Defendants and EDIG had agreed that the term "flash memory" should be given its plain and ordinary meaning which was "block erasable non-volatile memory". But the day before the Joint Claim Construction Statements (Doc 284) were due, the Defendants changed their definition to "block erasable non-volatile memory that is the main memory of the system". They're trying to put EDIG's tech in a small box. LOL. And as DM points out in Doc 296, the terms "main memory", "the system" or "RAM" don't appear anywhere in EDIG's '774 or '737 patents.

Love the way DM slams their attempt in this excerpt from Doc 296.

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Defendants’ additional limitation (“that is the main memory of the system”) did not
appear in Defendants’ construction until the day before the Joint Claim Construction Statement was filed with the Court. (Maltiel Decl. (Exh. 6) at fn 1). For the several preceding weeks, Defendants had contended that the phrase “flash memory” did not need to be construed and should be given its plain and ordinary meaning. That contention was set forth in Defendants’ Joint List of Proposed Terms to be Construed and Proposed Constructions (attached hereto as Exh. 9 at pages 2-3 (stating that terms not identified to be construed should be given their plain and ordinary meaning and excluding flash memory from the list of terms to be construed)). Then, on the eve of the filing of the Joint Claim Construction Statement, Defendants proposed a construction that materially diverted from the plain and ordinary meaning of flash memory by also requiring that the flash memory be “the main memory of the system.” If the prosecution history was as clear cut as Defendants must argue, it is inconceivable that a team of lawyers for twenty-eight Defendants could only have discovered this so-called “clear and unmistakable disclaimer” the day before the parties’ final positions were due to be submitted to the Court. -- [excerpt from pages 27-28 of Doc 296]