Goodard v. Google, Inc.

Filing 163

Goodard v. Google, Inc.

Doc. 163 Att. 29

EXHIBIT 30

Dockets.Justia.com

March 28, 2009 VIA E-MAIL David Marder, Esq. Robins, Kaplan, Miller & Ciresi LLP 800 Boylston Street, 25th Floor Boston, MA 02199 Re: Samsung Electronics Co., Ltd., et al. adv. Advanced Micro Devices, Inc., et al.; Civil Action No. CV-08-0986-SI

Dear David: Following up on my letter of yesterday's date proposing agreement on certain constructions, and in an ongoing effort to reach compromise, we propose the following modified construction for "channel-free region" and "channel-free zone" in the '893 patent: "area without a channel and through which current flows between the channel and the drain." This construction comes closer to AMD's proposed construction ("areas where there is no channel") and responds to AMD's concern in its opening claim construction brief regarding the technical term "inversion region" in Samsung's original construction. The modified construction also more clearly describes the portion of the substrate designated by Samsung's original construction. Does AMD accept the modified construction above of "channel-free region" and "channel-free zone"? We recognize that this may not obviate all of AMD's objections to our original construction. However, even if it does not, at least we will have narrowed the dispute concerning these claim terms.

cc:

Samuel Walling, Esq. William Manning, Esq.