Motorola Mobility, Inc. v. Microsoft Corporation

Filing 177

RESPONSE/REPLY Microsoft Corporation's Responsive Claim Construction Brief and Exhibits by Microsoft Corporation. (Attachments: #1 Index of Exhibits, #2 Exhibit 802, #3 Exhibit 906, #4 Exhibit 907, #5 Exhibit 908, #6 Exhibit 909, #7 Exhibit 910, #8 Exhibit 1005, #9 Exhibit 1006, #10 Exhibit 1117, #11 Exhibit 1118, #12 Exhibit 1119, #13 Exhibit 1120, #14 Exhibit 1121, #15 Exhibit 1122, #16 Exhibit 1411)(Miner, Curtis)

Exhibit 1119

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 10-24063-CIV-MORENO

MOTOROLA MOBILITY, INC.,
Plaintiff / Counterclaim Defendant,
v.
MICROSOFT CORPORATION,
Defendant / Counterclaim Plaintiff.

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PLAINTIFF MOTOROLA MOBILITY, INC.’S UPDATED PROPOSED
CLAIM CONSTRUCTIONS FOR THE PATENTS-IN-SUIT
Motorola Mobility, Inc. (“Motorola Mobility”) submits the attached chart identifying its
updated proposed constructions of the claim limitations of the patents-in-suit for which the
parties seek construction by the Court.
Motorola Mobility’s provides this submission without waiver of or prejudice to its right
to amend or supplement as a result of further analysis, ongoing discovery, and in response to
amendment or supplementation of constructions proposed by Microsoft Corporation
(“Microsoft”). In particular, Motorola Mobility may amend its constructions to narrow the gap
between its constructions and Microsoft’s to allow for resolution of as many claim construction
disputes as possible prior to the submission of the parties’ claim construction briefs.

Dated: June 3, 2011

By: /s/ Leslie M. Spencer_____

Jesse J. Jenner
Steven Pepe
Khue V. Hoang
Leslie M. Spencer
Ropes & Gray LLP
1211 Avenue of the Americas
New York, NY 10020
Telephone: [phone]
Norman H. Beamer
Mark D. Rowland
Gabrielle E. Higgins
Ropes & Gray LLP
1900 University Avenue, 6th Floor
East Palo Alto, CA 94303
Telephone: [phone]
Kevin J. Post
Megan F. Raymond
Ropes & Gray LLP
One Metro Center
700 12th Street NW, Suite 900
Washington, DC 20005
Telephone: [phone]
Edward M. Mullins
Hal M. Lucas
Astigarraga Davis Mullins & Grossman, P.A.
701 Brickell Avenue
16th Floor
Miami, FL 33131
Telephone: [phone]
Attorneys for Plaintiff / Counterclaim Defendant
MOTOROLA MOBILITY, INC.

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CERTIFICATE OF SERVICE
I hereby certify that on June 3, 2011, copies of the foregoing Plaintiff Motorola Mobility,
Inc.’s Updated Proposed Claim Constructions For The Patents-In-Suit were served by e-mail
upon the counsel of record included in the attached Service List.
/s/Leslie M. Spencer
Leslie M. Spencer

SERVICE LIST
Motorola Mobility, Inc. v. Microsoft Corp., Case No. 1:10-cv-24063-MORENO
Roberto Martinez, Esq.
Curtis Miner, Esq.
COLSON HICKS EIDSON
255 Alhambra Circle, Penthouse
Coral Gables, FL 33134
Tel: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Defendant /
Counterclaim Plaintiff
MICROSOFT CORPORATION
Of Counsel:
David T. Pritikin
Richard A. Cederoth
Douglas I. Lewis
John W. McBride
SIDLEY AUSTIN LLP
One South Dearborn
Chicago, IL 60603
Tel: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]

Brian R. Nester
Kevin C. Wheeler
SIDLEY AUSTIN LLP
1501 K Street NW
Washington, DC 20005
Tel: [phone]
Email: [e-mail]
[e-mail]

Motorola Patent No. 6,272,333
Claim Term/
Identified By
Microsoft term:
“data”
Microsoft term:
“controlling a delivery of
data”
Microsoft term:
“fixed portion of [a/the]
wireless communication
system”
Motorola term:

Claims

Motorola Proposed Construction

1, 7, 12

Digital information

1, 7, 12

Managing whether and when data is delivered

1, 3, 5, 7, 12 The stationary portion of the wireless
communication system that includes base stations
and a controller

1, 3, 5-7,
12-13

A portable device for use in a wireless
communication system

1, 3, 5-7,
12-13

A portion of memory that includes a list of all
software applications that are immediately
available for use by the subscriber unit

“subscriber unit”
Motorola term:
“application registry
comprising a list of all
software applications that are
currently accessible to the
subscriber unit”

26875538_1

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