Uniloc USA, Inc. et al v. NATIONAL INSTRUMENTS CORP. et al

Filing 243

Opposed MOTION for Leave to Construe Previously Construed Term by Pervasive Software, Inc.. (Attachments: # 1 Exhibit A (Rosenblatt Declaration), # 2 Exhibit B (Proposed Claim Construction), # 3 Text of Proposed Order)(Huston, Charles)

EXHIBIT B

Term
licensee unique ID*

Proposed Construction
Adopt the RI District Court Claim
Construction Order, p. 183 - “ A
unique identifier associated with a
licensee”

Intrinsic Evidence
As recited in Pervasive’s Motion for
Leave to Construe Previously
Construed Term

With the clarification:
“Cannot be based solely on platformrelated user information, including
software serial number or hardware
configuration information or both.”
* Pervasive does not contest the previous court rulings that the terms “licensee unique ID,” “security key,”
“enabling key,” and “registration key” are synonymous. Uniloc USA, Inc. v. Microsoft Corp., 447 F. Supp.2d 177,
184 (D.R.I. 2006).