Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 1 of 11
`Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 1 of 11
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`EXHIBIT 20
`EXHIBIT 20
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`Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 1 of 11
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`EXHIBIT 20
`EXHIBIT 20
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`Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 2 of 11
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`Plaintiff,
`
`OZMO LICENSING LLC,
`
`
`
`v.
`
`DELL TECHNOLOGIES INC. and
`DELL INC.,
`
`
`
`Defendants.
`
`Civil Action No. 6:22-cv-00642
`
`
`
`JURY TRIAL DEMANDED
`
`
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`
`
`
`PLAINTIFF’S DISCLOSURE OF PROPOSED CONSTRUCTIONS
`
`Plaintiff, Ozmo Licensing LLC (“Ozmo”), by and through its counsel, hereby identifies the
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`following proposed constructions for the terms identified by the respective parties, including
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`extrinsic evidence. Ozmo Licensing reserves the right to amend its proposed constructions/terms
`
`based on Dell’s proposals, disclosures, or as otherwise necessary as the claim construction process
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`progresses. Copies of Ozmo Licensing’s proposed extrinsic evidence can be found attached hereto
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`as Exhibit A and labeled with Bates Nos. OZMO_DELL_00001 through OZMO_DELL_000049.
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`1
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`Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 3 of 11
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`Ozmo Licensing's Proposal
`
`Extrinsic Evidence
`
`“WPAN” overview and definition –
`IEEE 802.15.1-2005, pp. 1-2.
`
`802.15 Personal Area Networks, G.
`Hackmann, available at
`https://www.cse.wustl.edu/~jain/cse574-
`06/ftp/wpans/index.html (Mar. 21, 2006).
`
`A short-range network usable to
`connect peripherals to devices in
`close proximity
`
`[Proposed by: Dell and Ozmo]
`
`“Wireless Local Area Network
`(WLAN)” definition – Computer
`Security Resource Center, Glossary,
`Wireless Local Area Network (WLAN),
`NAT’L INST. OF STANDARDS & TECH.,
`available at
`https://csrc.nist.gov/glossary/term/wirele
`ss_local_area_network (last visited Mar.
`20, 2023).
`
`“LAN (local area network)” definition &
`“WLAN (wireless local area network)”
`definition – The Fundamentals of
`Networking, What is a computer
`network?, IBM, available at
`https://www.ibm.com/topics/networking
`(last visited Mar. 20, 2023).
`
`N/A
`
`Plain and ordinary meaning
`
`[Proposed by: Dell]
`
`Plain and ordinary meaning
`
`[Proposed by: Dell]
`
`Claim Term
`WPAN
`
` -
`
` wireless personal area
`network (“WPAN”) – 814
`patent, claim 5
`- wireless personal area
`network (“WPAN”) – 991
`patent, claims 11-12, 19-
`20
`- wireless personal area
`network (WPAN) – 934,
`504 patent, all claims
`- WPAN – 659 patent, all
`claims
`- wireless personal area
`network (“WPAN”) – 906
`patent, all claims
`WLAN
`
` -
`
` wireless local area
`network (“LAN”) – 814
`patent, claim 3
`- wireless LAN – 991
`patent, claims 3-5
`- wireless local area
`network (“WLAN”) – 991
`patent, claims 19-20
`- wireless local area
`network (WLAN) – 934,
`504 patent, all claims
`- WLAN – 659 patent, all
`claims
`- wireless local area
`network (“WLAN”) – 906
`patent, all claims
`802.11x
`
` -
`
` 814 patent, claim 4
`- 991 patent, claims 7-8,
`19-20
`- 934, 504 patent, all
`claims
`- 659 patent, claim 13, 24
`- 906 patent, all claims
`
`
`
`2
`
`
`
`Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 4 of 11
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`N/A
`
`Plain and ordinary meaning
`
`[Proposed by: Dell]
`
`protocol
`
` -
`
` All patents, all claims
`
`A protocol governing a second
`network, which protocol has
`aspects in common with a first
`network protocol to reduce
`interference such that the second
`and first networks can co-exist
`
`[Proposed by: Dell and Ozmo]
`
`Conforms to a part, but not the
`entirety of
`
`[Proposed by: Dell and Ozmo]
`
`“Overlay” definition – Computer
`Networks A Systems Approach, 3rd ed.,
`p. 732.
