Red Bend Software, Inc. et al v. Google

Filing 96

BRIEF by Red Bend Software, Inc., Red Bend, Ltd. Opening Claim Construction Brief. (Attachments: # 1 Appendix A)(Tempesta, Jennifer)

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Red Bend Software, Inc. et al v. Google Appendix A to Plaintiffs' Red Bend Ltd. and Red Bend Software Inc.'s Opening Claim Construction Brief Red Bend Ltd. v. Google Inc., Civil Action No. 09-cv-11813-DPW Proposed Claim Constructions - July 15, 2010 Claim Terms Independent Red Bend Proposed Construction Google Proposed Construction at Issue Claims 1 compact difference result 8, 12, 21, 25, 42, 46, 55, 59 A difference result of a smaller size as compared to a conventional difference result (obtained by using techniques in existence prior to the invention of the patent-in-suit) in which the need to reflect changes to references due to delete/insert modifications is reduced or eliminated. A table of entries, where an entry is an addressable unit within the data table. Each entry may have a different size. An executable program is one example of a data table. A program comprising machine language instructions and corresponding bytes of data used by the program that are ready to be run on a computer. Values made the same. A difference result in which references that have changed due to delete/insert modifications do not appear. 2 data table 42, 46, 55, 59 A table of entries, each of which may have a different size. An executable program is one example of a data table. It cannot be source or other symbolic code. A program comprising machine language instructions and corresponding bytes of data used by the program that are ready to be run on a computer, excluding source or other symbolic code. Values made the same in the modified and new programs (or data tables) corresponding reference entries so that reference addresses are excluded from difference result. old for the the 3 executable program 8, 12, 21, 25 4 invariant references 8, 12, 21, 25, 42, 46, 55, 59 5a Dockets.Justia.com modified old data table 42, 46, 55, 59 An interim result, such as tables or data structures, related to the old data table. A version of the actual program or data table in its original executable form, with certain portions replaced. Doc. 96 Att. 1 Page 1 Appendix A to Plaintiffs' Red Bend Ltd. and Red Bend Software Inc.'s Opening Claim Construction Brief Red Bend Ltd. v. Google Inc., Civil Action No. 09-cv-11813-DPW Proposed Claim Constructions - July 15, 2010 Claim Terms Independent Red Bend Proposed Construction Google Proposed Construction at Issue Claims 5b modified old program modified new data table modified new program 8, 12, 21, 25 An interim result, such as tables or data structures, related to the old executable program. An interim result, such as tables or data structures, related to the new data table. An interim result, such as tables or data structures, related to the new executable program. 5c 42, 46, 55, 59 8, 12, 21, 25 5d Page 2 Appendix A to Plaintiffs' Red Bend Ltd. and Red Bend Software Inc.'s Opening Claim Construction Brief Red Bend Ltd. v. Google Inc., Civil Action No. 09-cv-11813-DPW Proposed Claim Constructions - July 15, 2010 Agreed Terms Claim Term difference result Independent Claims 8, 12, 21, 25, 42, 46, 55, 59 Agreed Construction Data representative of the difference between an old program (or data table) and a new program (or data table) used to carry out an update of the old program. An executable program (or portion of an executable program) that is to be updated. A data table (or portion of a data table) that is to be updated. A part of the data appearing in an entry in the data table which is used to refer to some other entry from the same data table. A reference can be either an address or a number used to compute an address. Entries that include references. For this purpose, "entries" are addressable units of a data table or program. As an example, a reference entry could be an individual machine instruction (such as an individual jump instruction) specifying a target address. old executable program; said old program old data table reference 8, 12, 21, 25 42, 46, 55, 59 8, 12, 21, 25, 42, 46, 55, 59 reference entries 8, 12, 21, 25, 42, 46, 55, 59 Page 3

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