Here are two main challenges
....

A. “flash memory” (Claims 1, 2 and 19 of the ‘774 Patent and Claim 5 of the ‘737 Patent)

e.Digital’s Proposed Construction: "block erasable non-volatile memory"

Defendants’ Proposed Construction: "block erasable non-volatile memory that is the main memory of the system "

They want to change the normal meaning of what block erasable non-volatile memory is, to something that it is not.

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B. “a flash memory module which operates as sole memory of the received

processed sound electrical signals and is capable of retaining recorded digital

information for storage in nonvolatile form” (Claims 1 and 19 of the ‘774

Patent)

e.Digital’s Proposed Construction:“a removable, interchangeable flash memory storage device that (1) is the only removable memory storage device that receives for storage the processed sound electrical signals, and (2) sole memoryof the received processed sound electrical signals: is capable of retaining for storage digital information without the need for ongoing power support”

Defendants’ Proposed Constructions: (1) flash memory module: “a removable, interchangeable flash memory recording medium” and (2) sole memoryof the received processed sound electrical signals: “the only memory of the received processed sound electrical signals, without another memory system such as RAM”

They want it to appear that e.Digital does not implement a RAM resource of any kind when it comes to the non-volatile memory usage, so that they can come back with.. "we utilize a RAM process, with that, we are not infringing e.Digital patents".

e.Digital greatly minimizes RAM resource that reflects whatever the read / write block size (not to be confused with erase block) considerations are of the non-volatile memory. While at the same time defendants are trying to pigeon hole, as i see it, "the only" memory that might be on a device, while e.Digital wants to stay open to more than the removable.

Which way will the judge go?

doni