construction
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`Court’s Construction
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`DISPUTED TERMS
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`available cards and
`occupying the entire digital
`matrix display; and wherein
`the scrolling direction
`depends only on the
`direction of said movement
`so that said replacement
`card is dependent from the
`initially displayed card and
`from the direction of said
`movement and is
`independent from the
`starting point and end point
`of said movement on said
`digital matrix display;
`lastingly displaying the
`replacement card on the
`whole of said digital matrix
`display, wherein each card
`of said several available
`cards has a distinct fixed or
`periodically refreshed
`image, the size of the
`images corresponding to the
`size of said digital matrix
`display.
`9. A method for replacing
`an initially displayed card
`
`“A method for
`replacing an
`
`’922 Patent;
`Claim 9
`
`Plain and ordinary
`meaning
`
`Limiting
`
`
`
`18
`
`

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`DISPUTED TERMS
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`Plaintiff’s
`Construction
`Preamble is not
`limiting.
`
`Defendants’
`Construction
`
`Court’s Construction
`
`Claim Language
`
`Term
`
`Patent/Claims
`
`initially displayed
`card displayed by
`a wristwatch by a
`replacement card,
`the method
`having the
`following steps:”
`
`displayed by a wristwatch
`by a replacement card, the
`method having the
`following steps:
`detecting a direction of a
`movement of at least one
`finger at any place and
`along at least two different
`directions on a two-
`dimensional touch-sensitive
`glass;
`scrolling on a digital matrix
`display of several available
`cards so as for said scrolling
`to stop of itself so as to
`align an edge of the
`replacement card with an
`edge of the matrix display,
`wherein one card of said
`several available cards and
`occupying the entire digital
`matrix display is replaced
`after the scrolling,
`immediately and without
`further user intervention, by
`a different card selected
`between said several
`available cards and
`occupying the entire digital
`
`19
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`Claim Language
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`Term
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`Patent/Claims
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`Plaintiff’s
`Construction
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`Defendants’
`Construction
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`Court’s Construction
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`DISPUTED TERMS
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`matrix display; and wherein
`the scrolling direction
`depends only on the
`direction of said movement
`so that said replacement
`card is dependent from the
`initially displayed card and
`from the direction of said
`movement and is
`independent from the
`starting point and end point
`of said movement on said
`digital matrix display;
`lastingly displaying the
`replacement card on the
`whole of said digital matrix
`display, wherein each card
`of said several available
`cards has a distinct fixed or
`periodically refreshed
`image, the size of the
`images corresponding to the
`size of said digital matrix
`display.
`1. A wristwatch having:
`a digital matrix display;
`a sheet of touch-sensitive
`glass;
`
`“A wristwatch”
`
`’922 Patent;
`Claim 1
`
`Plain and ordinary
`meaning
`
`Limiting
`
`
`
`20
`
`

`

`Case 2:23-cv-00083-RWS-RSP Document 83-1 Filed 08/02/24 Page 21 of 43 PageID #:
`1021
`
`
`
`DISPUTED TERMS
`
`Plaintiff’s
`Construction
`Preamble is not
`limiting.
`
`Defendants’
`Construction
`
`Court’s Construction
`
`Claim Language
`
`Term
`
`Patent/Claims
`
`a processing circuit
`specifically laid out so as to
`interpret the signals from
`the touch-sensitive glass, for
`selecting a card from
`several available cards
`depending on these signals
`and for displaying said card
`on the entire digital matrix
`display;
`wherein said touch-sensitive
`glass is a two-dimensional
`glass for detecting a
`movement of at least one
`finger at any place on the
`touch-sensitive glass along
`at least two different
`directions;
`wherein said processing
`circuit is specifically laid
`out so as to cause said
`several available cards to
`scroll past in order to
`lastingly replace the initially
`displayed card with a
`replacement card selected
`between said several
`available cards, wherein
`each card of said several
`
`21
`
`

`

`Case 2:23-cv-00083-RWS-RSP Document 83-1 Filed 08/02/24 Page 22 of 43 PageID #:
`1022
`
`
`
`Claim Language
`
`Term
`
`Patent/Claims
`
`Plaintiff’s
`Construction
`
`Defendants’
`Construction
`
`Court’s Construction
`
`DISPUTED TERMS
`
`available cards has a distinct
`fixed or periodically
`refreshed image,
`wherein the size of the
`image corresponds to the
`size of said digital matrix
`display so that the displayed
`card occupies the whole of
`said digital matrix display;
`wherein one card of said
`several available cards and
`occupying the entire digital
`matrix display is
`immediately and without
`further user intervention
`replaced after the scrolling
`by a different card of said
`several available cards that
`occupies the entire digital
`matrix display;
`wherein said processing
`circuit is further laid out so
`that the replacement card is
`dependent from the initially
`displayed card and from the
`direction of said movement
`and is independent from the
`starting point and end point
`
`22
`
`

