’108 Patent Claim

Agreed Proposed Construction

e.Digital’s Proposed Construction

Defendants’ Proposed Construction

Court’s Construction

memory

= plain and ordinary meaning

industry standard data storage format

= e.Digital already seeks to construe the term "data storage format" and does not believe that "industry standard" requires construction. To the extent the Court requires a construction for "industry standard data storage format," e.Digital proposes that "industry standard" has a plain and ordinary

memory

= Indefinite, or in the alternative, "a linked list used instead of a file allocation table (memory map) for sequentially accessing data segments within the primary memory"

industry standard data storage format

= "format in which data is stored that conforms to an industry standard"

plain and ordinary meaning

industry standard is plain and ordinary meaning

data storage format is file format in which data is stored