Google Inc. v. Rockstar Consortium US LP et al

Filing 139

JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT filed by Google Inc., Rockstar Consortium US LP, MobileStar Technologies LLC. (Attachments: # 1 Exhibit A, # 2 Exhibit B)(Curran, Patrick) (Filed on 10/24/2014) Modified on 10/27/2014 (cpS, COURT STAFF).

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EXHIBIT B A. U.S. Patent No. 5,838,551 (“the ’551 patent”) U.S. Patent No. 5,838,551 Claim Term Rockstar’s Proposal Rockstar’s Support “a Faraday cage” “an enclosure formed on one side by the EMI shield and on the other side by the ground member which completely surrounds the electronic component” “the board”/Antecedent basis of “the board” “the substrate” Generally, the ’551 Patent and its File History; Specification at Col. 1 lines 59-62; Col. 4 lines 14-20; Figures 1-6; Prosecution History, Office Action Response dated January 14, 1998 ; Newton’s Telecom Dictionary, 25 Anniversary Edition, Copyright 2009, at page 462; Chambers Dictionary of Science and Technology, Copyright 1999, at 431; American Heritage Science Dictionary, Copyright 2005, at page 226 Specification Abstract; Col. 1 lines 20-34, 41-45, 52-53; Col. 2 lines 61-64; Figures 1-6; Claims 1, 9, 10, 12 “extending across substantially the whole area within the confines of the edges of the substrate” Plain and ordinary meaning B. Generally, the ’551 Patent and its File History; Webster’s New 20th Century Dictionary 1817 (1983) U.S. Patent No. 6,037,937 (“the ’937 patent”) U.S. Patent No. 6,037,937 Claim Term Rockstar’s Proposal Rockstar’s Support “physical viewing area” Plain and ordinary meaning Generally, the ’937 Patent and its File History “manipulable area portion” “portion of the physical viewing area including a touch screen panel where displayed content information is subject to manipulation” The specification of the ’937 patent, including cols. 1:18-2:40; 4:35-41; 4:56-5:8; 5:27-40; and 6:35-8:11; and Figs 4-6; 8, and 10-14, and corresponding text. The prosecution history of the ‘937 patent, including Jan. 22, 1999 Amendment & Remarks/Arguments and June P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 U.S. Patent No. 6,037,937 Claim Term Rockstar’s Proposal Rockstar’s Support 16, 1999 Amendment & Remarks/Arguments. “control tool function” Plain and ordinary meaning “user input”/ “receiving a user “user input” input to the physical viewing area “information corresponding to corresponding to the manipulable a user’s touch” area portion and the representation of the control “receiving a user input to the tool” physical viewing area corresponding to the manipulable area portion and the representation of the control tool” “receiving information corresponding to a user’s touch to the physical viewing area where the representation of the control tool overlays the manipulable area portion.” [“manipulable area portion” used as construed above] “determining if the user input selects the control tool” “determining if the information corresponding to a user’s touch is intended to select or ignore the control tool” Generally, the ’937 Patent and its File History Webster’s New World, College Dictionary Third Edition, 1997 (defining “input”) See above for “manipulable area portion” The specification of the ’937 patent, including cols. 1:18-2:40; 4:35-41; 4:56-6:24; and 6:358:11; and Figs 4-6; 8, 10, and 1214, and corresponding text. The prosecution history of the ‘937 patent, including Jan. 22, 1999 Amendment & Remarks/Arguments and June 16, 1999 Amendment & Remarks/Arguments. See above for “user input” The specification of the ’937 patent, including cols. 2:5-40; 4:63-5:8; 5:27-40; 6:35-63; 7:26-8:11 and Figs 4-6; 8, and 12-14, and corresponding text. The prosecution history of the ’937 patent, including Jan. 22, 1999 Amendment & Remarks/Arguments and June 16, 1999 Amendment & Remarks/Arguments. “permitting the at least one control tool function to be activated when the user input does select the control tool” “permitting the at least one control tool function to be activated when the information corresponding to a user’s touch does select the control tool” P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 See above for “user input” Generally, the ’937 Patent and its File History U.S. Patent No. 6,037,937 Claim Term “means for providing a manipulable area portion in a physical viewing area, said manipulable area portion having at least one manipulation function associated therewith” Rockstar’s Proposal [“user input” used as construed above]. Function: providing a See above for “manipulable area manipulable area portion in a portion” physical viewing area and providing at least one The specification of the ’937 manipulation function patent, associated with the including cols. 4:7-21; 4:36-41; 4:48-5:8; 