Case 4:23-cv-01147-ALM Document 51-1 Filed 09/13/24 Page 1 of 7 PageID #: 1561
`
`
`
`
`
`Exhibit A
`
`

`

`Case 4:23-cv-01147-ALM Document 51-1 Filed 09/13/24 Page 2 of 7 PageID #: 1562
`
`EXHIBIT A – PLAINTIFF R2 SOLUTIONS LLC’S PROPOSED CONSTRUCTIONS AND SUPPORT
`
`Disputed Term/Phrase
`“processor and memory that
`are operable to perform the
`following operations:
`
`partitioning the data of each
`one of the data groups into a
`plurality of data partitions that
`each have a plurality of key-
`value pairs and providing each
`data partition to a selected one
`of a plurality of mapping
`functions that are each user-
`configurable to independently
`output a plurality of lists of
`values for each of a set of keys
`found in such map function's
`corresponding data partition to
`form corresponding
`intermediate data for that data
`group and identifiable to that
`data group, wherein the data of
`a first data group has a
`different schema than the data
`of a second data group and the
`data of the first data group is
`mapped differently than the
`data of the second data group
`so that different lists of values
`are output for the
`corresponding different
`intermediate data, wherein the
`different schema and
`
`Plaintiff’s Proposed Construction
`R2 Solutions contends that this phrase needs no
`construction and should be afforded its plain and
`ordinary meaning. R2 further contends that this
`phrase is not subject to 35 U.S.C. § 112, ¶ 6 and is
`not indefinite. See also the proposed constructions for
`“data group” and “a plurality of mapping functions
`that are each user-configurable.”
`
`Plaintiff’s Support
`’610 patent at 4:23-59; 6:18-8:13; FIG. 3 (and
`related text); FIG. 4 (and related text); FIG. 5 (and
`related text)
`
`Declaration of Bill Davis and accompanying
`exhibits
`
`“processor” – The New Penguin Dictionary of
`Computing, Penguin Books 2001, p. 387 (Exhibit
`D to R2’s 4-2 Disclosures)
`
`“memory” – The New Penguin Dictionary of
`Computing, Penguin Books 2001, p. 300 (Exhibit
`D to R2’s 4-2 Disclosures)
`
`R2 Solutions LLC v. Deezer S.A., Civil Action No.
`4:21-CV-00090-ALM, Dkt. No. 45, Claim
`Construction Memorandum Opinion and Order
`(E.D. Tex. Jan. 4, 2022) (Exhibit B to R2’s 4-2
`Disclosures)
`
`R2 Solutions LLC v. American Airlines Inc., Civil
`Action No. 4:22-CV-00353-ALM, Dkt. No. 58,
`Claim Construction Memorandum Opinion and
`Order (E.D. Tex. Apr. 3, 2023) (Exhibit C to R2’s
`4-2 Disclosures)
`
`American Airlines, Inc. et al. v. R2 Solutions LLC,
`IPR2023-00689 (PTAB Mar. 7, 2023) Petition, all
`exhibits, the Preliminary Response, and the
`Decision Denying Institution of Inter Partes
`Review
`
`
`
`1
`
`

`

`Case 4:23-cv-01147-ALM Document 51-1 Filed 09/13/24 Page 3 of 7 PageID #: 1563
`
`EXHIBIT A – PLAINTIFF R2 SOLUTIONS LLC’S PROPOSED CONSTRUCTIONS AND SUPPORT
`
`Plaintiff’s Proposed Construction
`
`Disputed Term/Phrase
`corresponding different
`intermediate data have a key in
`common; and reduce the
`intermediate data for the data
`groups to at least one output
`data group, including
`processing the intermediate
`data for each data group in a
`manner that is defined to
`correspond to that data group
`so as to result in a merging of
`the corresponding different
`intermediate data based on the
`key in common.”
`(Claim 17)
`
`“mapping” / “map” /
`“mapped”
`(Claims 1, 17)
`
`R2 Solutions contends that this phrase needs no
`construction and should be afforded its plain and
`ordinary meaning.
`
`Plaintiff’s Support
`
`
`FedEx Corporate Services, Inc. v. R2 Solutions
`LLC, IPR2022-01405 (PTAB Aug. 15, 2022)
`Petition, all exhibits, the Preliminary Response,
`and the Decision Denying Institution of Inter
`Partes Review
`
`Databricks, Inc. v. R2 Solutions LLC, IPR2024-
`00659 (PTAB Mar. 24, 2024) Petition, all exhibits,
`the Preliminary Response, the Decision Denying
`Institution of Inter Partes Review, Petitioner’s
`Request for Director Review, and Decision
`Denying Director Review.
`
`Cloudera, Inc. v. R2 Solutions LLC, IPR2024-
`00303 (PTAB Dec. 18, 2023) Petition, all exhibits,
`the Preliminary Response, Decision Denying
`Institution of Inter Partes Review, Petitioner’s
`Request for Director Review, and Decision
`Denying Director Review.
`
`All evidence identified by the other party
`’610 patent at Abstract; 2:1-42; 3:48-57; 6:18-35;
`7:36-8:58; FIG. 1 (and related text); FIG. 2 (and
`related text); FIG. 3 (and related text); FIG. 4 (and
`related text); FIG. 5 (and related text)
`
`R2 Solutions LLC v. Walmart Inc., Civil Action
`No. 4:21-CV-00091-ALM, Dkt. No. 54, Claim
`Construction Memorandum Opinion and Order
`(E.D. Tex. Jan. 4, 2022) (Exhibit B to R2’s 4-2
`Disclosures)
`
`
`
`2
`
`

