Case 4:23-cv-01147-ALM Document 69-1 Filed 11/22/24 Page 1 of 12 PageID #:
`
`4901
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`Court’s Construction
`
`
`
`I.
`
`
`#
`
`U.S. Pat. No. 8,190,610
`
`Claim Term, Phrase, or Clause
`
`1 Term for Construction: “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 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
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning.
`Not subject to 35 U.S.C. § 112,
`¶ 6 and not indefinite. See also
`the proposed constructions for
`“data group” and “a plurality of
`mapping functions that are each
`user-configurable.”
`
`Defendant’s Proposed
`Construction
`Governed by pre-AIA 35
`U.S.C. § 112, ¶ 6.
`
`Function: “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
`
`
`
`1
`
`
`
`4901
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`Court’s Construction
`
`
`
`I.
`
`
`#
`
`U.S. Pat. No. 8,190,610
`
`Claim Term, Phrase, or Clause
`
`1 Term for Construction: “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 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
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning.
`Not subject to 35 U.S.C. § 112,
`¶ 6 and not indefinite. See also
`the proposed constructions for
`“data group” and “a plurality of
`mapping functions that are each
`user-configurable.”
`
`Defendant’s Proposed
`Construction
`Governed by pre-AIA 35
`U.S.C. § 112, ¶ 6.
`
`Function: “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
`
`
`
`1
`
`
`
`Case 4:23-cv-01147-ALM Document 69-1 Filed 11/22/24 Page 2 of 12 PageID #:
`
`4902
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`#
`
`Claim Term, Phrase, or Clause
`
`Plaintiff’s Proposed
`Construction
`
`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)
`
`Complete Claim Language:
`
`17[pre] A computer system including a
`plurality of computing devices, the computer
`system configured to process data of a data set,
`wherein the data set comprises a plurality of
`data groups, the computer system comprises at
`least one 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
`
`
`
`2
`
`Court’s Construction
`
`Defendant’s Proposed
`Construction
`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
`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”
`
`Structure: Indefinite.
`
`
`
`Case 4:23-cv-01147-ALM Document 69-1 Filed 11/22/24 Page 3 of 12 PageID #:
`
`4903
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`Plaintiff’s Proposed
`Construction
`
`Defendant’s Proposed
`Construction
`
`Court’s Construction
`
`Plain and ordinary meaning.
`
`“[processing] / [process] /
`[processed] key/value pairs
`to generate intermediate
`key/value pairs”
`
`
`
`#
`
`Claim Term, Phrase, or Clause
`
`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
`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.
`
`2 Term for Construction: “mapping” / “map” /
`“mapped” (Claims 1, 17)
`
`Example Claim Language:
`
`[. . .]
`
`1[a] 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
`
`
`
`3
`
`
`
`Case 4:23-cv-01147-ALM Document 69-1 Filed 11/22/24 Page 4 of 12 PageID #:
`
`4904
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`#
`
`Claim Term, Phrase, or Clause
`
`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,
`
`1[b] 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 corresponding different intermediate data
`have a key in common; and
`
`[. . .]
`
`1[d] wherein the mapping and reducing
`operations are performed by a distributed
`system
`
`3 Term for Construction: “reducing” / “reduce”
`(Claims 1, 17)
`
`Example Claim Language:
`
`[. . .]
`
`Plaintiff’s Proposed
`Construction
`
`Defendant’s Proposed
`Construction
`
`Court’s Construction
`
`Plain and ordinary meaning.
`
`
`
`“[merging] / [merge]1 all
`intermediate data values
`sharing the same key into a
`single key-value pair or a
`list of values associated
`with the key”
`
`
`1 In response to R2’s Opening Brief, Databricks amended its proposed construction by replacing “combining/combine” with
`“merging/merge.” (Dkt. 62 at 21-22.)
`
`
`
`4
`
`
`
`Case 4:23-cv-01147-ALM Document 69-1 Filed 11/22/24 Page 5 of 12 PageID #:
`
`4905
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`#
`
`Claim Term, Phrase, or Clause
`
`Plaintiff’s Proposed
`Construction
`
`Defendant’s Proposed
`Construction
`
`Court’s Construction
`
`
`1[c] reducing 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
`
`[. . .]
`
`1[d] wherein the mapping and reducing
`operations are performed by a distributed
`system
`
`[. . .]
`
`17[c] 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.
`
`4 Term for Construction: “providing each data
`partition to a selected one of a plurality of
`mapping functions” (Claims 1, 17)
`
`Example Claim Language:
`
`Plain and ordinary meaning.
`
`“providing each data
`partition to one of a
`plurality of different
`mapping functions where
`
`
`
`
`
`5
`
`
`
`Case 4:23-cv-01147-ALM Document 69-1 Filed 11/22/24 Page 6 of 12 PageID #:
`
`4906
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`#
`
`Claim Term, Phrase, or Clause
`
`
`[. . .]
`
`1[a] 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,
`
`[. . .]
`
`5 Term for Construction: “[processing] /
`[process] the intermediate data for each data
`group in a manner that is defined to correspond
`to that data group” (Claims 1, 5, 17, 21)
`
`Example Claim Language:
`
`[. . .]
`
`1[c] reducing the intermediate data for the data
`groups to at least one output data group,
`
`Plaintiff’s Proposed
`Construction
`
`Defendant’s Proposed
`Construction
`each2 mapping function is
`selected for a partition
`based on the data group the
`partition originated from”
`
`Court’s Construction
`
`Plain and ordinary meaning.
`
`
`
`“[processing] / [process] the
`intermediate data for each
`data group in a manner that
`is defined to correspond to
`the data group from which
`the intermediate data
`originated”
`
`
`2 In response to R2’s Opening Brief, Databricks amended its proposed construction by replacing “the” with “each.” (Dkt. 62 at 22-26.)
