4. Courts Proposal: identifying the core issue for this case: "sole memory of the received processed sound electrical signals"....she is only concerned with this case and not what e.Digital may be after, or what the defendants may be after.

Courts construction "a flash memory module which operates as sole memory of the received processed sound electrical signals" She is not taking into consideration the digital issues of the original phrase, the issues of items 1 of both parties constructions which surround removable issue, or the tag issue of the defendants, "without another memory system such as RAM"

The phrase has a limited expression of e.Digitals original published patent term, with 3 caveats considering the device and not the flash, breaking it down with imposed meanings....

A. "requires that the device use only flash memory, not RAM or any other memory system, while engaging the CODEC, DSP (as applicable),"

lets eliminate, as she suggests, by the word "not" as it relates to the device...keeping in mind.... device = controller

"requires that the device use only flash memory, while engaging the CODEC, DSP (as applicable),"

The subject is the device not the flash...where for digital relating to removable flash, or any other flash modules, the flash does not engage directly the CODEC ......the DSP (used for digital compression).. where the judge modified the details ... (as applicable)....to allow all conditions in the courts construction for the sitings it made.

For the volatile overwrite RAM considerations involved for digital issues, the controller, CODEC and DSP, with their assorted details take care of it all up stream the storage memory... not the flash. She is inferring the device do this, not the flash memory.....the key word is device, flash, or embedded flash, just that flash be used by the controller in her consideration .

(as applicable)....

@ 5:63-5:65 from the patent, she considers the phrase from the patent to support the opinion.....[my inserts]

"Overall system design is based on the use of a microprocessor which can drive all system components. This eliminates the need for use of multiple interface logic that demands a lot of board space within the circuitry. The DSP or digital support processor is coupled to the microprocessor and to a CODEC for coding and decoding the analog signal (DA input to memory) received from the microphone or transmitted to the speaker. Codec also performs the analog to digital conversion. [ court consideration of all conditions "(as applicable)"] It functions to receive the analog signal input and convert it to PCM or pulse code modulation and then feed this signal to

4
"There is some basis to believe that the device can also operate on a purely analog basis.
Compare Claim 1 (including “analog-to-digital conversion circuitry”) with Claim 19 (containing
no reference to such circuitry). It appears that a CODEC is nevertheless necessary in purely
analog operations to “cod[e] and decod[e] the analog signal.” 5:63; compare 5:65 (“CODEC
also performs the analog to digital conversion”) (emphasis added)."

IMO, as the courts considers "pure analog "....I do not see that the way the patent is published for the 5:63-5:65 phrases above....I see a possible process of DA input to flash....which is a digital issue, where claim 19 has all digital concessions.

B. "requires that the device use only flash memory, not RAM or any other memory system, while engaging memory control functions."

again, lets eliminate as she suggests by the word "not" for the device.

"requires that the device use only flash memory, while engaging memory control functions."

I don't know how to interpret either phrase precisely, this has nothing to do with the direct removable flash issues, That aside, or why she is going there, the memory control functions are stored on a ROM....which is another memory entity ... "or any other memory system"

I can see it as a positive interpretation .... key word device, it uses flash and it does engage memory control functions. I see this as subjective, because of.... "or any other memory system"

C. "requires that the device use only flash memory, not RAM or any other memory system, while engaging storing the fully-manipulated data."

again, lets eliminate as she suggests by the word "not"

"requires that the device use only flash memory, while engaging storing the fully-manipulated data."

I can interpret that to mean, identifying key word "device" , that the device (controller) uses the flash to store data....and is not being specific as to how the data is being manipulated prior to being placed.

I do not see this as dispositive...

FWIW, I do not see detrimental issues in the considerations after setteling down and reviewing all the issues side by side.

doni