`Case 6:20-cv-00636—ADA Document 87-3 Filed 03/29/21 Page 1 of 3
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`EXHIBIT 24
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`EXHIBIT 24
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`
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`Case 6:20-cv-00636-ADA Document 87-3 Filed 03/29/21 Page 2 of 3
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`From:
`To:
`Cc:
`
`Subject:
`Date:
`
`Rumpler, Joseph
`Wells, Maclain
`Hattenbach, Ben; Zhong, Annita; Chu, Morgan (Internet); Ou, Philip; Soobert, Allan M.; Chaikovsky, Yar R.;
`Milvenan, Rick; Barton, Travis; Schnell, Austin; Nash, Brian C.; Steve Ravel; sonal.mehta_wilmerhale.com;
`Specht, Claire; "Cosmin Maier"
`Demaray v. Intel/Samsung -- claim construction of "narrow band rejection filter"
`Thursday, March 18, 2021 6:59:00 PM
`
`Maclain,
`
`In an effort to narrow or resolve the parties’ dispute on claim construction for the term “narrow
`band rejection filter” and the longer phrases including the term, Defendants amend their proposed
`construction of “narrow band rejection filter” from (changes annotated in red):
`
`
`“filter which rejects a narrow band of frequencies and passes all frequencies outside of the
`narrow band”
`
`to
`
`“filter which rejects a narrow band of frequencies (but passes all frequencies outside of the
`narrow band)”
`
`
`While we do not believe it necessary considering, for example, Dr. Glew’s testimony as to how a
`POSITA would understand “all” in the context of Dr. Demaray’s declaration to the PTO and in our
`construction (see, e.g., Glew Tr. 230:17-233:11), to the extent it facilitates agreement on a
`construction, we would also not oppose including “substantially” into the proposed construction:
`
`
`“filter which rejects a narrow band of frequencies (but passes substantially all frequencies
`outside of the narrow band)”
`
`
`Please let us know if either of these modifications eliminate the dispute and you can agree to our
`proposal. We are available to discuss tomorrow if helpful.
`
`One additional alternative we would also be willing to agree to is amending your construction from
`(changes annotated in red):
`
`
`“filter which rejects a narrow band of frequencies”
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`to
`
`“filter which rejects a narrow band of frequencies centered on one RF bias frequency”
`
`
`We believe this is well supported by the specification and intrinsic record, including Dr. Demaray’s
`declaration made to the PTO and the patentee’s subsequent statements. This would also remove
`the dispute you have raised in your opening brief regarding what the filter “passes.”
`
`If we can agree on any of the proposals above, we would also agree that the Court need not
`
`
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`Case 6:20-cv-00636-ADA Document 87-3 Filed 03/29/21 Page 3 of 3
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`construe the longer phrases including this term.
`
`Understanding the current deadline for your reply brief is tomorrow, if you would like additional
`time to consider these alternative proposals, confer and see if we can agree on this term, we would
`not oppose extending your deadline to submit your reply to over the weekend.
`
`If you’d like to discuss, or have other alternatives for the parties to consider so that we may reach
`agreement on these terms in view of the arguments made in briefing so far, please let us know.
`
`Thanks,
`Joe
`
`
`
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