Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 1 of 19
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`Case No.: 6:21-cv-00755-ADA
`
`JURY TRIAL DEMANDED
`
`Plaintiffs,
`
`Involuntary Plaintiff,
`
`
`
`
`
`v.
`
`
`
`
`
`
`
`GENTEX CORPORATION and INDIGO
`TECHNOLOGIES, LLC,
`
`
`
`THALES VISIONIX, INC.,
`
`
`
`
`
`META PLATFORMS, INC. and
`FACEBOOK TECHNOLOGIES, LLC,
`
`
`
`
`
`
`Defendants.
`
`JOINT CLAIM CONSTRUCTION STATEMENT
`Pursuant to the Court’s Scheduling Order, ECF No. 27 as amended by ECF No. 37,
`
`Plaintiffs Gentex Corporation and Indigo Technologies, LLC (collectively, “Plaintiffs”) and
`
`Defendants Meta Platforms, Inc. and Facebook Technologies, LLC1 (collectively, “Defendants”)
`
`submit this Joint Claim Construction Statement. The claim terms identified below as being in
`
`dispute are found in United States Patent Nos. 6,757,068 (the “’068 patent”), 7,301,648 (the
`
`“’648 patent”), 8,224,024 (the “’024 patent”), 6,922,632 (the “’632 patent”), and 7,725,253 (the
`
`“’253 patent”). The patents fall into three families: the ’068 and ’648 Patents (“Family One”),
`
`the ’632 and ’253 Patents (“Family Two”), and the ’024 Patent (“Family Three”). There are no
`
`claim terms on which the parties agree as to construction.
`
`
`1 Effective March 18, 2022, Facebook Technologies, LLC is now known as Meta Platforms
`Technologies, LLC. An Unopposed Motion to Correct Docket was submitted on April 13, 2022.
`See ECF No. 50.
`
`1
`
`

`

`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 2 of 19
`
`
`
`I.
`
`LIST OF DISPUTED CLAIM TERMS
`
`A.
`
`Family One Patent Constructions
`
`Patent and Claims
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`Plain and ordinary meaning, in light of the claims and
`specification—i.e., for “sourceless orientation
`tracker,” an orientation tracker that does not require
`setup of a fixed source that propagates a signal to the
`tracked sensor; and for “sourceless measurement,” a
`measurement from a sourceless sensor3
`
`Plain and ordinary meaning, in light of the claims and
`specification—i.e., track a position of a first part of a
`limb of a user, or an object or part of an object
`associated with a limb of the user
`
`Plain and ordinary meaning, in light of the claim and
`specification
`
`Term
`(Proposed by Defendants unless
`otherwise indicated)
`
`1 Defendants: “sourceless”
`
`
`Plaintiffs: “sourceless orientation
`tracker” / “sourceless
`measurement”
`
`“can be used anywhere with no set-up of a source”2
`
`’068 Patent, claims
`1, 11-13, 50, 54
`
`’648 Patent, claims
`1, 16, 40, 41
`
`2 Defendants: “track a position of a first
`localized feature”
`
`’068 Patent, claims
`1, 54-55
`
`Indefinite
`
`
`Plaintiffs: “track a position of a first
`localized feature associated
`with a limb of the user”
`
`3 “redisplaying the first object at a
`second position on the display device
`determined based on the change in the
`position of the first localized feature”
`
`’648 Patent, claim 1
`
`’068 Patent, claim 26 Indefinite
`
`4 “system”
`
`Proposed by Plaintiffs
`
`’068 Patent, claim 56 The word “system” should be given its plain and
`ordinary meaning.
`
`
`“method”
`
`
`2 Defendants object to Plaintiffs’ inclusion of the construction for “sourceless measurement” as “a measurement from a sourceless sensor.” Plaintiffs did not propose this
`construction in Plaintiffs’ February 14, 2022 Identification of Revised Initial Terms and Constructions or March 21, 2022 Opening Claim Construction Brief.
`3 Plaintiffs respond that their opening brief stated, “A ‘sourceless measurement’ is simply a measurement from a sourceless sensor.” Pls.’ Br. 4.
`
`2
`
`

