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Message: defendants claim construct...

The term “interchangeable” appears in both claim 1 and claim 19 of the ‘774 patent. (Ex.A, 10:54-57; 12:30-33 (emphasis added).) The claim language (“removable, interchangeable, flash memory recording medium”) shows that “interchangeable” is used as an adjective to describe the nature of the “flash memory recording medium,” which is confirmed by the ‘774 patent specification:

"The interconnect means 28 comprises a socket 30 configured to be PCMCIA compatible and sized to receive the flash memory module 29. When inserted within the socket 30, pins of the module 29 seat within pin receptacles of the interconnect means 28.In this sense, the small memory module is functionally similar to a cassette, in that it is inserted and removed at will. Furthermore, it can be readily inserted in other compatible machines for interchangeable use."

I have no idea what the defendants are getting at here, however, "compatibility" seems to be their focus. If I were to highlight the focus on compatibility it would be like this...

"The interconnect means 28 comprises a socket 30 configured to be PCMCIA compatible and sized to receive the flash memory module 29. When inserted within the socket 30, pins of the module 29 seat within pin receptacles of the interconnect means 28.In this sense, the small memory module is functionally similar to a cassette, in that it is inserted and removed at will. Furthermore, it can be readily inserted in other compatible machines for interchangeable use."

"configured" means to me... more than one way, where PCMCIA form factor was the choice due to popularity issues. A company will not stay static with its configurations and will stay abreast of all form factors, of which, there were competing issues of the day.

doni

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