6:54-7:25; and 7:45manipulable area portion 8:11; and Figs 4-6 and 8 and corresponding text. [“manipulable area portion” used as construed above]. The prosecution history of the Structure: Display module 470, touch panel 474, LCD 472, memory 440, feature processor 430, analog controller 460, program 510, and touchscreen program 520, as disclosed in Figs 4, 5, 6, and 8; col. 4:7-21; 4:36-41; 4:48-5:8; 5:27-33; 6:54-7:25; and 7:45-8:11, and equivalents thereto. “means for displaying a representation of a control tool overlaying the manipulable area portion, said control tool having at least one control tool function associated therewith” Function: displaying a representation of a control tool overlaying the manipulable area portion, said control tool having at least one control tool function associated therewith ’937 patent, including Jan. 22, 1999 Amendment & Remarks/Arguments and June 16, 1999 Amendment & Remarks/Arguments. See above for “manipulable area portion” The specification of the ’937 patent, including cols. 4:7-21; 4:36-41; 4:48-6:63; and Figs 4-8 and [“manipulable area portion” used corresponding text. as construed above]. The prosecution history of the ’937 patent, including Jan. 22, Structure: Display module 1999 Amendment & 470, touch panel 474, LCD Remarks/Arguments and June 472, memory 440, feature 16, 1999 Amendment & processor 430, and program Remarks/Arguments. 510, as disclosed in Figs 4, 5, 6, 7, and 8; col. 4:7-21; 4:3641; and 4:48-6:63, and all P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 Rockstar’s Support U.S. Patent No. 6,037,937 Claim Term Rockstar’s Proposal Rockstar’s Support equivalents thereto. “means for receiving a user input to the physical viewing area corresponding to the manipulable area portion and the representation of the control tool” Function: receiving a user input See above for “manipulable area portion,” “user input” and “receiving a user input to the physical viewing area corresponding to the manipulable area portion and the [“manipulable area portion,” representation of the control “user input,” and “receiving a tool” user input to the physical viewing area corresponding to the The specification of the ’937 manipulable area portion and the patent, including cols. 4:7-21; representation of the control 4:36-41; 4:48-6:63; 7:45-8:11; and Figs 4-6, 8, and 10-11 and tool” used as construed above]. corresponding text. to the physical viewing area where the representation of the control tool overlays the manipulable area portion Structure: Touch panel 474, analog controller 460, LCD 472, memory 440, feature processor 430, program 510 and touchscreen program 520, as disclosed in Figs 4, 5, 6, 8, 10, and 11; col. 4:7-21; 4:3641; 4:48-6:63; and 7:45-8:11, and all equivalents thereto. “means for determining if the user input selects the control tool” The prosecution history of the ’937 patent, including Jan. 22, 1999 Amendment & Remarks/Arguments and June 16, 1999 Amendment & Remarks/Arguments. Function: determining if the See above for “user input” and user input is intended to select or “determining if the user input selects the control tool” ignore the control tool [“user input” used as construed The specification of the ’937 patent, including cols. 4:7-21; above]. 4:36-41; 4:48-5:40; 6:25-6:63 Structure: Touch screen panel 7:45-8:11; and Figs 4-6 and 8-11 and corresponding text. 474, analog controller 460, LCD 472, memory 440, feature processor 430, program 510 and touchscreen program 520, as disclosed in Figs. 4, 5, 6, 8, 9, 10, and 11; col. 4:7-21; 4:36-41; 4:485:40; 6:25-6:63; and 7:45P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 The prosecution history of the ’937 patent, including Jan. 22, 1999 Amendment & Remarks/Arguments and June 16, 1999 Amendment & Remarks/Arguments. U.S. Patent No. 6,037,937 Claim Term Rockstar’s Proposal Rockstar’s Support 8:11, and all equivalents thereto. “means for activating the at least one manipulation function when the user input does not select the control tool or permitting the at least one control tool function to be activated when the user input does select the control tool” Function: activating the at least one manipulation function when the user input does not select the control tool or permitting the at least one control tool function to be activated when the user input does select the control tool See above for “user input” and “permitting the at least one control tool function to be activated when the user input does select the control tool” The specification of the ’937 patent, including cols. 4:7-21; 4:36-41; 4:48-6:63; 7:45-8:11; [“user input” and “permitting the and Figs 4-6 and 8-11 and at least one control tool function corresponding text. to be activated when the user input does select the control tool” The prosecution history of the used