`

`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 3 of 19
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`
`
`
`
`
`Term
`(Proposed by Defendants unless
`otherwise indicated)
`
`Patent and Claims
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`The claim is indefinite, including at least as a mixed
`method and apparatus claim.
`
`5 “a body stabilized information cockpit” ’648 Patent, claim 20 “a display at a fixed location on an information
`surround, which is a kind of cylindrical or spherical
`bubble of information that follows the user’s body
`position around”
`
`Plain and ordinary meaning, in light of the claim and
`specification—i.e., an information cockpit displayed
`at a fixed location relative to a user’s body
`
`
`
`3
`
`

`

`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 4 of 19
`
`
`
`B.
`
`Family Two Patent Constructions
`
`Term
`(All Proposed by Defendants)
`
`6 Plaintiffs:
`“expected sensor measurement” (’632 patent, claims 3, 11-12, 30, 32)
`“expected measurement” (’632 patent, claim 14)
`“expected utility of a measurement” (’632 patent, claims 21, 33-34)4
`“highest expected utility of a measurement” (’253 patent, claim 7)
`
`
`Defendants: “expected” / “highest expected”
`
`7 Plaintiffs:
`“state estimate characterizes an estimate of a location of the object”
`(’632 patent, claim 5)
`“state estimate characterizes configuration information for one or more
`sensing elements fixed to the object” (’632 patent, claim 6)
`“information characterizing a relative location of said sensing elements”
`(’632 patent, claim 13)
`“mapping . . . characterizes a linear mapping”(’632 patent, claim 17)
`“information characterizing [an/the] uncertainty in the actual
`measurement”(’632 patent, claims 18-19)
`“information characterizing a type of a sensor” (’632 patent, claim 59)
`“information characterizing a position or an orientation of a sensor”
`(’632 patent, claim 60)
`“information characterizing one or more calibration parameters of a
`sensor” (’632 patent, claim 61)
`
`
`Defendants: “characterizes” / “characterizing”
`
`Patent and
`Claims
`
`’632 patent,
`claims 3, 11-12,
`14, 21, 30, 32-34
`
`’253 patent,
`claim 7
`
`’632 patent,
`claims 5-6, 13,
`17-19, 59-61
`
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`Indefinite
`
`Plain and ordinary meaning, in light of the claims
`and specification
`
`Indefinite
`
`Plain and ordinary meaning, in light of the claims
`and specification
`
`
`4 This includes the disputed term “generating a sequence of candidates of pairs of sensing elements selected from the set of sensing elements, the sequence based on an expected
`utility of a measurement associated with said elements to the estimation subsystem” as used in ’632 patent, claim 33.
`
`4
`
`

`

`
`
`
`
`Term
`(All Proposed
`by Defendants)
`8
`“estimation
`module”
`
`Patent
`and
`Claims
`’632
`patent,
`claims
`47-52,
`62-65,
`68-69
`
`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 5 of 19
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`Means-plus-function under § 112, ¶ 6.
`
`’632 patent, claims 47-52—Function: “maintaining
`estimates of tracking parameters in the estimation
`module, including repeatedly passing data based on the
`estimates of the tracking parameters from the
`estimation module to one or more of the sensor
`modules, receiving from said one or more sensor
`modules at the estimation module data based on
`measurements obtained from the associated sensors,
`and the data passed to the sensor modules, and
`combining the data received from said one or more
`sensor modules and the estimates of the tracking
`parameters in the estimation module to update the
`tracking parameters”
`
`Structure: Indefinite
`
`Plain and ordinary meaning, in light of the claims and specification—i.e., “module that
`accepts sensor configuration and measurement information and updates a state estimate
`using some or all of that information.” (35 U.S.C. § 112, ¶ 6 does not apply.)
`
`Alternatively, if 35 U.S.C. § 112, ¶ 6 applies:
`
`’632 patent, claims 47-52—Function: “maintaining estimates of tracking parameters”
`
`Structure: “accepting configuration information from each of the sensor modules
`regarding the characteristics of the sensors associated with the sensor module, configuring
`the estimation module using the provided configuration information, and repeatedly
`(a) passing data based on the estimates of the tracking parameters to one or more of the
`sensor modules, (b) receiving from said one or more sensor modules data based on
`measurements obtained from the associated sensors, and the data passed to the sensor
`modules, and (c) combining the data received from said one or more sensor modules and
`the estimates of the tracking parameters to update the tracking parameters.” In addition,
`claims 48-52 provide additional structural limitations as applicable to those claims.
`
`If additional structure is required: The portion of a navigation or tracking system that is
`specific to updating the states of the system, which processes information from sensing
`elements and updates the states using an iterative process, where the iterative process may
`be a stochastic model, such as a Kalman filter, a complementary extended Kalman filter,
`any of the other algorithms described at 6:60-7:14 and 10:40-11:9 of the specification, or
`equivalents. See, e.g., ’632 patent at 3:60-61, 6:60-7:14, 10:40-11:9, 20:6-19, 26:3-12.
`The structure associated with the estimation module and claimed functions further includes
`the portions of the specification regarding updating tracking parameters and providing them
`to the sensor modules, or any algorithm equivalent to this functionality. See, e.g., id. at
`13:47-64, 15:61-16:5, 17:5-16, 45:51-46:16.
`
`5
`
`