`
`“Partial” definition – Webster’s II New
`College Dictionary, 2001, pp. 800-01.
`Webster’s II New College Dictionary,
`3rd ed., p. 820.
`
`“Consistent” definition – Webster’s II
`New College Dictionary, 2001, p. 240.
`Webster’s II New College Dictionary,
`3rd ed., p. 246.
`
`“Compliant” definition – Webster’s II
`New College Dictionary, 2001, p. 230.
`Webster’s II New College Dictionary,
`3rd ed., p. 235.
`
`N/A
`
`Plain and ordinary meaning
`
`[Proposed by: Dell and Ozmo]
`
`overlay protocol
`
` -
`
` 814 patent, all claims
`- 991 patent, all claims
`- 934, 504 patent, all
`claims
`- 659 patent, claim 4
`- 906 patent, all claims
`
`partially consistent /
`partially compliant
`
` -
`
` partially consistent – 814
`patent, all claims
`- partially consistent – 991
`patent, claims 1-7, 9, 11-
`14, 16-17
`- partially consistent, but
`not entirely consistent –
`991 patent, claims 19-20
`- partially compliant –
`934, 504 patent, all claims
`- partially compliant – 659
`patent, all claims
`- partially complaint – 906
`patent, all claims
`at least partially disable
`the wireless connection /
`disable the second
`connection
`
` -
`
` at least partially disable
`the wireless connection –
`934, 504 patent, claims 1-
`6
`- disable the second
`connection – 659 patent,
`claim 6
`- at least partially disable
`the wireless connection –
`906 patent, all claims
`
`
`
`3
`
`
`
`Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 5 of 11
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`N/A
`
`N/A
`
`N/A
`
`N/A
`
`Plain and ordinary meaning
`
`[Proposed by: Dell]
`
`Plain and ordinary meaning
`
`[Proposed by: Dell]
`
`Plain and ordinary meaning
`
`[Proposed by: Dell]
`
`Not means-plus-function
`
`Plain and ordinary meaning
`
`Alternatively, if MPF:
`Function: coordinate a mutually
`agreeable inactivity period
`
`Structure: processing unit 28,
`memory module 29, wireless
`circuit 27, software platform 36,
`and/or algorithm at '814 patent,
`12:20-48, and their equivalents
`
`[Proposed by: Dell]
`
`maintaining wireless
`network connections /
`maintain network
`connections / maintain the
`second network
`connection during a
`mutually agreeable
`inactivity period
`
` -
`
` maintaining wireless
`network connections –
`814 patent, all claims
`- maintain network
`connections – 991 patent,
`all claims
`- maintain the second
`network connection
`during a mutually
`agreeable inactivity period
`– 991 patent, claim 8
`disabling at least a part of
`the wireless radio circuit
`following a start of the
`inactivity time
`
` -
`
` 659 patent, claim 8
`the disabling / the at least
`part is disabled
`
` -
`
` 934, 504 patents, claim 2
`
`logic to coordinate a
`mutually agreeable
`inactivity period
`
` -
`
` 814 patent, claims 5, 11
`- 991 patent, claims 11-12,
`20
`
`
`
`4
`
`
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`Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 6 of 11
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`N/A
`
`Not means-plus-function
`
`Plain and ordinary meaning, see
`"data forwarding logic"
`
`Alternatively, if MPF:
`Function: data forwarding
`between an originating node that
`is a node in of one of the first and
`second networks and a destination
`node that is a node in of the other
`of the first and second networks,
`the logic for data forwarding
`including logic for processing a
`data packet from the originating
`node to identify an address of the
`destination node in the data
`packet and using that address to
`transmit data into the second
`network
`
`Structure: Software platform 36
`(Fig. 6), wireless circuit 27,
`processing unit 28, memory
`module 29, and/or control and
`datapath logic 33, and their
`equivalents
`
`[Proposed by: Dell]
`
`logic for data forwarding
`between an originating