`
`
`
`6
`
`
`
`Case 4:23-cv-01147-ALM Document 69-1 Filed 11/22/24 Page 7 of 12 PageID #:
`
`4907
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`#
`
`Claim Term, Phrase, or Clause
`
`Plaintiff’s Proposed
`Construction
`
`Defendant’s Proposed
`Construction
`
`Court’s Construction
`
`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
`
`[. . .]
`
`17[c] 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
`
`[. . .]
`
`21 the at least one processor and memory being
`configured to process the intermediate data
`for each data group in a manner that is
`defined to correspond to that data group
`includes, for each data group, the at least one
`processor and memory being configured to
`employ an iterator that corresponds to that data
`group.
`
`
`
`
`7
`
`
`
`Case 4:23-cv-01147-ALM Document 69-1 Filed 11/22/24 Page 8 of 12 PageID #:
`
`4908
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`#
`
`Claim Term, Phrase, or Clause
`
`6 Term for Construction: “schema” (Claims 1,
`17)
`
`Example Claim Language:
`
`[. . .]
`
`1[b] 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 corresponding different intermediate data
`have a key in common; and
`
`[. . .]
`
`7 Term for Construction: “the different schema
`and corresponding different intermediate data
`have a key in common” (Claims 1, 17)
`
`Example Claim Language:
`
`[. . .]
`
`1[b] 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
`
`Plaintiff’s Proposed
`Construction
`Plain and ordinary meaning.
`
`Court’s Construction
`
`
`
`Defendant’s Proposed
`Construction
`“a set of attributes (such as
`DeptID, LastName,
`DeptName) and their
`properties (such as their
`data types: integer DeptID,
`string LastName, string
`DeptName)”
`
`
`
`
`
`
`
`
`[AGREED]
`
`[AGREED]
`
`“the different data group
`schemas have a key in
`common with the
`corresponding different
`intermediate data”
`
`
`
`
`8
`
`
`
`Case 4:23-cv-01147-ALM Document 69-1 Filed 11/22/24 Page 9 of 12 PageID #:
`
`4909
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`#
`
`Claim Term, Phrase, or Clause
`
`Plaintiff’s Proposed
`Construction
`
`Defendant’s Proposed
`Construction
`
`Court’s Construction
`
`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 corresponding different
`intermediate data have a key in common;
`
`[. . .]
`
`8 Term for Construction: “A method of
`processing data of a data set over a distributed
`system, wherein the data set comprises a
`plurality of data groups, the method
`comprising:” (Claim 1)
`
`Example Claim Language:
`
`1[pre] A method of processing data of a data
`set over a distributed system, wherein the
`data set comprises a plurality of data groups,
`the method comprising:
`
`[. . .]
`
`9 Term for Construction: “A computer system
`including a plurality of computing devices, the
`computer system configured to process data of a
`data set, wherein the data set comprises a
`plurality of data groups, the computer system
`comprises at least one processor and memory
`
`[AGREED]
`
`[AGREED]
`
`Limiting preamble in Claim 1.
`
`[AGREED]
`
`[AGREED]
`
`Limiting preamble in Claim
`17.
`
`
`
`9
`
`
`
`Case 4:23-cv-01147-ALM Document 69-1 Filed 11/22/24 Page 10 of 12 PageID #:
`
`4910
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`#
`
`Claim Term, Phrase, or Clause
`
`Plaintiff’s Proposed
`Construction
`
`Defendant’s Proposed
`Construction
`
`Court’s Construction
`
`that are operable to perform the following
`operations:” (Claim 1)
`
`Example Claim Language:
`
`17[pre] A computer system including a
`plurality of computing devices, the computer
`system configured to process data of a data
`set, wherein the data set comprises a
`plurality of data groups, the computer
`system comprises at least one processor and
`memory that are operable to perform the
`following operations:
`
`[. . .]
`
`10 Term for Construction: “data group” (Claims
`1-5, 17-21)
`
`Example Claim Language:
`
`1[pre] A method of processing data of a data set
`over a distributed system, wherein the data set
`comprises a plurality of data groups, the
`method comprising:
`
`[. . .]
`
`1[a] partitioning the data of each one of the
`data groups into a plurality of data partitions
`
`[AGREED]
`
`[AGREED]
`
`“a group of data and a
`mechanism for identifying
`data from that group”
`
`
`
`10
`
`
`
`Case 4:23-cv-01147-ALM Document 69-1 Filed 11/22/24 Page 11 of 12 PageID #:
`
`4911
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`Plaintiff’s Proposed
`Construction
`
`Defendant’s Proposed
`Construction
`
`Court’s Construction
`
`[AGREED]
`
`[AGREED]
`
`“two or more mapping
`functions that are each
`configurable by a user”
`
`#
`
`Claim Term, Phrase, or Clause
`
`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,
`
`[. . .]
`
`11 Term for Construction: “plurality of mapping
`functions that are each user-configurable”
`(Claims 1, 17)
`
`Example Claim Language:
`
`[. . .]
`
`1[a] 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
`
`
`
`11
`
`
`
`Case 4:23-cv-01147-ALM Document 69-1 Filed 11/22/24 Page 12 of 12 PageID #:
`
`4912
`EXHIBIT A - P.R. 4-5(d) CLAIM CONSTRUCTION CHART
`
`#
`
`Claim Term, Phrase, or Clause
`
`group and identifiable to that data group,
`
`[. . .]
`
`
`Plaintiff’s Proposed
`Construction
`
`Defendant’s Proposed
`Construction
`
`Court’s Construction
`
`
`
`
`
`12
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