`

`
`
`Term
`(All Proposed
`by Defendants)
`
`Patent
`and
`Claims
`
`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 6 of 19
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`Alternatively, if 35 U.S.C. § 112, ¶ 6 applies:
`
`’632 patent, claims 62-65—Function: “estimating a pose of an object”
`
`Structure: “configuring the estimation module based on an enumeration of the set of
`sensing elements available to the tracking or navigation system, processing measurement
`information from either inside-out sensors, outside-in sensors, or a combination of inside-
`out and outside-in sensors depending on the sensors available, and repeatedly updating an
`estimated pose of an object based on measurements from the set of sensing elements
`available to the tracking or navigation system.” In addition, claims 63-65 provide
`additional structural limitations as applicable to those claims.
`
`If additional structure is required: The portion of a navigation or tracking system that is
`specific to updating the states of the system, which processes information from sensing
`elements and updates the states using an iterative process, where the iterative process may
`be a stochastic model, such as a Kalman filter, a complementary extended Kalman filter,
`any of the other algorithms described at 6:60-7:14 and 10:40-11:9 of the specification, or
`equivalents. See, e.g., ’632 patent at 3:60-61, 6:60-7:14, 10:40-11:9, 20:6-19, 26:3-12.
`
`The structure associated with the estimation module and claimed functions further includes
`the portions of the specification regarding enumerating sensing elements available to the
`navigation or tracking system, or equivalents. See, e.g., id. at 19:1-6, 19:20-25.
`
`
`’632 patent, claim 62—Function: “configuring an
`estimation module of the tracking or navigation system
`based on an enumeration of the set of sensing elements
`available to the tracking or navigation system so that
`the estimation module can process measurement
`information from either inside-out sensors, outside-in
`sensors, or a combination of inside-out and outside-in
`sensors depending on the sensors available”
`
`Structure: Indefinite
`’632 patent, claim 63—Function: “configuring the
`estimation module includes configuring the estimation
`module so that the estimation module can process
`measurement information from either inside-out
`sensors, outside-in sensors, range sensors, or any
`combination of the above sensors”
`
`Structure: Indefinite
`’632 patent, claim 64—Function: “configuring the
`estimation module includes configuring the estimation
`module so that the estimation module can process
`measurement information from either inside-out
`sensors, outside-in sensors, inertial sensors, or any
`combination of the above sensors”
`
`Structure: Indefinite
`’632 patent, claim 65—Function: “configuring the
`estimation module so that the estimation module can
`process measurement information from either inside-
`
`6
`
`

`

`
`
`Term
`(All Proposed
`by Defendants)
`
`Patent
`and
`Claims
`
`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 7 of 19
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`out sensors, outside-in sensors, dead reckoning sensors,
`or any combination of the above sensors”
`
`Structure: Indefinite
`’632 patent, claim 68—Function: “estimat[ing] a
`pose of an object based on measurement data from
`sensing elements” and “enabl[ing] selective
`performance of (a) receiving data from at least one
`inside-out bearing sensor, and updating an estimated
`pose of an object based on the data received from the
`inside-out bearing sensor, (b) receiving data from at
`least one outside-in bearing sensor, and updating an
`estimated pose of an object based on the data received
`from the outside-in bearing sensor, and (c) receiving
`data from at least one inside-out bearing sensor and at
`least one outside-in bearing sensor, and updating an
`estimated pose of an object based on the data received
`from the outside-in bearing sensor and the inside-out
`bearing sensor”
`
`Structure: Indefinite
`
`Alternatively, if 35 U.S.C. § 112, ¶ 6 applies:
`
`’632 patent, claim 68—Function: “estimating a pose of an object based on measurement
`data from sensing elements”
`
`Structure: “selectively performing (a) receiving data from at least one inside-out bearing
`sensor, and updating an estimated pose of an object based on the data received from the
`inside-out bearing sensor, (b) receiving data from at least one outside-in bearing sensor, and
`updating an estimated pose of an object based on the data received from the outside-in
`bearing sensor, and (c) receiving data from at least one inside-out bearing sensor and at
`least one outside-in bearing sensor, and updating an estimated pose of an object based on
`the data received from the outside-in bearing sensor and the inside-out bearing sensor.”
`
`If additional structure is required: The portion of a navigation or tracking system that is
`specific to updating the states of the system, which processes information from sensing
`elements and updates the states using an iterative process, where the iterative process may
`be a stochastic model, such as a Kalman filter, a complementary extended Kalman filter,
`any of the other algorithms described at 6:60-7:14 and 10:40-11:9 of the specification, or
`equivalents. See, e.g., ’632 patent at 3:60-61, 6:60-7:14, 10:40-11:9, 20:6-19, 26:3-12.
`
`The structure associated with the estimation module and claimed functions further includes
`the portions of the specification specific to updating a pose estimate for a tracked object, or
`equivalents. See, e.g., id. at 12:37-40, 16:59-64.
`
`
`7
`
`