as construed above]. ’937 patent, including Jan. 22, 1999 Amendment & Structure: Memory 440, Remarks/Arguments and June 16, 1999 Amendment & feature processor 430, program 510 and touchscreen Remarks/Arguments. program 520, as disclosed in Figs. 4, 5, 6, 8, 9, 10, and 11; col. 4:7-21; 4:36-41; 4:486:63; and 7:45-8:11, and all equivalents thereto. “means for receiving a subsequent user input selecting a predetermined portion of the control tool, after at least one control tool function is permitted to be activated” Function: receiving subsequent user input selecting a predetermined portion of the control tool, after at least one control tool function is permitted to be activated See above for “user input” and “permitting the at least one control tool function to be activated when the user input does select the control tool” The specification of the ’937 patent, including cols. 4:7-21; 4:36-41; [“user input” and “permitting the 4:48-5:8; and 5:41-6:63; and Figs at least one control tool function 4-6 and 8-11 and corresponding to be activated when the user text. input does select the control tool” used as construed above]. The prosecution history of the ’937 patent, including Jan. 22, Structure: Touch panel 474, 1999 Amendment & P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 U.S. Patent No. 6,037,937 Claim Term Rockstar’s Proposal analog controller 460, LCD 472, memory 440, feature processor 430, program 510 and touchscreen program 520, as disclosed in Figs. 4, 5, 6, 8, 9, 10 and 11; col. 4:7-21; 4:36-41; 4:48-5:8; and 5:416:63, and all equivalents thereto. “means for activating the function of changing a display of information in response to the subsequent user input” Rockstar’s Support Remarks/Arguments and June 16, 1999 Amendment & Remarks/Arguments. Function: activating the See above for “user input” function of changing a display of information in response to The specification of the ’937 patent, including cols. 2:21-40; the subsequent user input. 4:7-21; 4:36-41; 4:48-5:8; and 5:41-6:63; and Figs 4-6 and 8-11 [“user input” used as construed and corresponding text. above]. Structure: Memory 440, feature processor 430, program 510 and touchscreen program 520, as disclosed in Figs. 4, 5, 6, 8, 9, 10 and 11; col. 2:21-40; 4:7-21; 4:36-41; 4:48-5:8; and 5:41-6:63, and all equivalents thereto. “wherein the means for displaying a representation of the control tool includes displaying arrows indicating direction” Function: displaying a representation of a control tool including arrows indicating direction overlaying the manipulable area portion and providing at least one control tool function associated with the overlayed control tool Structure: Display module 470, touch panel 474, LCD 472, memory 440, feature processor 430, and program 510, as disclosed in Figs. 4, 5, P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 The prosecution history of the ’937 patent, including Jan. 22, 1999 Amendment & Remarks/Arguments and June 16, 1999 Amendment & Remarks/Arguments. See above for “user input” The specification of the ’937 patent, including cols. 2:21-40; 4:7-21; 4:36-41; 4:48-5:26; 5:4163; and 6:25-32; and Figs 4-11 and corresponding text. The prosecution history of the ’937 patent, including Jan. 22, 1999 Amendment & Remarks/Arguments and June 16, 1999 Amendment & Remarks/Arguments. U.S. Patent No. 6,037,937 Claim Term Rockstar’s Proposal Rockstar’s Support 6, 7, 8, 9, 10 and 11; col. 2:2140; 4:7-21; 4:36-41; 4:485:26; 5:41-63; and 6:25-32, and all equivalents thereto. “wherein the means for displaying the representation of the control tool includes displaying an opaque representation of the control tool” Function: displaying an opaque representation of a control tool and providing at least one control tool function associated with the overlayed control tool Structure: Display module 470, touch panel 474, LCD 472, memory 440, feature processor 430, and program 510, as disclosed in Figs. 4, 5, 6; col. 2:21-40; 4:7-21; 4:3641; 4:48-5:26; and 6:25-32, and all equivalents thereto. “wherein the means for displaying the representation of the control tool includes displaying a virtually transparent representation of the control tool” Function: displaying a virtually transparent representation of a control tool and providing at least one control tool function associated with the overlayed control tool Function: displaying a virtually transparent representation of a control tool and providing at least one control tool function associated with the overlayed control tool Structure: Display module 470, touch panel 474, LCD 472, memory 440, feature processor 430, and program 510, as disclosed in Figs. 4, 5, P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 The specification of the ’937 patent, including cols. 2:21-40; 4:7-21; 4:36-41; 