`

`Case 2:23-cv-00083-RWS-RSP Document 83-1 Filed 08/02/24 Page 23 of 43 PageID #:
`1023
`
`
`
`Claim Language
`
`Term
`
`Patent/Claims
`
`Plaintiff’s
`Construction
`
`Defendants’
`Construction
`
`Court’s Construction
`
`DISPUTED TERMS
`
`Limiting
`
`
`
`’678 Patent;
`Claim 1
`
`of said movement on said
`digital matrix display.
`
`1. A method combining
`gesture detection by an
`inertial sensor and gesture
`detection with a touch
`panel for switching a
`wristwatch from a first
`power mode to a second
`power mode, wherein the
`inertial sensor comprises
`an accelerometer and a
`processor and/or other
`processing means, and
`wherein the wristwatch
`comprises a
`microcontroller
`controlling a display of
`indication on a digital
`matrix display of the
`wristwatch and a touch
`controller for interpreting
`touch signal provided by a
`touch panel underneath a
`cover glass and for
`converting said signals
`into command signal, the
`
`“A method
`combining
`gesture detection
`by an inertial
`sensor and
`gesture detection
`with a touch
`panel for
`switching a
`wristwatch from a
`first power mode
`to a second power
`mode, wherein
`the inertial sensor
`comprises an
`accelerometer and
`a processor and/or
`other processing
`means, and
`wherein the
`wristwatch
`comprises a
`microcontroller
`controlling a
`display of
`
`Plain and ordinary
`meaning
`Only preamble terms
`“wherein the inertial
`sensor comprises an
`accelerometer and a
`processor and/or
`other processing
`means” and “wherein
`the wristwatch
`comprises a
`microcontroller
`controlling a display
`of indication on a
`digital matrix display
`of the wristwatch and
`a touch controller for
`interpreting touch
`signal provided by a
`touch panel
`underneath a cover
`glass and for
`covering said signals
`
`23
`
`

`

`Case 2:23-cv-00083-RWS-RSP Document 83-1 Filed 08/02/24 Page 24 of 43 PageID #:
`1024
`
`
`
`DISPUTED TERMS
`
`Defendants’
`Construction
`
`Court’s Construction
`
`Plaintiff’s
`Construction
`into command signal”
`are limiting
`
`
`
`Claim Language
`
`Term
`
`Patent/Claims
`
`indication on a
`digital matrix
`display of the
`wristwatch and a
`touch controller
`for interpreting
`touch signal
`provided by a
`touch panel
`underneath a
`cover glass and
`for converting
`said signals into
`command signal”
`
`method comprising:
`using the accelerometer of
`the inertial sensor for
`generating an acceleration
`signal used for detecting a
`gesture on the cover glass of
`said wristwatch, while the
`microcontroller and the
`touch controller are in a
`sleep power mode;
`using the processor and/or
`other processing means of
`the inertial sensor for
`discriminating between
`gesture and no gesture
`based on a direction of said
`acceleration signal and on a
`slope or frequency of said
`acceleration signal as
`measured by said
`accelerometer being a three
`dimensional accelerometer,
`in response to a detection of
`a gesture by said inertial
`sensor, waking up the touch
`controller;
`using the touch controller
`for detecting a tap gesture
`
`24
`
`

`

`Case 2:23-cv-00083-RWS-RSP Document 83-1 Filed 08/02/24 Page 25 of 43 PageID #:
`1025
`
`
`
`Claim Language
`
`Term
`
`Patent/Claims
`
`Plaintiff’s
`Construction
`
`Defendants’
`Construction
`
`Court’s Construction
`
`DISPUTED TERMS
`
`on the cover glass with the
`touch panel;
`waking up the
`microcontroller in said
`wristwatch upon detection
`of a tap gesture by said
`touch controller,
`using said microcontroller
`for detecting said gesture
`and for discriminating
`between gesture and no
`gesture based at least on
`signals from the touch
`panel.
`
`1. A method combining
`gesture detection by an
`inertial sensor and gesture
`detection with a touch panel
`for switching a wristwatch
`from a first power mode to a
`second power mode,
`wherein the inertial sensor
`comprises an accelerometer
`and a processor and/or other
`processing means, and
`wherein the wristwatch
`comprises a microcontroller
`
`’678 Patent;
`Claim 1
`
`“other processing
`means of the
`inertial sensor for
`discriminating
`between gesture
`and no gesture
`based on a
`direction of said
`acceleration
`signal and on a
`slope or
`frequency of said
`acceleration
`
`Not governed by 35
`U.S.C. § 112(6).
`In the alternative, to
`the extent the Court
`finds this term is
`governed by 35
`U.S.C. § 112(6):
`Function:
`“discriminating
`between gesture and
`no gesture based on a
`direction of said
`
`
`
`Mean-plus-function
`under §112, ¶6.
`Function:
`“discriminating
`between gesture and
`no gesture based on a
`direction of said
`acceleration signal and
`on a slope or
`frequency of said
`acceleration signal as
`measured by said
`accelerometer being a
`
`25
`
`