`

`
`
`Term
`(All Proposed
`by Defendants)
`
`Patent
`and
`Claims
`
`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 8 of 19
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`’632 patent, claim 69—Function: “estimat[ing] a
`pose of an object based on measurement data from
`sensing elements” and “enabl[ing] selective
`performance of one of: (a) updating an estimate of the
`position or orientation of the object relative to an
`environment, (b) updating an estimate of the position
`or orientation, relative to the object, of at least one
`sensing element fixed to the object, and (c) updating an
`estimate of the position or orientation, relative to the
`environment, of at least one sensing element fixed in
`the environment”
`
`Structure: Indefinite
`
`9
`
`“estimation
`subsystem”
`
`’632
`patent,
`claims
`1-2, 4,
`14, 33
`
`
`Means-plus-function under § 112, ¶ 6.
`
`’253 patent, claims 1, 3—Function: “updat[ing] a
`location estimate for the object based on configuration
`
`Alternatively, if 35 U.S.C. § 112, ¶ 6 applies:
`
`’632 patent, claim 69—Function: “estimating a pose of an object based on measurement
`data from sensing elements”
`
`Structure: “selectively performing one of (a) updating an estimate of the position or
`orientation of the object relative to an environment, (b) updating an estimate of the position
`or orientation, relative to the object, of at least one sensing element fixed to the object, and
`(c) updating an estimate of the position or orientation, relative to the environment, of at
`least one sensing element fixed in the environment.”
`
`If additional structure is required: The portion of a navigation or tracking system that is
`specific to updating the states of the system, which processes information from sensing
`elements and updates the states using an iterative process, where the iterative process may
`be a stochastic model, such as a Kalman filter, a complementary extended Kalman filter,
`any of the other algorithms described at 6:60-7:14 and 10:40-11:9 of the specification, or
`equivalents. See, e.g., ’632 patent at 3:60-61, 6:60-7:14, 10:40-11:9, 20:6-19, 26:3-12.
`
`The structure associated with the estimation module and claimed functions further includes
`the portions of the specification specific to updating a pose estimate for a tracked object, or
`equivalents. See, e.g., id. at 12:37-40, 16:59-64.
`
`Plain and ordinary meaning, in light of the claims and specification—i.e., “subsystem that
`accepts sensor configuration and measurement information and updates a state estimate
`using some or all of that information.” (35 U.S.C. § 112, ¶ 6 does not apply.)
`
`Alternatively, if 35 U.S.C. § 112, ¶ 6 applies:
`
`
`8
`
`

