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).
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
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?