Google Inc. v. Rockstar Consortium US LP et al

Filing 140

JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT CORRECTION OF DOCKET # 139 filed by Google Inc., Rockstar Consortium US LP, MobileStar Technologies. (Attachments: # 1 Exhibit Exhibit A, # 2 Exhibit Exhibit B)(Liu, Jason) (Filed on 10/27/2014) Modified on 10/28/2014 (cpS, COURT STAFF).

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND DIVISION

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GOOGLE INC.,

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CASE NO. 13-cv-5933-CW

Plaintiff,
v.

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ROCKSTAR CONSORTIUM US LP
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MOBILESTAR TECHNOLOGIES
17 LLC,
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JOINT CLAIM CONSTRUCTION
AND PREHEARING STATEMENT
UNDER PATENT LOCAL RULE 43

Defendants.

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CASE NO. 13-CV-5933-CW
JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

1

Under Patent Local Rule 4-3 and the Court’s Minute Order and Case

2 Management Order, Plaintiff Google Inc. (“Google”) and Defendants Rockstar
3 Consortium US LP and MobileStar Technologies LLC (“Rockstar”) hereby submit
4 this Joint Claim Construction and Prehearing Statement.
5
6 I.

CONSTRUCTION OF THOSE CLAIM TERMS, PHRASES, OR
CLAUSES ON WHICH THE PARTIES AGREE

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8
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The Parties agree to the construction of the following terms:
Term
“integrated circuit
component”

Claims
‘551 Patent, claims 2-3

Agreed Construction
“a circuit constructed on a single
monolithic substrate”

“the physical viewing area
corresponding to the
manipulable area portion
and the representation of
the control tool”

‘937 Patent, claims 1, 13

“the physical viewing area where the
representation of the control tool
overlays the manipulable area
portion”

Order of steps

‘937 Patent, claim 1

[1.3] must occur before [1.4];
[1.4] must occur before [1.5];
[1.5] must occur before [1.6].

Order of steps

‘937 Patent, claim 2

[2.2] must occur before [2.3].

“dynamically displaying at
least a portion of the call
trace information that was
received”

‘572 Patent, claim 17

“displaying at least a portion of the
call trace information that was
received without requiring further
user interaction between receiving
and displaying the call trace
information”

20

“independent connections
with different bandwidths”

‘973 Patent, claims 1, 8,
21, 33

Plain meaning

21

“means for displaying on
the display a portion of the
received notification
messages and the
associated message type
indicators as entries in a
single selectable list”

‘973 Patent, claim 1

Function: displaying on the display
a portion of the received notification
messages and the associated
message type indicators as entries in
a single selectable list

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Structure: Display 2400, feature
processor 3300, memory 3400,
display module 3700, and message
center 6100, including as recited and
described in Figures 2, 3, 6, 7A, and
7B, and equivalent

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CASE NO. 13-CV-5933-CW
JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

1
2
3
4

Term
“means for displaying on
the display detailed
information about a sender
of the selected pending
message upon direction
from the user”

Claims
‘973 Patent, claim 2

Structure: Display 2400, feature
processor 3300, memory 3400,
display module 3700, and message
center 6100, including as recited and
described in Figures 2, 3, 6, 7A, and
7B, and equivalent

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6
7
8
9
10
11
12

“means for displaying at
least one of sender home
telephone number data,
sender business telephone
number data, sender
cellular telephone number
data, sender e-mail address
data, and sender fax
number data”

‘973 Patent, claim 3

“means for displaying one
of the portions of the
received notification
messages and the
associated graphical icon
as a single entry in the
single selectable list”

‘973 Patent, claim 4

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Function: displaying one of the
portions of the received notification
messages and the associated
graphical icon as a single entry in
the single selectable list
Structure: Display 2400, feature
processor 3300, memory 3400,
display module 3700, and message
center 6100, including as recited and
described in Figures 2, 3, 6, 7A, and
7B, and equivalent