4:48-5:26; and 6:25-32; and Figs 4-6 and corresponding text. The prosecution history of the ’937 patent, including Jan. 22, 1999 Amendment & Remarks/Arguments and June 16, 1999 Amendment & Remarks/Arguments. The specification of the ’937 patent, including cols. 2:21-40; 4:7-21; 4:36-41; 4:48-5:26; and 6:25-34; and Figs 4-11 and corresponding text. The prosecution history of the ’937 patent, including Jan. 22, 1999 Amendment & Remarks/Arguments and June 16, 1999 Amendment & Remarks/Arguments. U.S. Patent No. 6,037,937 Claim Term Rockstar’s Proposal Rockstar’s Support 6, 7, 8, 9, 10 and 11; col. 2:2140; 4:7-21; 4:36-41; 4:485:26; and 6:25-34, and all equivalents thereto. C. U.S. Patent No. 6,128,298 (“the ’298 patent”) U.S. Patent No. 6,128,298 Claim Term Rockstar’s Proposal “means for receiving from the first network, a data packet having destination information, which includes a destination address and a destination port, corresponding to a node in the second network and having source information, which includes a source address and a source port, corresponding to a node in the first network” Function: receiving from the first network, a data packet having destination information, which includes a destination address and a destination port, corresponding to a node in the second network and having source information, which includes a source address and a source port, corresponding to a node in the first network “means for maintaining the source information taken from the data packet in correlation with a unique value representing a port of the filter node” Structure: Packet Driver 30 and equivalents Function: maintaining the source information taken from the data packet in correlation with a unique value representing a port of the filter node “means for replacing in the data packet the source address with an address of the filter node and the source port with the filter node port value” Structure: Software and/or hardware implementing translation table / Address Translation 40 and equivalents Function: replacing in the data packet the source address with an address of the filter node and the source port with the filter node port value Structure: Software and/or hardware implementing translation table / Address P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 Rockstar’s Support See 7:65-8:6 and Fig. 2. See 5:37-60; 8:9-11 and Fig. 2. See 5:37-60; 8:9-11 and Fig. 2. U.S. Patent No. 6,128,298 Claim Term Rockstar’s Proposal Rockstar’s Support Translation 40 and equivalents “means for sending to the second network, the data packet having the replaced source information, whereby that packet is routed according to its destination information to the corresponding second network node” Function: sending to the second network, the data packet having the replaced source information, whereby that packet is routed according to its destination information to the corresponding second network node “means for receiving from the second network, a data packet having the address of the filter node as the destination address” Structure: Packet Driver 32 and equivalents Function: receiving from the second network, a data packet having the address of the filter node as the destination address “means for correlating the destination port of the destination information in the data packet to particular source information being maintained” Structure: Packet Driver 32 and equivalents Function: correlating the destination port of the destination information in the data packet to particular source information being maintained “means for replacing, in the data packet, the destination information with the particular source information” Structure: Software and/or hardware implementing translation table / Address Translation 40 and equivalents Function: replacing, in the data packet, the destination information with the particular source information “means for sending to the first network the data packet having the replaced destination information, whereby that packet is routed according to its destination information to the Structure: Software and/or hardware implementing translation table / Address Translation 40 and equivalents Function: sending to the first network the data packet having the replaced destination information, whereby that packet is routed according to its destination information to the P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 See 7:65-8:6 and Fig. 2. See 7:65-8:6 and Fig. 2. See 5:37-60; 8:9-11 and Fig. 2. See 5:37-60; 8:9-11 and Fig. 2. See 7:65-8:6 and Fig. 2. U.S. Patent No. 6,128,298 Claim Term corresponding first network node” Rockstar’s Proposal Rockstar’s Support corresponding first network node Structure: Packet Driver 30 and equivalents “means for ignoring a data packet Function: ignoring a data packet received from the second received