those explanations aside....

For the phrase at hand....

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

The defendants can argue it to their favor and the plaintiff can argue it to their favor.

That phrase can be interpreted either one way or the other.

It comes down to what flash memory is, it's make up....and explaining this phrase of your ink to a jury.

"and typically support a limited number of writes over the life of the device."

For that, it's not a matter of "typically".....especially for 1994.....and it's not totally matter of writes.... both programming and "flashing"(erasing) are detrimental to the substrate.

For that inherent condition flash is not conducive to being used as a processing agent.

With that, the court does not want to directly weigh in on the matter.

doni