Pursuant with the Agreed Scheduling Order (Dkt. No. 24), Plaintiff CommWorks Solutions, LLC (“CommWorks” or “Plaintiff”) and Defendants Comcast Cable Communications, LLC and Comcast Cable Communications Management, LLC (collectively, “Comcast” or “Defendants”) jointly submit this Joint Claim Construction Statement setting forth the parties’ proposed constructions for the identified terms of U.S. Patent Nos. 6,832,249 (“the ’249 Patent”), 7,027,465 (“the ’465 Patent”), 7,177,285 (“the ’285 Patent”), 7,760,664 (“the ’664 Patent”), 8,923,846 (“the ’846 Patent”), and RE42,883 (“the ’883 Patent”).
• “model[] said digital cross connect system as a [] link” (Claims 1 and 9 of the ’664 Patent): “represent[] said digital cross connect system as a routing link.” • “representing each of said interconnections as a link” (Claim 7 of the ’664 CommWorks Exhibit 2006 Unified Patents v. CommWorks
The parties’ constructions of each disputed term in the asserted patents are set forth in the following chart.
Party Proposing Term(s) Plaintiff’s Proposed Construction Defendants’ Proposed Construction Court’s Construction plain and ordinary meaning connect [system] to the appropriate destination” # Claim Term successfully provisioned” (Claim 49 of the ’664 Patent) “transport address” (Claims 1, 4, 5, 6, 7, 8 of the ’846 Patent) “home subscription server (HSS)” (Claim 2 of the ’846 Patent) Joint proposal “IP address associated with a mobile node while the subscriber is visiting a particular foreign link” Defendants
“the current IP address, not the static home address, through which the mobile device can be reached when visiting a foreign link” “the master database for a given user containing subscription related information to support the network entities actually handling calls/sessions” “the component in a mobile network switching system that connects calls originating from and received for a mobile device” no construction required / plain and ordinary meaning alternatively, if construed, “master user database that supports the IP Multimedia Subsystem (IMS) network entities that handle the calls/sessions” no construction required / plain and ordinary meaning alternatively, if construed, “primary node in the IP Defendants “serving-call state control function (S-