from the second network, if the destination port of network, if the destination port of the destination information in the destination information in that data packet can not be that data packet can not be correlated to the maintained correlated to the maintained source information” source information See 3:22-24; 3:48-51; 5:37-60, and Fig. 2. “means for receiving from the first network, a data packet having a destination address corresponding to a node in the second network” Structure: Software and/or hardware implementing translation table / Address Translation 40 and equivalents Function: receiving from the first network, a data packet having a destination address corresponding to a node in the second network See 7:65-8:6 and Fig. 2. “means for maintaining the source address taken from the data packet” Structure: Packet Driver 30 and equivalents Function: maintaining the source address taken from the data packet See 5:37-60; 8:9-11 and Fig. 2. “means for replacing, in the data packet, the source address with an address of the filter node, wherein the source address includes a source port number and the address of the filter node includes a port number of the filter node” Structure: Software and/or hardware implementing translation table / Address Translation 40 and equivalents Function: replacing, in the data packet, the source address with an address of the filter node, wherein the source address includes a source port number and the address of the filter node includes a port number of the filter node “means for sending to the second Structure: Software and/or hardware implementing translation table / Address Translation 40 and equivalents Function: sending to the second P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 See 5:37-60; 8:9-11 and Fig. 2. See 7:65-8:6 and Fig. 2. U.S. Patent No. 6,128,298 Claim Term Rockstar’s Proposal network the data packet having the replaced source address, whereby that packet is routed to the corresponding second network node” network the data packet having the replaced source address, whereby that packet is routed to the corresponding second network node “means for receiving a return packet from the second network, responsive to the data packet having the replaced source information” Structure: Packet Driver 32 and equivalents Function: receiving a return packet from the second network, responsive to the data packet having the replaced source information “means for replacing, in the return packet, the destination address with the maintained source address” Structure: Packet Driver 32 and equivalents Function: replacing, in the return packet, the destination address with the maintained source address “means for sending to the first network the return packet having the replaced destination address, whereby that packet is routed to the corresponding the first network node” Structure: Software and/or hardware implementing translation table / Address Translation 40 and equivalents Function: sending to the first network the return packet having the replaced destination address, whereby that packet is routed to the corresponding the first network node “means for buffering further data packets received from the first network while waiting for the return packet, and Structure: Packet Driver 30 and equivalents Function: buffering further data packets received from the first network while waiting for the return packet Rockstar’s Support See 7:65-8:6 and Fig. 2. See 5:37-60; 8:9-11 and Fig. 2. See 7:65-8:6 and Fig. 2. See 4:27-31 and Fig. 2. Structure: at least one queue and associated hardware and/or software and equivalents means for controlling means (b) Function: controlling means (b) See 4:27-31 and Fig. 2. through (g) on an individual basis through (g) on an individual basis for processing the further for processing the further packets, if any, that were packets, if any, that were P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 U.S. Patent No. 6,128,298 Claim Term Rockstar’s Proposal buffered” buffered “filter node” Structure: at least one queue and associated hardware and/or software and equivalents Plain and ordinary meaning “in correlation with” Plain and ordinary meaning “maintaining, by the filter node” Plain and ordinary meaning “maintaining the source information taken from the outgoing data packet in correlation with a unique value representing a port of the filter node” “maintaining the source address taken from the data packet” “ignoring” Plain and ordinary meaning Order of steps of claims 11, 14, 15, 19, 23, 24 Antecedent basis of “the source address taken from the data packet” Antecedent basis of “the [corresponding] public node network” No construction necessary Rockstar’s Support D. Plain and ordinary meaning Plain and ordinary meaning No construction necessary. Antecedent basis