`node that is a node in of
`one of the first and second
`networks and a destination
`node that is a node in of
`the other of the first and
`second networks, the logic
`for data forwarding
`including logic for
`processing a data packet
`from the originating node
`to identify an address of
`the destination node in the
`data packet and using that
`address to transmit data
`into the second network
`
` -
`
` 991 patent, claims 19-20
`
`
`
`5
`
`
`
`Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 7 of 11
`
`N/A
`
`N/A
`
`Not means-plus-function
`
`Plain and ordinary meaning
`
`Alternatively, if MPF:
`Function: receiving a poll request
`that contains information required
`to unambiguously identify a
`station that is a node in the
`second network, wherein the
`routing module coordinates
`retrieval of information from the
`station
`
`Structure: processing unit 28,
`memory module 29, wireless
`circuit 27, software platform 36,
`and/or algorithm at '814 patent,
`13:39-58, and their equivalents
`
`[Proposed by: Dell]
`Not means-plus-function
`
`Plain and ordinary meaning
`
`Alternatively, if MPF:
`Function: initiating device
`discovery by sending broadcast
`discovery requests on a pre-
`defined channel
`
`Structure: processing unit 28/24,
`memory module 29/25, wireless
`circuit 27/19, software platform
`36, and/or algorithm at '814
`patent, 14:4-9, and their
`equivalents
`
`[Proposed by: Dell]
`
`a routing module for
`receiving a poll request
`that contains information
`required to
`unambiguously identify a
`station that is a node in the
`second network, wherein
`the routing module
`coordinates retrieval of
`information from the
`station
`
` -
`
` 814 patent, claim 2
`- 991 patent, claims 2, 19-
`20
`
`wherein the network-
`enabled hub and the
`device include logic, in
`one or both of the
`network-enabled hub and
`the device, for initiating
`device discovery by
`sending broadcast
`discovery requests on a
`pre-defined channel
`
` -
`
` 991 patent, claim 9
`
`
`
`6
`
`
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`Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 8 of 11
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`N/A
`
`N/A
`
`Not means-plus-function
`
`Plain and ordinary meaning
`
`Alternatively, if MPF:
`Function: uniquely identifying the
`destination node from data
`received from the originating
`node such that the network-
`enabled hub can use that data to
`transmit data into the second
`wireless network
`
`Structure: processing unit 28,
`memory module 29, wireless
`circuit 27, software platform 36,
`and/or algorithm at '814 patent,
`7:52-8:15, and their equivalents
`
`[Proposed by: Dell]
`Not means-plus-function
`
`Plain and ordinary meaning
`
`Alternatively, if MPF:
`Function: indicating
`characteristics and/or state of the
`network-enabled hub and/or
`device
`
`Structure: processing unit 28/24,
`memory module 29/25, wireless
`circuit 27/19, software platform
`36, and/or algorithm at '814
`patent, 13:38-58, and their
`equivalents
`
`[Proposed by: Dell]
`
`logic for uniquely
`identifying the destination
`node from data received
`from the originating node
`such that the network-
`enabled hub can use that
`data to transmit data into
`the second wireless
`network
`
` -
`
` 814 patent, claim 11
`
`wherein the network-
`enabled hub and the
`device further include
`logic, in one or both of the
`network-enabled hub and
`the device, for indicating
`characteristics and/or state
`of the network-enabled
`hub and/or device
`
` -
`
` 991 patent, claim 10
`
`
`
`7
`
`
`
`Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 9 of 11
`
`N/A
`
`N/A
`
`N/A
`
`Means-plus-function
`
`Function: processing data
`received via the wireless radio
`circuit
`
`Structure: processing unit 28
`
`[Proposed by: Ozmo]
`
