First off....the Markman is not about liability issues....so I have no idea why you go to such an extreme to express it as such.
As for the sole memory issue the defendants are after....
" If that ends up with "changing the total meaning of a patent" so be it."
That is exactly what it's about.
If the defendants get the judge to follow their consideration.....game over.
It's up to the judge to decide what possible verbiage is allowed.....after hearing from both sides.
There's nothing cryptic about my comments if you are reading the brifs.
The defendants and plaintiff are very clear in giving their opinions of what they want and feel.
doni