`

`Case 2:23-cv-00083-RWS-RSP Document 83-1 Filed 08/02/24 Page 26 of 43 PageID #:
`1026
`
`
`
`DISPUTED TERMS
`
`Court’s Construction
`
`Defendants’
`Construction
`three dimensional
`accelerometer”
`Structure: None
`disclosed in the
`specification,
`rendering the term
`indefinite
`
`Plaintiff’s
`Construction
`acceleration signal
`and on a scope or
`frequency of said
`acceleration signal as
`measured by said
`accelerometer being a
`three dimensional
`accelerometer”
`Structure: “inertial
`sensor, touch
`controller,
`microcontroller,
`dedicated circuit,
`processor or any
`combination thereof”
`or equivalents thereof
`
`Claim Language
`
`Term
`
`Patent/Claims
`
`signal as
`measured by said
`accelerometer
`being a three
`dimensional
`accelerometer”
`
`controlling a display of
`indication on a digital
`matrix display of the
`wristwatch and a touch
`controller for interpreting
`touch signal provided by a
`touch panel underneath a
`cover glass and for
`converting said signals into
`command signal, the
`method comprising:
`using the accelerometer of
`the inertial sensor for
`generating an acceleration
`signal used for detecting a
`gesture on the cover glass of
`said wristwatch, while the
`microcontroller and the
`touch controller are in a
`sleep power mode;
`using the processor and/or
`other processing means of
`the inertial sensor for
`discriminating between
`gesture and no gesture
`based on a direction of
`said acceleration signal
`and on a slope or
`frequency of said
`
`26
`
`

`

`Case 2:23-cv-00083-RWS-RSP Document 83-1 Filed 08/02/24 Page 27 of 43 PageID #:
`1027
`
`
`
`Claim Language
`
`Term
`
`Patent/Claims
`
`Plaintiff’s
`Construction
`
`Defendants’
`Construction
`
`Court’s Construction
`
`DISPUTED TERMS
`
`acceleration signal as
`measured by said
`accelerometer being a
`three dimensional
`accelerometer,
`in response to a detection of
`a gesture by said inertial
`sensor, waking up the touch
`controller;
`using the touch controller
`for detecting a tap gesture
`on the cover glass with the
`touch panel;
`waking up the
`microcontroller in said
`wristwatch upon detection
`of a tap gesture by said
`touch controller,
`using said microcontroller
`for detecting said gesture
`and for discriminating
`between gesture and no
`gesture based at least on
`signals from the touch
`panel.
`14. A wristwatch which can
`be operated in a plurality of
`power modes including a
`
`“other processing
`means being
`
`’678 Patent;
`Claim 14
`
`Not governed by 35
`U.S.C. § 112(6).
`
`Mean-plus-function
`under §112, ¶6.
`
`
`
`27
`
`

`

`Case 2:23-cv-00083-RWS-RSP Document 83-1 Filed 08/02/24 Page 28 of 43 PageID #:
`1028
`
`
`
`DISPUTED TERMS
`
`Court’s Construction
`
`Claim Language
`
`Term
`
`Patent/Claims
`
`arranged for
`discriminating
`between gesture
`and no gesture
`based on a
`direction of said
`acceleration
`signal as
`measured by said
`accelerometer
`being a three
`dimensional
`accelerometer,
`and on a slope or
`frequency of said
`acceleration
`signal, while the
`microcontroller
`and the touch
`controller are in a
`sleep power
`mode”
`
`first power mode and a
`second power mode,
`comprising:
`a display;
`a microcontroller;
`a touch panel underneath a
`cover glass of said
`wristwatch for detecting a
`gesture on said cover glass;
`a touch controller for
`interpreting touch signal
`provided by the touch panel
`and for converting said
`signals into command
`signal;
`an inertial sensor
`comprising an
`accelerometer and a
`processor and/or other
`processing means, said
`accelerometer being
`arranged for generating an
`acceleration signal and the
`processor and/or other
`processing means being
`arranged for
`discriminating between
`gesture and no gesture
`based on a direction of
`
`Defendants’
`Construction
`Function:
`“discriminating
`between gesture and
`no gesture based on a
`direction of said
`acceleration signal as
`measured by said
`accelerometer being a
`three dimensional
`accelerometer, and on
`a slope or frequency of
`said acceleration
`signal, while the
`microcontroller and
`the touch controller
`are in a sleep power
`mode”
`Structure: None
`disclosed in the
`specification,
`rendering the term
`indefinite
`
`Plaintiff’s
`Construction
`In the alternative, to
`the extent the Court
`finds this term is
`governed by 35
`U.S.C. § 112(6):
`Function:
`“discriminating
`between gesture and
`no gesture on a
`direction of said
`acceleration signal as
`measured by said
`accelerometer being a
`three dimensional
`accelerometer, and on
`a slope or frequency
`of said acceleration
`signal, while the
`microcontroller and
`the touch controller
`are in a sleep power
`mode”
`Structure: “inert