`

`
`
`Term
`(All Proposed
`by Defendants)
`
`Patent
`and
`Claims
`
`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 9 of 19
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`
`’253
`patent,
`claims 1,
`3, 4, 6
`
`
`data and measurement information accepted from the
`sensor subsystem”
`
`Structure: Indefinite
`’253 patent, claim 4—Function: “perform[ing]
`computations independently of an implementation of
`the sensor modules”
`
`Structure: Indefinite
`
`’253 patent, claim 6—Function: “estimat[ing] a
`position or orientation of an object”
`
`
`’253 patent, claims 1, 3, and 4—Function: “updating a location estimate for the object”
`
`Structure: “accepting from the sensor subsystem configuration data and measurement
`information for localizing an object, and updating a location estimate for the object based
`on configuration data and measurement information accepted from the sensor subsystem.”
`In addition, claims 3 and 4 provide additional structural limitations as applicable to those
`claims.
`
`If additional structure is required:
`For ’253 patent, claims 1, 3, and 4: The portion of a navigation or tracking system that is
`specific to updating the states of the system, which processes information from sensing
`elements and updates the states using an iterative process, where the iterative process may
`be a stochastic model, such as a Kalman filter, a complementary extended Kalman filter,
`any of the other algorithms described at 6:60-7:14 and 10:40-11:9 of the specification, or
`equivalents. See, e.g., ’632 patent at 3:60-61, 6:60-7:14, 10:40-11:9, 20:6-19, 26:3-12.
`
`In addition, for ’253 patent, claim 1: The structure associated with the estimation
`subsystem and its claimed functions further includes the portions of the specification
`specific to updating a location estimate for a tracked object, or equivalents. See, e.g., id. at
`12:37-40, 16:59-64.
`
`In addition, for ’253 patent, claims 3-4: The structure associated with the estimation
`subsystem and its claimed functions further includes the portions of the specification
`regarding the sensor fusion core performing calculations independently of the specific
`implementation of sensor modules associated with sensing elements and vice versa, or
`equivalents. See, e.g., id. at 4:26-31, 16:38-44, 17:33-38.
`
`Alternatively, if 35 U.S.C. § 112, ¶ 6 applies:
`
`’253 patent, claim 6—Function: “estimating the position or orientation of the object”
`
`9
`
`

`

`
`
`Term
`(All Proposed
`by Defendants)
`
`Patent
`and
`Claims
`
`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 10 of 19
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`Structure: Indefinite
`
`’632 patent, claim 1, 2, and 4—Function: “accepting
`configuration data from the sensor subsystem” and
`“repeatedly updating a state estimate, including
`accepting measurement information from the sensor
`subsystem, and updating the state estimate according to
`the accepted configuration data and the accepted
`measurement data”
`
`Structure: Indefinite
`’632 patent, claim 14—Function: “calculat[ing] a
`difference between the actual measurement and the
`expected measurement”
`
`
`Structure: “accepting parameters specific to the enumerated sensing elements and
`estimating the position or orientation of the object based on the accepted parameters.”
`
`If additional structure is required: The portion of a navigation or tracking system that is
`specific to updating the states of the system, which processes information from sensing
`elements and updates the states using an iterative process, where the iterative process may
`be a stochastic model, such as a Kalman filter, a complementary extended Kalman filter,
`any of the other algorithms described at 6:60-7:14 and 10:40-11:9 of the specification, or
`equivalents. See, e.g., ’632 patent at 3:60-61, 6:60-7:14, 10:40-11:9, 20:6-19, 26:3-12.
`
`The structure associated with the estimation subsystem and its claimed functions further
`includes the portions of the specification regarding accepting parameters specific to
`enumerated sensing elements, see, e.g., id. at 18:34-38, 19:1-6, 19:20-25, and updating a
`location estimate for a tracked object based on these parameters, see, e.g., id. at 12:37-40,
`16:59-64, or equivalents.
`
`Alternatively, if 35 U.S.C. § 112, ¶ 6 applies:
`
`’632 patent, claims 1, 2, 4, and 14—Function: “providing or updating a state estimate for
`the object”
`
`Structure: “accepting configuration data from the sensor subsystem, configuring the
`estimation subsystem according to the accepted configuration data, accepting measurement
`information from the sensor subsystem, and providing or repeatedly updating the state
`estimate according to the accepted configuration data and the accepted measurement data.”
`In addition, claims 2, 4, and 14 provide additional structural limitations as applicable to
`those claims.
`
`If additional structure is required:
`
`10
`
`