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Function: displaying at least one of
sender home telephone number data,
sender business telephone number
data, sender cellular telephone
number data, sender e-mail address
data, and sender fax number data
Structure: Display 2400, feature
processor 3300, memory 3400,
display module 3700, and message
center 6100, including as recited and
described in Figures 2, 3, 6, 7A, and
7B, and equivalent

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Agreed Construction
Function: displaying on the display
detailed information about a sender
of the selected pending message
upon direction from the user

“means for displaying a
sender identification and
the associated graphical
icon as a single entry in the
single selectable list”

‘973 Patent, claim 5

Function: displaying a sender
identification and the associated
graphical icon as a single entry in
the single selectable list
Structure: Display 2400, feature
processor 3300, memory 3400,
display module 3700, and message
center 6100, including as recited and
described in Figures 2, 3, 6, 7A, and
7B, and equivalent

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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

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2
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Term
“means for displaying a
sender identification and
the associated message
type indicator as a single
entry in the single
selectable list”

Claims
‘973 Patent, claim 6

Structure: Display 2400, feature
processor 3300, memory 3400,
display module 3700, and message
center 6100, including as recited and
described in Figures 2, 3, 6, 7A, and
7B, and equivalent

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“means for displaying on
the display screen an
identification of the sender
and the associated message
type indicator for each of
the received notification
messages as entries in a
single selectable list to
allow the user to select one
of the pending messages
from the single selectable
list for viewing”

‘973 Patent, claim 21

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Function: displaying on the display
screen an identification of the sender
and the associated message type
indicator for each of the received
notification messages as entries in a
single selectable list to allow the
user to select one of the pending
messages from the single selectable
list for viewing
Structure: Display 2400, feature
processor 3300, memory 3400,
display module 3700, and message
center 6100, including as recited and
described in Figures 2, 3, 6, 7A, and
7B, and equivalent

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Agreed Construction
Function: displaying a sender
identification and the associated
message type indicator as a single
entry in the single selectable list

“means for directing the
‘973 Patent, claim 21
display screen to display
detailed information about
the sender of the selected
pending message in
response to selection by the
user”

Function: directing the display
screen to display detailed
information about the sender of the
selected pending message in
response to selection by the user
Structure: Display 2400, feature
processor 3300, memory 3400,
display module 3700, and message
center 6100, including as recited and
described in Figures 2, 3, 6, 7A, and
7B, and equivalent

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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

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2
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Term
“means for displaying each
of the sender identification
and the associated
graphical icons as separate
entries in the single
selectable list”

Claims
‘973 Patent, claim 24

5

Structure: Display 2400, feature
processor 3300, memory 3400,
display module 3700, and message
center 6100, including as recited and
described in Figures 2, 3, 6, 7A, and
7B, and equivalent

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7
8
9
10

“means for displaying the
detailed sender information
for the selected pending
message only upon
direction from the user”

‘973 Patent, claim 25

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14

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18
19

“means for directing the
display screen to display at
least one of sender home
telephone number data,
sender business telephone
number data, sender
cellular telephone number
data, sender e-mail address
data, and sender fax
number data”

‘973 Patent, claim 26

“address of the filter node”

‘298 Patent, claims 11,
14-15, 19, 23-24, 27-28,
31

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Function: directing the display
screen to display at least one of
sender home telephone number data,
sender business telephone number
data, sender cellular telephone
number data, sender e-mail address
data, and sender fax number data
Structure: Display 2400, feature
processor 3300, memory 3400,
display module 3700, and message
center 6100, including as recited and
described in Figures 2, 3, 6, 7A, and
7B, and equivalent

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Function: displaying the detailed
sender information for the selected
pending message only upon
direction from the user
Structure: Display 2400, feature
processor 3300, memory 3400,
display module 3700, and message
center 6100, including as recited and
described in Figures 2, 3, 6, 7A, and
7B, and equivalent

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Agreed Construction
Function: displaying each of the
sender identification and the
associated graphical icons as
separate entries in the single
selectable list

“unique identifier of the filter node
on a public network such as the
Internet”

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The Parties agree the following terms require the specified antecedent basis:
‘937 Patent Antecedent
Basis Constructions
“the user input”

