Rockstar Consortium US LP et al v. Google Inc

Filing 200

Joint Claim Construction Chart Pursuant to Patent Rule 4-5(d) by Google Inc. (Attachments: # 1 Appendix A - U.S. Patent No. 7,236,969, # 2 Appendix B - U.S. Patent No. 7,469,245, # 3 Appendix C - U.S. Patent No. 7,672,970, # 4 Appendix D - U.S. Patent No. 7,895,178, # 5 Appendix E - U.S. Patent No. 7,895,183, # 6 Appendix F - U.S. Patent No. 7,933,883, # 7 Appendix G - Ordering Agreements and Disputes, # 8 Appendix H - Antecedent Basis Agreements and Disputes)(Anderson, Carl)

APPENDIX H:
ANTECEDENT BASIS AGREEMENTS AND DISPUTES.
U.S. PATENT NO. 7,236,969
Claim Term
the advertising machine

Rockstar’s Construction
[Agreed]

Google’s Construction
[Agreed]

Court’s Construction
Refers to “an advertising
machine” in the preamble

the desired information

[Agreed]

[Agreed]

Claims 1, 8, and 17: refers to
“desired information” in the
preamble

the first database

[Agreed]

[Agreed]

Refers to “a first database”
in the “searching” step for
method claims, or earlier in
the “database search engine”
element for apparatus claims

the particular advertisement

[Agreed]

[Agreed]

Refers to “a particular
advertisement in a second
database” in the
“correlating” step for method
claims, or the “associative
search engine” element for
apparatus claims

1

the received search argument [Agreed]

[Agreed]

Refers to “a search
argument” that was received
in the “receiving” step for
method claims, or the
“server computer” element
for apparatus claims

the search results

[Agreed]

[Agreed]

Refers to “search results” in
the “searching” step for
method claims, or the
“database search engine”
element for apparatus claims

the second database

[Agreed]

[Agreed]

Refers to “a second
database” in the
“correlating” step for method
claims, or earlier in the
“associative search engine”
element for apparatus claims

the server computer

[Agreed]

[Agreed]

Refers to “a server” in the
“searching” step for method
claims, or “a server
computer” in the “server
computer” element for
apparatus claims

“the desired information”,
as recited in claim 22 of the
’969 patent

information sought for by
the user

Indefinite

2

U.S. PATENT NO. 7,469,245
Claim Term
the advertising machine

Rockstar’s Construction
[Agreed]

Google’s Construction
[Agreed]

Court’s Construction
Refers to “an advertising
machine” in the preamble

the at least one
advertisement

[Agreed]

[Agreed]

Refers to “at least one
advertisement” in the
“selecting” step of claim 1
orthe “select” element of
claim 9=.

the communications link

[Agreed]

[Agreed]

Refers to “a communications
link” in the preamble

the data processing device

[Agreed]

[Agreed]

Refers to “a data processing
device of a user” in the
preamble

the refined search results

[Agreed]

[Agreed]

Refers to “the search results”
after the application of the
“refining” or “refine” step

the search argument

[Agreed]

[Agreed]

Refers to “a search
argument” in the second
“receiving” step of claim 1
or the first “receive” element
of claim 9

the search refinement input

[Agreed]

[Agreed]

Refers to “search refinement
input” that is received in
claims 8 and 17.

3

the search results

[Agreed]

[Agreed]

Refers to “search results” in
the “searching” step of claim
1, or the “search” element of
claim 9.

the user preference data

[Agreed]

[Agreed]

Refers to “user preference
data” in the “creating” step
of claim 1, or the “create”
element of claim 9.

the user preference edit input

[Agreed]

[Agreed]

Refers to “user preference
edit input” that is received in
claim 14.

the user preference input

[Agreed]

[Agreed]

Refers to “user preference
input” in the first “receiving”
step of claim 1, or the second
“receive” element of claim 9.

the user preference reprioritization input

[Agreed]

[Agreed]

Refers to “user preference
re-prioritization input” that is
received in claim 8.

4

U.S. PATENT NO. 7,672,970
Claim Term
the advertisement database

Rockstar’s Construction
[Agreed]

Google’s Construction
[Agreed]

Court’s Construction
Refers to “an advertisement
database” in the “select” or
“selecting” limitations

the advertisement selection

[Agreed]

[Agreed]

Refers to the “selection of an
advertisement” in the prior
“receive” or “receiving”
limitation

the advertising machine

[Agreed]

[Agreed]

Refers to “an advertising
machine” in the preambles

the at least one
advertisement

[Agreed]

[Agreed]

Refers to “at least one
advertisement” in the
“select” or “selecting”
limitations, or to “an
advertisement” in the second
“interacting” limitations

the at least one differing
advertisement

[Agreed]

[Agreed]

Refers to “at least one
differing advertisement” in
the prior “select” or
“selecting” limitations

the communications link

[Agreed]

[Agreed]

Refers to “a communications
link” in the preambles

5

the data processing device
[of the user]

[Agreed]

[Agreed]

Refers to “a data processing
device of a user” in the
preamble, or “a data
processing device” in the
first element of claim 41.

the fee record

[Agreed]

[Agreed]

Refers to “a fee record” in
the last limitation of the
corresponding independent
claim

the non-selection of the at
least one advertisement

[Agreed]

[Agreed]

Refers to “non-selection of
the at least one
advertisement” in the prior
“receive” or “receiving”
limitation

the search argument

[Agreed]

[Agreed]

Refers to “a search
argument” in the “receive”
or “receiving” limitations

the search results

[Agreed]

[Agreed]

Refers to “search results” in
the “search,” “searching,” or
first “interacting” limitations

the selection of the
advertisement

[Agreed]

[Agreed]

Refers to the “selection of an
advertisement” in the prior
“receive” or “receiving”
limitation

the server computer

[Agreed]

[Agreed]

Refers to “a server
computer” in the preamble

6

the user

[Agreed]

[Agreed]

7

Refers to “a user” in the
preamble (in claim 45 the
user is “a person or
individual operating the data
processing device.”)