exists in preceding limitation(s) “the corresponding node in the public network” Generally, the ’298 Patent and its File History Generally, the ’298 Patent and its File History Generally, the ’298 Patent and its File History Generally, the ’298 Patent and its File History Generally, the ’298 Patent and its File History Generally, the ’298 Patent and its File History Generally, the ’298 Patent and its File History Generally, the ’298 Patent and its File History Generally, the ’298 Patent and its File History U.S. Patent No. 6,333,973 (“The ’973 patent”) U.S. Patent No. 6,333,973 Claim Term Rockstar’s Proposal Rockstar’s Support “means for automatically receiving notification messages corresponding to pending messages of different types, the notification messages including information regarding the source of each of the pending messages and the type of each of the pending messages, wherein each of the notification messages is Function: automatically receiving notification messages corresponding to pending messages of different types, the notification messages including information regarding the source of each of the pending messages and the type of each of the pending messages, wherein each of the notification messages is ’973 Patent at 5:9-39 and Figs. 23 and accompanying text. P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 ’973 Patent File History, including all office actions and their responses, the interview summary, and the notice of allowability. U.S. Patent No. 6,333,973 Claim Term Rockstar’s Proposal automatically sent to the user when one of the pending messages is initially received and wherein the notification messages are received from an interface with independent connections with different bandwidths for the different types of pending messages” automatically sent to the user when one of the pending messages is initially received and wherein the notification messages are received from an interface with independent connections with different bandwidths for the different types of pending messages “means for determining a message type of the pending messages from the information corresponding to the received notification messages” Structure: GSM Radio 3210, A/D and D/A 3235, and antenna 2200 and 3100, including as recited and described in Figures 2 and 3, and equivalents Function: determining a message type of the pending messages from the information corresponding to the received notification messages “means for associating a message type indicator with each of the received notification messages based on the determined message type” Structure: Feature processor 3300, memory 3400, and message center 6100, including as recited and described in Figures 3, 6, 7A, and 7B, and equivalents Function: associating a message type indicator with each of the received notification messages based on the determined message type “means for receiving a selection of one of the pending messages based on the entries in the single selectable list” Structure: Feature processor 3300, memory 3400, and message center 6100, including as recited and described in Figures 3, 6, 7A, and 7B, and equivalents Function: receiving a selection of one of the pending messages based on the entries in the single selectable list Structure: Display 2400, feature processor 3300, sliding keypad 3500, analog controller 3600, and P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 Rockstar’s Support ’973 Patent at 2:32-40, 5:14-18, 5:50-6:2 and 8:27-9:5, and Figs. 3, 6, 7A, and 7B and accompanying text. ’973 Patent at 2:41-50, 5:14-18, 5:50-6:2 and 8:27-9:5, and Figs. 3, 6, 7A, and 7B and accompanying text. ’973 Patent 5:9-18, 5:50-6:2, and 6:40-59, and Figs. 2 and 3 and accompanying text. U.S. Patent No. 6,333,973 Claim Term “means for retrieving [manipulating] the selected pending message for viewing and manipulation by the user” Rockstar’s Proposal display module 3700, including as recited and described in Figures 2 and 3, and equivalents Function: retrieving the selected pending message for viewing and manipulation by the user Rockstar’s Support ’973 Patent 2:41-50, 3:54-56, 5:65-6:7 and 8:27-9:5, and Figs. 4, 6, 7A, and 7B and accompanying text. Structure: GUI manager 4100 and message center 6100, including as recited and described in Figures 4, 6, 7A, and 7B, and equivalents “means for accessing an external Function: accessing an external ’973 Patent 3:48-67, 5:9-31, and mail server” mail server 8:27-9:5, and Figs. 2, 6, 7A, and 7B and accompanying text. Structure: Mobile telephone 1100 and message center 6100, including as recited and described in Figures 2, 6, 7A, and 7B, and equivalents “means for retrieving the selected Function: retrieving the selected ’973 Patent 2:41-50, 3:48-67, pending message from the pending message from the 5:9-31, and 8:27-9:5, and