Case 4:23-cv-01147-ALM Document 66-1 Filed 11/19/24 Page 1 of 4 PageID #:
`4890
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`Exhibit A
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`Case 4:23-cv-01147-ALM Document 66-1 Filed 11/19/24 Page 2 of 4 PageID #:
`4891
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`Carder Brooks
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`From:
`Sent:
`To:
`Cc:
`Subject:
`
`Emma,
`
`Carder Brooks
`Thursday, November 14, 2024 2:30 PM
`Emma Lee; DG-R2Solutions
`R2 V Databricks
`RE: R2 v Databricks -- Proposed Comprise Construction
`
`We cannot agree to that construction. The inclusion of the additional language seems unrelated to the
`parenthetical, it improperly narrows the meaning of the term to require "organization of data" according to the
`attributes (whatever that means), and it doesn't seem to be technically correct in the context of the patent. As we
`said before, R2 would agree to the construction "a set of attributes."
`
`Thanks,
`
`Carder W. Brooks I Attorney I 817.806.3814
`Nelson Bumgardner Conroy PC I 3131 W. 7th Street, Suite 300 I Fort Worth, TX 76107
`carder@nelbum.com I www.nelbum.com
`
`nelson bumgardnerconroy
`
`This message and any attached documents contain information from the law firm of Nelson Bumgardner Conroy PC that
`may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this
`information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
`delete the message and its attachments.
`
`From: Emma Lee <Emma.Lee@fenwick.com>
`Sent: Wednesday, November 13, 2024 2:20 PM
`To: Carder Brooks <carder@nelbum.com>; DG-R2Solutions <R2Solutions@nelbum.com>
`Cc: R2 V Data bricks <R2vDatabricks@fenwick.com>
`Subject: RE: R2 v Databricks -- Proposed Comprise Construction
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`Carder,
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`We are amenable to dropping the parenthetical for "schema" if R2 agrees to construe the term as "organization of data
`according to a set of attributes." Please let us know if this works for R2.
`
`Additionally, as explained in our responsive claim construction brief, Data bricks updated the following proposed
`constructions in response to arguments raised in R2's opening brief and in an effort to minimize the disputes for the
`Court:
`
`Term
`"reducing"/ "reduce"
`
`Original Proposed Construction
`"[combining]/ [combine] all
`intermediate data values sharing
`
`Amended Proposed Construction
`"[merging]/ [merge] all
`intermediate data values sharing
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`
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`Case 4:23-cv-01147-ALM Document 66-1 Filed 11/19/24 Page 3 of 4 PageID #:
`4892
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`"providing each data partition
`to a selected one of a plurality
`of mapping functions"
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`the same key into a single key-
`value pair or a list of values
`associated with the key"
`"providing each data partition to
`one of a plurality of different
`mapping functions where the
`mapping function is selected for a
`partition based on the data group
`the partition originated from"
`
`the same key into a single key-
`value pair or a list of values
`associated with the key"
`" providing each data partition to
`one of a plurality of different
`mapping functions where each
`mapping function is selected for a
`partition based on the data group
`the partition originated from"
`
`Best,
`S. Emma Lee (she/her)
`Fenwick I Associate I +1415-875-2007 I emma.lee@fenwick.com
`
`From: Carder Brooks <carder@nelbum .com >
`Sent: Monday, November 4, 2024 9:58 AM
`To: Emma Lee <Emma.Lee@fenwick.com >; DG-R2Solutions <R2Solutions@nelbum.com>
`Cc: R2 V Data bricks <R2vDatabricks@fenwick.com >
`Subject: RE: R2 v Databricks -- Proposed Comprise Construction
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`** EXTERNAL EMAIL **
`Emma,
`
`R2 would agree to the construction "a set of attributes," but not to a construction that includes the parenthetical. Let
`us know if that works for Databricks.
`
`Thanks,
`
`Carder W. Brooks I Attorney I 817.806.3814
`Nelson Bumgardner Conroy PC I 3131 W. 7th Street, Suite 300 I Fort Worth, TX 76107
`carder@nelbum.com I www.nelbum.com
`
`nelson bumgardnerconra;
`
`This message and any attached documents contain information from the law firm of Nelson Bumgardner Conroy PC that
`may be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or use this
`information. If you have received this transmission in error, please notify the sender immediately by reply e-mail and then
`delete the message and its attachments.
`
`From: Emma Lee <Emma.Lee@fenwick.com >
`Sent: Friday, November 1, 2024 4:05 PM
`To: DG-R2Solutions <R2Solutions@nelbum .com >
`Cc: R2 V Data bricks <R2vDatabricks@fenwick.com >
`Subject: R2 v Databricks -- Proposed Comprise Construction
`
`Counsel-
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`2
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`
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`Case 4:23-cv-01147-ALM Document 66-1 Filed 11/19/24 Page 4 of 4 PageID #:
`4893
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`Upon review of R2 Solutions' opening claim construction brief, Data bricks proposes the following compromise
`construction for the term "schema" in effort to resolve the dispute. Please let us know if R2 will agree to this proposal.
`Data bricks reserves the right to proceed with its original proposed construction if R2 does not agree.
`
`Term
`
`"schema"
`
`Original Proposed Construction
`"a set of attributes (such as DeptlD,
`LastName, DeptName) and their
`properties (such as their data types:
`integer DeptlD, string LasName, string
`DeptName)"
`
`New Proposed Construction
`"a set of attributes (such as DeptlD,
`LastName, DeptName)"
`
`Best,
`S. Emma Lee (she/her)
`Fenwick I Associate I +1415-875-2007 I emma .lee@fenwick.com
`
`3
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