Refers to “a user input” in the “receiving” limitation of claim 1,
or the “means for receiving” limitation of claim 13

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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

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‘937 Patent Antecedent
Basis Constructions
“said control tool” / “the
control tool”

Refers to “a control tool” in the “displaying” limitation of claim
1, or the “means for displaying” limitation of claim 13

“said manipulable area
portion” / “the manipulable
area portion”

Refers to “a manipulable area portion” in the “providing”
limitation of claim 1, or the “means for providing” limitation of
claim 13

“the representation of the
control tool”

Refers to “a representation of a control tool” in the “displaying”
limitation of claim 1, or the “means for displaying” limitation
of claim 13

“the at least one control tool
function”

Refers to “at least one control tool function” in the “displaying”
limitation of claim 1, or the “means for displaying” limitation
of claim 13

“the at least one
manipulation function”

Refers to “at least one manipulation function” in the
“providing” limitation of claim 1, or the “means for providing”
limitation of claim 13

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The Parties agree on the function only for the following means plus function
terms. The parties do not agree on what structure, if any, corresponds to these
functions. As set out in Exhibits A and B, Google maintains that certain terms are
indefinite; Rockstar disagrees.
Term
“means for determining a
message type of the
pending messages from the
information corresponding
to the received notification
messages”

Claims
‘973 Patent, claim 1

Agreed Construction
The function is “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”

‘973 Patent, claim 1

The function is “associating a
message type indicator with each of
the received notification messages
based on the determined message
type “

“means for receiving a
‘973 Patent, claim 1
selection of one of the
pending messages based on
the entries in the single
selectable list”

The function is “receiving a
selection of one of the pending
messages based on the entries in the
single selectable list”

“means for retrieving
[manipulating] the selected
pending message for
viewing and manipulation
by the user.”

The function is “retrieving the
selected pending message for
viewing and manipulation by the
user”

‘973 Patent, claim 1

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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

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Term
“means for accessing an
external mail server”

Claims
‘973 Patent, claim 7

Agreed Construction
The function is “accessing an
external mail server”

“means for retrieving the
selected pending message
from the external mail
server”

‘973 Patent, claim 7

The function is “retrieving the
selected pending message from the
external mail server”

“means for associating a
message type indicator
with each of the received
notification messages
based on the message type
of the corresponding
pending message”

‘973 Patent, claim 21

The function is “associating a
message type indicator with each of
the received notification messages
based on the message type of the
corresponding pending message”

“means for determining a
characteristic of the
communication event”

‘131 Patent, claim 1

The function is “determining a
characteristic of the communication
event”

“means for selecting a
notification based on the
characteristic”

‘131 Patent, claim 1

The function is “selecting a
notification based on the
characteristic ”

“means for sending the
user the selected
notification”

‘131 Patent, claim 1

The function is “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”

‘131 Patent, claim 1

The function is “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”

‘131 Patent, claim 1

The function is “allowing the further
notification information regarding
the communication event to be sent
to the user in the selected format”

“means for buffering
further data packets
received from the first
network while waiting for
the return packet”

‘298 Patent, claim 32

The function is “buffering further
data packets received from the first
network while waiting for the return
packet”

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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

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Term
“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”

Claims
‘298 Patent, claim 27

Agreed Construction
The function is “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 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”

‘298 Patent, claim 27

The function is “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”

‘298 Patent, claim 28

The function is “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”

‘298 Patent, claim 28

The function is “correlating the
destination port of the destination
information in the data packet to
particular source information being
maintained”

“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 corresponding first
network node”

‘298 Patent, claim 28

The function is “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 corresponding
first network node”

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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

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Term
“means for ignoring a data
packet received from the
second network, if the
destination port of the
destination information in
that data packet can not be
correlated to the
maintained source
information”

Claims
‘298 Patent, claim 29

Agreed Construction
The function is “ignoring a data
packet received from the second
network, if the destination port of
the destination information in that
data packet can not be correlated to
the maintained source information”

“means for receiving from
the first network, a data
packet having a destination
address corresponding to a
node in the second
network”