U.S. PATENT NO. 7,895,178
Claim Term
the advertisement database

Rockstar’s Construction
[Agreed]

Google’s Construction
[Agreed]

Court’s Construction
Refers to “an advertisement
database” in the first
“selecting” limitation of
claim 1

the advertising machine

[Agreed]

[Agreed]

Refers to “an advertising
machine” in the preambles

the at least one
advertisement

[Agreed]

[Agreed]

Refers to “at least one
advertisement” in the first
“selecting” limitation of
claim 1, or the first
“receiving” limitation of
claim 12

the at least one other
advertisement

[Agreed]

[Agreed]

Refers to “at least one other
advertisement” in the second
“selecting” limitation of
claim 1, or the third
“receiving” limitation of
claim 12

the communications link

[Agreed]

[Agreed]

Refers to “a communications
link” in the preambles

the data processing device
[of the user]

[Agreed]

[Agreed]

Refers to “a data processing
device of a user” in the
preambles

8

the display of the data
processing device

[Agreed]

[Agreed]

Refers to “a display of the
data processing device” in
the first “displaying”
limitation of claim 12

the modified search results

[Agreed]

[Agreed]

Refers to “modified search
results” in the “producing”
limitation of claim 1, or the
third “receiving” limitation
of claim 12

the search argument

[Agreed]

[Agreed]

Refers to “a search
argument” in the first
“receiving” limitation of
claim 1, or “creating”
limitation of claim 12

the search refinement input

[Agreed]

[Agreed]

Refers to “search refinement
input” in the second
“receiving” limitation of
claim 1, or the second
“receiving” limitation of
claim 12

the search request

[Agreed]

[Agreed]

Refers to “a search request”
in the “creating” limitation
of claim 12

the search results

[Agreed]

[Agreed]

Refers to “search results” in
the “searching” limitation of
claim 1, or the first
“receiving” limitation of
claim 12

9

U.S. PATENT NO. 7,895,183
Claim Term
the advertisement

Rockstar’s Construction
[Agreed]

Google’s Construction
[Agreed]

Court’s Construction
Refers to “at least one
advertisement” in the
“selecting” limitation of
claim 1, the “receiving”
limitation of claim 9, or the
“select” limitation of claim
14

the advertising machine

[Agreed]

[Agreed]

Refers to “an advertising
machine” in the preambles

the at least one
advertisement

[Agreed]

[Agreed]

Refers to “at least one
advertisement” in the
“selecting” limitation of
claim 1, the “receiving”
limitation of claim 9, or the
“select” limitation of claim
14

the at least one computer

[Agreed]

[Agreed]

Refers to “at least one
computer” in the preamble

the communications link

[Agreed]

[Agreed]

Refers to “a communications
link” in the preambles

the data processing device
[of the user]

[Agreed]

[Agreed]

Refers to “a data processing
device of a user” in the
preambles

10

the display of the data
processing device

[Agreed]

[Agreed]

Refers to “a display of the
data processing device”
identified in the same claim
limitation of claims 1 and
14, or in the first
“displaying” limitation of
claim 9

the search argument

[Agreed]

[Agreed]

Refers to “a search
argument” in the “receiving”
limitation of claim 1, the
“creating” limitation of
claim 9, or the “receive”
limitation of claim 14

the search results

[Agreed]

[Agreed]

Refers to “search results” in
the “searching” limitation of
claim 1, the “receiving”
limitation of claim 9, or the
“search” limitation of claim
14

“the communication
interface” as recited in
claim 12 of the ’183 patent

software operable to allow
interaction between the
advertising machine and
another computer or
computers
Plain and ordinary meaning.

Indefinite

“the search term” as recited
in claims 7 and 20 of the
’183 patent

Indefinite

11

U.S. PATENT NO. 7,933,883
Claim Term
the advertising machine

Rockstar’s Construction
[Agreed]

Google’s Construction
[Agreed]

Court’s Construction
Refers to “an advertising
machine” in the preambles

the at least one
advertisement

[Agreed]

[Agreed]

Refers to “at least one
advertisement” in the
“selecting” limitation of
claim 1, or the “select”
limitation of claim 20

the communications link

[Agreed]

[Agreed]

Refers to “a communications
link” in the preambles

the data processing device
[of the user]

[Agreed]

[Agreed]

Refers to “a data processing
device of a user” in the
preambles

the search argument

[Agreed]

[Agreed]

Refers to “a search
argument” in the “receiving”
limitation of claim 1, or the
“receive” limitation of claim
20

the search results

[Agreed]

[Agreed]

Refers to “search results” in
the “searching” limitation of
claim 1, or the “search”
limitation of claim 20

12

the user profile data

[Agreed]

[Agreed]

13

Refers to “user profile data”
in the “creating” limitation
of claim 1, or the “create”
limitation of claim 20