`

`
`
`Term
`(All Proposed
`by Defendants)
`
`Patent
`and
`Claims
`
`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 11 of 19
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`
`Structure: Indefinite
`
`’632 patent, claim 33—Function: “estimat[ing] a
`position or orientation of an object”
`
`Structure: Indefinite
`
`For ’632 patent, claims 1, 2, 4, and 14: The portion of a navigation or tracking system
`that is specific to updating the states of the system, which processes information from
`sensing elements and updates the states using an iterative process, where the iterative
`process may be a stochastic model, such as a Kalman filter, a complementary extended
`Kalman filter, any of the other algorithms described at 6:60-7:14 and 10:40-11:9 of the
`specification, or equivalents. See, e.g., ’632 patent at 3:60-61, 6:60-7:14, 10:40-11:9, 20:6-
`19, 26:3-12.
`
`In addition, for ’632 patent, claims 2, 4: The structure associated with the estimation
`subsystem and its claimed functions further includes the portions of the specification
`regarding the interactions between the sensor fusion core and sensor modules associated
`with one or more of the sensing elements, or equivalents. See, e.g., id. at 18:34-38, 19:1-6,
`19:20-25.
`
`In addition, for ’632 patent, claim 14: The structure associated with the estimation
`subsystem and its claimed functions further includes the portions of the specification
`regarding accepting the information necessary to calculate an innovation in the sensor
`measurement, or equivalents. See, e.g., id. at 15:47-51, 24:55-64, 26:3-5.
`
`Alternatively, if 35 U.S.C. § 112, ¶ 6 applies:
`
`’632 patent, claim 33—Function: “estimating a position or orientation of an object”
`
`Structure: “accepting parameters specific to the set of sensing elements, configuring the
`estimation subsystem based on the accepted parameters, and generating a sequence of
`candidates of pairs of sensing elements selected from the set of sensing elements, the
`sequence based on an expected utility of a measurement associated with said elements to
`the estimation subsystem.”
`
`
`11
`
`

`

`
`
`Term
`(All Proposed
`by Defendants)
`
`Patent
`and
`Claims
`
`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 12 of 19
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`10
`
`
`“sensor
`module(s)”
`
`’632
`patent,
`claims
`47-50,
`54-55,
`57, 59-
`61
`
`’253
`patent,
`claims 2,
`3, 4
`
`Means-plus-function under § 112, ¶ 6.
`
`’632 patent, claims 47-50, 54-55, 57, 59-61—
`Function: “providing configuration information to the
`estimation module regarding characteristics of the
`sensors associated with the sensor module”;
`“[receiving] data based on estimates of the tracking
`parameters from the estimation module;” and
`“[sending] data based on measurements obtained from
`the associated sensors”
`
`Structure: Indefinite
`
`If additional structure is required: The portion of a navigation or tracking system that is
`specific to updating the states of the system, which processes information from sensing
`elements and updates the states using an iterative process, where the iterative process may
`be a stochastic model, such as a Kalman filter, a complementary extended Kalman filter,
`any of the other algorithms described at 6:60-7:14 and 10:40-11:9 of the specification, or
`equivalents. See, e.g., ’632 patent at 3:60-61, 6:60-7:14, 10:40-11:9, 20:6-19, 26:3-12.
`
`The structure associated with the estimation subsystem and its claimed functions further
`includes the portions of the specification regarding generating a sequence of pairs of
`sensing elements based on the expected utility of the measurements associated with those
`sensing elements, or equivalents. See, e.g., id. at 19:29-37.
`Plain and ordinary meaning, in light of the claims and specification—i.e., “interface or
`interfaces between a set of one or more sensors and a tracking system.” (35 U.S.C. § 112,
`¶ 6 does not apply.)
`
`Alternatively, if 35 U.S.C. § 112, ¶ 6 applies:
`
`’632 Patent, claims 47-50, 54-55, 57, 59-61—Function: “providing information from a set
`of one or more sensors to the estimation module”
`
`Structure: “providing configuration information regarding the characteristics of a set of
`one or more sensors associated with the sensor module, and repeatedly (a) receiving from
`the estimation module data based on the estimates of the tracking parameters, and
`(b) providing to the estimation module data based on measurements obtained from the
`associated sensors and the data received by the sensor module from the estimation module.”
`In addition, claims 48-50, 54-55, 57, and 59-61 of the ’632 Patent provide additional
`structural limitations as applicable to those claims.
`
`If additional structure is required:
`
`12
`
`

