RE: the word “interchangeable”

e.Digital proposes:

“capable of ready transfer to another device”

Defendants propose that the term “interchangeable” be construed as “readily insertable in other compatible devices.” (Ex. G, Joint Claim Construction Statement (“JCCS”), at 8.) This construction is consistent with the plain and ordinary meaning of the term as it appears in the claims, and is fully supported by the ‘774 patent specification. See Phillips, 415 F.3d at 1313 (“[T]he specification ‘is always highly relevant to the claim construction analysis.’”) (quoting Vitronics, 90 F.3d at 1582). e.Digital ignores that the flash memory module is to be inserted into a “compatible” device, even though that idea comes directly from those parts of the specification actually cited by e.Digital in the JCCS.

They want to have it considered to be totally proprietary to a device family while e.Digital does not. Thing is, e.Digital formatting is not tied to one physical form factor.

doni