‘298 Patent, claim 31

The function is “receiving from the
first network, a data packet having a
destination address corresponding to
a node in the second network”

“means for sending to the
second network the data
packet having the replaced
source address, whereby
that packet is routed to the
corresponding second
network node”

‘298 Patent, claim 31

The function is “sending to the
second network the data packet
having the replaced source address,
whereby that packet is routed to the
corresponding second network
node”

“means for receiving a
‘298 Patent, claim 31
return packet from the
second network, responsive
to the data packet having
the replaced source
information”

The function is “receiving a return
packet from the second network,
responsive to the data packet having
the replaced source information”

“means for sending to the
‘298 Patent, claim 31
first network the return
packet having the replaced
destination address,
whereby that packet is
routed to the corresponding
the first network node”

The function is “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

‘298 Patent, claim 32

The function is “buffering further
data packets received from the first
network while waiting for the return
packet”

means for controlling
means (b) through (g) on
an individual basis for
processing the further
packets, if any, that were
buffered”

‘298 Patent, claim 32

The function is “controlling means
(b) through (g) on an individual
basis for processing the further
packets, if any, that were buffered”

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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

1 II.
2

EACH PARTY'S PROPOSED CONSTRUCTION OF EACH
DISPUTED CLAIM TERM, PHRASE, OR CLAUSE, TOGETHER
WITH AN IDENTIFICATION OF INTRINSIC AND OTHER
EVIDENCE

3
4

Exhibits A and B, attached hereto, identify the disputed claim terms. Exhibit

5 A contains Google’s proposed constructions for each disputed claim term and
6 intrinsic and other evidence in support; Exhibit B contains Rockstar’s proposed
7 constructions for each disputed claim term and intrinsic and other evidence in
8 support.
9
10 III.

MOST SIGNIFICANT TERMS

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12

The parties identify the following ten claim terms, or groups of claim terms,

13 as the most significant at this time to resolution of the case. Where the parties have
14 listed groups of claim terms, the parties believe there is a single dispute that will
15 resolve construction of the grouped claim terms:
16

1.

“pending message” (claims 1, 2, 5-8, 10-13, 21-23, 25, ‘973 patent)

17

2.

“the board” / antecedent basis of “the board” (claim 1, ‘551 patent)

18

3.

“sending the user” (claims 1 and 5, ‘131 patent)

19

4.

“call” (claims 17-20) / “call trace” (claims 17-20) / “call trace
information” (claims 17-20, ‘572 patent)

5.

“permitting the at least one control tool function to be activated when
the user input does select the control tool” (claims 1, 13, ‘937 patent)

6.

“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”
(claims 1, 8, 33, ‘973 patent)

7.

“a Faraday cage” (claim 1, ‘551 patent)

8.

“manipulable area portion” (claims 1-3, 9, 13-15, and 21, ‘937 patent)

9.

“determining if the user input selects the control tool” (claims 1 and 13,
‘937 patent)

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25
26
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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

1

10.

“storing the call trace information” (claim 20, ‘572 patent)

2

A.

Google’s Position

3

Despite Google’s request that Rockstar reduce the number of asserted claims,

4 Rockstar is currently asserting over 80 claims from seven patents. Google has made
5 good faith efforts to narrow and to limit the number of claim construction disputes,
6 and to focus the disputes before the Court despite the fact that Rockstar continues to
7 assert an unreasonable number of patents, and an unreasonable number of claims
8 from those patents.
Google prepared a detailed proposal for case narrowing, and sent that

9

10 proposal to Rockstar on September 24, 2014. After the Federal Circuit’s stay of the
11 Texas actions, Google asked Rockstar to confirm that any case narrowing
12 procedures in this action would apply equally to the Texas actions that have been
13 stayed while this action is pending. Google believes that the parties should agree
14 that any claims or patents eliminated from the California action through case
15 narrowing would also be eliminated from the stayed Texas actions. Without such an
16 agreement, there will not be an actual “narrowing” of the parties’ dispute—only
17 venue-shifting would be accomplished. This would defeat the efficiencies that the
18 Federal Circuit identified as the basis for the stay. With this condition, Google
19 remains committed to the case narrowing procedure that Google first proposed
20 nearly two months ago. At this time, it appears that Rockstar is only willing to
21 narrow its case against Google – not against Google’s customers, the OEM
22 defendants in the Texas actions.1
23