`

`Case 4:23-cv-01147-ALM Document 51-1 Filed 09/13/24 Page 4 of 7 PageID #: 1564
`
`EXHIBIT A – PLAINTIFF R2 SOLUTIONS LLC’S PROPOSED CONSTRUCTIONS AND SUPPORT
`
`Disputed Term/Phrase
`
`Plaintiff’s Proposed Construction
`
`“reducing” / “reduce”
`(Claims 1, 17)
`
`R2 Solutions contends that this term needs no
`construction and should be afforded its plain and
`ordinary meaning.
`
`
`Plaintiff’s Support
`
`
`R2 Solutions LLC v. American Airlines Inc., Civil
`Action No. 4:22-CV-00353-ALM, Dkt. No. 58,
`Claim Construction Memorandum Opinion and
`Order (E.D. Tex. Apr. 3, 2023) (Exhibit C to R2’s
`4-2 Disclosures)
`
`R2 reserves the right to rely on testimony from
`Bill Davis in response to any expert evidence
`relied on by Defendant.
`
`All evidence identified by any other party
`
`’610 patent at Abstract; 2:19-51; 4:4-59; 5:40-
`6:17; 6:18-7:35; 7:61-8:14; FIG. 1 (and related
`text); FIG. 2 (and related text); FIG. 3 (and related
`text); FIG. 4 (and related text); FIG. 5 (and related
`text)
`
`R2 Solutions LLC v. Walmart Inc., Civil Action
`No. 4:21-CV-00091-ALM, Dkt. No. 54, Claim
`Construction Memorandum Opinion and Order
`(E.D. Tex. Jan. 4, 2022) (Exhibit B to R2’s 4-2
`Disclosures)
`
`R2 Solutions LLC v. American Airlines Inc., Civil
`Action No. 4:22-CV-00353-ALM, Dkt. No. 58,
`Claim Construction Memorandum Opinion and
`Order (E.D. Tex. Apr. 3, 2023) (Exhibit C to R2’s
`4-2 Disclosures)
`
`R2 reserves the right to rely on testimony from
`
`
`
`3
`
`

`

`Case 4:23-cv-01147-ALM Document 51-1 Filed 09/13/24 Page 5 of 7 PageID #: 1565
`
`EXHIBIT A – PLAINTIFF R2 SOLUTIONS LLC’S PROPOSED CONSTRUCTIONS AND SUPPORT
`
`Disputed Term/Phrase
`
`Plaintiff’s Proposed Construction
`
`“providing each data partition
`to a selected one of a plurality
`of mapping functions”
`(Claims 1, 17)
`
`R2 Solutions contends that this term needs no
`construction and should be afforded its plain and
`ordinary meaning.
`
`
`“[processing] / [process] the
`intermediate data for each data
`group in a manner that is
`defined to correspond to that
`
`R2 Solutions contends that this phrase needs no
`construction and should be afforded its plain and
`ordinary meaning. See also the proposed construction
`for “data group.”
`
`
`
`4
`
`Plaintiff’s Support
`Bill Davis in response to any expert evidence
`relied on by Defendant.
`
`All evidence identified by any other party
`
`’610 patent at Abstract; 2:1-42; 3:48-57; 6:18-35;
`7:36-8:58; FIG. 1 (and related text); FIG. 2 (and
`related text); FIG. 3 (and related text); FIG. 4 (and
`related text); FIG. 5 (and related text)
`
`R2 Solutions LLC v. Walmart Inc., Civil Action
`No. 4:21-CV-00091-ALM, Dkt. No. 54, Claim
`Construction Memorandum Opinion and Order
`(E.D. Tex. Jan. 4, 2022) (Exhibit B to R2’s 4-2
`Disclosures)
`
`R2 Solutions LLC v. American Airlines Inc., Civil
`Action No. 4:22-CV-00353-ALM, Dkt. No. 58,
`Claim Construction Memorandum Opinion and
`Order (E.D. Tex. Apr. 3, 2023) (Exhibit C to R2’s
`4-2 Disclosures)
`
`R2 reserves the right to rely on testimony from
`Bill Davis in response to any expert evidence
`relied on by Defendant.
`
`All evidence identified by any other party
`
`’610 patent at Abstract; 4:4-59; 5:40-6:17; 6:18-
`7:35; 7:61-8:14; FIG. 3 (and related text); FIG. 4
`(and related text); FIG. 5 (and related text)
`
`
`