Figs. 2, external mail server” external mail server 3, 6, 7A, and 7B and accompanying text. Structure: Mobile telephone 1100, antenna 2200 and 3100, and message center 6100, including as recited and described in Figures 2, 3, 6, 7A, and 7B, and equivalents “means for associating a message Function: associating a message ’973 Patent at 5:14-18, 5:50-6:2 type indicator with each of the type indicator with each of the and 8:27-9:5, and Figs. 3, 6, 7A, received notification messages received notification messages and 7B and accompanying text. based on the message type of the based on the message type of the corresponding pending message” corresponding pending message “pending message” “notification message” (as used in the phrases “notification Structure: Feature processor 3300, memory 3400, and message center 6100, including as recited and described in Figures 3, 6, 7A, and 7B, and equivalents Plain and ordinary meaning Plain and ordinary meaning P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 Generally, the ’973 Patent and its File History. Generally, the ’973 Patent and its File History. U.S. Patent No. 6,333,973 Claim Term messages corresponding to pending messages”) (claims 1, 8, 21) “wherein the notification messages are received from an interface with independent connections with different bandwidths for [the] different types of pending messages” “wherein the notification messages are received from an interface with independent connections with different bandwidths for the different types of the plurality of message senders” “retrieving” Rockstar’s Proposal Plain and ordinary meaning Generally, the ’973 Patent and its File History. Plain and ordinary meaning Generally, the ’973 Patent and its File History. Plain and ordinary meaning Generally, the ’973 Patent and its File History. Generally, the ’973 Patent and its File History. Generally, the ’973 Patent and its File History. Generally, the ’973 Patent and its File History. Order of steps of claim 8 No construction necessary Order of steps of claim13 No construction necessary Order of steps of claims 33 No construction necessary E. Rockstar’s Support U.S. Patent No. 6,463,131 (“the ’131 patent”) U.S. Patent No. 6,463,131 Claim Term “means for determining a characteristic of the communication event” “means for selecting a notification based on the characteristic” Rockstar’s Proposal Function: determining a characteristic of the communication event Structure: Processor 142 and memory 144, including as recited and described in Figure 1, and equivalents Function: selecting a notification based on the characteristic Structure: Processor 142 and memory 144, including as recited and described in Figure 1, and P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 Rockstar’s Support ’131 Patent at 4:49-5-14 and Fig. 1 and accompanying text. ’131 Patent at 4:49-5-14 and Fig. 1 and accompanying text. U.S. Patent No. 6,463,131 Claim Term Rockstar’s Proposal “means for sending the user the selected notification” equivalents Function: sending the user the selected notification “means for receiving a selection from the user indicating a format for delivery of further notification information regarding the communication event” Structure: Processor 142, transducer 143, and memory 144, including as recited and described in Figure 1, and equivalents Function: receiving a selection from the user indicating a format for delivery of further notification information regarding the communication event “means for allowing the further notification information regarding the communication event to be sent to the user in the selected format” Structure: Processor 142, transducer 143, and memory 144, including as recited and described in Figure 1, and equivalents Function: allowing the further notification information regarding the communication event to be sent to the user in the selected format “means for selecting includes a choice between at least a tactile alert and a nontactile alert” Structure: Processor 142, transducer 143, and memory 144, including as recited and described in Figure 1, and equivalents Function: selecting includes a choice between at least a tactile alert and a nontactile alert “communication event” “incoming communication event” Structure: Processor 142 and memory 144, including as recited and described in Figure 1, and equivalents “any type of voice or data transfer between two or more points” Part of the non-limiting preamble and no construction necessary in light of the construction for P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 Rockstar’s Support ’131 Patent at 4:49-5-14 and Fig. 1 and accompanying text. ’131 Patent at 4:49-5-14 and Fig. 1 and accompanying text. ’131 Patent at 4:49-5-14 and Fig. 1 and accompanying text. ’131 Patent at 4:49-5-14 and Fig. 1 and accompanying