Given the number of patents, claims, and claim terms currently at issue,

24 Google respectfully submits that in addition to the ten terms identified pursuant to
25
26

1

Rockstar’s position statement complains that “No response from Google (or the EDTX
defendants) has been received” to a particular question. To clarify the record, Rockstar posed this
27
question for the first time today, October 24, 2014.

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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

1 Rule 4-3(c), there remain additional terms that are significant to resolution of this
2 case. For example, many asserted claims include means-plus-function limitations.
3 These means-plus-function limitations must be construed before trial, and their
4 construction is at least as “significant to the resolution of the case” as any other term
5 identified for construction. Moreover, as examples, Google also identifies the
6 following additional terms as equally “most significant to the resolution of this
7 case:”
1.

“means for receiving a selection from the user indicating a format for
delivery of further notification information regarding the
communication event” / “receiving a selection from the user indicating
a format for delivery of further notification information” (claims 1 and
5, ‘131 patent)

11

2.

“further notification information” (claims 1 and 5, ‘131 patent)

12

3.

“wizard” (claim 1, ‘591 patent)

13

4.

“logging the call trace information” (claim 19, ‘572 patent)

14

5.

“maintaining, by the filter node” (claim 11) / “maintaining the source
information taken from the outgoing data packet in correlation with a
unique value representing a port of the filter node” (claims 14, 19, 23) /
“maintaining the source address taken from the data packet” (claim 24)
/ “means for maintaining the source information taken from the
outgoing data packet in correlation with a unique value representing a
port of the filter node” (claim 27) / “means for maintaining the source
address taken from the data packet” (claim 31) (claims 11, 14, 19, 23,
24, 27, 31, ‘298 patent)

6.

“receiving a user input to the physical viewing area corresponding to
the manipulable area portion and the representation of the control tool”
(claims 1, 13, ‘937 patent)

7.

“extending across substantially the whole area within the confines of
the edges of the substrate” (claim 1, ‘551 patent)

8.

“collection of palettes” (claim 1, ‘591 patent)

9.

“filter node” (claims 11-12, 14-15, 17, 19, 23-24, 27-32, ‘298 patent)

8
9
10

15
16
17
18
19
20
21
22
23
24
25

While Google considers the claim terms above representative of terms that are

26 significant for the resolution of the case, Google notes that resolution of claim
27 construction disputes will not occur until summary judgment briefing and argument,
28 which is many months away. (Dkt. 88.) The parties have not yet engaged in expert
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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

1 discovery and are still pursuing fact discovery from each other and from third
2 parties. Further discovery (or case narrowing) may cause the list of “most
3 significant” terms to be different at the time of summary judgment briefing relative
4 to what it is today. Thus, Google’s motions for summary judgment may seek
5 construction of terms not listed above, as necessitated by subsequent case
6 developments, including upcoming fact and expert discovery.
7

B.

8

Rockstar is agreeable to case narrowing and has made several case narrowing

Rockstar’s Position

9 proposals to Google. However, and as indicated above, Google has rejected each
10 case narrowing proposal. Google insists on making any case narrowing proposal in
11 this case contingent on Rockstar’s agreement “that any claims or patents eliminated
12 from this California action through case narrowing would also be eliminated from
13 the stayed Texas actions.” So that Rockstar could consider Google’s “contingency,”
14 Rockstar asked Google (and the EDTX defendants) to provide a clear “yes” or “no”
15 response to this statement: “Will each of the defendants in the presently-stayed
16 EDTX case agree to be bound by any infringement and validity findings in the
17 NDCA case?” No response from Google (or the EDTX defendants) has been
18 received. Case narrowing is a two-way street requiring effort and agreement from
19 both parties to limit not just the number of asserted claims, but also the number of
20 prior art references and obviousness combinations.
21
22 IV.