`Means-plus-function
`
`Function: generating data to be
`transmitted by the wireless radio
`circuit
`
`Structure: processing unit 28
`
`[Proposed by: Ozmo]
`
`Means-plus-function
`
`Function: initiating and
`maintaining wireless network
`connections with nodes of a
`wireless network external to the
`network-enabled hub,
`maintaining at least a first
`wireless network connection
`using a first wireless network
`protocol and a second wireless
`network connection using a
`second wireless network protocol,
`that can be maintained, at times,
`simultaneously with each other in
`a common wireless space
`
`Structure: wireless circuit 27,
`processing unit 28, and software
`platform 36
`
`[Proposed by: Ozmo]
`
`logic for processing data
`received via the wireless
`radio circuit
`
` -
`
` 814 patent, claim 1 and
`all asserted dependent
`claims
`
`logic for generating data
`to be transmitted by the
`wireless radio circuit
`
` -
`
` 814 patent, claim 1 and
`all asserted dependent
`claims
`
`logic for initiating and
`maintaining wireless
`network connections with
`nodes of a wireless
`network external to the
`network-enabled hub,
`maintaining at least a first
`wireless network
`connection using a first
`wireless network protocol
`and a second wireless
`network connection using
`a second wireless network
`protocol, that can be
`maintained, at times,
`simultaneously with each
`other in a common
`wireless space
`
` -
`
` 814 patent, claim 1 and
`all asserted dependent
`claims
`
`
`
`8
`
`
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`Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 10 of 11
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`
`
`N/A
`
`N/A
`
`Not means-plus-function
`
`Plain and ordinary meaning
`
`[Proposed by: Ozmo]
`
`Plain and ordinary meaning
`
`[Proposed by: Ozmo]
`
`Jointly determine
`
`[Proposed by: Ozmo]
`
`
`
`data forwarding logic
`
` -
`
` 814 patent, claim 1 and
`all asserted dependent
`claims
`- 991 patent, claims 1, 19
`and all asserted dependent
`claims
`first [wireless] network /
`second [wireless] network
`
` -
`
` 814 patent, claim 1 and
`all asserted dependent
`claims
`- 991 patent, claim 1 and
`all asserted dependent
`claims
`- 659 patent, claim 1 and
`all asserted dependent
`claims
`configured to agree / can
`agree / mutually agreeable
`
` -
`
` 814 patent, claim 5
`- 991 patent, claims 8, 11,
`12, 20
`- 906 patent, claims 1, 4
`- 934 patent, claims 1, 4
`- 504 patent, claims 1, 4
`
`
`
`
`9
`
`
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`Case 6:22-cv-00642-ADA Document 32-20 Filed 03/31/23 Page 11 of 11
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`Dated: March 20, 2023
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`Respectfully Submitted,
`
`/s/ Alyssa H. Ruderman
`KARL RUPP
`State Bar No. 24035243
`SOREY & HOOVER, LLP
`100 N. 6th Street, Ste. 502
`Waco, Texas 76701
`903.230.5600 (telephone)
`903.230.5656 (facsimile)
`krupp@soreylaw.com
`
`
`
`
`
`
`
`James J. Foster
`jfoster@princelobel.com
`Matthew D. Vella
`mvella@princelobel.com
`Robert R. Gilman
`rgilman@princelobel.com
`Aaron S. Jacobs
`ajacobs@princelobel.com
`Alyssa H. Ruderman
`aruderman@princelobel.com
`PRINCE LOBEL TYE LLP
`One International Place, Suite 3700
`Boston, MA 02110
`Tel: (617) 456-8000
`
`COUNSEL for PLAINTIFF
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the above and foregoing document has
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`been delivered to all counsel of record via electronic transmission on this 20th day of March,
`2023.
`
`
`
`
`
`
`
`
`
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`
`
`/s/ Alyssa H. Ruderman
`
`
`
`
`
`
`
`10
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`
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