`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`Civil Action No. 4:23-cv-01147-ALM
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`Jury Trial Demanded
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`JOINT CLAIM CONSTRUCTION CHART PURSUANT TO P.R. 4-5(d)
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`Pursuant to P.R. 4-5(d) and the Court’s Scheduling Order, Plaintiff and Defendant
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`R2 Solutions LLC,
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` Plaintiff,
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`v.
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`Databricks, Inc.,
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` Defendant.
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`(collectively, the “Parties”) jointly file the Claim Construction Chart attached hereto as
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`Exhibit A addressing terms for construction in this case. The Parties will continue to meet and
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`confer in advance of the claim construction hearing and will provide the Court with an updated
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`list to the extent agreements are reached.
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`Dated: November 22, 2024
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`/s/ Edward R. Nelson III
`Edward R. Nelson III
`State Bar No. 00797142
`ed@nelbum.com
`Brent N. Bumgardner
`State Bar No. 00795272
`brent@nelbum.com
`Christopher G. Granaghan
`State Bar No. 24078585
`chris@nelbum.com
`Carder W. Brooks
`State Bar No. 24110604
`carder@nelbum.com
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`NELSON BUMGARDNER CONROY PC
`3131 West 7th Street, Suite 300
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`
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`Respectfully submitted,
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`/s/ Vigen Salmastlian
`Michael J. Sacksteder (Admitted E.D. Texas)
`FENWICK & WEST LLP
`555 California Street, 12th Floor
`San Francisco, California 94104
`Telephone: 415.875.2300
`Facsimile: 415.281.1350
`Email: msacksteder@fenwick.com
`
`Vigen Salmastlian
`CA Bar No. 276846 (Admitted E.D. Texas)
`Email: vsalmastlian@fenwick.com
`FENWICK & WEST LLP
`801 California Street,
`Mountain View, CA 94041
`Telephone:
`650.988.8500
`
`
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`Case 4:23-cv-01147-ALM Document 69 Filed 11/22/24 Page 2 of 2 PageID #: 4900
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`Fort Worth, Texas 76107
`817.377.9111
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`COUNSEL FOR
`PLAINTIFF R2 SOLUTIONS LLC
`
`Dargaye Churnet
`CA Bar No. 303659 (Admitted E.D. Texas)
`Email: dchurnet@fenwick.com
`FENWICK & WEST LLP
`730 Arizona Avenue, 1st Floor
`Santa Monica, CA 90401
`Telephone: 310.434.5400
`Facsimile: 650.938.5200
`
`Jessica M. Kaempf (Admitted E.D. Texas)
`FENWICK & WEST LLP
`401 Union Street, 5th Floor
`Seattle, WA 98101
`Telephone: 206.389.4510
`Facsimile: 206.389.4511
`Email: jkaempf@fenwick.com
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`ATTORNEYS FOR DEFENDANT
`DATABRICKS INC.
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`
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`CERTIFICATE OF SERVICE
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`I hereby certify that on November 22, 2024, I electronically filed the foregoing
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`
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`instrument with the Clerk of the Court using the CM/ECF system, which will send notification of
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`such filing to all counsel of record.
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`
`
`/s/ Edward R. Nelson III
`
`2
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`

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