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Message: Patent # 108 Court Construction ( 1 )
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Dec 15, 2014 09:31AM
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Dec 15, 2014 09:55AM
Joint Claim Construction Worksheet In Re: e.Digital Cases, Case Nos. 13-cv-2897-H-BGS; 13-cv-2899-H-BGS; 13-cv-2914-H-BGS; 13-cv-2915-H-BGS; 13-cv-2938-H-BGS; 13-cv-2946-H-BGS
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U.S. Patent No. 5,839,108 ("the ’108 Patent") ’108 Patent Claim
Agreed Proposed Construction
e.Digital’s Proposed Construction
Defendants’ Proposed Construction
Court’s Construction
1.
A method of memory management for a primary memory created from a non-volatile, long-term storage medium, said method enabling direct manipulation of contiguous and non-contiguous discrete data segments stored therein by a file system, and comprising the steps of:
(a)
creating the primary memory from a non-volatile, long-term storage medium, wherein the primary memory comprises a plurality of blocks in which the data segments are to be stored;
(b)
coupling a cache
In Re: e.Digital Cases
, Case Nos. 13-cv-2897-H-BGS; 13-cv-2899-H-BGS; 13-cv-2914-H-BGS; 13-cv-2915-H-BGS; 13-cv-2938-H-BGS; 13-cv-2946-H-BGS
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’108 Patent Claim
Agreed Proposed Construction
e.Digital’s Proposed Construction
Defendants’ Proposed Construction
Court’s Construction
memory to the primary memory, said cache memory providing temporary and volatile storage for at least one of the data segments
;
(c) writing a new data segment from the
cache memory to the primary memory by linking said new data segment to a sequentially previous logical data segment by the following steps:
(1) receiving the new data segment in the
cache memory ;
(2) moving the new data segment from the
cache memory to a next available space within primary memory such that the new
In Re: e.Digital Cases
, Case Nos. 13-cv-2897-H-BGS; 13-cv-2899-H-BGS; 13-cv-2914-H-BGS; 13-cv-2915-H-BGS; 13-cv-2938-H-BGS; 13-cv-2946-H-BGS
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’108 Patent Claim
Agreed Proposed Construction
e.Digital’s Proposed Construction
Defendants’ Proposed Construction
Court’s Construction
data segment is stored in
primary memory in non-used memory space;
(3) identifying the previous logical data segment in
primary memory;
(4)
creating a logical link between the previous logical data segment and the new data segment such that the logical link provides a path for sequentially accessing the data segments within the primary memory;
(5)
creating additional serial and logical links as subsequent new data segments are written to primary memory, said logical links providing the path for serially accessing
limitation within which it is contained as set forth above. To the extent the term is to be construed separately, e.Digital proposes that the term be accorded its plain and ordinary meaning.
coupling a cache memory to the primary memory, said cache memory providing temporary and volatile storage for at least one of the data segments
= plain and ordinary meaning
coupling a cache memory to the primary memory, said cache memory providing temporary and volatile storage for at least one of the data segments
= "creating a removable, interchangeable electrical connection between the cache memory and the primary memory"
plain and ordinary meaning
In Re: e.Digital Cases
, Case Nos. 13-cv-2897-H-BGS; 13-cv-2899-H-BGS; 13-cv-2914-H-BGS; 13-cv-2915-H-BGS; 13-cv-2938-H-BGS; 13-cv-2946-H-BGS
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’108 Patent Claim
Agreed Proposed Construction
e.Digital’s Proposed Construction
Defendants’ Proposed Construction
Court’s Construction
the data segments regardless of contiguity of the data segments relative to each other within the
primary memory; and
(6) storing the data segments to
primary memory in a manner consistent with an industry standard data storage format while retaining linking between data segments created in previous steps.
non-volatile, long-term storage medium
= plain and ordinary meaning
direct manipulation of contiguous and non-contiguous discrete data segments
= plain and ordinary meaning
file system
= plain and ordinary meaning
non-volatile, long-term storage medium
= "memory that holds its data without the need for ongoing power support"
direct manipulation of contiguous and non-contiguous discrete data segments
= Indefinite, or in the alternative, "manipulation of contiguous and noncontiguous data segments directly in the primary memory through changes to data segment headers without using a file allocation table"
file system
= Indefinite, or in the
Not indefinite
plain and ordinary meaning
Not indefinite
volatile, long-term storage medium, wherein the primary memory comprises a plurality of blocks in which the data segments are to be stored
= "causing a portion or portions of a non-volatile long term storage medium, comprised of a plurality of blocks in which the data segments are to be stored, to perform at least one of a host’s primary memory functions"
creating
= e.Digital believes that this claim term should be construed together with the rest of the
volatile, long-term storage medium, wherein the primary memory comprises a plurality of blocks in which the data segments are to be stored
= Indefinite, or in the alternative, "dividing the non-volatile, long-term memory into equal size blocks, each block being the smallest amount of data that can be read from or written to the memory in a single read or write operation"
creating
= "making or producing"
Creating 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
plain and ordinary meaning
Preamble = not limiting
primary memory
= e.Digital believes that this claim term should be construed together with the rest of the limitation within which it is contained as set forth below. To the extent the term is to be construed separately, e.Digital proposes the following construction: "addressable storage to which a computer system’s microprocessor has direct access"
creating the primary memory from a non-
Preamble = limiting
primary memory
= "main memory of a computer system, i.e., the main general-purpose storage to which the microprocessor has direct access"
creating the primary memory from a non-
Preamble not limiting.
see next page
Not indefinite
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