`

`
`
`Term
`(All Proposed
`by Defendants)
`
`Patent
`and
`Claims
`
`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 13 of 19
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`’632 patent, claims 47-50, 54-55, 57, 59-61: The structure associated with the sensor
`module and its claimed functions further includes the portions of the specification regarding
`receiving updated tracking parameters from the estimation subsystem, or equivalents. See,
`e.g., ’632 patent at 13:47-65, 15:61-16:5, 17:5-16, 18:34-38, 45:27-44, 45:51-46:16.
`
`In addition, for ’632 patent, claim 59: The structure associated with the sensor module
`and its claimed functions further includes the portions of the specification regarding
`configuration information about the type of sensor, or equivalents. See, e.g., id. at 10:7-11,
`30:37-56, 35:11-53, 42:47-51.
`
`In addition, for ’632 patent, claim 60: The structure associated with the sensor module
`and its claimed functions further includes the portions of the specification regarding
`measurement information about the position or orientation of a sensor, or equivalents. See,
`e.g., id. at 13:11-14, 14:8-15:42.
`
`In addition, for ’632 patent, claim 61: The structure associated with the sensor module
`and its claimed functions further includes the portions of the specification regarding
`configuration information about the calibration parameters of a sensor, or equivalents. See,
`e.g., id. at 13:47-54, 15:61-16:5, 17:5-16, 18:56-59, 27:34-36, 28:18-46.
`
`Alternatively, if 35 U.S.C. § 112, ¶ 6 applies:
`
`’253 Patent, claims 2-4—Function: “providing information from a set of one or more
`sensors”
`
`Structure: “providing an interface for interacting with a corresponding set of one or more
`sensing elements.” In addition, claims 3 and 4 provide additional structural limitations as
`applicable to those claims.
`
`If additional structure is required:
`
`13
`
`’253 Patent, claims 2, 4—Function: “providing an
`interface for interacting with a corresponding set of one
`or more sensing elements”
`
`Structure: Indefinite
`’253 Patent, claim 3—Function: “performing
`computations independently of an implementation of
`the estimation subsystem”
`
`
`

`

`
`
`Term
`(All Proposed
`by Defendants)
`
`Patent
`and
`Claims
`
`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 14 of 19
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`Structure: Indefinite
`
`11 “sensor
`subsystem”
`
`’253
`Patent:
`claims 1,
`2
`
`Means-plus-function under § 112, ¶ 6.
`
`’253 patent, claims 1, 2—Function: “provid[ing]
`configuration data to the estimation subsystem and …
`provid[ing] measurement information to the estimation
`subsystem for localizing an object”
`
`Structure: Indefinite
`
`For ’253 patent, claims 3-4: The structure associated with the sensor module and its
`claimed functions further includes the portions of the specification specific to the sensor
`fusion core performing calculations independently of the specific implementation of sensor
`modules, and vice versa, or equivalents. See, e.g., id. at 4:26-31, 16:38-44, 17:33-38,
`20:36-44, 22:38-50.
`
`Plain and ordinary meaning, in light of the claims and specification—i.e., “subsystem that
`provides configuration information and measurement information from sensors to the
`estimation subsystem.” (35 U.S.C. § 112, ¶ 6 does not apply.)
`
`Alternatively, if 35 U.S.C. § 112, ¶ 6 applies:
`
`’253 patent, claims 1, 2—Function: “providing information to the estimation subsystem
`for localizing an object,”
`
`Structure: “providing configuration data to the estimation subsystem, and providing
`measurement information to the estimation subsystem for localizing an object.”
`
`If additional structure is required:
`For ’253 patent, claims 1, 2: A software subsystem that provides an interface between
`sensors and an estimation subsystem, collects configuration data from sensors, and sends
`measurement information about sensor measurements to the estimation subsystem to update
`the state of the system. See, e.g., ’632 patent at 16:41-46, 17:27-28, 18:3-8, 18:48-51.
`
`In addition, for ’253 patent, claim 2: The structure associated with the sensor subsystem
`and its claimed functions further includes the sensor modules discussed above, or
`equivalents.
`
`
`14
`
`

`

`
`
`Term
`(All Proposed
`by Defendants)
`12 “data
`processing
`module”
`
`Patent
`and
`Claims
`’632
`patent,
`claims
`66, 67
`
`Case 6:21-cv-00755-ADA Document 54 Filed 04/15/22 Page 15 of 19
`
`Defendants’ Position
`
`Plaintiffs’ Position
`
`Means-plus-function under § 112, ¶ 6.
`
`’632 patent, claim 66—Function: “selectively
`perform[ing] one of (a) receiving data from at least one
`inside-out bearing sensor, and updating an estimated
`pose of an object based on data received from the
`inside-out bearing sensor (b) receiving data from at
`least one outside-in bearing sensor, and updating an
`estimated pose of an object based on data received
`from the outside-in bearing sensor, and (c) receiving
`data from at least one inside-out bearing sensor and at
`least one outside-in bearing sensor, and updating an
`