THE ANTICIPATED LENGTH OF TIME NECESSARY FOR THE
CLAIM CONSTRUCTION HEARING

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Should the Court order a separate hearing on claim construction, the parties

25 believe that at least six hours will be necessary.
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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

1 V.

POSSIBLE WITNESSES AT THE CLAIM CONSTRUCTION
HEARING

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3

A.

4

Should the Court order a separate hearing on claim construction, Google may

Google's position

5 call Dr. Marwan Hassoun to provide testimony regarding the ‘551 patent, including
6 indefiniteness of the term “extending across substantially the whole area within the
7 confines of the edges of the substrate.”2
8

B.

9

Should the Court order a separate hearing on claim construction, Rockstar

Rockstar's position

10 does not intend to present any live witnesses in support of its claim constructions.
11 However, if Google calls Dr. Hassoun in support of the alleged indefiniteness of the
12 term “extending across substantially the whole area within the confines of the edges
13 of the substrate,” Rockstar will call Dr. Dean Neikirk in rebuttal to Dr. Hassoun.
14

Notwithstanding Google’s statement in footnote 2, Google’s Rule 4-2

15 disclosure does not indicate which patents or which terms the various experts
16 identified therein may be called to testify about. The information about Dr.
17 Hassoun’s anticipated testimony was not disclosed until Google sent its draft of the
18 Rule 4-3 statement shortly before the joint filing of this document. Consistent with
19 Rockstar’s Rule 4-2 disclosure, this Rule 4-3 disclosure properly indicates that it
20 “will call Dr. Dean Neikirk in rebuttal to Dr. Hassoun.”
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22
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25
26

2

Google disclosed its intent to rely on testimony from Dr. Hassoun as claim construction
evidence in Google’s Patent Rule 4-2(b) disclosure. Dr. Neikirk was not mentioned in Rockstar’s
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Patent Rule 4-2(b) disclosure.

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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

Respectfully submitted,

1
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3

DATED: October 24, 2014

QUINN EMANUEL URQUHART &
SULLIVAN, LLP

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By: /s/ Patrick D. Curran
Charles K. Verhoeven (Bar No. 170151)
Sean Park (Bar No. 219032)
David Eiseman (Bar No. 114758)
Kristin J. Madian (Bar No. 233436)
[e-mail]
50 California Street, 22nd Floor
San Francisco, California 94111
[phone]
[phone] facsimile

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Victoria F. Maroulis (Bar No. 202603)
[e-mail]
555 Twin Dolphin Drive, 5th Floor
Redwood Shores, California 94065
[phone]
[phone] facsimile
Patrick D. Curran (Bar No. 241630)
[e-mail]
51 Madison Avenue, 22nd Floor
New York, New York 10010
[phone]
[phone] facsimile
Attorneys for Google Inc.

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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW

1 DATED: October 24, 2014

Respectfully submitted,

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By /s/ Joshua W. Budwin
Courtland L. Reichman (SBN 268873)
McKool Smith Hennigan, P.C.
255 Shoreline Drive Suite 510
Redwood Shores, CA 94065
[phone]
[phone] (facsimile)
Mike McKool (Admitted Pro Hac Vice)
[e-mail]
Douglas A. Cawley (Admitted Pro Hac Vice)
[e-mail]
Ted Stevenson III (Admitted Pro Hac Vice)
[e-mail]
David Sochia (Admitted Pro Hac Vice)
[e-mail]
McKool Smith, P.C.
300 Crescent Court Suite 1500
Dallas, TX 75201
[phone]
[phone] (facsimile)
Joshua W. Budwin (Admitted Pro Hac Vice)
[e-mail]
McKool Smith, P.C.
300 W. 6th Street, Suite 1700
Austin, TX 78701
[phone]
[phone] (facsimile)
Attorneys For Defendants
Rockstar Consortium U.S. LP and Mobilestar
Technologies LLC

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JOINT CLAIM CONSTRUCTION AND PREHEARING STATEMENT

CASE NO. 13-CV-5933-CW