Regarding the other critical claim construction.

“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”.

The Defendants' are trying to break the claim construction into two different terms: (1) flash memory module (2) sole memory.

I don't agree with this at all since the sentence reads, "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 nonvoltaile form." The above italicized words clearly are meant to define and describe the term flash memory module.

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) 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 memory of the received processed sound electrical signals: “the only memory of the received processed sound electrical signals, without another memory system such as RAM”