`Exhibit B
`Philips North America, LLC v. Fitbit, Inc. (D. Mass) Case No. 1:19-cv-11586-IT
`Fitbit’s Chart of Additional Claim Terms for Construction [Opposed Petition Filed Separately]
`
`
`PHILIPS’ CONSTRUCTION
`
`FITBIT’S CONSTRUCTION
`
`COURT’S CONSTRUCTION
`
`TERM
`
`PATENT &
`CLAIMS
`
`U.S. Pat. No.
`6,013,007
`Claims 1, 21
`
`“means for
`presenting the
`athletic
`performance
`feedback data to an
`athlete”
`
`No Construction Necessary
`Proposed Construction:
`a display and/or audio
`headphones (and equivalents
`thereof) that presents the athletic
`performance feedback data to an
`athlete
`35 U.S.C. § 112, ¶ 6
`Structure:
`a display and/or audio
`headphones and equivalents
`thereof (See, e.g., Figs. 1A, 2, 3,
`5, 6, original claims, col. 4 ll. 4-
`13, col 4. Ll. 34-40, col. 7 ll. 56-
`67)
`Function:
`presenting the athletic
`performance feedback data to an
`athlete
`
`
`
`35 U.S.C. § 112, ¶ 6
`
`Function: presenting the athletic
`performance feedback data to an
`athlete
`
`Structure: a preset interval or a
`button to initiate presentation of
`performance feedback data;
`audio headphones wired through
`the CPU in the GPS-based
`performance monitor to an audio
`module;
`the audio module containing:
`(1) an amplifier connected to a
`voice/speech synthesizer; or
`(2) a micro controller
`generating audio output using a
`series of stored compressed
`digital audio files; and
`feedback data scrolled across a
`display on the monitor while
`simultaneously announced via the
`wired audio headphones. Figs. 1A-
`C, 2-6, Col. 7:57-67, 4:34-39;
`5:50-58, 3:18-39, 4:13-16; 2:22-
`29; 5:5-10
`
`
`
`TERM
`
`“modem”
`
`PATENT &
`CLAIMS
`
`U.S. Pat. No.
`6,013,007
`Claim 21
`
`U.S. Pat. No.
`7,088,233
`Claim 26
`
`“bi-directional
`communications
`module has a
`powered-down
`state”
`
`U.S. Pat. No.
`7,088,233
`
`“means for
`signaling the bi-
`directional
`communications
`module to transition
`from the powered-
`down state to the
`powered-up state”
`
`Case 1:19-cv-11586-IT Document 65-2 Filed 05/14/20 Page 2 of 3
`Exhibit B
`Philips North America, LLC v. Fitbit, Inc. (D. Mass) Case No. 1:19-cv-11586-IT
`Fitbit’s Chart of Additional Claim Terms for Construction [Opposed Petition Filed Separately]
`
`
`PHILIPS’ CONSTRUCTION
`
`FITBIT’S CONSTRUCTION
`
`COURT’S CONSTRUCTION
`
`
`
`
`
`
`
`No construction necessary.
`Alternatively: a device that
`modulates a digital signal into an
`analog one for transmission and
`which demodulates a received
`analog signal into a digital one.
`
`No construction necessary.
`Alternatively: bi-directional
`communications module has a
`powered state that is lower than
`the powered-up state
`
`No Construction Necessary
`Proposed Construction:
`a radiofrequency (RF) receiver,
`switch, pressure pad, or magnet
`(or equivalents
`thereof)
`that
`causes
`the
`bi-directional
`communications module
`to
`transition from the powered-down
`state to the powered-up state.
`Structure:
`a radiofrequency (RF) receiver,
`mechanical switch, pad, or
`
`a modulator capable of sending
`signals through a standard
`telephone line and a demodulator
`capable of receiving signals from a
`standard telephone line
`
`bi-directional communications
`module consumes no power in
`powered-down state
`
`35 U.S.C. § 112, ¶ 6
`
`Function: signaling the bi-
`directional communications
`module to transition from the
`powered-down state to the
`powered-up state (as construed
`above)
`
`Structure: a mechanical switch,
`pressure pad, magnet, or
`combination of RF transmitter and
`un-powered RF receiver that are
`tuned to the same frequency, and
`
`
`
`Case 1:19-cv-11586-IT Document 65-2 Filed 05/14/20 Page 3 of 3
`Exhibit B
`Philips North America, LLC v. Fitbit, Inc. (D. Mass) Case No. 1:19-cv-11586-IT
`Fitbit’s Chart of Additional Claim Terms for Construction [Opposed Petition Filed Separately]
`
`
`PHILIPS’ CONSTRUCTION
`
`FITBIT’S CONSTRUCTION
`
`COURT’S CONSTRUCTION
`
`TERM
`
`PATENT &
`CLAIMS
`
`
`
`magnet or equivalents thereof.
`(See, e.g., Fig. 7, col.14 ll. 35-47)
`Function:
`signaling the bi- directional
`communications module to
`transition from the powered-down
`state to the powered-up state
`
`structural equivalents thereof. Fig.
`7, 14:15-60; 16:16-30.
`
`If Philips’ construction of
`“powered-down state” is adopted,
`then indefinite, as there is not
`structure disclosed to signal a
`transition from a lower-power
`state to a higher-power state
`
`
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