text. ’131 Patent at 4:9-10. Generally, the ’131 Patent and its File History. U.S. Patent No. 6,463,131 Claim Term “sending the user” / “to be sent to the user” “notification” (as used in the phrases “selecting a notification based on the characteristic” and “the selected notification”) (claims 1, 3, 4, 5, 7, 8) “further notification information” “receiving a selection from the user indicating a format for delivery of further notification information” Order of steps of claim 5 F. Rockstar’s Proposal “communication event” Plain and ordinary meaning Plain and ordinary meaning Plain and ordinary meaning Plain and ordinary meaning No construction necessary Rockstar’s Support Generally, the ’131 Patent and its File History. Generally, the ’131 Patent and its File History. Generally, the ’131 Patent and its File History. Generally, the ’131 Patent and its File History. Generally, the ’131 Patent and its File History. U.S. Patent No. 6,765,591 (“the ’591 patent”) U.S. Patent No. 6,765,591 Claim Term Rockstar’s Proposal Rockstar’s Support “a collection of palettes that provide virtual private network sub-elements associated with the virtual private network elements, the palette displayed being controlled by user selection of an element” “properties dialogs” a display of virtual private network subelements available for each of the plurality of virtual private network elements, the display shown being controlled by user selection of an element 8:3-45, 8:62-9:30, figures 21-24, 28, 30, 31. Plain and ordinary meaning “wizard” Plain and ordinary meaning. “managing a virtual private network” Rockstar maintains that the preamble is not limiting and, if limiting, should be given its plain and ordinary meaning. Generally, the ’591 Patent and its File History 5:10-17, 7:19-23, figures 5, 16, 26. Generally, the ’591 Patent and its File History P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 G. U.S. Patent No. 6,937,572 (“the ’572 patent”) U.S. Patent No. 6,937,572 Claim Term “network compatible device” Rockstar’s Proposal Plain and ordinary meaning Or in the alternative, should a construction be required: Rockstar’s Support The specification of the ’572 patent, including cols. 1:8-22; 1:62-67; 2:41-44; 5:51-59; and Fig. 1 and corresponding text. “network device configured to communicate over a packetswitched network” “end point device” The prosecution history of the ‘572 patent, including Oct, 1, 2004 Amendment and Remarks/Arguments and March 2, 2005 Amendment and Remarks/Arguments. Plain and ordinary meaning The specification of the ’572 patent, including cols. 1:8-22; 1:62-67; 2:41-44; 5:51-59; and Fig. 1 and corresponding text. Or in the alternative, should a construction be required: “end point user device configured to communicate over a packet-switched network” “logging the call trace information” The prosecution history of the ‘572 patent, including Oct, 1, 2004 Amendment and Remarks/Arguments and March 2, 2005 Amendment and Remarks/Arguments. Plain and ordinary meaning The specification of the ’572 patent, including cols. 1:47-50; 3:26-28; 3:46-52; 5:51-59; and 6:11-12. Or in the alternative: “recording call trace information received” P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1 The prosecution history of the ‘572 patent, including May 24, 2004 Office Action; September 23, 2004 Interview Request; October 1, 2004 Amendment & Remarks/Arguments; November 24, 2004 Office Action; March 2, 2005 Amendment and Remarks/Arguments February 28, 2005 Examiner Interview Summary Record. U.S. Patent No. 6,937,572 Claim Term “storing the call trace information” Rockstar’s Proposal “storing call trace information received on non-volatile memory” Rockstar’s Support September 13, 2014 Deposition of Brian Egan. The specification of the ’572 patent, including cols. 6:11-6:14. The prosecution history of the ‘572 patent, including May 24, 2004 Office Action; September 23, 2004 Interview Request; October 1, 2004 Amendment & Remarks/Arguments; November 24, 2004 Office Action; March 2, 2005 Amendment and Remarks/Arguments February 28, 2005 Examiner Interview Summary Record. September 13, 2014 Deposition of Brian Egan. (Egan Dep. Tr. [rough] 222:24-223:5). Generally, the ’572 Patent and its File History “call” Plain and ordinary meaning “call trace” Plain and ordinary meaning Generally, the ’572 Patent and its File History “call trace information” Plain and ordinary meaning Generally, the ’572 Patent and its File History “generating a request for call trace information” Plain and ordinary meaning Generally, the ’572 Patent and its File History Order of steps of claim 17 No construction necessary Generally, the ’572 Patent and its File History P.R. 4-3 EXHIBIT A CHART OF DISPUTED TERMS McKool 1024230v1

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