`

`Case 4:23-cv-01147-ALM Document 51-1 Filed 09/13/24 Page 6 of 7 PageID #: 1566
`
`EXHIBIT A – PLAINTIFF R2 SOLUTIONS LLC’S PROPOSED CONSTRUCTIONS AND SUPPORT
`
`Disputed Term/Phrase
`data group”
`(Claims 1, 5, 17, 21)
`
`Plaintiff’s Proposed Construction
`
`“schema” (Claims 1, 17)
`
`R2 Solutions contends that this term needs no
`construction and should be afforded its plain and
`ordinary meaning.
`
`
`
`
`5
`
`Plaintiff’s Support
`R2 Solutions LLC v. Walmart Inc., Civil Action
`No. 4:21-CV-00091-ALM, Dkt. No. 54, Claim
`Construction Memorandum Opinion and Order
`(E.D. Tex. Jan. 4, 2022) (Exhibit B to R2’s 4-2
`Disclosures)
`
`R2 Solutions LLC v. American Airlines Inc., Civil
`Action No. 4:22-CV-00353-ALM, Dkt. No. 58,
`Claim Construction Memorandum Opinion and
`Order (E.D. Tex. Apr. 3, 2023) (Exhibit C to R2’s
`4-2 Disclosures)
`
`R2 reserves the right to rely on testimony from
`Bill Davis in response to any expert evidence
`relied on by Defendant.
`
`All evidence identified by any other party
`
`’610 patent at 3:19-4:3; 6:8-17; 8:46-58; FIG. 3
`(and related text); FIG. 4 (and related text); FIG. 5
`(and related text)
`
`R2 Solutions LLC v. Walmart Inc., Civil Action
`No. 4:21-CV-00091-ALM, Dkt. No. 54, Claim
`Construction Memorandum Opinion and Order
`(E.D. Tex. Jan. 4, 2022) (Exhibit B to R2’s 4-2
`Disclosures)
`
`R2 Solutions LLC v. American Airlines Inc., Civil
`Action No. 4:22-CV-00353-ALM, Dkt. No. 58,
`Claim Construction Memorandum Opinion and
`Order (E.D. Tex. Apr. 3, 2023) (Exhibit C to R2’s
`
`

`

`Case 4:23-cv-01147-ALM Document 51-1 Filed 09/13/24 Page 7 of 7 PageID #: 1567
`
`EXHIBIT A – PLAINTIFF R2 SOLUTIONS LLC’S PROPOSED CONSTRUCTIONS AND SUPPORT
`
`Disputed Term/Phrase
`
`Plaintiff’s Proposed Construction
`
`“the different schema and
`corresponding different
`intermediate data have a key in
`common” (Claims 1, 17)
`
`R2 Solutions contends that this phrase needs no
`construction and should be afforded its plain and
`ordinary meaning.
`
`
`
`
`
`
`6
`
`Plaintiff’s Support
`4-2 Disclosures)
`
`R2 reserves the right to rely on testimony from
`Bill Davis in response to any expert evidence
`relied on by Defendant.
`
`All evidence identified by any other party
`’610 patent at Abstract; 1:31-45; 1:66-2:8; 8:46-
`58; FIG. 3 (and related text); FIG. 4 (and related
`text); FIG. 5 (and related text)
`
`R2 Solutions LLC v. Walmart Inc., Civil Action
`No. 4:21-CV-00091-ALM, Dkt. No. 54, Claim
`Construction Memorandum Opinion and Order
`(E.D. Tex. Jan. 4, 2022) (Exhibit B to R2’s 4-2
`Disclosures)
`
`R2 Solutions LLC v. American Airlines Inc., Civil
`Action No. 4:22-CV-00353-ALM, Dkt. No. 58,
`Claim Construction Memorandum Opinion and
`Order (E.D. Tex. Apr. 3, 2023) (Exhibit C to R2’s
`4-2 Disclosures)
`
`R2 reserves the right to rely on testimony from
`Bill Davis in response to any expert evidence
`relied on by Defendant.
`
`All evidence identified by any other party
`
`
`