Defendants’ proposed construction, by incorporating the term “main memory” which can be synonymous with volatile memory like RAM, is therefore inconsistent with the express language of Claim 1. Such volatile main memory, such as RAM, is also not necessarily comprised of a plurality of blocks as required by the express language of Claim 1.

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“[c]reating the primary memory from a non-volatile, long-term storage medium wherein the primary memory comprises a plurality of blocks in which data segments are stored.”

I think the court plainly sees the difference...there is no mistaking what non-volatile memory is.

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Defendants initial cobnstruction...

primary memory = "main memory of a computer system, i.e., the main general-purpose storage to which the microprocessor has direct access"

That is an association as being a RAM entity in relation to a processor...giving no association to a non-volatile entity....as primary memory is associated to a non-volatile memory.

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defendants are not going to convince the court on this matter.

doni